State Comments on Frozen Data - 2017

• Metric 1a2. AL0000000100900020 - Facility now considered a minor source (SMOP voided 9/25/13) and was removed from the CMS plan; however, ICIS was recently updated.
• Metric 1a4. AL0000000109704005 - Facility is currently considered a minor source under Title V; the MSOP was voided on 6/14/16. This facility is appearing on the Number of CMS Majors list but not on the Number of Active Majors list. AL0000000112500032 - Facility became a minor source on 9/30/2016 and removed from the CMS plan. This facility is appearing on the Number of CMS 80% Synthetic Minors list but does not appear on the Number of Active Synthetic Minors list. AL0000000109708004 - Facility became a minor source on 7/31/13 and removed from the CMS plan. This facility is appearing on the Number of CMS 80% Synthetic Minors list but does not appear on the Number of Active Synthetic Minors list.
• Metric 1a5. Both of the HPV Minors are EPA actions that have not been resolved in ICIS. These are not state actions and should not be reflected under state metrics.
• Metric 1b5. AL0000000100500023 - Facility was reclassified as a synthetic minor source on 3/28/16; however, ICIS was not updated until 01/2018 so this facility is appearing on the CMS Majors list.
• Metric 1b6. AL0000000112500032 - Facility is now considered a minor source under Title V regulations; the SMOP was voided on 9/30/2016 and was recently removed from the CMS plan. AL0000000109708004 - Facility became a minor source on 7/31/13 and was recently removed from the CMS plan. Facilities Not Appearing On This List: AL0000000100500023 - Facility was reclassified as a synthetic minor source on 3/28/16; however, ICIS was not updated until 01/2018 so this facility is appearing on the CMS Majors list.

• Metric 1a3 - COG315482 is a certification under a general permit and should not be counted as an individual permit. Permit COB001000 is missing because it was entered as a Non-NPDES individual permit. ICIS helpdesk has been notified and is working on correcting the permit type.
• Metric 1a4 - COR03C170, COR03C171, COR03K336, COR03K407, COR03L295, COR03L847, COR03M761 are listed as Unpermitted Facilities, which is incorrect. COG315482 is a certification under a general permit and is currently counted as an individual permit. COA932052, COA932059, COA932071,COA932082 have NOIs under review for coverage under general permit COA933000 COA932081, COA932085 certifications under general permit COA933000 will be issued in June 2018 For 1b7 - COG315482 is a certification under a general permit and should not be counted as an individual permit.
• Metric 1b8 - COG315482 is a certification under a general permit and should not be counted as an individual permit.
• Metric 5b4 - COG075604, COR03P988 and COR03Q329 are possibly incorrect, research and corrections are being processed.
• Metric 7j2 - COS000008 resolved. COR03M867 permit expired 9/30/2015. RNC status is carry over from 2014. COR03M248 permit expired 9/30/2016. Penalty payments were late but do not constitute SNC or Cat I noncompliance. COE024000 facility was compliant but RNC was not manually corrected properly (also compliance tracking for COEs is turned off so I don't know why this is showing up). COR03I226 permit expired 2015. Violations do not appear in ICIS. COR03M456 violations occurred 4/21/2015, 10/30/2015 so RNC status is carry over. COR03M909 violations do not appear in ICIS.
• Metric 7j3 - COU000101 and COU310001 appear to be linked to an enforcement actions issued in 1996 and 1992 and should be flagged for errors in database. 181 Permits are Terminated but still show violations - these may have violations in error, corrections are being processed.

• Metric 1a4 - The number of active NPDES non-major general permits is erroneous. CT does not enter all GP registrants into ICIS. Those listed were entered into ICIS because CT DEEP inspected them at some point in the past or because they used NetDMR.
• Metric 7j1 - Number of major and non-major facilities with single event violations reported in the review year. In addition to the SEVs listed, CT cited non-major facilities and facilities with general permits with SEVs. These are not entered into ICIS.
• Metric 7j2 - Number of active facilities with SNC/Category 1 noncompliance. CT verified the quarters with SNC/Category 1 codes. CT did not verify whether blank quarters should be blank. EPA administratively resolved Category 1 violations for NPDES non-majors during the reporting year.
• Metric 7j3 - Number of active facilities with RNC/Category 2 noncompliance or effluent, single event, compliance schedule, or permit event violations open during the year. The number should be 85 instead of 88. CT0101001 is shown as having four E-90 violations. ICIS and ECHO only identified two such violations. CT0000841 is shown as having two E-90 violations. ICIS and ECHO only identified one such violation. While CT confirmed ICIS has violations posted for the remainder of the listed noncompliance, CT did not confirm there are no violations where none are listed. The veracity of each listed violation was not verified; most permittees self-report using NetDMR. CT does not enter compliance schedules into ICIS.

• Metric 1a1: Facility 1000322216 Delaware City Refinery - Old Data is not an active facility. This is a placeholder for older refinery data. The current facility, captured in this count correctly is 1000300016 Delaware City Refining Co-Delaware City. Subtract 1 from this total. Facility 1000500002 Invista is not an active facility. This facility became a Natural Minor facility as of 1/13/15. It is possible that the change in status was not received by ICIS-Air until FFY2017, but not sure. Subtract 1 from this total. Facilities 1000300064 (Air Liquide Industrial US LP); 1000300010 (Chemours Edgemoor Plant) and 1000300015 (Fisker Automotive) were all shutdown during FFY17, however because they were active at some point in FFY17, they should be in this count I believe. Total count should be 54.
• Metric 1a2: Facility 1000300038 Honeywell International Inc. - Claymont is a Natural Minor facility. EPA has two pollutants classified as Synthetic Minor, should be Natural Minor, which is causing the facility overall to be captured as a SM. This is out of the state's control, EPA needs to correct the pollutant classification. Subtract 1 from this. Total should be 76.
• Metric 1b4: Facility 1000322216 is a placeholder for old refinery data. Subtract 1 from this. Total should be 54.
• Metric 1b5: The FCE conducted at Facility 1000300291 (Magellan) was done by EPA, not Delaware. Therefore should not be included in this count. Magellan isn't due for Delaware until FFY18. Subtract 1 from this. Total should be 25.
• Metric 1b6: All of our SMs that are roving crushers are not on Delaware's CMS Plan. This count includes 1 of these (Corrado Construction). In addition, there were 5 facilities showing as due for FFY17, that have been closed for several years that were still active on the CMS for some reason. Manually corrected ICIS-Air to remove those from the CMS Plan as well. Lastly, EPA conducted an inspection at Facility 1000300059 (Rogers Corporation), not our inspection so not on our list. Count should be 23.
• Metric 1j1: The review for Facility 1000300064 (Air Liquide) while done in FFY17 was actually the one that should've been reviewed in FFY16 (on the TVACC covering calendar year 2015). Facility did not submit a TVACC covering calendar year 2016 (and was due) that would've been reviewed in FFY17. Facility shutdown so no way to get the missing TVACC. So while due, it was never received, thus never reviewed. This count should be reduced by 1 as it was not for the TVACC this metric would be addressing. Total reviews should be 49. That means we are missing 4 reviews which is accurate (2 of those 4 have been done, just done in FFY18)
• Metric 1j2: While Facility 1000300015 (Fisker) was an active TV facility during FFY17 (as it would relate to earlier metrics), it was only kept that way for state billing purposes. The facility was sold to another facility and they were given a different ID#. That facility (WX), sold to Boxwood who is captured in this list. So, count should be less 1 as no TVACC was expected from Fisker. Total should be 53.

• Metrics 1b7 and 1b8: DE0020028 and DE0050962- permits are active in ICIS; limits are in state database, having data transfer issues between databases DE0021539 and DE0051063 - permits are active in ICIS; data group number updated on 6/11/18. 
• Metric7J3:
  • DE0000051 - the pH violations are actually not violations. Facility is allowed to be out of the 6-9 range for short periods of time. None of the out of range pH values were out of compliance with time limits.
  • DE0000523 - No violations. There are data transmission errors between state database and ICIS, state IT department is working on resolving issues.
  • DE0000256 - There is a violation showing for this facility in ECHO but not in ICIS. I do not know what is causing this violation but there have been none for this facility during this time period.
  • DE0021539 - PMP has been received in the office, date has been updated in state database. Facility was late in submitting report.
  • DE0050288 - No violations, there is a data transmission issue for the DMR; state IT department is working on resolving issues.
  • DE0050601 - No violations, there is a data transmission issue for the DMR, state IT department is working on resolving issues.
  • DE0050962 - Violation showing is from a report that was submitted under old permit. Report was submitted on time but because the permit is renewed, I haven't been able to update ICIS with the date. A request was sent to ICIS support on 6/11/18.

• Metrics 5b and 5b1: Twenty-two facilities identified in the BR/Active LQG universe are foreign flagged cruise ships and should not be on this list since FDEP relies on the US Coast Guard to perform routine cruise ship inspections. FDEP recommends that a data flag be created to remove cruise ships from Metric 5b and 5b1.
• Metric 1g: Total dollar amount of final penalties or SEP credit. Total dollar amount of final penalties/SEP credit should be $232,317. The cause was identified and corrected. The correct total is currently reflected in RCRAInfo.

• Metric 1a6 - Number of Minors Subject to Formal Enforcement
  Three facilities on this list were not minor sources when the formal enforcement action was issued. Two facilities have been shutdown so they do not appear in metrics 1a1-1a5 and the other facility changed classification after the enforcement action. This metric is flawed in that the look-back period is different for source classification (current year only) than for the formal enforcement action (4 most recent years)
• Metric 1b4 - Number of Active Title V Facilities
  At least three facilities were Title V during FY2017, but were re-classified later:
  • Facility ID GA0000001300900019, Central State Hospital, Title V removed 6/4/18
  • Facility ID GA0000001312100558, Geiger International, Title V removed 5/8/18
  • Facility ID GA0000001332100004, Crisp County Power Commission, Title V removed 6/4/18
• Metric 1j2 - Number of Facilities with TVACC
  Due Two facilities where Title V permit was not issued until 2017, so no ACC would be submitted during FY17.
  • Facility ID GA0000001313500329, MAS Georgia LFG, LLC (Richland Creek): Title V Permit issued 6/6/17
  • Facility ID GA0000001316900010, Atlanta Gas Light Company - Macon LNG Plant: Title V Permit issued 2/22/17
  • Several facilities were major CMS status during FY17 as follows and ACCs were due:
    • Facility ID GA0000001300900019, Central State Hospital: went from major to true minor 6/4/18
    • Facility ID GA0000001305100006, Ga Power Company - Plant Kraft: not removed from CMS until 11/17/16,
    • Facility ID GA0000001306700015, Boral Bricks - Atlanta Plant: not removed from CMS until 11/3/17,
    • Facility ID GA0000001306700018, Sutton R L WPCP: not removed from CMS until 3/31/17,
    • Facility ID GA0000001309500002, Ga Power Company - Plant Mitchell: not removed from CMS until 11/17/16,
    • Facility ID GA0000001320500037, Balfour Pole Company, LLC: Major to SM 5/17/18.
    • Facility ID GA0000001324700052, Jet Corr II, Inc.: not removed from CMS until 1/19/17
    • Facility ID GA0000001328700024, Nationwide Fiberglass Inc.: not removed from CMS until 9/13/17
    • Facility ID GA0000001332100004, Crisp County Power Commission: Major to SM 6/4/18
      
      This metric is fundamentally flawed in that it only looks at the CMS status for the fiscal year. In Georgia, ACCs are due based on calendar year, so an ACC would be expected only if the facility was a Title V source during the calendar year leading up to the fiscal year. In this case, ACCs were received in 2017 for calendar year 2016. Limiting expected ACCs to CMS major sources ignores minor sources subject to Title V, primarily landfills.

• Metric 5a1 - Georgia has meet the 106 Work plan requirement for inspecting all NPDES major permitted facilities once every 2 years. We have also discovered additional inspections completed for these active facilities that did not transfer via EDT and will be correcting the data transfer errors.
• Metric 5b1 - Georgia has meet the 106 Work plan requirement for inspecting all NPDES non-major individual permitted facilities once every 5 years. We have also discovered additional inspections completed for these active facilities that did not transfer via EDT and will be correcting the data transfer errors.
• Metric 5b2 - Georgia has meet the 106 Work plan requirements for inspecting all NPDES non-major general permitted facilities once every 5 years or 10% for SW Construction permits. We have also discovered additional inspections completed for these active facilities that did not transfer via EDT and will be correcting the data transfer errors.
• Metrics 7j1 - Georgia has discovered internal data entry process changes that need to be made to close SEVs in the proper time-frame. We have also discovered errors with our internal database preventing the closures of these SEVs and will be correcting the errors.
• Metrics 7k1 and 8a3 - Due to data entry errors, EDT data transfer errors and SEVs remaining open for an extended amount of time, the quarters of SNC and RNC are incorrectly represented. We are in the process of correcting these internal process, data entry and EDT data transfer errors in addition to the RNC status to correctly represent facility noncompliance.

• Metric 1a1 - Number of Active Major Sources (128) - correct. By the end of FFY17, the number dropped to 127 with one facility reclassified to below Major source status. Without that facility, the list of major sources matches the list in metrics 1b4 and 1j2
• Metric 1a4 - Number of Other Active Facilities in CMS (87) - in correct- see comment There are 100 “Other” CMS Facilities targeted each year - the count in this metric is flawed because of the addition/deletion of facilities on the list over the course of the year when facilities originally targeted are found to be closed and new facilities are added to the list to compensate.
• Metric 1a6 - Number of Minors Subject to Formal Enforcement (30) - correct. 17 formal enforcement actions taken in FFY16. One of which was escalation of a previously issued NON to a formal action and one of which is an ACO with no penalty
• Metric 1b4 - Number of Active Title V Facilities (127) - correct By the end of FFY17, the number dropped to 127 with one facility reclassified to below Major source status. Without that facility, the list of major sources matches the list in metrics 1a1 and 1j2.
• Metric 1b7 - Number of Other CMS minors (103) - correct. There are 100 “Other” CMS Minor Facilities targeted each year. More are shown because of timing of additions/ deletions to the list over the course of the year.
• Metric 1d1 - Number of Facilities with an FRV identified (55) - incorrect- see state comment FRV with a discovery date within FFY2017 totals 66 of which 53 were resolved with informal enforcement at ACMS sources and 18 was subject to formal enforcement. It is unknown why this metric is undercounting the activity. Many of the ACMS sources are end-dated in ICIS air after close of the fiscal year which may be contributing to the problem.
• Metric 1d2 - Number of Case Files with an FRV identified (56) - incorrect. Some facilities make have had enforcement discovered in 2017, action taken in 2018 after the CMS flag was removed and are not showing up in this list. This includes Zatec (MA0000002512001049), Signature Bread (MA0000002511900772) and Nasoya Foods USA LLC (MA0000002512100937). 
• Metric 1e1 - Number of Informal Enforcement Actions (45) - correct. Note: Extract only counts informal enforcement at ACMS facilities.43 Informal actions were taken in FFY17 plus two hold-overs from 2016 were recorded. An additional 23 enforcement actions have been taken during the FFY17 year at Non-ACMS facilities.
• Metric 1g2 - Number of facilities with Formal enforcement actions (17) - correct. One facility received two enforcement actions within FFY17 1h2- number of formal enforcement actions with an assessed penalty (17) - correct The one case noted without penalty was for Excel Recycling. This Consent Order without Penalty was for Noise Violations and put the facility on a testing schedule.
• Metric 1i7 - number of stack tests (70) - correct. There are a total of 77 Tests reported in ICIS Air for FFY17. The 7 tests not shown in the metric are all at minor and non-CMS sources.
• Metric1j1 - number of facilities with a reviewed TVACC (118) - incorrect. During FFY2017 one facility has been reclassified to below OP and is not captured in the results of this metric (Granby Landfill) ALSO- the requirement to submit a TVACC for review is a condition of a valid operating permit. 8 facilities are listed as having not filed a TVACC for review. These facilities do not yet have an OP and therefore are not subject to the TVACC requirement.
• Metric 1j2 - Number of facilities with TVACC Due (127) – correct. Technically, this metric is incorrect. The only Title V sources with a TVACC "Due" are those that have received a Title V Permit. Only 118 facilities have an active permit that imposes the conditions that they submit the TVACC. There are no means to differentiate those facilities with Title V Permits vs those without in ICIS-Air so there is no way to make this metric accurate.

• Metric 1a1 - Number of active majors is 116, NOT 119
• Metric 1b4 - Number of active Title V facilities is 116, NOT 117

• Metric 1b7: Maine has not yet entered their NPDES Data Group codes into ICIS-NPDES. The number of active NPDES individual DMR filers shown is not correct, and does not accurately reflect the true number of permits. This number is expected to change after the NPDES Data Group codes are entered into ICIS-NPDES.
• Metric 1b8: Maine has not yet entered their NPDES Data Group codes into ICIS-NPDES. The number of active NPDES individual DMR filers with permit limits in ICIS shown is not correct, and does not accurately reflect the true number of permits. This number is expected to change after the NPDES Data Group codes are entered into ICIS-NPDES.

In general, the data in the US EPA’s FY17 report is consistent with data in the Michigan Air Compliance and Enforcement System (MACES) database except for the following: 

• Metrics 1a1, 1a2: Active 'major' and 'synthetic minor' facilities represented in the data metric may included those facilities that were later identified as 'minor' during FY17.
• Metric 1a4: There were no actual CMS minor sources in FY17. The state count should be zero.
• Metric 1a5: There were no State lead, minor source HPV cases in Michigan in FY17. The state count should be zero.
• Metric 1g1: Total number of formal enforcement actions is 13 including one added minor source.
• Metric 1g2: Total number of facilities is 12 including one added minor source.
• Metric 1h1: Total penalty is $1,442,200 including on added minor source.
• Metric 1h2: Total number of formal enforcement actions with penalty is 13 including one added minor source.
• Metric 1j1: The number of Title V Annual Compliance Certifications (TVACC) reviewed in FY17 and identified in ICIS-Air is actually 431 (out of 477 TVACC received).

• Metric 1b4 - Data Verification Number of Active Title V Facilities
  • NC0000003701400204 TAPAHA DYNAMICS, LLC Caveat - ARO did not Add TV Air Program to IBEAM after T Version Air Permit was issued.
• Metric 1b5 - Data Verification Number of CMS Majors
  • NC000A0000370770008700015 1/19/2017 Caveat - This inspection on 1/19/2017 is being rejected by ICIS because this compliance monitoring action is colliding with old AFS actions that where migrated into ICIS by EPA. This issue has been reported to EPA for correction.
• Metric 1b6 - Data Verification Number of CMS 80% Synthetic Minors
  • NC0000003701900111 ISP MINERALS INC - SILER CITY MANUFACTUR Caveat - This Planned Facility was in AFS and was migrated into ICIS by EPA. This facility was never permitted and NC has never sent data to ICIS via EDT.
• Metric 1c1 - Data Verification Number of Facilities with an FCE (Facility Count)
  • NC000A0000370770008700015 1/19/2017 Caveat - This inspection on 1/19/2017 is being rejected by ICIS because this compliance monitoring action is colliding with old AFS actions that where migrated into ICIS by EPA. This issue has been reported to EPA for correction.
• Metric 1j1 - Data Verification Number of Facilities with a Reviewed TVACC
  • NC000A0000370770008700016 3/10/2017 - This TVACC is being rejected by ICIS because its compliance monitoring action is colliding with old migrated AFS actions in ICIS.

Ohio EPA has identified errors/deficiencies for several FY17 CWA metrics that are displayed in ECHO. The corrected metric data for Ohio is as follows:

• Metric 1a1: Number of active NPDES major individual permits – 299
• Metric 1a2: Number of active NPDES major general permits – 0 (Ohio’s data is consistent with ECHO)
• Metric 1a3: Number of active NPDES non-major individual permits – 3,320
• Metric 1a4: Number of active NPDES non-major general permits – 30,079
• Metric 1b7: Number of active NPDES individual DMR filers – 3,619
• Metric 1b8: Number of active NPDES individual DMR filers with permit limits in ICIS – 3,619
• Metric 5a3: Number of inspected Major facilities – 154
• Metric 5b3: Number of inspected non-major individual or unpermitted facilities – 1,396
• Metric 5b4: Number of inspected non-major general permit covered facilities – 55
• Metric 7j1: Number of major and non-major facilities with single-event violations reported in the review year – 0
• Metric 7j2: Number of active facilities with SNC/Category 1 noncompliance – 682
• Metric 7j3: Number of active facilities with RNC/Category 2 noncompliance or effluent, single event, compliance schedule, or permit event violations open during the year – 1,725

Oklahoma Department of Environmental Quality Water Quality Division’s Federal Fiscal Year 2017 (10/01/2016-09/30/2017) State Review Framework. The Oklahoma Department of Environmental Quality (Oklahoma DEQ) Water Quality Division has completed their data metric review of the CWA data on the State Review Framework (SRF) for Federal Fiscal Year (FFY) 2017. The following caveats and revision in metric values need to be added to Oklahoma DEQ-Water Quality Division’s FFY2017 SRF:

1. Oklahoma DEQ does not code into EPA’s ICIS-NPDES Production database the Stormwater Construction and Stormwater Industrial facility data (metric 1a4), inspections (metric 5b2 and 5b4), and enforcement actions (metric 7j1-7j3, 7k1, and 8a3), but the data is maintained in Oklahoma DEQ’s in-house database. Oklahoma DEQ is working on flowing this data from their state database to the EPA’s ICIS-NPDES database.
2. The Metric Data listed is reflective of the Oklahoma Department of Environmental Quality's Water Quality Division Data and the Oklahoma Department of Agriculture, Food and Forestry (ODAFF). ODAFF is the delegated authority for the Concentrated Animal Feeding Operation (CAFO) program and ODAFF will report their revised values separately from Oklahoma DEQ-Water Quality Division. The CAFO permit can be identified within the metric as any permit Id number that begins with OKG01.
3. Oklahoma DEQ has revised their Compliance Monitoring Strategy with EPA to no longer do 100% CEI Inspections on Major facilities to 90%. The remaining 10% CEI inspections are performed on Minor or General facilities. Major, Minor, and General permits have their CEI, CSI, PCI, and Audit inspections coded into ICIS-NPDES. All Routine Inspections are maintained in the state database. Oklahoma DEQ is working on flowing this data from their state database to the EPA’s ICIS-NPDES database.
4. Metric 1a3 - Number of Active Non-Majors with Individual Permits revised value is 353. Watts WWT (OK0077777) and Forgan WWT (OK0066666) are not discharge permits. They are total retention systems, which were entered into ICIS-NPDES because they accept Industrial user's wastewater and the Industrial User permit requires the entry of a Receiving POTW ID (ICIS required data element).
5. Metric 1a4 - Number of Active Non-Majors with General Permits revised value is 4370. Stormwater-Construction and Stormwater- Industrial permits are maintained in the Oklahoma DEQ's state database. During this period, there were 1506 Stormwater-Industrial and 2700 Stormwater-Construction permits. Oklahoma DEQ-WQD has permitted 118 General Discharge permits and 49 MS4 Phase II permits. The Oklahoma Department of Agriculture, Food and Forestry (ODAFF) is delegated to permit the general CAFO (OKG01) permits on the list.
6. Metric 1b7 - Number of Active Individual DMR filers is revised to 457. Tulsa MS4 (OKS000201) and OKC MS4 (OKS000101) are multi-sector permits that do not require permit limits or DMRs. Watts WWT (OK0077777) and Forgan (OK0066666) are not discharge permits, therefore the facilities are not required to file DMRs or have permit limits. Boswell WWT is an in Effect permit that is missing from the list and does have permit limits and is a DMR filer. The following missing facilities from the list did have permit data and were DMR filers during FY2017, however the permits were terminated prior to the end of FY2017:
   • OK0022586 - Stillwater Electric Utility terminated 10/25/2016
   • OK0027171 - Frederick East WWT terminated 11/08/2016
   • OK0030317 - American Water Services terminated 06/19/2017
   • OK0040673 - Coal Creek Minerals terminated 10/31/2016
   • OK0045390 - Aaon, Inc. terminated 03/27/2017
   • OK0045993 - Anchor Stone Co-Jenks terminated 11/03/2016
   • OK0046027 - Wynnewood Refining Co terminated 05/12/2017
7. Metric 1b5 - Permit Limit data for major and non-major facilities is revised to 457. There were 353 minor individually permitted facilities and 104 major permitted facilities. Tulsa MS4 (OKS000201) and OKC MS4 (OKS000101) are multi-sector permits that do not require permit limits or DMRs. Watts WWT (OK0077777) and Forgan (OK0066666) are not discharge permits, therefore the facilities are not required to file DMRs or have permit limits. Boswell WWT is an in Effect permit that is missing from the list and does have permit limits and is a DMR filer. The following missing facilities from the list did have permit data and were DMR filers during FY2017, however the permits were terminated prior to the end of FY2017:
   • OK0022586 - Stillwater Electric Utility terminated 10/25/2016
   • OK0027171 - Frederick East WWT terminated 11/08/2016
   • OK0030317 - American Water Services terminated 06/19/2017
   • OK0040673 - Coal Creek Minerals terminated 10/31/2016
   • OK0045390 - Aaon, Inc. terminated 03/27/2017
   • OK0045993 - Anchor Stone Co-Jenks terminated 11/03/2016
   • OK0046027 - Wynnewood Refining Co terminated 05/12/2017
8. Metric 1b8 - Number of active NPDES individual DMR filers with permit limits is revised to 457. Tulsa MS4 (OKS000201) and OKC MS4 (OKS000101) are multi-sector permits that do not require permit limits or DMRs. Watts WWT (OK0077777) and Forgan (OK0066666) are not discharge permits, therefore the facilities are not required to file DMRs or have permit limits. Boswell WWT is an in Effect permit that is missing from the list and does have permit limits and is a DMR filer. The following missing facilities from the list did have permit data and were DMR filers during FY2017, however the permits were terminated prior to the end of FY2017:
   • OK0022586 - Stillwater Electric Utility terminated 10/25/2016
   • OK0027171 - Frederick East WWT terminated 11/08/2016
   • OK0030317 - American Water Services terminated 06/19/2017
   • OK0040673 - Coal Creek Minerals terminated 10/31/2016
   • OK0045390 - Aaon, Inc. terminated 03/27/2017
   • OK0045993 - Anchor Stone Co-Jenks terminated 11/03/2016
   • OK0046027 - Wynnewood Refining Co terminated 05/12/2017
9. Metric 7j1 - Number of major and non-major NPDES facilities with single event violations is revised to 110. The following Stormwater facilities should be included in the list:
   • OKR1026851 Allen Contracting Inc.
   • OKR1027454 Rausch Coleman Holmes 
   • OKR1026485 Shay Development
   • OKR052412 ATC-Drivetrain
   • OKR1026656 Woodland Hills -Keith six MHP
   • CGC, LL
   • Western Skies
   • Johnson Controls
   • Sherwood Construction
   • Core Construction
   • Atlas Gen-ODOT
10. Metric 7j2 - Number of Active facilities with SNC/Category 1 noncompliance is revised to 476. There were 11 Stormwater Construction facilities listed in metric 7j1 with single event violations that received a formal enforcement action that were not entered into ICIS-NPDES, but were maintained a state database. Industrial Stormwater has a total of 323 DMR filers, in which 247 Industrial Stormwater facilities were either greater than 30 days late submitting their DMR or the DMR is not submitted. Oklahoma DEQ is working on flowing this data from their state database to the EPA’s ICIS-NPDES database.
11. Metric 7j3 - Number of Active facilities with RNC/Category 2 noncompliance for effluent, single event, compliance schedule, or permit event violations open during the year is 271.
12. Metric 7k1 - Major and non-major facilities in noncompliance revised value count is 747 out a universe of 4,829 permits.
13. Metric 5a1 and 5a3 - Inspection coverage of NPDES Majors is revised to 91. A total of 84 facilities had a CEI inspection and 7 facilities that did not have a CEI inspection had a Routine inspection.
14. Metric 5b1 - Inspection Coverage -  NPDES Non-Major individual facilities is revised to 227. A total of 15 facilities had a CEI inspection and 212 facilities that did not have a CEI inspection had a Routine inspection. The 4 Unpermitted facilities that had an inspection conducted are listed in the list, have been removed from the count because they do not have individual permits.
15. Metric 5b3 - Inspection Coverage - NPDES Non-Major individual or unpermitted facilities is revised to 231. A total of 15 individual non-major facilities had a CEI inspection, 4 unpermitted facilities, and 212 individual non-major facilities that did not have a CEI inspection had a Routine inspection.
16. Metric 5b2 and 5b4 - Inspection Coverage - NPDES Non-Majors with General Permits is revised to 1166. A total of 956 Stormwater –Construction, 143 Stormwater-Industrial, and 67 General NPDES Discharge facilities were inspected. General discharge permit CEIs are coded into ICIS-NPDES, but General routine inspections are maintained in the state's database.

• Metric 1a1: SC00005600361 - CUMMINS INC CTC CHARLESTON - Operated as CM facility during FFY 2017, TV on 01/01/2018. SC00006800046 - GEORGIA-PACIFIC WOOD PRODUCTS LLC - Operated under construction permit for FFY 2017. TV on 10/01/2017. SC00020600514 - FEHRER AUTOMOTIVE NORTH MAERICA LLC - Operated as CM for FFY 2017, TV on 01/01/2018.
• Metric 1a2: SC00009000069 - JAMES HARDIE BULIDING PRODUCTS INC - Operated as a minor facility for FFY 2017. Facility became CM on 01/01/2018. SC00017800049 - CATERPILLAR INC NEWBERRY - Closed since 07/11/2017. SC00019000258 - CAROLINA INTERNATIONAL TRUCKS - Exempt facility as of 12/20/2016. SC00020600135 - SOLVAY USA INC - Operated under construction permit during FFY 2017. CM on 04/01/2018. SC00020600548 - PACIFIC INDUSTRIAL DEVELOPMENT CORP - Facility was an exempt facility during FFY 2017, became CM on 04/01/2018. SC00021400017 - PINEWOOD SITE CUSTODIAL TRUST - Operated as a minor facility for FFY 2017. CM on 01/01/2018. SC00099000685 - ARCHER WESTERN CONSTRUCTION - Operated under construction permit for FFY 2017. CM on 10/02/2017.
• Metric 1a4: SC00010400083 - EVANS READY-MIX INC - Facility has been closed since 2006. SC00020600199 - SIEGWERK USA CO -Facility went from a CM to State Op (MI) on 04/01/2016.
• Metric 1a6: SC00000400032 - CAROLINA FABRICATION INC - Facility is Closed. Last Violation was 09/19/2013 and was resolved 06/22/2015. Penalty $22500. SC00012400131 - CROWN CASTING LLC - Facility is Closed (11/09/2016) Last Violation occurred on 09/02/2015 and resolved on 11/14/2016-INFORMAL No Penalty. Last Penalty was from a violation on 03/13/2013 which was resolved on 01/07/2015 with a penalty of $24000. SC00020600164 - PIEDMONT CONCRETE PRODUCTS INC - Last violation occurred on 07/07/2014 and was resolved on 09/17/2015. Penalty $4000. SC00099000073 - FURR GRADING AND PAVING INC - Closed. Last violation occurred on 04/11/2013 and was resolved on 01/23/2014. Penalty $6000. SC00099000125 - BROAD RIVER MATERIALS - Closed. Last violation occurred on 04/27/2015 and was resolved on 01/08/2016. Penalty $8500.
• Metric 1b4: SC00005600361 - CUMMINS INC CTC CHARLESTON - Operated as CM for FFY 2017, TV on 01/01/2018. SC00006800046 - GEORGIA-PACIFIC WOOD PRODUCTS LLC - Operated under construction permit for FFY 2017, TV on 10/01/2017. SC00020600514 - FEHRER AUTOMOTIVE NORTH AMERICA LLC - Facility operated as CM for FFY 2017, TV on 01/01/2018.
• Metric 1b5: SC00000800144 - AMERESCO FEDERAL SOLUTIONS - Facility is operating under construction permit. SC00011400041 - PHOENIX SERVICES LLC GEORGETOWN - Facility closed on 08/31/2016. SC00012400074 - FUJIFILM MANUFACTURING USA INC - Facility permit merged (permit closed) in 2015. SC00015600113 - MICHELIN NORTH AMERICA INC LEXINGTON US7 - Facility permit merged (permit closed) in 2015. SC00019000033 - INTERTAPE POLYMER GROUP - Facility closed in 2016.
• No discrepancies for metric IDs: 1a3, 1a5, 1b7, 1c1, 1c2, 1d1, 1d2, 1e1, 1e2, 1f1, 1f2, 1g1, 1g2, 1h1, 1h2, 1i7, 1j1, 1j2

1. Metric 1a4 - There are 19 SDPG#'s that are Pretreatment Metal Finisher General Permit Covered Facilities and not to be counted. There is not a way for the logic to remove these from the count.
2. Metric 5a3 - The Brookings Municipal Utilities and City of Huron were Pretreatment Audits. There is not a way for the logic to remove these from the count.
3. Metric 7j2 - There are 2 SDPG#'s that are Pretreatment Metal Finisher General Permit Covered Facilities and not to be counted. There is not a way for the logic to remove these from the count.
4. Metric 7j3 - There are 8 SDPG#'s that are Pretreatment Metal Finisher General Permit Covered Facilities and not to be counted. There is not a way for the logic to remove these from the count.

Please see the following sites regarding metric 1a2. Officially using 1a5; however, we did drill down and analyze 1a2.

• TND981860992 MATTHEWS AURORA FUNERAL SOLUTIONS - (N) in 2018; LQG in 2017. Not pulling from SRF Replicated Query in RCRAinfo. But verified individually in RCRAinfo.
• TND987787686 E I DUPONT AGRICULTURAL PRODUCTS - EVALUATION CENTER - Not pulling from SRF Replicated Query in RCRAinfo; see query above. But verified individually in RCRAinfo.
• TND003332012 Bromid LLC 01/2004 LQG Receipt, CEI in 2001. No LQG fees reporting activity since 2004 in our internal Waste Audit Database Oracle.
• TNR000024562 Imperial Pools Inc 07/2009 (N) but still marked active status - H; CEI 2008. Not in our Waste Audit active LQG database. Should be marked inactive.
• TNR000023929 MEMPHIS HOUSING AUTHORITY (MHA) - WOODWARD ST 2008 N but H; CEI 01/2009 Not in our Waste Audit active LQG database. Should be marked inactive.
• TNR000034496 Precision Flooring Products Inc. 3/2012 LQG; 10/2013 CSE Not in our Waste Audit active LQG database. Should likely be marked inactive.
• TND987767910 Quala Systems Inc. 2007 N but marked H; CSE 1990 Not in our Waste Audit active LQG database. Should be marked inactive.
• TNR000029009 RAPAC Inc. LQG 2012; CSE 2010 Not in our Waste Audit active LQG database. Should be marked inactive.
• TND086020112 Trumbull Asphalt N in 2009; CSE 2013 Not in our Waste Audit active LQG database. Should be marked inactive.

• Metric 1a1 - Current and historic Title V Major facilities appear in Enforcement and Compliance History Online (ECHO), regardless of the FFY17 permit status. Texas Commission On Environmental Quality (TCEQ) Records indicate there were 1,130 active Title V Major facilities in FFY17. TCEQ is developing a process to update facility status in ICIS Air and ECHO. 
• Metric 1a2 - TCEQ does not capture or maintain this information.
• Metric 1a3 - TCEQ does not capture or maintain the number of active minor facilities subject to the NESHAP program; however, TCEQ is developing a process to report minor sources that receive a violation for federal requirements.
• Metric 1a4 - TCEQ does not capture or maintain this information. The 156 facilities included in this number are minor facilities and should not have active CMS plans. TCEQ is working with EPA to remove these facilities and is developing a process to update facility status in ICIS Air and ECHO.
• Metric 1a5 - The 6 facilities included in this number are for historic HPVs that were major at the time of the violation. 1a6 - TCEQ does not have a Synthetic Minor program; however, TCEQ is developing a process to report federally reportable violations at minor sources.
• Metric 1b4 - Current and historic Title V facilities appear as active in ECHO, regardless of the FFY17 permit status. TCEQ Records indicate there were 1,335 active Title V facilities in FFY17. TCEQ is developing a process to update permit status in ICIS Air and ECHO.
• Metric 1b5 - TCEQ records show that there were 705 Title V major facilities with an FCE conducted in FFY17. ECHO is including historic Title V facilities that are no longer required to be on a CMS plan and are not due for an FCE. TCEQ completed all required FCE for the review year. TCEQ is in the process of updating historic information and developing a process to update facility status in ICIS Air and ECHO.
• Metric 1b6 - TCEQ does not have a Synthetic Minor program and does not maintain this information.
• Metric 1b7 - TCEQ does not capture or maintain this information.
• Metric 1c1 - TCEQ records show that there were 705 Title V major facilities where FCEs were conducted in FFY17. ECHO reflects an ACC as an FCE in error. TCEQ is reviewing the record.
• Metric 1c2 - TCEQ records show that 723 FCEs were completed during FFY17. ECHO data includes four duplicate entries, and reflects an ACC as an FCE in error. TCEQ is reviewing the records.
• Metric 1d2 - TCEQ records indicate that there was a case that occurred in FFY16 that was combined with a case from FFY17; this is not included in ECHOs FFY17 count.
• Metric 1e1 - Currently TCEQ only flows those FRVs that are also HPVs at major sources. TCEQ Records indicate the number of informal enforcement actions during FFY17 was 81. An informal enforcement action precedes development of an enforcement case. The number in ECHO reflects the number of informal enforcement actions that were effective prior to case development at the time of TCEQ's monthly data flow.
• Metric 1e2 - Currently TCEQ only flows those FRVs that are also HPVs at major sources. TCEQ Records indicate the number of facilities that received an informal enforcement action during FFY17 was 68. An informal enforcement action precedes development of an enforcement case. The number in ECHO reflects the number of informal enforcement actions at facilities that were effective prior to case development at the time of TCEQ's monthly data flow.
• Metric 1f1 - TCEQ records indicate that there was a case that occurred in FFY16 that was combined with a case from FFY17; this is not included in ECHOs FFY17 count.
• Metric 1g1 - TCEQ Records indicate the number of formal enforcement actions issued to Title V major facilities during FFY17 was 29. TCEQ is developing a process to correctly report case files for all FRVs, not only HPVs.
• Metric 1g2 - TCEQ Records indicate that the number of Title V major facilities that received formal enforcement actions during FFY17 was 28. TCEQ is developing a process to correctly report case files for all FRVs, not only HPVs.
• Metric 1h1 - TCEQ continues to enhance upload capabilities and is currently mapping ICIS-AIR requirements to ensure all required information is reported. 1h2 - TCEQ continues to enhance upload capabilities and is currently mapping ICIS-AIR requirements to ensure all required information is reported.
• Metric 1i7 - The ECHO data reflects stack test reviews at Title V major facilities only. TCEQ does not capture or maintain the total number of stack tests that occurred for any given fiscal year.
• Metric 1j2 - Current and historic Title V facilities appear as active in ECHO, regardless of the FFY17 permit status. TCEQ records indicate there were 1,130 active Title V facilities in FFY17. TCEQ is developing a process to correctly indicate facility status in ICIS Air and ECHO.

• Metric 1a1 - TCEQ records indicate that there were 705 NPDES majors. The EPA database included 14 permits that were either cancelled, expired, or designated as a minor.
• Metric 1a3 - TCEQ records indicate that there were 2,179 non-majors. The EPA database included 216 permits that were either cancelled, expired, or designated as a major. It also omitted 19 permits that should have been included.
• Metric 1a4 - TCEQ records indicate that there were 2,200 general permits. The EPA database included an additional 244 permits outside of the timeframe that TCEQ used to generate these metrics (i.e., EPA Fiscal Year, October 1, 2106 thru September 30, 2017 versus TCEQ Fiscal Year, September 1, 2016 thru August 31, 2017). Additionally, TCEQ is working with EPA to remove two permits that were not associated to the Water Quality Texas data.
• Metric 5b3 - There is currently no mechanism to report entities with authorization types CAFO IP, Sludge DIS, or IND SW. It was determined that there were 29 of these entities with an investigation.
• Metric 5b4 - TCEQ is not flowing non-major general permits to ICIS-NPDES. This will be included in the next flow enhancement.
• Metric 7j1 - TCEQ is not flowing non-major general permits to ICIS-NPDES. This will be included in the next flow enhancement.

• Metric 1a5 - The Echo number of 990 provided was from the 2013 BR data as modified to exclude one-time temporary notifiers and legacy sites. 
• Metric 1b1 - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator and Conditionally Exempt Small Generator sites to meet the Large Quantity Generator commitment. TCEQ met the approved alternative CMS by conducting inspections at 494 facilities during FY17. This includes 150 facilities which are not required to obtain EPA IDs and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads.
• Metric 1c1 - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator and Conditionally Exempt Small Generator sites to meet the Large Quantity Generator commitment. TCEQ investigations found new violations at 283 facilities during FY17. This includes 69 facilities which are not required to obtain EPA IDs and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads.
• Metric 1c2 - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator and Conditionally Exempt Small Generator sites to meet the Large Quantity Generator commitment. TCEQ data includes 283 sites with new violations cited during the review period and an additional 321 facilities which have or had outstanding violations cited in prior to the review period. This brought the total number of facilities to 604. This includes 162 facilities which are not required to obtain EPA IDs and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads.
• Metric 1d1 - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator and Conditionally Exempt Small Generator sites to meet the Large Quantity Generator commitment. TCEQ data reflects 250 sites with informal enforcement actions, including 19 with duplicate EPA IDs that result in error, and 77 facilities which are not required to obtain EPA IDs and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads.
• Metric 1d2 - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator and Conditionally Exempt Small Generator sites to meet the Large Quantity Generator commitment. TCEQ data reflects 277 informal enforcement actions, including 19 with duplicate EPA IDs that result in error, and 84 actions for facilities which are not required to obtain EPA IDs and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads.
• Metric 1e1 - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator and Conditionally Exempt Small Generator sites to meet the Large Quantity Generator commitment. TCEQ records indicate there were 12 sites with a new SNC. This includes 2 sites that did not flow up due to date discrepancies and 2 facilities which are not required to obtain EPA IDs. TCEQ is reviewing the date discrepancies and is continuing to improve functionality to ensure complete and accurate data uploads.
• Metric 1f1 - This 79 includes 38 facilities which are not required to obtain EPA IDs and cannot be uploaded into RCRAInfo.
• Metric 1f2 - ECHO reports 48 and TCEQ's data reflects 83. TCEQ records indicate an additional 32 facilities with formal enforcement actions which are not required to obtain EPA IDs and cannot be uploaded into RCRAInfo.
• Metric 1g - ECHO reports show $875,559. TCEQ data reflects $1,060,852. The $185,293 difference in the penalty amounts is due to the fact that some facilities are not required to obtain EPA IDs and cannot be uploaded to RCRAInfo.

• Metric 1a2 - No permit fits in this category.
• Metric 1a4 - Virginia does not flow general permit info into ICIS except for the nutrient trading permit (Permit ID contains 'VAN'). The facilities and permit IDs listed that contain 'VAG' or 'VAR' are records with federal inspections done in the past (entered by EPA). This list only represents a fraction of the VPDES General Permit universe.
• Metric 5b4 - Virginia currently does not flow general permit information other than data of nutrient trading general permit; this list includes only inspections conducted for the nutrient trading permit starting from 01/01/2017.

• My review and data verification is for the Hanford Site Title V. This is a subset of the sources in Washington State jurisdiction.
• My review and data verification is for the sources in the Central Region only. This is a subset of the sources in Washington State jurisdiction. Title V sources include: Goldendale Generating Station, Greater Wenatchee Regional Landfill, PUD No. 1 of Klickitat County, Roosevelt Regional Landfill, and SDS Lumber Company. Synthetic Minor 80 sources include: Central Washington University, Dolco Packaging Corporation, and Zosel Lumber Company.
• My review and data verification is for the sources in the ECY's Industrial Section only. This is a subset of the sources in Washington State jurisdiction. Nine Title V sources.
• Metric ID 1j2 - Number of Facilities with TVACC Due should not include Grays Harbor Energy (ID # WAORC0005302701186). Though the facility is operating, a Title V permit has not been issued.

• Metric 5a1 - Inspection Coverage-NPDES Majors. Count. This metric does not include 12 inspections performed on major permit WV0050717. This information is in the ICIS database and the permit is included in the Universe.
• Metric 1b6 - DMR data entry rate for major and non-major facilities. Not Counted. This includes many facilities with data that is not counted.
• Metric 5b1 - Inspection Coverage of NPDES non-majors with individual permits. Count. This does not include 752 inspections performed on non-major permits where the electronic data feed has not been finalized under the eRule.
• Metric 7k1 - Major and non-major facilities in noncompliance. Problems with data conversion from the West Virginia data system to the ICIS system has resulted in inaccurate rates being reported to the ECHO system for facilities in both SNC/Category 1 and RNC. Some of the many problems encountered are: Permit Inspectable Units coded as No Flows and Not Constructed being analyzed as SNC/Cat 1 DMR Non-receipt in ECHO; Annual, Semi-Annual, and Quarterly Reporting requirements being coded as SNC/Cat 1 DMR Non-receipt in ECHO if DMR results are not submitted in a specific month; pH parameter without a monthly average result reported being coded as SNC/Cat 1 DMR Non-receipt in ECHO; Parameter level Alternate reporting limits being coded as SNC/Cat 1 DMR Non-receipt in ECHO if no data for the alternate not required is not provided; and several other incorrect analysis by ECHO of the data submitted to ICIS resulting in inaccurate RNC numbers.
  
  Although the programmers at West Virginia Department of Environmental Protection have solved several of the problems noted above and have applied them to the 2017 SRF frozen dataset they have not had time to apply them to the 2015 and 2016 DMR data that was uploaded to ICIS in the beginning stages of compliance with the federal eRule. This data information is causing the 2017 SRF frozen dataset to still show facilities in both SNC/Cat 1 DMR Non-receipt status and also in RNC.
  
  Additionally, many facilities that were first uploaded into ICIS to comply with the federal eRule contained permits that were subsequently coded as G3A and do not meet the definition of facilities required to submit data under the eRule. Although these facilities were provided so they could be removed from the dataset for ECHO analysis many still remain as part of the 2017 SRF frozen data in error and also result in inaccurate data metrics.