State Comments on Frozen Data - 2018

• Metric 5b3
  Number of inspected non-major individual or unpermitted facilities.
  Review of inspections for non-major individual or unpermitted facilities in ICIS-NPDES found 198 non-major individual and unpermitted facilities inspected in FY2018; 138 inspected NPDES facilities were verified in ICIS-NPDES as of 03/19/2019; 58 unpermitted not entered into ICIS-NPDES due to resource shortage
• Metric 5b4
  Number of inspected non-major general permit covered facilities.
  Review of inspections for non-major general covered facilities in ICIS-NPDES found 180 inspections in ICIS as of 03/19/2019; 17 entered into ICIS-NPDES on 3/18/19 (163 entered as of 03/15/2019); 26 entered into ICIS-NPDES on 3/19/2019; 26 general covered facilities not entered into ICIS-NPDES due to lack of resources.
• Metric 7j1
  Number of major and non-major facilities with single-event violations reported in the review year.
  Review of single event violations in ICIS-NPDES found 28 NPDES permit facilities with new single event violations in FY2018 as of 03/21/20119. The following were not included ECHO Data Metrics: AR0040860, 08/04/2018 violation (D0016) Permit Violations - Failure to Submit Timely Permit Renewal Application; and ARR155472, 02/09/2018 violation (B0040) Management Practice Violations - Improper Chemical Handling; B0R41 WW Stormwater Construction - Failure to Maintain Records; (BR19A) WW Stormwater Construction - Failure to properly install/implement BMPs; (BR19B) WW Stormwater Construction - Failure to properly operate and maintain BMPs. These may have been entered into ICIS-NPDES after 03/15/2019.
• Metric 7j2
  Number of active facilities with SNC/Category 1 noncompliance.
  Review of violations and RNC Status in ICIS-NPDES found 427 NPDES permit facilities in SNC/Category 1 noncompliance in FY2018 as of 03/21/20119: Permit coverage for ARG640092 was terminated 02/01/2017 and permit ARG640167 was terminated 12/01/2016, both before FY2018 started.
• 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.
  Review of violations and RNC Status in ICIS-NPDES found 531 NPDES permit facilities could be verified in RNC/Category 2 noncompliance in FY2018 as of 03/21/2019. The ECHO query considered permit schedule violations for permits that were terminated before the beginning of FY2018, and compliance schedule violations from formal enforcement actions issued by USEPA, not the state. The state is not responsible for the schedule violations.
  • Two NPDES facilities: ARR000481 SANDY HILLS MINE; ARR00B303 NORMAN CLIFTON AUTO PARTS, are included in this category even though their NPDES permit coverage was terminated 07/01/2014 and 08/02/2013, respectively. The permit schedule reports have been closed.
  • 7 NPDES facilities are included in this category for violations of compliance schedule events from formal enforcement actions issued by USEPA Region 6 (not the state). The state does not address violations associated with USEPA formal enforcement actions.
  • One facility tracked under ARR155472 (Blue Springs Holding Company, LLC) should have been included in this category, but was entered into ICIS-NPDES after 30.15/2019.
  • The following single event violations are addressed under the formal enforcement action: 02/09/2018 B0040 Management Practice Violations - Improper Chemical Handling; B0R41 WW Stormwater Construction - Failure to Maintain Records; BR19A WW Stormwater Construction - Failure to properly install/implement BMPs; BR19B WW Stormwater Construction - Failure to properly operate and maintain BMPs

A data flow issue has been identified from Arizona Department of Environmental Qualities' database to ICIS

• Town of Marana WRF - AZ0024520
• Central Buckeye WWTP - AZ0025313
• Superior Sanitary District - AZ0021199: Shows an exceedance in ICIS for Total Suspended Solids on their monthly dmr when there actually is no exceedance.
• The following are Stormwater permitted facilities and not Individual Major AZPDES(NPDES) facilities
  • City of Tucson Stormwater - AZS000001
  • Pima County Stormwater - AZS000002
  • City of Phoenix MS4 - AZS000003
  • City of Mesa - AZS000004
  • City of Tempe - AZS000005
  • Stormwater - AZS000018
  • City of Glendale Stormwater - AZS00019
  • City of Scottsdale Stormwater -AZS000020.

• Metric 7j2
  This metric includes continuing RNC for old violations including but not limited to historic permit compliance schedule violations. We estimate that at least 5 facilities are impacted by these factors.
• Metric 7j3
  This metric includes expired and terminated permits as well as continuing RNC for old violations including but not limited to historic permit compliance schedule violations. We estimate that at least 164 facilities are impacted by these factors.

• Metric 1a2
  The term active should be interpreted as a facility that has not notified that they are no longer conducting regulated activity. Therefore, Metric 1a2 is most likely not representative of the universe of operating generators. CT DEEP relies on Metric 1a5, the number of generators who have filed a biennial report (FY2015 BR = 386 LQG’s, 247 traditional, 139 pharmaceutical), as a more representative count of LQGs actively operating in the state.
• Metric 1b1
  CT DEEP conducted 14 inspections in addition to the 82 inspections reported. These 14 inspections were comprised of:
  • 1 Non-Financial Record Review (NRR) – Clean Harbors Environmental Services Inc. (CTD000604488);
  • 7 Financial Record Reviews (FRR) – Americas Styrencs LLC Allyn’s Point Styrenics Plant (CTD001159730); Ashrroft Inc (CTD001840974); Bass Plating Co. (CTD001145671); Dyno Nobel Inc.(CTD058509712); Hamilton Sustrand Corp (CTD001145341); TD Development LLC (CTD06529158); UTC Pratt & Whitney (CTD003935905);
  • 6 Case Development Inspections (CDI) – BJ Wholesale (CTR000517789); Cascades Boxboard Group CT LLC (CTD001147867); Eastern Connecticut Fire School (CTR000518191); Environmental Serv Mitchell Assoc (CTD01811802); Red Technologies LLC (CTR000505958); Town of Berlin Public Works Facilities (CTR000518357);
• Metric 5a
  Two-year inspection coverage for operating TSDFs is a combination of inspections performed by CT DEEP and US EPA Region 1 (8 total).
• Metric 5b
  For FFY 18 CT DEEP chose the LQG Flex Alternative and deviated from the national inspection goal of inspecting 20% of the LQG universe by inspecting 10% of the traditional LQG universe and inspecting 5% of the Pharmaceutical LQG universe. To meet these goals, CT DEEP inspected 25 LQGs and proposed to inspect 7 Pharmaceutical LQGs. Instead of inspecting 7 pharmaceutical LQGs, CT inspected 4 Pharmaceutical LQGs and 3 additional traditional LQGs and redirected remaining resources to inspect manifest initiative sites and a mix of other inspection types. The following traditional LQGs inspected in FY2018 were not on the 2015 BRS: Hicks and Otis CTD001170331, Midneroc CTR0005110, and Greenfield Global CTR000511865.
• Metric 1g
  The penalty amount reported includes the total penalty component offset by the performance of Supplemental Environmental Projects.

• 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 5b4
  Number of inspected non-major general permit covered facilities. DEEP also conducted post-closure inspections at 2 facilities that were previously registered under the stormwater construction general permit, which were not listed in ECHO.
• Metric 7j1
  Number of major and non-major facilities with single event violations reported in the review year. There were additional SEVs cited that are not listed. CT does not enter into ICIS SEVs for non-major facilities or facilities with general permits.
• 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.
• Metric 7j3
  Number of active facilities with RNC/Category 2 noncompliance or effluent, single event, or schedule violations open during the year. CT0021504 is shown as having two E-90 violations. CT 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 violation was not verified. Most permittees self-report using NetDMR. CT does not enter compliance schedules into ICIS.

• Metric 1a1
  Note that DCRC - Old Data is a placeholder for reporting old refinery data, not an actual active facility (so that would subtract 1). Another facility became TV during FFY18 (Honeywell/City of Wilmington - not reported to EPA until FFY19) so that would be plus 1 bringing the count back to 50.  Boxwood's Formosa shutdown in FFY19, so should be on this count, so plus 2 = 52.
• Metric 1a2
  Lars Recycling and Perdue Agribusiness were SM in FFY18, but closed during FFY18 so should be on this list. HOWEVER, I see that they're on metric 1a4, so assume search criteria resulted in them being there as opposed to this metric.
• Metric 1a3
  This is Formosa who shut down in FFY19, not a minor facility so don't know why it's being referred to that here.
• Metric 1a4
  Boxwood Lars shutdown in FFY19.  Perdue Agribusiness shutdown in FFY18.  Not sure what metric criteria is pulling these facilities for this metric.  Believe this should be 0.
• Metric 1b4
  Count is right but DCRC Old Data is placeholder for historic reporting for refinery, not an active facility (-1) but Honeywell/City of Wilmington became TV in FFY18, just not reported to EPA until FFY19 so plus one brings it back to 52.
• Metric 1b6
  BPack for some reason on CMS in ICIS-Air. Never was in our system.  Manually removed from CMS in ICIS-Air.  Count is reduced by 1 to equal 19.
• Metric 1j1
  The review of a TVACC on this metric for OSG, was actually a review of the previous FFY's TVACC that didn't get done in its respective FFY, wasn't done until FFY18.  Therefore, the review of the TVACC received in FFY18 has not been done yet. So count is reduced by 1 to 47.

• Metrics 1f1 and 1g3
  There should be 2 additional facilities with formal actions, however we are having a data transfer problem between the state database and ICIS. I have been working with both our state IT Department and the ICIS helpdesk to resolve these issues. DE0000299 and DE0051063 also received Notices of Administrative Penalty and Secretary's Order during the review period, however these may not be showing in ICIS.
• Metric 7j2
  There should only be one possible facility with SNC/Category 1 non-compliance - DE0020338 for recurring effluent violations, however we do currently have a data transfer issue with this permit as well so that could be part of the problem. DE0050083 should not be on this list as the data has been submitted and updated in ICIS. This was also due to a data transfer problem.
• Metric 7j3
  DE0000035 should not be on this list (may clear after the deadline refresh) - this is a data transfer issue and I am working to resolve it. I manually entered the data for the review period but I am working on the data solution with the IT department. DE0050601 should not be on this list (may clear after the deadline refresh) - this was also a data transfer issue that seems to have been corrected. Additionally, the permit was terminated during the review period (July 2018) so it will not be a problem in the future.

• Metric 8b
  Timeliness of SNC Determinations. One facility showing up as not having a timely SNC determination. This is a data translation error and has been corrected in RCRAInfo. The correction should be reflected in ECHO after the next ECHO translation.
• Metric 1a2
  Thirty-one of the 500 handler LQGs 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 reporting Metrics.
• Metric 1a5
  Twenty-three of the 467 BR LQGs 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 reporting Metrics.

• Metric 5a1
  Georgia has met 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 met 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 met 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 and 7k1
  Georgia has identified deficiencies in procedures and flow errors resulting in inaccurate SNC/RNC statuses due to SEVs remaining unresolved or not included in EDT because of duplicate entries. We are correcting these issues and updating our internal process.
• Metrics 7k1 and 8a3
  Georgia has identified a general permit category (Drinking water filter backwash) that was previously using e-reporting incorrectly resulting in inaccurate SNC/RNC statuses. We are correcting these issues and reaching out to the facilities to educate them on proper data entry.
• Metrics 1a4
  Georgia has identified a flow error that has resulted in an incorrect permit status for a large number of the expired Industrial Stormwater permits. These permits are “administratively continued” in ICIS and should be set to “expired”. We will be correcting these manually in ICIS.
• Metrics 7k1
  Georgia has identified deficiencies in processes and procedures involving our third party contractor’s system for accepting Stormwater annual reports and the reporting of the received date resulting in inaccurate SNC/RNC statuses. We are working on updating the third party system and the data for FFY2018.

• Metric 1a4
  GA0000001328300005, Lanzatech Freedom Pines Biorefinery removed from CMS 7/12/17 and 2/15/19 manually
• Metrics 1b5 and 1b6
  GA0000001308900313, Carlyle Compressor, was Major and had FCE on 5/8/18, SM permit issued 1/9/19; GA0000001312100254, PPG Industries, was Major and had FCE on 5/31/18, SM permit issued 12/27/18; GA0000001324700030, Cellofoam North America, Inc., was major and had FCE 1/25/18, SM permit issued 12/26/18.
• Metric 1j1
  This metric ignores the reporting period for which the ACC is due. For example, GA0000001331300001, Shaw Industries Group Inc. Plant 81 held a Title V permit through 7/5/17 and therefore was required to submit an ACC in FFY18.
• Metric 1j2
  This is a flawed metric and the results do not appear to be consistent with the definition of the metric. Georgia bases whether ACCs are due dependent on whether a facility held a Title V permit during the previous calendar year; therefore, an ACC would be expected in FFY18 if the facility held a Title V permit during CY17. CMS status is not the most appropriate basis, but rather whether or not the facility was subject to Title V. Several CMS Major facilities in Georgia do not yet hold a Title V permit, because they are under a Construction permit. Several non-major facilities hold Title V permits and submit ACCs, primarily landfills subject to NSPS WWW or XXX.

• METRIC 1B5
  083-00001 should have been captured, but wasn't. TV major facility that had an FCE due on 6/20/18(9/30/18 FFY18), but not conducted until 10/11/18 (FFY19)
• METRIC 1i7
  The following stack tests were conducted during FFY18, but are not captured for this metric: 001-00323 conducted 11/15/1017; 027-00071 conducted 2/1/2018; 047-00022 conduced 6/21/2018; 067-00038 conducted 1/26/2018; 075-00021 conducted 5/10/2018; 083-00193 conducted 10/5/2017; 777-00126 conducted 7/19/2018

The errors in the data are the result of data transfer issues between the state system and ICIS-NPDES. Specifically, the inspection counts and the facilities in noncompliance are not accurate due to such data transfer issues. The state continues to work with EPA to correct these issues and ensure accurate data.

• Metric 1b7
  Incorrect count. This value is underreported due to issues with the transfer of data from the state database to ICIS-NPDES. All active individual NPDES permit holders are DMR filers.
• Metric 1b8
  Conflicts between the state system and ICIS-NPDES has resulted in permit limits for some facilities not being entered in ICIS-NPDES. Metric 5a3
  The Iowa DNR conducted inspections at 65 major facilities during FY2018.
• Metric 5b3
  The Iowa DNR conducted inspections at 320 non-major facilities during FY2018.
• Metric 7j2
  This number is over-reporting the level of noncompliance due to issues with data transfer from the state database to ICIS-NPDES. The DMR non-receipt violations are generally caused by conflicts between the systems not allowing the data to be entered into ICIS-NPDES. The compliance schedule violations are due to the state not transmitting the schedule event completion dates to ICIS-NPDES.
• Metric 7j3
  This number is over-reporting the level of noncompliance due to issues with data transfer from the state database to ICIS-NPDES. Many of the facilities are identified as being in noncompliance for compliance schedule violations due to the state not transmitting the schedule event completion dates to ICIS-NPDES.

• Metric 1b1
  Should also include the following inspections that are not marked to Extract to Public because they are Administrative ID#s: IAR000523068; IAR000523050; IAR000522813; and IAFILE000548.
• Metric 1c2
  Should also include the following sites that are not marked to Extract to Public because they are Administrative ID#s: IAR000522193; IAR000517474; IAR000519827; IAFILE000021; IAR000522458; and IAFILE000735.
• Metric 1d1
  Should also include the following informal enforcement actions that are not marked to Extract to Public because they are Administrative ID#s: IAR000522193 and IAR000522458.
• Metric 1d2
  Should also include the following informal enforcement actions that are not marked to Extract to Public because they are Administrative ID#s: IAR000522193 and IAR000522458.
• Metric 1f1
  Should also include the following formal enforcement actions that are not marked to Extract to Public because they are Administrative ID#s: IAR000510081; IAR000522342; and IAR000522367.
• Metric 1f2
  Should also include the following formal enforcement actions that are not marked to Extract to Public because they are Administrative ID#s: IAR000510081; IAR000522342; and IAR000522367.

• Metric 1c2
  Should also include the following site that is not marked to Extract to Public because it is an Administrative IDs: KSR000510180

• Metric 7j2
  Number of active facilities with SNC/Category 1 noncompliance is erroneously elevated due to the implementation of electronic discharge monitoring report system (NetDMR). Where limits are coded for untracked non-major facilities and NetDMR is not immediately used, non-receipt DMR violations are generated for DMRs that may have been received through standard paper submission and are not entered into ICIS.

• Metric 1b7 - Number of active NPDES individual DMR filers
  Maine has not completed entering 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 - Number of active NPDES individual DMR filers with permit limits in ICIS
  Maine has not completed entering 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. 1e1: Facilities with Informal Actions - There were 33 Facilities with State Informal Actions.

In general, the data in the US EPA’s FY18 ECHO report is consistent with data in the Michigan Air Compliance and Enforcement System (MACES) database except for the following

• Metric 1a1, 1a2
  Active major and synthetic minor; facilities represented in the data metric may include those facilities that were later identified as minor during FY18.
• Metric 1a4
  These sources were later identified as minor sources but were on the original FY18 CMS Plan.
• Metric 1a5
  There were no State lead, minor source HPV cases in Michigan in FY18. The state count should be zero.

Missouri has had translation issues over the last year. Our data is incorrect in RCRAInfo which means it is incorrect in ECHO. We are working on correcting this issue.

• Metric 1c2
  Should also include the following sites that are not marked to Extract to Public because they are Administrative ID#s: MOR000554816; MOR000541185; MOD006266373; MOR000505545; MOR000542886; MOR000545822; MOR000505578; MO7180090014; MOD065757320.
• Metric 1f1
  Should also include the following site that is not marked to Extract to Public because it is an Administrative IDs: MOR000519082
• Metric 1f2
  Should also include the following site that is not marked to Extract to Public because it is an Administrative IDs: MOR000519082
• Metric 1g
  Total dollar amount of final penalties for EPA should be $11,839. This is associated with the following site that is not marked to Extract to Public because it is an Administrative ID#: MOR000519082

• Matric 1a4 Number of active NPDES non-major general permits
  There are 48 Stormwater Mining permits that begin with MTR3 that should be excluded from the report. This Master General Permit is terminated and was terminated on January 1 2013. The permits authorized under this MGP have been incorporated into the Stormwater Industrial MGP - (MTR0)

• Metric 1c1 Count = 970 plus 1
  NC000A0000370980023200007 FS Inspection 11/14/2017 rejected from ICIS
• Metric 1c2 Count = 970 plus 1
  NC000A0000370980023200007 FS Inspection 11/14/2017 rejected from ICIS
• We had a glitch in our data submission on 11/9/2018. The data was restored in ICIS on 11/13/2018. As a result, the Data Metric Analysis - Element 1 for timely reporting in FY2018 will be affected.

• Metric 1a1
  The NC data system has 7 additional permits that are listed as NPDES major, and the ECHO system has 1 permit listed as major that is listed as minor in the NC data system. The accurate count of NPDES major individual permits is 226. NC is working with EPA to correct the data.
• Metric 1a3
  ECHO has 7 permits listed as NPDES minor that should be major. NC is working with EPA to correct the data.
• Metric 1b7
  13 permits in the NC data system have been updated to include missing data group information. The accurate count of NPDES individual DMR filers is 1410. NC is working with EPA to correct the data.
• Metric 1b8
  The NC data system has 21 permits that have permit limits but do not currently upload to ICIS as they have monitoring frequencies less than monthly. NC is working with EPA to correct the data.

• 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 – 2,951;
• Metric 1a4
  Number of active NPDES non-major general permits – 20,051;
• Metric 1b7
  Number of active NPDES individual DMR filers – 3,250;
• Metric 1b8
  Number of active NPDES individual DMR filers with permit limits in ICIS – 3,250;
• Metric 1e1
  Facilities with Informal Actions – 803;
• Metric 1f1
  Facilities with Formal Actions – 59;
• Metric 1g3
  Facilities with Penalties – 50;
• Metric 5a3
  Number of inspected Major facilities – 152;
• Metric 5b3
  Number of inspected non-major individual or unpermitted facilities – 1,380;
• Metric 5b4
  Number of inspected non-major general permit covered facilities – 73;
• Metric 7j1
  Number of major and non-major facilities with single-event violations reported in the review year – 0 (Ohio’s data is consistent with ECHO);
• Metric 7j2
  Number of active facilities with SNC/Category 1 noncompliance – 709;
• 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 – 723

Oklahoma Department of Environmental Quality Water Quality Division’s Federal Fiscal Year 2018 (10/01/2017-09/30/2018) 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) 2018. The following caveats and revision in metric values need to be added to Oklahoma DEQ-Water Quality Division’s FFY2018 SRF:

• Metric 1A4
  Number of Active non-major general permits: The Concentrated Animal Feeding Operation (CAFO) Program for Oklahoma is delegated to the Oklahoma Department of Agriculture, Food and Forestry (ODAFF), a State Agency. However, there are approximately 18 permits (OKG010095 to )KG010280) that are still showing EPA, Region 6 as the Agency.
• Metric 7j2
  Active Facilities with SNC/Category 1 noncompliance: The permits counted (64) may not be accurate as the number includes approximately 60 permits (OKG340001 to OKG340127) that were terminated in 2016.
• Oklahoma DEQ does not code into EPA’s ICIS-NPDES Production database the Stormwater Construction 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.
• 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.
• 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.
• Metric 1a1
  Number of Active NPDES Major individual permits is 103. The 105 listed in the metric includes 2 Individual MS4 Phase I permits in its universe.
• Metric 1a3
  Number of Active Non-Majors with Individual Permits revised value is 354. 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).
• Metric 1a4
  Number of Active Non-Majors with General Permits revised value is 3,920. Stormwater-Construction and Stormwater- Industrial permits are maintained in the Oklahoma DEQ's state database. During this period, there were 1578 Stormwater-Industrial and 2117 Stormwater-Construction permits. Oklahoma DEQ-WQD has permitted 176 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.
• Metric 1b7
  Number of Active Individual DMR filers is revised to 457. Tulsa MS4 (OKS000201) and OKC MS4 (OKS000101) are individual stormwater 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 (OK0032255) and Otoe-Missouria Tribe of OK (OK0100617) are In Effect permits that are missing from the list; they do have permit limits and are DMR filers.
• Metric 1b5
  Permit Limit data for major and non-major facilities is revised to 457. There were 354 minor individually permitted facilities and 103 major permitted facilities. Tulsa MS4 (OKS000201) and OKC MS4 (OKS000101) are individual stormwater 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 (OK0032255) and Otoe-Missouria Tribe of OK (OK0100617) are In Effect permits that are missing from the list; they do have permit limits and are DMR filers.
• Metric 1b8
  Number of active NPDES individual DMR filers with permit limits is revised to 457. Tulsa MS4 (OKS000201) and OKC MS4 (OKS000101) are individual stormwater 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 (OK0032255) and Otoe-Missouria Tribe of OK (OK0100617) are In Effect permits that are missing from the list; they do have permit limits and are DMR filers.
• Metric 7j1
  Number of major and non-major NPDES facilities with single event violations is revised to 107. The following Stormwater facilities should be included in the list: OKR050781–OK Foods;OKR050852- Nestle Purina Petcare Co;OKR052412-ATC Drivetrain, Inc;OKR053246- A1 State Line Auto Salvage;OKR053460- Shawnee Milling Co.;OKR1021524- Sonoma Development Group;OKR1026484- Atlas General Contractors;OKR1026485- Shay Developers;OKR1026851- Allen Contracting;OKR1027184- Blockone;OKR1027187- Silver Star Construction;OKR1027424- The Cummins Construction Co;OKR1027454- Rausch Coleman Homes;OKR1027940- Sherwood Construction;OKR1028064- Duit Construction Co;OKR1028144- CMS Willowbrook;OKR1028510-A-Tech;OKR1028605- Manhattan Road and Bridge (EPC-2465)
• Metric 7j2
  Number of Active facilities with SNC/Category 1 noncompliance is revised to 356. Industrial Stormwater has a total of 192 Facilities who are DMR filers, of which 118 Industrial Stormwater facilities were either greater than 30 days late submitting their DMRs or the DMRs were not submitted. Oklahoma DEQ is working on flowing this data from their state database to the EPA’s ICIS-NPDES database.
• 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 238. There were 18 Stormwater Construction facilities listed in metric 7j1 with single event violations that received formal enforcement actions that were not entered into ICIS-NPDES, but were maintained a state database.
• Metric 7k1
  Major and non-major facilities in noncompliance revised value count is 594 out a universe of 4,377 permitted universe.
• Metric 5a1 and 5a3
  Inspection coverage of NPDES Majors is revised to 92. A total of 92 facilities had a CEI inspection or a Routine inspection.
• Metric 5b1
  Inspection Coverage NPDES Non-Major individual facilities is revised to 249. A total of 249 Non-Major NPDES Individual facilities had a CEI inspection or a Routine inspection.
• Metric 5b3
  Inspection Coverage- NPDES Non-Major individual or unpermitted facilities is revised to 254. A total of 249 individual non-major facilities had a CEI inspection or Routine Inspection and 5 unpermitted facilities had an inspection.
• Metric 5b2 and 5b4
  Inspection Coverage- NPDES Non-Majors with General Permits is revised to 1572. A total of 1211 Stormwater -Construction, 295 Stormwater-Industrial, and 66 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 1f1
  Facilities with Formal Actions revised value is 145. Industrial and Construction Stormwater are maintained in a state database.
• Metric 1g3
  Facilities with Penalties is revised to 20. Industrial and Construction Stormwater are maintained in a state database.

In FY18 RIDEM participated in an LQG Flexibility program and completed CEIs of 20 LQGs in fulfillment of the quantity proposed to the Region. Review of the data revealed that the following inspections are recorded in RCRA Info but do not appear in ECHO:

• RID980913354 - Interplex Engineered Products (LQG)
• RIR000516583 - Beacon Automotive (VSQG)
• RID001207190 - T and C Woodworking (VSQG)
• The following formal actions with final penalties are recorded in RCRA Info but do not appear in ECHO
  • RIR000016253 (Walgreens #3486) - $6,607 301 7/23/18
  • RI5000011585 (Walgreens #3719) - $6,607 301 7/23/18
  • RIR000016295 (Walgreens #3704) - $6,607 301 7/23/18
  • RI5000010611 (Walgreens #3345) - $6,607 301 7/23/18
  • RI5000010744 (Walgreens #2246) - $6,607 301 7/23/18
  • RI5000010744 (Walgreens #9943) - $6,607 301 7/23/18

• Metric 1a4
  There are 20 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.
• Metric 1e1
  There are 9 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.
• Metric 5a3
  The City of Mitchell and The City of Sioux Falls were Pretreatment Audits and not to be counted. There is not a way for the logic to remove these from the count. 4.
• Metric 7j2
  There are 4 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.
• Metric 7j3
  There are 7 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.

• Metric 1a1
  SC00000800088 ALLNEX USA INC Facility was CM for FFY 2018; TV permit becomes effective on 04/01/2019. SC00002000235 OWT INDUSTRIES INC Facility became TV Major on 01/01/2019; therefore was not a TV Major source for FFY 2018. SC00005600372 THE BOEING COMPANY Facility became TV Major on 01/01/2019; therefore was not a TV Major source for FFY 2018. SC00018800052 WILBERT PLASTIC SERVICES Facility became TV Major on 01/01/2019; therefore was not a TV Major source for FFY 2018.
• Metric 1a2
  SC00000400050 ACS MANUFACTURING INC CM Permit effective 12/06/18. SC00000800152 RECLEIM LLC CM permit effective 10/01/18. SC00005600445 CINTAS - CHARLESTON CM Effective 10/01/18. SC00005600547 CHARLESTON BLAST AND PAINT CM permit effective 2/14/19. SC00015200136 COBB-VANTRESS INC - KINARDS SC CM permit effective 1/1/19. SC00020600439 HEMMELRATH COATINGS INC CM effective on 10/01/18. SC00020600540 MH INDUSTRIES LLC CM Effective 10/01/2018. SC00099000692 C R JACKSON INC - VARNVILLE ASPHALT PLANT CM Permit effective 2/14/19. SC00099000698 ROGERS GROUP INC - GRAY COURT ASPHALT PLANT CM permit effective 1/1/18.
• Metric 1a3
  Not listed, but have subpart 61 SC00000800041 SAVANNAH RIVER NUCLEAR SOLUTIONS LLC SAVANNAH RIVER SITE. SC00004200029 AMOCO CHEMICALS CO; SC00004200059 BERKELEY CO WATER and SANITARY AUTHORITY LANDFILL; SC00004200089 DAK AMERICAS LLC SC00004600029 DAK AMERICAS LLC COLUMBIA SITE. SC00005600411 BEES FERRY LANDFILL. SC00006000007 MILLIKEN and CO MAGNOLIA PLT. SC00009000002 GIANT CEMENT COMPANY. SC00013400107 HORRY COUNTY SOLID WASTE AUTHORITY LANDFILL. SC00013800017 WEYLCHEM US INC. SC00016800043 DOMTAR PAPER COMPANY LLC. SC00018600004 SI GROUP INC ORANGEBURG SC00018600005 HOLCIM US INC. SCS00021800031 UNION COUNTY REGIONAL MSW LANDFILL
• Metric 1a4
  SC00010400083 EVANS READY-MIX INC Facility has been closed since 2006. No CMS should have been active for FFY 2018. SC00020600199 SIEGWERK USA CO Facility has been a minor source since 04/01/2016. No CMS for FFY 2018. SC00021400094 PINEWOOD SITE CUSTODIAL TRUST Facility does not exist in SC database. Should not have CMS for FFY 2018.
• Metric 1b4
  SC00002000235 OWT INDUSTRIES INC TV permit effective as of 1/1/19 (FFY 2019; not FFY 2018). SC00005600372 THE BOEING COMPANY TV issued 01/01/2019. SC00018800052 WILBERT PLASTIC SERVICES TV issued 01/01/2019.
• Metric 1b5
  SC00019000009 MERIDIAN BRICK LLC - COLUMBIA FACILITY Facility merged with 1900-0010 over 10 years ago.
• Metric 1c2
  SC00005600166 SALISBURY ELECTICAL SAFETY LLC Facility was missed for FFY2018 due to programing errors in EFIS pertaining to transfer of ownership. This facility will be inspected the week of 10/22/18.
• Metric 1j2
  SC00005600361 CUMMINS INC CTC CHARLESTON TV permit became effective on 01/01/2018; first certification due 02/14/2019 (FFY 2019). SC00006800046 GEORGIA-PACIFIC WOOD PRODUCTS LLC TV permit became effective on 10/01/2017; first TVACC due 11/14/2018 (FFY 2019). SC00012000181 ENGINEERED PRODUCTS LLC Facility was removed from Verification check list. TVACC was submitted (10/31/17); reviewed and is in ICIS-Air. Compliance Monitoring ID: SC0001200018100084; SC00020600489 LOCKHART POWER COMPANY WELLFORD RENEWABLE ENERGY FACILITY Facility was removed from Verification checklist. TVACC was submitted (2/15/18) ; reviewed and is in ICIS-Air. Compliance Monitoring ID: SC0002060048900023; Other Notes: NOV, CO, Split Penalty were added per each referral. SC data entry procedure has been updated to only include one NOV/CO/total Penalty if multiple referrals are addressed in one of those documents. These will be manually linked in ICIS-Air.

• Metric 1a1 - Number of Active Majors
  Current and historic Title V Major facilities appear in Enforcement and Compliance History Online (ECHO), regardless of the FFY18 permit status. Texas Commission On Environmental Quality (TCEQ) Records indicate there were 1,209 active Title V Major facilities in FFY18. TCEQ has removed facilities in the Integrated Compliance Information System (ICIS) Air that either no longer had Title V permits or are minor sources. ECHO will not show the updated list of facilities until the following fiscal year (FFY20).
• Metric 1a2 - Number of Active Synthetic Minors
  TCEQ does not capture or maintain this information.
• Metric 1a3 - Number of Active Minors Subject to NESHAP Part 61
  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 - Number of Other Active Facilities on CMS Plan
  TCEQ does not capture or maintain this information. The 129 facilities shown on ECHO are minor facilities and should not have active compliance monitoring strategy (CMS) plans. TCEQ has removed facilities in the Integrated Compliance Information System (ICIS) Air that either no longer had Title V permits or are minor sources. ECHO will not show the updated list of facilities until the following fiscal year (FFY20).
• Metric 1a5 - Number of HPV Minors
  The 7 facilities shown on ECHO are for historic HPVs that were major at the time of the violation.
• Metric 1a6 - Number of Minors Subject to Formal Enforcement
  TCEQ does not capture or maintain this information.
• Metric 1b4 - Number of Active Title V Facilities
  Current and historic Title V facilities appear as active in ECHO, regardless of the FFY18 permit status. TCEQ Records indicate there were 1,423 active Title V facilities in FFY18. TCEQ removed facilities in the Integrated Compliance Information System (ICIS) Air on active compliance monitoring strategy (CMS) plans that either no longer had Title V permits or are minor sources. However, ECHO business rules maintain facilities removed within the fiscal year until the following fiscal year. TCEQ expects the facility count to align more closely with actual numbers for the FFY20 data verification.
• Metric 1b5 - Number of CMS Majors
  TCEQ records show that there were 667 Title V major facilities with an FCE conducted in FFY18. 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 FCEs for the review year. TCEQ removed facilities in the Integrated Compliance Information System (ICIS) Air on active compliance monitoring strategy (CMS) plans that either no longer had Title V permits or are minor sources. However, ECHO business rules maintain facilities removed within the fiscal year until the following fiscal year. TCEQ expects the facility count to align more closely with actual numbers for the FFY20 data verification.
• Metric 1b6 - Number of CMS 80% Synthetic Minors
  TCEQ does not have a Synthetic Minor program and does not maintain this information.
• Metric 1b7 - Number of Other CMS Minors
  TCEQ does not capture or maintain this information.
• Metric 1c1 - Number of Facilities with an FCE (Facility Count)
  TCEQ records show that there were 667 Title V major facilities where FCEs were conducted in FFY18. TCEQ is reviewing the records.
• Metric 1c2 - Number of FCEs (Activity Count)
  TCEQ records show that 689 FCEs were completed during FFY18. The additional facilities within ECHO are due to duplicate entries within ECHO: Evaluation ID TX000A0000000015064140004 is a duplicate of TX000A0000000015064140003. Evaluation IDs TX000A0000000014995160003 and TX000A0000000014995160004 are duplicates of TX000A0000000014995160002. Evaluation ID TX000A0000000014854180008 is a duplicate of TX000A0000000014854180004. Evaluation ID TX000A0000000015180660004 is a duplicate of TX000A0000000015180660002. Evaluation ID TX000A0000000014835920005 is a duplicate of TX000A0000000014835920003. Evaluation ID TX000A0000000014537560004 is a duplicate of TX000A0000000014537560001.
• Metric 1d1, 1d2, 1e1, 1e3, 1f1, 1f2, 1g1, 1g2, 1h1, 1h2,
  All ICIS-Air data elements were not finalized at the time TCEQ began ICIS-Air mapping. TCEQ continues to enhance upload capabilities to ensure this information is accurately captured.
• Metric 1i7 - Number of Stack Tests that occurred
  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 1j1 - Number of Facilities with a Reviewed TVACC
  TCEQ records show that there were 1160 Title V major facilities where TVACCs were reviewed in FFY18. TCEQ is reviewing the records.
• Metric 1j2 - Number of Facilities with TVACC Due - Current and historic Title V facilities appear as active in ECHO, regardless of the FFY18 permit status. TCEQ removed facilities in the Integrated Compliance Information System (ICIS) Air on active compliance monitoring strategy (CMS) plans that either no longer had Title V permits or are minor sources. However, ECHO business rules maintain facilities removed within the fiscal year until the following fiscal year. TCEQ expects the facility count to align more closely with actual numbers for the FFY20 data verification.

• Metric 1a1 - Number of active NPDES major individual permits
  TCEQ records show that there were 720 permits classified as majors. EPA’s count of 722 included one permit that fell outside the fiscal year date range. TX0105058 and TX0062201 are associated to City of Houston Sims Bayou while still under EPA’s delegation and upon issuance by TCEQ, TX0105058 will be terminated.
• Metric 1a3 - Number of active NPDES non-major individual permits
  TCEQ records show that there were 2392 minors. EPA’s count included 4 permits that fell outside the fiscal year date range.
• Metric 1a4 - Number of active NPDES non-major general permits
  TCEQ records show that there were 24,863 General Permits. EPA’s count of 25,257 included 393 that fell outside the fiscal year date range.
• Metric 1e1 - Facilities with Informal Actions
  TCEQ records indicate a total of 1,029 facilities, with Informal Actions, 748 of which match ECHO. The additional 281 Informal Actions are not configured to flow to ICIS-NPDES; this issue will be resolved in the next flow enhancement within the limitations of ICIS-NPDES.
• Metric 1f1 - Facilities with Formal Actions
  The TCEQ issued formal actions against 203 facilities. There were actions against 32 facilities that do not appear in ECHO due to data flow constraints. Specifically, there was one formal action that was associated to more than one facility and 31 formal actions against stormwater facilities in which the permit number was expired and does not exist in the federal database. The TCEQ completed the ICIS upload of active construction general permits on 09/27/18 and multi-sector general permits on 10/02/18.
• Metric 1g3 - Facilities with Penalties
  The TCEQ issued formal actions (with penalties) against 203 facilities. There were actions against 32 facilities that do not appear in ECHO due to data flow constraints. Specifically, there was one formal action that was associated to more than one facility and 31 formal actions against stormwater facilities in which the permit number was expired and does not exist in the federal database. The TCEQ completed the ICIS upload of active construction general permits on 09/27/18 and multi-sector general permits on 10/02/18.
• 5a3 - Number of inspected major facilities
  TCEQ records indicate a total of 301 major facilities that were inspected in FFY2018, 300 of which match ECHO. One facility is not in ECHO due to multiple associated programs conducted during the investigation. The capability to flow investigations with multiple programs will be included in the next flow enhancement.
• Metric 5b3 - Number of inspected non-major individual or unpermitted facilities
  TCEQ records indicate a total of 393 non-major individual and unpermitted facilities that were inspected in FFY2018, 377 of which match ECHO. Two facilities are due to multiple associated programs conducted during the investigation, 2 are due to SEVs not flowing to ICIS properly, 3 are due to TCEQ currently not flowing certain non-majors, and 9 are due to the inability to flow Stormwater investigations. These will be included in the next flow enhancement.
• Metric 5b4 - Number of inspected non-major general permit covered facilities
  TCEQ is not flowing non-major general permits to ICIS NPDES. This will be included in the next flow enhancement.
• Metric 7j1 - Number of major and non-major facilities with single-event violations reported in the review year
  TCEQ is not flowing non-major general permits to ICIS NPDES. This will be included in the next flow enhancement.
• Additional SSO data was included by EPA

• Metric 1b1 - Number of sites with on-site inspections
  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 406 facilities during FY18. This includes 126 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 - Number of sites with new violations during review year
  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 152 facilities during FY18. This includes 29 with duplicate EPA IDs that result in error and 42 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 - Number of sites in violation at any time during the review year regardless of determination date
  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 152 sites with new violations cited during the review period and an additional 251 facilities which have or had outstanding violations cited in prior to the review period. This brought the total number of facilities to 403. This includes 67 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 - Number of sites with informal enforcement actions
  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 125 sites with informal enforcement actions, including 27 with duplicate EPA IDs that result in error, and 35 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 - Number of informal enforcement actions
  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 147 informal enforcement actions, including 37 with duplicate EPA IDs that result in error, and 47 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 - Number of sites with new SNC during year
  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 8 sites with a new SNC. This includes 3 sites with duplicate EPA IDs and one with no EPA ID that result in error. TCEQ is reviewing the date discrepancies and is continuing to improve functionality to ensure complete and accurate data uploads.
• Metric 1f1 - Number of sites with formal enforcement actions
  ECHO lists 37 but there are 36 in the downloaded report. Includes 42 sites that could not be uploaded to RCRAInfo due to data errors or not being required to have an EPA ID.
• Metric 1f2 - Number of formal enforcement actions
  ECHO lists 45 but there are 43 in the downloaded report. Includes 52 actions that could not be uploaded to RCRAInfo due to data errors or not being required to have an EPA ID.
• Metric 1g - Total dollar amount of final penalties
  The $1,487,663 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. There was also a discrepancy in a penalty, which has been corrected and will upload to ECHO.

• Metric 1d1
  There may be one 123 informal enforcement action to add after the data freeze, based on further confirmation still needed from agency Enforcement staff. A closure/de-referral memo was received by VDEQ Central Office with instructions to enter the SNN data and RTC information, but with no RCRAInfo form. That data was entered into RCRAInfo but need to confirm whether a 123 enforcement record needs to be added or not. The affected EPA ID# is VAD982579872, Columbus Avenue LLC.

• ORC LCON Caveat for Metric 1j2
  Number of facilities with TVACC due should be 11. Grays Harbor Energy is subject to the Title 5 program. A Title 5 permit has not been issued. Therefore, an ACC is not due.
• This is a subset of the sources in Washington State jurisdiction. Title V sources include: Kinross Gold Corporation Buckhorn Mill, Ponderay Newsprint Company, Boise Cascade Arden Lumber, Boise Cascade Plywood, Boise Cascade Lumber, Vaagen Brothers Lumber, Avista (KFGS), GTN#8, GTN#7, Washington State University, and Guy Bennett Lumber (Columbia Grain, REC Solar, and Boise White Paper should not be on the active majors list and we are in the process of making appropriate changes to ICIS). Synthetic minor sources include: JR Simplot Othello, McCain Foods USA, Tidewater Terminal, Andeavor Logistics, Lamb Weston Connell, JR Simplot Moses Lake, Basic American Foods, Lamb Weston Quincy, Terex/Genie Industries, D and L Foudry, and SGL Automotive Carbon (Yellowstone Pipeline, IMERYS, Inc., and Tyson Fresh Meat are NOC and should not be on the active synthetic mi nors lis t. We are in the process of making the appropriate changes to ICIS).

• Metric 1a4
  Individual Mining permits totals for Notices to Comply between the dates of October 2017 and September 2018. These exclude Voids, Duplicates, and Late Submittals. Failure to Submits – 212
• Metric 1b7 and 1b8
  WV0000108 – Kincaid Enterprises – Facility is closed but has ongoing legal issues.
• Metric 1e1
  For Mining permits, 432 was the total Facilities with Informal Actions.
• Metric 1f1
  Formal actions for Water permits not in ICIS (State only permits and solid waste facilities): 6 Mining facilities with formal actions: 5
• Metric 1g3
  Penalties for Water permits not in ICIS (State only permits and solid waste facilities): 3 Mining facilities with penalties: 12
• Metric 5a3
  Water inspections not uploaded due to feed issues: 3
• Metric 5b3
  Water inspections not uploaded due to feed issues: 14. 1129 DMR-Mining Permits were inspected in the time period. That would include our one active major so subtract 1 to 1128. The 48 number in 5a3 for major permits should include our major because it has always been entered directly to ICIS.
• Metric 7j1
  Number of non-major facilities with SEV’s for Mining: 157.
• Metric 7j2
  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 and 2018 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 and 2018 SRF frozen dataset to still show facilities in both SNC/Cat 1 DMR Non-receipt status and in RNC.
• Metric 7j2 and 7j3
  Individual Mining permits totals for Notices to Comply between the dates of October 2017 and September 2018. These exclude Voids, Duplicates, and Late Submittals. QNCR – 220 Total – 432