State Comments on Frozen Data - 2019

EPA captures (or "freezes") aggregated state data yearly. These frozen datasets are used in several places on EPA's website, including portions of the Enforcement and Compliance History Online (ECHO) website. Frozen data are used in the Comparative Maps and State Dashboards.

Several states have indicated that at the time the data were frozen, that errors existed. States that identified problems with the data were asked to send either a data file with corrected information, or a link to a state website that explained data errors or corrections.

State comments on frozen data are available through the links below, organized by the submission year. Additional data quality information which is not specific to the frozen data is available through the known data problems and State Review Framework Recommendations Tracker.

2019 Comments on Frozen Data
State Media Comment
Alaska CWA 7j3 Metric: This metric continues to be problematic as it shows terminated permits with antiquated outstanding reports, late reports, and assigned SEV's, some going back over 10 years. Currently, the C10 and C20 violations remain in the permits historical record and cannot be resolved. It is my understanding that both EPA Regions and HQ are aware of this, but I hope moving forward that more time and effort can be put into the coding logic of this metric to ensure accurate percentages are being shown for each State's permit universe that is in RNC status.
Alabama CAA Continue to struggle with the issues outlined in the flags. Incorrect number of Majors and Title V facilities. All minor facilities being assigned to CMS plan when they were not put into ICIS by the Department nor are they like that on the database. JCDH's database reflects the current total and it appears that ICIS has issues with historical migrated data that do not reflect proper status or programs.

Metric 1a5: AL0000000103300006 Constellium - clearly contains an HPV resolved date of 10/2007 for the state action. Should not be included here due to Federal action from 2005 that has yet to be resolved. This should be reserved for state actions only.
Arkansas CWA

Data Verification Metrics 1a1, 1a2, 1a3, 1b7, 1b8, 1e1, 5a3, and 7j2 were reviewed and verified in the ICIS-NPDES database. The following Metrics were found Incorrect/Deficient or incomplete due to lack of resources:

  • Under Review 1a4 - Number of active NPDES non-major general permits. Due to resource limitations, the universe of stormwater construction Notices of Coverages is not complete.
  • Under Review 1f1 - Facilities with Formal Actions. Review of Formal Enforcement Actions in ICIS-NPDES found 47 (instead of 48) NPDES permit facilities with new Formal Enforcement Actions in FY2019 as of 03/09/2020. One facility for Formal Enforcement Action AR-9564 is linked to two NPDES IDs was counted twice in ECHO even though the two NPDES IDs (ARG550583 & ARU500127) have the same facility FRS ID 110070508261.
  • Under Review 1g3 - Facilities with Penalties. Review of Formal Enforcement Actions in ICIS-NPDES found 29 (instead of 30) NPDES permit facilities with Penalties in FY2019 as of 03/09/2020. One facility with one penalty from Formal Enforcement Action AR-9564 is linked to two NPDES IDs and was counted twice in ECHO even though the two NPDES IDs (ARG550583 & ARU500127) have the same facility FRS ID 110070508261.
  • Incorrect/Deficiency 5b3 - Number of inspected non-major individual or unpermitted facilities. Due to resource limitations, inspections for unpermitted facilities are not complete in ICIS-NPDES.
  • Incorrect/Deficiency 5b4 - Number of inspected non-major general permit covered facilities. Due to resource limitations, inspections for general permit covered facilities are not complete in ICIS-NPDES.
  • Incorrect/Deficiency 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 42 (instead of 41) NPDES permit facilities with new single event violations in FY2019 as of 03/09/2020. The following were not included in ECHO Data Metrics: AR0048844, 03/04/2019 violation (D0016) Permit Violations - Failure to Submit Timely Permit Renewal Application.
  • Incorrect/Deficiency 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 544 (instead of 551) NPDES permit facilities could be verified in RNC/Category 2 noncompliance in FY2019 as of 03/09/2020. The ECHO query considered permit schedule violations for permits that were terminated before the beginning of FY2019, and compliance schedule violations from formal enforcement actions issued by USEPA Region 6, not the state. The state is not responsible for enforcing compliance schedule violations from EPA Formal Enforcement Actions issued in 2007 and 2008. The following 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. These facilities should be associated with the EPA Metrics. ARR10A987 (EPA Order 06-2007-N001), ARR10C780 (EPA Order 06-2007-N003), ARR150775 (EPA Order 06-2007-N005), ARR150985 (EPA Order 06-2007-N007), ARR151050 (EPA Order 06-2007-N008), ARR151661 (EPA Order 06-2007-N012), ARR152383 (EPA Order 06-2008-N008). 
Arizona CWA Metric 1a4 Number of active NPDES non-major general permits; We currently we do not know how many non-major general permits are not flowing. MSGP not flowing because SIC Code for Treatment Works (TW) does not currently exist in ICIS as an option. CGP not flowing because addresses are generally non-existent in the data, typical location identified by coordinates, and ICIS does not allow for address field to be left blank (or the NULL format has not been determined as a workaround). Terminations of general permit NOIs may not be flowing, or may have not flowed for some duration in the past. There are CGP NOIs in the list that were terminated prior to FFY19 that should not be included.

Metric 1b8 Number of active NPDES individual DMR filers with permit limits in ICIS; AZ0023582 City of Goodyear – Corbett Wash WRF – A data upload issue has been discovered affecting permit limits. AZ0024520 Town of Marana WRF – A data upload issue has been discovered affecting permit limits. AZ0025313 Town of Buckeye – A data upload issue has been discovered affecting permit limits. AZ0023990 CAP Havasu Plant – Data flow issue. AZ0024082 Big Park Domestic Wastewater Improvement District – Data flow issue.

Metric 5a3 Number of inspected major facilities; Some inspections in this are not clearly categorized as: file review, pretreatment, collection system. AZ0024031 City of Mesa – Northwest WRP - Collection System inspection only. AZ0025178 City of Casa Grande WRF – 1 collection System inspection and 1 CEI AZPDES inspection. AZ0025208 Town of Florence WWRF – 1 collection System inspection and 1 CEI AZPDES inspection. AZ0025607 Nogales International WWTP – PCA;

Metric 5B3 State – Number of inspected non-major individual or unpermitted facilities; Some inspections in this are not clearly categorized as: file review, pretreatment, collection system. AZ0025828 Town of Cave Creek WRF – File review only.

Metric 5b4 – Number of inspected non-major general permit covered facilities; These inspections are currently not flowing to ICIS/ECHO.

Metric 7J1 – Number of major and non-major facilities with single-event violations reported in the review year; ADEQ is not entering Single Event Violations into ICIS at this time. Per SRF findings and countermeasures ADEQ will train on using existing codes per discussion with Compliance in Fall 2019.

Metric 7J2 – State – Number of facilities with SNC/Category 1 noncompliance; AZ0021804 Jerome is under a Consent Order for copper and ammonia. They are also in compliance with their permit schedule. They should not be shown as SNC in Q4. AZ0025305 Houston Creek was not in SNC for Q1. The Formal Action is entered incorrectly in ICIS which is triggering a false violation in ICIS. Additionally, Houston Creek's permit was not terminated and they are operating under a granted permit in a Consent Order while they are paying their permit fees. Facility has been under a Consent Order since 10/2014 for copper exceedances.

Metric 7J3 State – Number of facilities with RNC/Category 2 noncompliance or effluent, single event, or schedule violations open during year; AZ0020001 Pima County – Tres Rios WWRF. Cannot find any reported noncompliance FY 2019 in ICIS. AZ0020231 Town of Gila Bend – Exceedance for E- Coli. Resolved pending. AZ0023582 City of Goodyear – Corbett Wash WRF – A data upload issue has been discovered affecting permit limits. AZ0020249 City of Globe – Pinal Creek WWTP – Confirmed E. Coli violation in Azurite. Formal action for copper is entered incorrectly. Globe met all schedule requirements and there should not be 2 schedule violations. AZ0021199 Superior Sanitary District WWTP – was under a Consent Order for copper exceedance which became effective 2/13/2018. Formal Action in ICIS needs to be updated. Town of Superior achieved the first deadline (due date 2/13/2018) on February 13, 2019. They achieved the second deadline (due 7/13/2018) on August 14, 2018. The Order was terminated on April 24 2019. AZ0022152 USDOI NPS – Grand Canyon NP – South Rim WWTP has been under a Consent Order for ammonia since January 2018. Three ammonia violations should be covered under the Consent Order. ICIS needs to be updated to demonstrate that GC met their schedule violations (2 schedule violations are an error). SNC violations are in error as well since ammonia is addressed in Order. Confirmed copper and ammonia exceedances. GC should only show two quarters of RNC. AZ0023442 City of Phoenix – Val Vista WTP – Echo shows violation as other violation. Working to identify what the violation is. AZ0023990 CAP Havasu Plant. Data Flow issue. AZ0024082 BIG PARK DOMESTIC WASTEWATER IMPROVEMENT DISTRICT WWTP. Permit limit data flow issue. AZ0024520 TOWN OF MARANA WATER RECLAMATION FACILITY. Data flow issue. AZ0025208 Town of Florence – has an open Formal Action in ICIS dating back to 2016 that needs to be closed that will resolve the 6 compliance schedule items. The Order was terminated on July 7, 2016. All compliance conditions have been met. Confirmed 1 BOD exceedance in Q2 is correct. AZ0025747 JRC Goodyear (AZ0025747) had two effluent violations in Q2. The violations are shown as resolved pending. AZ0025607 Nogales International WWTP – The formal action in ICIS needs to be updated for the Nogales International WWTP (AZ0025607). All of the deadlines were met prior to the FY2019. The facility should only show in RNC for Q2, Q3, Q4. Confirmed effluent limit violations and missing parameters. AZ0025771 City of Willcox WWTP – Need to validate what actual compliance schedule violations exist. All effluent violations should be linked to the Order. Need to enter compliance schedule and link violations to order. AZIF20044 Town of Wickenburg shows no violations in Azurite and should not be shown in RNC for 4 quarters. The false violations appear to be due to a data flow issue.

1b8 Number of active NPDES individual DMR filers with permit limits in ICIS; AZ0025151 - City of Mesa - Southeast Water Reclamation Plant - has DMR flow issues in ICIS.
Connecticut
 
CWA Metric 1a4 - The number of active NPDES non-major general permits is erroneous. CT does not enter all Stormwater 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.
RCRA 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, as a more representative count of Large Quantity Generators (LQGs) actively operating in the state.

Metric 5b: For FFY19 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 excluding Pharmaceutical LQG's and redirected remaining resources to inspect manifest initiative sites and a mix of other inspection types.

Metric 1b2: CT DEEP conducted 10 inspections in addition to the 66 inspections reported. These 10 inspections were comprised of: 5 Non-Financial Record Review (NRR) -); 3 Financial Record Reviews (FRRs); and 2 Case Development Inspections (CDIs). The following traditional LQG inspections conducted in FY 2019 were not on the 2015 BRS: AGT CT5000001149, SUN Products CTP000033483, Overhaul Support CTR000505743, Colonial Coatings CTD983894452, Yankee Casting CTD010186872. These sites either changed generator status post-inspection or notified as LQG's post the 2015 BRS and therefore did not appear on the SRF.
Delaware CWA DE0000523 (Boxwood Industrial Park) should not be in this category. Data steward is working with ICIS helpdesk to resolve this issue. It's a problem with how the permit is entered in the state and federal database. 
RCRA Multiple errors flagged. Data is correct in RCRAInfo; however is not being pulled into ECHO correctly.
Florida CWA All SEV codes were not being transferred into ECHO upon initial verification. The missing codes were added by sending an override request to EPA, which were then fulfilled. This may indicate that there is an issue with the query. We verified that the SEV codes were accurately reflected in metric 7j1. Facility FLR05H994 was terminated 10/2/16. Status of SNC DMR non-receipt violation for 2018 Q3, Q4 & 2019 Q1 and Q2. Ran the corrected RNC status on 2/24/20 with a result of 'unknown'. 
RCRA Metric 1a2: Thirty-three of the 525 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.
Georgia CAA Metric 1a4: All three facilities listed were removed from CMS in FFY18: GA0000001300900019, Central State Hospital; GA0000001305100172, Savannah Health Services, LLC d/b/a Memorial University Medical Center; GA0000001327700061, Chickasha of Georgia.

Metric 1b5: 2 were true minor facilities prior to start of FFY2019: GA0000001300900019, Central State Hospital: True Minor since 5/10/18; GA0000001327700061, Chickasha of Georgia: True Minor since 6/25/18; 3 were major at the time of 2019 FCE; GA0000001306300026, Darling Ingredients, Inc.: A-SM 7/25/19; GA0000001309700065, SAF Metal Fabrication: A-SM 2/7/19; GA0000001323300029, Kimoto Tech: A-SM 5/10/19; 3 permits were revoked prior to start of FFY 2019: GA0000001312100036, Atlanta Utoy Creek WPCP: permit revoked 2/16/18; GA0000001312100070, Westrock Packaging Systems, LLC: permit revoked 10/10/17; GA0000001324500003, DSM Chemicals North America: permit revoked 8/1/18.

Metric 1b6: 3 were major at time of 2019 FCE: GA0000001306300026, Darling Ingredients, Inc. GA0000001309700065, SAF Metal Fabrication; GA0000001323300029, Kimoto Tech.

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 FFY19 if the facility held a Title V permit during CY18. 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: GA0000001300300017, Atkinson County - SR 50 MSW Landfill: B-TV; GA0000001300900019, Central State Hospital: TV through 5/9/18; GA0000001300900038, Union Hill Church Road MSW Landfill: B-TV revoked 9/4/18; GA0000001301300083, MAS Georgia LFG, LLC (OAK GROVE): initial TV issued 9/5/19; GA0000001301500103, Bartow County MSW Landfill: B-TV; GA0000001302100078, YKK USA Inc Macon: TV through 9/12/18; GA0000001302100195, Macon Walker Road MSW Landfill: B-TV; GA0000001303500016, MAS Georgia LFG, LLC (PINE RIDGE): initial TV issued 5/31/19; GA0000001303900027, Camden County Solid Waste Department: B-TV; GA0000001305100210, Dean Forest Road Landfill: B-TV; GA0000001305100263, Elba Liquefaction Terminal: under construction until 10/15/19; GA0000001305900084,Athens-Clarke County MSW LF: B-TV; GA0000001305900102, CII Methane Management III Landfill Gas to Energy Project: B-TV; GA0000001306300026, Darling Ingredients, Inc.: TV through 7/24/19; GA0000001306300106, Clayton County SR 3 Love Joy Landfill: B-TV; GA0000001308100062, Crisp County US 41S MSW Landfill: B-TV; GA0000001308700058, Decatur County Solid Waste Facility: B-TV; GA0000001308900127, CITGO Petroleum Corporation - Doraville Terminal: TV through 5/21/19; GA0000001308900255, Arch Wood Protection, Inc.: SM-TV; GA0000001308900313, Carlyle Compressor Remanufacturing: TV through 1/8/19; GA0000001309300022, Roseburg Forest Products South, L.P. - Vienna Particleboard Plant: temporarily closed; GA0000001309500095, Dougherty County Fleming/Gaissert Rd MSW Landfill: B-TV; GA0000001309700065, SAF Metal Fabrication: TV through 2/6/19; GA0000001311500096, Floyd County Walker Mountain Landfill: B-TV; GA0000001312100254, PPG Industries Inc.: TV through 12/26/18; GA0000001312100558, Geiger International: TV through 4/26/18; GA0000001312100847, Quality Investment Properties Metro, LLC: TV through 9/25/19; GA0000001312900070, Redbone Ridges MSW Landfill: B-TV; GA0000001313500139, Dolco Packaging: TV through 7/30/18; GA0000001313500235, Quality Investment Properties Suwanee, LLC: TV through 12/26/18; GA0000001313500329, MAS Georgia LFG, LLC (Richland Creek): initial TV issued 10/24/19; GA0000001313900106, Hall County, Engineering Division: B-TV; GA0000001313900115, Mincey Marble Manufacturing, Inc.: TV revoked 12/26/18; GA0000001313900155, Mincey Marble Manufacturing, Inc.: initial TV issued 2/4/20; GA0000001314700029, Hartwell Compressor Station: initial TV issued 5/22/19; GA0000001315100009, Atlas Roofing Corp: TV through 11/27/18; GA0000001316500012, U.S. Silica Company: temporarily closed until 4/2/19; GA0000001317100011, Cedar Grove Landfill: B-TV; GA0000001317500060, Laurens County Old Macon Rd. Landfill: B-TV; GA0000001317900026, Elan Technology Inc. - Midway Facility: construction permit only; GA0000001318500100, Better Way Products: temporarily closed until 10/7/19; GA0000001320500037, Balfour Pole Company, LLC: TV through 5/10/18; GA0000001321300040, Murray County - U.S. 411 Westside MSW Landfill: B-TV; GA0000001321500051, Exide Technologies: temporarily closed; GA0000001321500181, Pine Grove Landfill: B-TV; GA0000001323300029, Kimoto Tech: TV through 5/9/19; GA0000001324500003, DSM Chemicals North America: TV revoked 8/1/18; GA0000001324500024, Boral Bricks - Plant #6: TV revoked 9/5/18; GA0000001324700030, Cellofoam North America, Inc.: TV through 12/25/18; GA0000001327500066, City of Thomasville MSW Landfill: B-TV; GA0000001328500081, Lagrange I-85/SR109 SLF: B-TV; GA0000001328700024, Premium Fiberglass Pools: temporarily closed until 1/11/19; GA0000001330500031, Broadhurst Environmental Landfill: B-TV; GA0000001331300070, Shaw Industries, Inc. - Plant WD: TV through 2/15/18; GA0000001331300074, Shaw Industries Group Inc. - Plant 23: TV through 2/12/18; GA0000001331300131, Old Dixie Municipal Solid Waste Landfill: B-TV; GA0000001332100004, Crisp County Power Commission: TV through 5/9/18.

Metrics 1e1, 1e2, 1g1, 1g2. Why does EPA consider these true minor facilities federally reportable? GA0000001324700073, Golden State Foods; GA0000001377700130, Thompson Building Wrecking Company.
CWA Metric 1a4 - Georgia has identified an error that has resulted in an incorrect permit status for a number of the expired Industrial and Construction Stormwater permits. These permits are "administratively continued" in ICIS and should be set to "expired". We are investigating how this occurred to prevent this in the future and will be working with our contractor and Region Administrator for a correction.

Metric 1E1 - Georgia has identified a flow error for some informal enforcement action types due to a change in the ICIS code list for informal enforcement actions. We are in the process of updating our local data to match the update to the ICIS code list.

Metric 5a1, 5b1, and 5b2 - Georgia has met the 106 Work plan requirement for inspecting all NPDES major permitted facilities once every 2 years, all non-major individual permitted facilities once every 5 years, and 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. We are correcting these issues and updating our internal database and processes.

Metrics 7k1 - Georgia has identified deficiencies in processes and procedures involving our 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 system and the data for FFY2019.
Iowa CAA Penalties assessed for the year were not being counted because the field used to populate the penalty amount is not a minimum data requirement field that is required to be populated in ICIS. We attempted to add the penalty amounts for Federal Fiscal year 2019. Any metric chosen to be tracked should be based on a minimum data requirement field. Penalty dollars is not a required field.
CWA Due to challenges with the transfer of data from the state system to ICIS-NPDES, a large volume of facilities are inaccurately identified as non-compliant, specifically regarding compliance schedule violations and DMR Non-Receipt violations. Iowa does not transmit single event violation information. The Iowa DNR continues to work with EPA and Windsor Solutions to improve the quality of data transmitted to EPA.
RCRA Metric 1b1 - 7 facilities in RCRAInfo Not Flagged to extract to Public Databases;
Metric 1c1 - 2 facilities in RCRAInfo Not Flagged to extract to Public Databases;
Metric 1c2 - 6 facilities in RCRAInfo Not Flagged to extract to Public Databases;
Metric 1d1 - 2 facilities in RCRAInfo Not Flagged to extract to Public Databases;
Metric 1d2 - 2 facilities in RCRAInfo Not Flagged to extract to Public Databases.
Idaho
 
CAA There are 28 sources tests that are entered in ICIS-Air that are not being picked up by Metric 1j7.
CWA Metric codes 1f1 and 1g3: Missing EAID 10 2019 011 - confirmed as added in ICIS but is not showing up in verification.
Illinois CAA 1e1 - Number of Informal Enforcement Actions (Activity Count) - Illinois EPA data indicates 99 Informal Enforcement Actions occurred; the metric conveys 102 Informal Enforcement Actions, but the metrics erroneously included 3 USEPA Informal Enforcement Actions.

1j1 - Number of Title V Annual Compliance Certifications with a Reviewed Title V Annual Compliance Certification Due - ECHO's 1j1 metric conveys 431 Title V Annual Compliance Certifications were reviewed, but Illinois EPA data indicates that 476 Annual Compliance Certifications were reviewed. In accordance with meeting minimum data requirements (MDRs) per the Clean Air Act, Illinois EPA reported a total of 476 reviewed Annual Compliance Certifications. Ongoing discrepancies with 1j1 metric numbers may be due to how dataflow is mapped, and the inclusion of reviews conducted on REVISED Annual Compliance Certifications submitted by facilities.
Indiana CAA The Indiana Department of Environmental Management (IDEM) strives to ensure that CAA Compliance and Enforcement data that is posted to ECHO is timely and accurate, and IDEM is constantly working with the EPA to assure the accuracy of the information that makes its way to ECHO. However, based on our current business practices and the development and gathering of evidence, timely entry of all stack testing and enforcement data into the ICIS database is not always possible.
Kansas CAA Due to the implementation of a new database system, the Kansas Environmental Information Management System (KEIMS), KDHE experienced delayed access to ICIS from KEIMS which may result in minimal discrepancies.
Kentucky
 
CAA Kentucky has verified the FFY2019 CAA data with the following caveats: Kentucky has been working to improve the interface between the State's database and ICIS-Air. The need for these improvements is reflected in the discrepancies between the State's database and ICIS-Air. Kentucky continues to apprise U.S. EPA regularly concerning Kentucky's attempts to improve the data interface between the two systems.
CWA Kentucky has verified the FFY2019 CWA data with the following caveats: KyDEP identified and was unable to correct discrepancies in the data for CWA metrics 1a3, 1a4, 1b7, and 1b8. These discrepancies result from permits terminated in ICIS-NPDES which do not show as terminated in the ECHO data verification data. There are discrepancies for 11 permits for metric 1a3, 1,411 permits for metric 1a4, and 41 permits under 1b7 and 1b8 combined. U.S. EPA is responsible for the data flow between ICIS-NPDES and ECHO. KyDEP identified and was unable to correct data related to compliance and inspections for the following CWA metrics: one permit for metric 1e1, 2 permits for 7j1, 5 permits for 5b3 (ECHO identifies as minor where ARM identifies as major), and 1 permit for metric 5b4. Kentucky received stipulated penalties in FFY2019 under Federal consent decrees with Revelation Energy and the Southern Coal Company et al., in the amount of $500.00 each. These stipulated penalties do not appear on the ECHO data verification report. Kentucky is unable to verify whether or not these stipulated penalties were entered in ICIS-NPDES under the Federal consent decrees, which may be associated with other states. On Single Event Violations (SEVs) under metric 7j1, SEVs generated from source investigations do not migrate to ICIS-NPDES. This is due to the inability to develop consistent profiles for investigations due to the widely varying nature of these investigations. 

CWA
Louisiana
  • 1f1 - Facilities with Formal Actions includes 12 facilities that should not be included. The facilities are linked to enforcement action LA-WEAOA1500154 which was originally issued 5/8/2015 but was amended 4/24/2019 to remove the 12 facilities. The following 12 facilities are not linked to the 4/24/2019 amendment: oLAG541663 Jaelyn Parc STF; LAG541677 Density Utilities LA, LLC; oLAG541678 Madison Trace Subdivision; oLAU006242 Kingston; LAU006249 Lucky Hit Subd; oLAU006251 St. Jude; oLAU006254 Country Bend; LAU006255 Wildwood; oLAU006256 Greenleaf; oLAU006259 Country Crossing; LAU006263 Highland Apts Oak Lane & Cypress Point; oLAU007449 Advanced Construction Co - Blossom Creek.
  • 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.
Massachusetts RCRA

I am verifying the Handler Universe Totals.

  • TSDs: this number is correct.
  • LQGs: Massachusetts does not recognize 'temporary' or 'short-term' generator status; it's either yes/no. Due to this, the number of active generators is always in flux. Further, with the adoption of myRCRAid in June of 2018, sites are now managing their generator status and associated permit activities in real-time.
  • BR LQGs: BR LQGs reflect a different number than permitted LQGs in that many LQG's are protective filers who did not generate at LQG levels in the reporting year and therefore did not have to file. Others may not have filed and are in some form of 'enforcement discretion', enforcement, or slated for enforcement.
Maine CAA 1j2: Number of facilities with TVACC Due; we expected 51, 1e1: Number of Facilities with an Informal Enforcement Action (Activity Count); we expected 8 Letters of Warning.

1e2: Number of Facilities with an Informal Enforcement Action (Facility Count); we expected 8 Letters of Warning.
CWA FY2019 Production CWA Data for Maine:
  • Element 1 - Data
    • 1e1 - The number of Facilities with Informal Actions should be 39.
    • 1f1 - The number 14 is a bit high for Facilities with Formal Actions, as all of the Cooke facilities are being counted (even though it was one action).
    • 1g3 - Facilities with Penalties should be 5. Both EFIS and ICIS display the correct data. There seems to be a disconnect between ICIS and ECHO.
  • Element 3 - Violations
    • 7j1 - The Number of major and non-major facilities with SEVs reported in the review year should be 5. 
Michigan CAA In general, the data in the US EPA's FY19 SRF 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 FY19.
  • Metric 1a4: These sources were later identified as minor sources but may have been on the original FY19 CMS Plan.
  • Metric 1a5: There were no State leads, minor source HPV cases in Michigan in FY19. The state count should be zero.
Minnesota
CAA The Minnesota Pollution Control Agency (MPCA) has made all reasonable effort to verify and correct the data presented in the ECHO State Review Framework environment. This has been done by ensuring that the data contained in the respective EPA program systems, ICIS-NPDES, RCRAInfo, and ICIS-AIR are in agreement with the TEMPO data system maintained by the MPCA as implementer of these programs for the State of Minnesota. Where discrepancies still exist, they are often beyond the control of the MPCA because they are related to the procedures by which the EPA ECHO database aggregates and assesses the data stored in the stand-alone program systems. The MPCA is unable to correct or influence any errors that arise in this process, which is wholly within the control of the EPA. For complete and current information on regulated parties in Minnesota, the MPCA suggests that data be accessed through our 'What's in My Neighborhood' website.
CWA The Minnesota Pollution Control Agency (MPCA) has made all reasonable effort to verify and correct the data presented. This is done by ensuring that the data contained in the respective EPA program systems, ICIS-NPDES, RCRAInfo, and AFS are in agreement with the Tempo data system maintained by the MPCA as implementer of these programs for the State of Minnesota. Where discrepancies still exist, they are often beyond the control of the MPCA because they are related to the procedures by which the EPA ECHO database aggregates and assesses the data stored in the stand-alone program systems. The MPCA is unable to correct or influence any errors that arise in this process, which is wholly within the control of the EPA. The MPCA is in the process of implementing an ICIS-NPDES data flow to accurately represent the MPCA's collected eReporting rule required data into ICIS-NPDES. Until the MPCA's ICIS-NPDES data flow is fully implemented, the information presented through the dashboard will not be complete, current, and/or accurate. For complete and current information on regulated parties in Minnesota, the MPCA suggests that data be accessed through our 'What's in my Neighborhood' website and/or 'Wastewater Data Browser'.
Missouri CWA Missouri's data problems are related to discrepancies between the Missouri Clean Water Information System (MoCWIS) and the national program system ICIS-NPDES. Discharge Monitoring Reports and facilities compliance status displayed in ECHO may not be accurate. Specifically, facilities may appear to be in noncompliance for failing to submit required discharge monitoring reports, which may or may not be the case. Users are encouraged to contact the Missouri Department of Natural Resources to verify the compliance status of their facility prior to taking action based upon the data obtained from ECHO.
North Carolina CWA Metric 1a1 - ECHO has 1 permit listed as NPDES major that should be minor and is missing 2 permits that should be NPDES majors. NC is working with EPA to correct the data.
Metric 1a3 - ECHO has 2 permits listed as NPDES minors that should be majors and missing 1 permit that should be a NPDES major. NC is working with EPA to correct the data.
Metric 1a4 - ECHO has 5 animal permits, 1 single-family residence CoC, and 1 stormwater CoC not present in the NC data system. NC is working with EPA to correct the stormwater data.
Metric 1b8 - The NC data system has 24 permits that have permit limits but do not currently upload to ICIS as they have monitoring frequencies less than monthly.
Metric 5a3 - ECHO has 1 permit listed as NPDES major that should be minor. NC is working with EPA to correct the data.
Metric 5b3 - ECHO has 1 permit listed as NPDES minor that should be major. NC is working with EPA to correct the data.
Metric 7j2 - The North Carolina data system does not classify violations as Category 1 or SNC.
Metric 7j3 - The North Carolina data system does not classify violations as Category 2 or RNC.
RCRA
Nebraska It appears one hazardous waste inspection is missing - Forney Auto Repair in David City. The site was a CESGQ in Nebraska, there were no violations. The number of site inspections should be 30 not 29. 
New Hampshire RCRA NHDES uses state database (HazWMS for LQG universe).
New Jersey
 
CAA Most of the metrics have slight differences when compared to the data in New Jersey database (NJEMS). This is inherent when 2 databases do not collect and store data in the same way. NJ and Region 2 of EPA have agreed to work together to reconcile differences with the Facility level data.
CWA Metrics 1e1, 1f1, & 1g3 are slightly lower than expected. NJ's reporting shows 1e1 as 218, 1f1 as 72, & 1g3 as 65.
Metrics 7j2 & 7j3 are listed as under review. NJ believes these numbers are higher than expected. A thorough review with our contractor is needed to verify we are extracting data from our database that properly resolves RNCs.
RCRA Metric 1a2 - NJ has used manifest data entered into our NJEMS system to identify our HW generator size for many years. Since the migration to EPA's E-manifest system, NJ does not have the manifest data to accurately determine our LQG universe. DEP staff have been working with Region 2 to resolve this issue so DEP can get an accurate accounting of LQG universe for the past 2 fiscal years.
Metric 1a5 - NJ processed about 800 BRs through EasiTrack for the CY2017.
Metric 1c1, 1c2, & 1e1 - 2.A recent issue with our RCRAInfo dataflow is currently under investigation by our contractor. There appears to be some instances that violations in our system are not being sent to RCRAInfo, but the inspection & enforcements data was sent. When this is resolved we expect to be able to send a batch upload of the missing violation data. 
New York CWA The number of active CAFO facilities is not accurate for FY 2019. DEC made changes to permit IDs in FY 2019, so the number of facilities is inflated. Data in the system as of 1/1/2020 should be accurate for these facilities.
Ohio
 
CAA 15 NOVs were issued and resolved in FFY 2018 (not FFY 2019) for 14 facilities. ICIS Air has incorrectly assigned FRV determination dates in FFY 2019 for each of them and reported this incorrect date to ECHO. Ohio EPA cannot correct these errors. The correct issuance and resolution dates were reported to ICIS Air. A number of discrepancies between the Ohio EPA enforcement and compliance database and ICIS Air, primarily related to facility classification changes, operating status, and program applicability. These were corrected in ICIS Air by Ohio EPA.
CWA There are cases where the information in ICIS, and ECHO, does not line up with the information in Ohio's database. We are actively working with USEPA to identify and correct errors in the transfer of data to ICIS and resolve these discrepancies. Complete and accurate data for NPDES Permittees is maintained by Ohio and can be obtained by contacting Ohio EPA.
Metric 1a1: Number of active NPDES major individual permits - 297;
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 - 2,954;
Metric 1a4: Number of active NPDES non-major general permits - 15,223;
Metric 1b7: Number of active NPDES individual DMR filers - 3,251;
Metric 1b8: Number of active NPDES individual DMR filers with permit limits in ICIS - 3,251;
Metric 1e1: Facilities with Informal Actions - 584;
Metric 1f1: Facilities with Formal Actions - 56;
Metric 1g3: Facilities with Penalties - 41;
Metric 5a3: Number of inspected Major facilities - 113;
Metric 5b3: Number of inspected non-major individual or unpermitted facilities - 815;
Metric 5b4: Number of inspected non-major general permit covered facilities - 63;
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 - 789;
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 - 1020.
Oklahoma CWA 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) 2019. The following caveats and revision in metric values need to be added to Oklahoma DEQ-Water Quality Division's FFY2019 SRF:
1. Oklahoma DEQ does not code into EPA's ICIS-NPDES Production database the Stormwater Construction & Stormwater Industrial facility data (metric 1a4), inspections (metric 5b2 & 5b4), and enforcement actions (metric 7j1-7j3, 7k1, & 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 & 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 345. 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 4748. Stormwater-Construction & Stormwater- Industrial permits are maintained in the Oklahoma DEQ's state database. During this period, there were 1591 Stormwater-Industrial and 2927 Stormwater-Construction permits. Oklahoma DEQ-WQD has permitted 181 General Discharge permits and 49 MS4 Phase II permits. The Oklahoma Department of Agriculture, Food & Forestry (ODAFF) is delegated to permit the general CAFO (OKG01) permits on the list.
6. Metric 7j1 Number of major and non-major NPDES facilities with single event violations is revised to 128. The following Stormwater facilities should be included in the list: OKR1021364 Covell-35 Development, LLC, Cross Timbers; OKR1022600 Cheyenne Ridge - Edmond; OKR1025423 R & R Land Development; OKR1025971 Dequasie Development, LLC; OKR1026353 Guthrie 156, LLC; OKR1026904 Claud Cypert, South Fork Phase II; OKR1027457 G & W Property - Lakes at Cross Timbers; OKR1027599 Shawnee Harrison - Domino Plaza; OKR1028315 Duit Construction Co. - DOT JP2032404; OKR1028448 Duit Construction Co - Turner Turnpike; OKR1028510 RDNJ, LLC dba A-Tech Paving; OKR1029084 Bishop Paving; OKR1029278 Manchester Green Homes; OKR1029500 Garrett & Co. - Garrett Property; OKR1029617DDSI Broadway Hefner, LLC; OKR028080 DHD Corp. OKR050781 OK Foods, Inc. - Heavener; OKR052369 Angel Ornamental Iron Works; OKR052581 Vertical Aerospace; OKR053000 Enterprise Dirt Sales, LLC; OKR053015 Anchor Glass Container Corporation; OKR053217 Galaxy Chemicals, LLC; OKR053495 Standard Materials Group, Inc.
7. Metric 7j2 Number of Active facilities with SNC/Category 1 noncompliance is revised to 320. Industrial Stormwater has a total of 376 Facilities who are DMR filers, of which 159 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.
8. 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 307. There were 23 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 in a state database.
9. Metric 7k1 Major and non-major facilities in noncompliance revised value count is 809 out a universe of 5200 NPDES discharge permitted universe.
10. Metric 5a1 & 5a3 Inspection coverage of NPDES Majors is revised to 94. A total of 94 facilities had a CEI inspection or a Routine inspection.
11. Metric 5b1 & 5b3 Inspection Coverage NPDES Non-Major individual facilities is revised to 243. A total of 243 individual non-major facilities had a CEI inspection or Routine Inspection and 5 unpermitted facilities had an inspection.
12. Metric 5b2 & 5b4 Inspection Coverage-NPDES Non-Majors with General Permits is revised to 970. A total of 761 Stormwater-Construction, 53 Stormwater-Industrial, 6 General MS4 Phase II, 73 Industrial Stormwater No Exposure, and 77 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.
13. Metric 8a3 Percentage of active major facilities in SNC and non-major facilities in Category I noncompliance during the reporting year is revised to 320 from a NPDES discharge permitted universe of 5200.
14. Metric 1e1 Facilities with Informal Actions is revised to 101. Industrial & Construction Stormwater, state permit, and TRLs are maintained in a state database. Universe Total Facilities with Informal Enforcement Total Informal Enforcement Actions: Unpermitted 0, Construction Storm water: 4, Industrial Storm water: 0; Minor: 26; Major: 68; General discharge: 2; State Permit: 1; General Total Retention Lagoon (TRL): 0; Industrial User: 0; Municipal Total Retention Lagoon (TRL): 0; Totals: 101.
15. Metric 1f1 Facilities with Formal Actions revised value is 210. Industrial & Construction Stormwater, state permit, and TRLs are maintained in a state database. Universe Total Facilities with Formal Enforcement Total Formal Enforcement Actions: Unpermitted: 4; Construction Storm water: 18; Industrial Storm water: 8; Minor: 107, 141; Major: 39, 48; General discharge: 23; State Permit: 8; General Total Retention Lagoon (TRL): 2; Industrial User: 8; Municipal Total Retention Lagoon (TRL): 2; Totals: 210, 262;
16. Metric 1g3 Facilities with Penalties is revised to 30. Industrial & Construction Stormwater, state permit, and TRLs are maintained in a state database. Universe Total Facilities with Penalties: Unpermitted: 3; Construction Storm water: 5; Industrial Storm water: 2; Minor: 10; Major: 6; General discharge: 1; State Permit: 2; General Total Retention Lagoon (TRL): 0; Industrial User: 1; Municipal Total Retention Lagoon (TRL): 0; Totals: 30.
Oregon CWA ICIS-NPDES data for Oregon are accurate according to state databases, with the exception of actual inspection dates for stormwater permits. The change in procedure to electronically transfer correct stormwater inspection dates from the state database to ICIS-NPDES began on October 1, 2019. Oregon ICIS-NPDES Data Steward, Martina Frey, compared state data to ICIS-NPDES. Specific data issues and comments were flagged during verification. We verified and submitted the data verification report for federal fiscal year 2019 (Oct 2018-Sep 2019) data.
Pennsylvania
 
CAA The 1I7 Metric Issue appears to be an issue between the ICIS-AIR and ECHO applications as half the stack tests appear and half don't, and all the stack tests that are missing were successfully transmitted to the ICIS-AIR system per the weekly transaction reports.
CWA Nearly all required facilities are now using PA DEP's electronic DMR submission system, however, PA DEP continues to work with EPA in addressing complications in uploading a portion of the data to the federal database. PA DEP NPDES permits are issued by both its Clean Water Program and its Mining Program. Work continues with aligning data for both programs to simplify reporting and to address what appears to be deficiencies in the SRF Report. The Mining Program is new to electronic reporting and continues to address various complications with the reporting and uploading processes. Additionally, NPDES permits starting with PAC (construction stormwater), PAD, and PAL are only tracked in ICIS, not state systems.
Rhode Island RCRA RIDEM has reviewed the RCRA data in ECHO and identified a few missing data elements that are present in RCRAInfo but not in ECHO. The data caveats are identified below and marked by the data metric item number. In addition, RIDEM participated in an LQG flexibility plan which included the inspection of 20% of its LQG universe and 5% of its LQG retail pharmacy sites. This activity is not reflected in the ECHO calculation of LQG coverage for FY19.
1b1: RIDEM completed three (3) additional CEIs which were not reflected in the list of inspections in this metric a/o 1/15/20. The missing CEIs are: RIR000513606 - L. Gee Collision; RIR000509935 - Price Auto Sales; RID075687665 - Williams, Roger Medical Center;
1d1 & 1d2: RIDEM also issued informal actions to the following Generators: RIR000509935 - Price Auto Sales; RIR000514455 - Saver's Store #1104. The enforcement actions are listed in RCRA Info but were not extracted to ECHO. Both facilities are SQGs.
1f1 & 1f2: RIDEM also obtained a Consent Order in Superior Court to close out the following case: RIR000508820 - Wanskuck Steam & Power, Inc. 725 Branch Ave., Providence.
1g: RIDEM collected additional penalties during the fiscal year in the following cases: RID987489473 - Technic, Inc Engineered Powders Division - $2,500.00; RIR000509257 - Plastic Development Corp - $4,174.00. 
South Carolina
 
CAA

Re-submitting Data Verification for SC as we had several source tests added since last verification and some CM/TV facilities switch lists. South Carolina Comments for FFY2019 Data Verification:
1a1: SC00000800149 - Facility TV effective 1/1/20; was operating under cons. SC00001600022 - Facility TV effective 1/1/20; was operating under cons. SC00002000135-Should be under CM for FFY 2019; SC00003000026 - Facility TV effective 1/1/20; was operating under cons. SC00003600079 - Facility TV effective 1/1/20; was operating under cons. SC00006400070-Facility TV effective 10/01/19; was operating under cons. SC00009000102 - Facility TV effective 10/01/19; was operating under cons. SC00012000013 - Moved to CM list. CM effective 4/1/20; should be under TV list; SC00013600037-Facility TV effective 10/01/19; was operating under cons. SC00020600321-Facility TV effective 10/01/19; was operating under cons. SC00020600555-Facility TV effective 10/01/19; was operating under cons. SC00021400095 - Missing Closed 11/12/2019; was active during FFY 2019.

1a2: SC00002000135-Moved to TV list with 11/12 pull; should be under CM list. SC00002000286-CM effective 10/01/19. SC00008200091-CM effective 10/01/19; SC00008800040- CM effective 1/1/20; SC00012000013 - CM effective 4/1/20; should be under TV list. SC00015200111- Missing Closed 11/1/2019; SC00015600131 - CM effective 2/3/20; SC00018200021 - CM effective 12/23/19; SC00018600103-CM effective 10/01/19; SC00018800113 - CM effective 12/12/19; SC00020600537-CM effective 1/1/20; SC00099000093 - Facility merged with SC00099000283 on July 15, 2016. Therefore, this permit is no longer active. SC00099000273- Facility merged with SC00099000283 on July 15, 2016. Therefore, this permit is no longer active. SC00099000699 - CM effective 1/1/20.

1a3: SC00000800041- Missing; SC00004200029- Missing; SC00004200059- Missing; SC00004200089- Missing; SC00004600029- Missing; SC00005600411- Missing; SC00006000007- Missing; SC00009000002- Missing; SC00013400107- Missing; SC00013800017- Missing; SC00016800043- Missing; SC00018600004- Missing; SC00018600005- Missing; SC00021800031- Missing.

1a4: SC00010400083- Facility not in SC database; Facility has been closed since 10/01/2006. SC00020600199- Facility has been operating under SOP since 1/1/2016; SC00021400094- Facility not in SC database; SC00099000338 - Facility closed on 12/20/19 - Facility had a comprehensive inspection on 7/26/19, and FCE on 7/26/19. 1b4: SC00000800149 - Facility TV effective 1/1/20; was operating under cons. SC00001600022 - Facility TV effective 1/1/20; was operating under cons. SC00002000135- Should be under CM for FFY 2019; SC00003000026 - Facility TV effective 1/1/20; was operating under cons. SC00003600079 - Facility TV effective 1/1/20; was operating under cons. SC00006400070- Facility TV effective 10/01/19; was operating under cons. SC00009000102 - Facility TV effective 10/01/19; was operating under cons. SC00013600037- Facility TV effective 10/01/19; was operating under cons. SC00020600321-Facility TV effective 10/01/19; was operating under cons. SC00020600555- Facility TV effective 10/01/19; was operating under cons. SC00021400095- Missing Closed 11/12/2019; was active during FFY 2019. 1b5: SC00000800144- Facility is operating under a construction permit. Not currently classified as MA and no FCE is due.

1b6: SC00000400001- Facility closed 3/1/16. No FCE. SC00000800040- Facility closed 6/18/14. No FCE. SC00010400083- Facility closed 8/24/06. No FCE. SC00012000505- Facility closed 9/9/14. No FCE. SC00015600171- Facility is operating under construction permit. Not currently classified as SM-80, no FCE due. SC00018200021- Facility has been operating as SOP - CM effective 12/23/19. No FCE due.

1i7: SC0000080008800073 - Passed Test from 7/30/19; SC0000080008800074 - Failed Test from 7/30/19.

1j2: SC00002000117 - Operated under TV for FFY 2019; Facility becomes CM on 4/1/20. SC00021400095 - Operated under TV for FFY 2019; Facility closed Nov 2019.

RCRA The one error that was found has been corrected in RCRAInfo.
South Dakota CWA 1. Metric 1a4 - There are 23 SDPGs that are Pretreatment Metal Finisher general permit covered facilities and not to be counted. The logic cannot remove these from the count. The correct number is 246.
2. Metric 1e1 - There are 5 SDPGs that are Pretreatment Metal Finisher general permit covered facilities and not to be counted. The logic cannot remove these from the count. The correct number is 107.3.
3. Metric 7j2 - There is 1 SDPG that is a Pretreatment Metal Finisher general permit covered facility and not to be counted. The logic cannot remove these from the count. The correct number is 38. 4.
4. Metric 7j3 - There are 9 SDPGs that are Pretreatment Metal Finisher general permit covered facilities and not to be counted. The logic cannot remove these from the count. The correct number is 94.
Tennessee CAA For metric 1a1, Vulcan Construction Materials is not a major/title V source for visual emissions nor any other pollutant. Vulcan is a synthetic minor source and the EPA has this company classified incorrectly.
Texas
 
CAA Metric ID - Metric Name - Comments for ECHO (FY19 CAVEAT);
1a1 - Number of Active Majors - Current and historic Title V Major facilities appear in Enforcement and Compliance History Online (ECHO), regardless of the FFY19 permit status. Texas Commission on Environmental Quality (TCEQ) Records indicate there were 1,421 active Title V Major facilities in FFY19. 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 (FFY21).
1a2 - Number of Active Synthetic Minors - TCEQ does not capture or maintain this information.
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.
1a4 - Number of Active CMS Minors - TCEQ does not capture or maintain this information. The 25 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).
1a5 - Number of HPV Minors - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1a6 - Number of Minors Subject to Formal Enforcement - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1b4 - Number of Active Title V Facilities - Current and historic Title V facilities appear as active in ECHO, regardless of the FFY19 permit status. TCEQ Records indicate there were 1,619 active Title V facilities in FFY19. 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. 1b5 - Number of CMS Majors - TCEQ records show that there were 671 Title V major facilities with an FCE conducted in FFY19. 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.
1b6 - Number of CMS 80% Synthetic Minors - TCEQ does not have a Synthetic Minor program and does not maintain this information.
1b7 - Number of Other CMS Minors - TCEQ does not capture or maintain this information.
1c1 - Number of Facilities with an FCE (Facility Count) - TCEQ records show that there were 671 Title V major facilities where FCEs were conducted in FFY19. TCEQ is reviewing the records.
1c2 - Number of FCEs (Activity Count) - TX000A0000000015565960005 is a duplicate of TX000A0000000015565960004; no other duplicates were identified during review.
1d1 - Number of Facilities with an FRV Identified (Facility Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1d2 - Number of Case Files with an FRV Identified (Activity Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1e1 - Number of Informal Enforcement Actions (Activity Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1e2 - Number of Facilities with an Informal Enforcement Action (Facility Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1f1 - Number of Case Files with an HPV Identified (Activity Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1f2 - Number of Facilities with an HPV Identified (Facility Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1g1 - Number of Formal Enforcement Actions (Activity Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1g2 - Number of Facilities with a Formal Enforcement Action (Facility Count) - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1h1 - Total Amount of Assessed Penalties - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
1h2 - Number of Formal Enforcement Actions with an Assessed Penalty - TCEQ continues to enhance upload capabilities of all ICIS-Air data elements to ensure this information is accurately captured.
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.
1j1 - Number of Facilities with a Reviewed TVACC - TCEQ records show that there were 1122 Title V major facilities where TVACCs were reviewed in FFY19. TCEQ is reviewing the records.
1j2 - Number of Facilities with TVACC Due - Current and historic Title V facilities appear as active in ECHO, regardless of the FFY19 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.
CWA
Metric ID - Metric Name FY19 Data - Comments for ECHO (FY19 CAVEAT);
1a1 - Number of active NPDES major individual permits - TCEQ records show that there were 710 permits classified as majors. EPA's count of 724 included thirteen permits 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. (Based on ECHO data pull from January 10, 2020.)
1a3 - Number of active NPDES non-major individual permits - TCEQ records show that there were 2206 minors. EPA's count of 2438 included 237 permits that fell outside the fiscal year date range and the following were missing from their list: TX0138517, TX0138070, TX0317961, TX0137952, and TX0138886. (Based on ECHO data pull from January 10, 2020.)
1a4 - Number of active NPDES non-major general permits - TCEQ records show that there were 34,758 General Permits. EPA's count of 35,172 included 414 that fell outside the fiscal year date range. (Based on ECHO data pull from January 10, 2020.) 1b7 - Number of active NPDES individual DMR filers - TCEQ records show that there were 3052 DMR filers. EPA's count of 3057 included 5 permits that were expired and outside the fiscal year date range (TX0112291, TX0124541, TX0126471, TX0131636, and TXL005003). 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. (Based on ECHO data pull from January 10, 2020.)
1b8 - Number of active NPDES individual DMR filers with permit limits in ICIS - TCEQ records show that there were 2765 DMR filers with permit limits. EPA's count of 2769 included 4 permits that were expired and outside of the fiscal year date range (TX0112291, TX0124541, TX0126471, and TXL005003). 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. (Based on ECHO data pull from January 10, 2020.)
1f1 - Number of major and non-major facilities with formal enforcement actions concluded during the review year - The TCEQ issued formal actions against 204 facilities. There were actions against 15 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were 15 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.
1g3 - Number of major and non-major facilities with penalties assessed during the review year - The TCEQ issued formal actions with penalties against 203 facilities. There were actions against 15 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were 15 formal actions with penalties 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 show that there were 228 majors investigated by TCEQ during FY19. EPA's count of 235 included four permits that fell outside the fiscal year date range: TX0103501, TX0022365, TX0078565, TX0023931 were conducted in FY18.
5b4 - Number of inspected non-major general permit covered facilities - TCEQ data flow to ICIS-NPDES was recently enhanced to flow non-major general permits investigation information. The FFY20 TCEQ data should align more closely with ECHO data next year.
7j1 - Number of major and non-major facilities with single-event violations reported in the review year - TCEQ data flow to ICIS-NPDES was recently enhanced to flow non-major general permits investigation information. The FFY20 TCEQ data should align more closely with ECHO data next year. 
RCRA Metric ID - Metric Name FY19 Data - Comments for ECHO (FY19 CAVEAT); 1a2 - Number of active LQGs - TCEQs number does not include those one-time temporary notifiers.
1a5 - Number of BR LQGs - TCEQs number does not include those one-time temporary notifiers.
1b1 - Number of sites with on-site inspections - TCEQ data flow requires an EPA ID. For certain facilities such as CESQG, Transporters, or facilities that did not have an active EPA ID at the time of the investigation, the inspection record is not reflected in RCRAInfo. TCEQ continues to improve the process of assigning an EPA ID to all facilities where an inspection was conducted.
1c1 - Number of sites with new violations during review year - TCEQ data flow requires an EPA ID. For certain facilities such as CESQG, Transporters, or facilities that did not have an active EPA ID at the time of the investigation, the inspection record is not reflected in RCRAInfo. TCEQ continues to improve the process of assigning an EPA ID to all facilities where an inspection was conducted.
1c2 - Number of sites in violation at any time during the review year regardless of determination date - TCEQ data includes 250 sites with new violations cited during the review period and an additional 107 facilities which have or had outstanding violations cited in prior to the review period. This brought the total number of facilities to 357. This includes 76 facilities that are not required to obtain EPA IDs or did not have an EPA ID assigned to the investigation and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads.
1d1 - Number of sites with informal enforcement actions - TCEQ data flow requires an EPA ID. For certain facilities such as CESQG, Transporters, or facilities that did not have an active EPA ID at the time of the investigation, the inspection record is not reflected in RCRAInfo. TCEQ continues to improve the process of assigning an EPA ID to all facilities where an inspection was conducted.
1d2 - Number of informal enforcement actions - TCEQ data flow requires an EPA ID. For certain facilities such as CESQG, Transporters, or facilities that did not have an active EPA ID at the time of the investigation, the inspection record is not reflected in RCRAInfo. TCEQ continues to improve the process of assigning an EPA ID to all facilities where an inspection was conducted.
1e1 - Number of sites with new SNC during year - TCEQ records indicate there were 13 sites with a new SNC. This includes 1 site with duplicate EPA IDs and 4 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.
1f1 - Number of sites with formal enforcement actions - Includes 30 sites that could not be uploaded to RCRAInfo due to ongoing data flow issues or the facility not being required to have an EPA ID.
1f2 - Number of formal enforcement actions - Includes 33 actions that could not be uploaded to RCRAInfo due to ongoing data flow issues or the facility not being required to have an EPA ID;
1g - Total dollar amount of final penalties - The $1,868,778 difference in the penalty amounts reflects case information that could not be uploaded to RCRAInfo due to ongoing data flow issues or the facility not being required to have an EPA ID.
Virginia
 
CWA 1a4 (Number of active NPDES non-major general permits) - The storm water industrial permits (SWI, VAR05%) listed are limited to permits with inspections done in the past by EPA; they do not represent the entire VA SWI universe. Records for MS4, industrial storm water, construction storm water, and CAFO are not yet transmitted to ICIS, therefore, not included in metric 1a4.
1e1 (Facilities with informal actions) - Actions listed for the nonmetallic mineral mining permits are limited to NOVs issued during current permit term (effective date 07/01/19). Records for MS4, industrial storm water, construction storm water, and CAFO are not yet transmitted to ICIS, therefore, not included in metric 1e1.
1f1 (Facilities with formal actions) - Records for MS4, industrial storm water, construction storm water, and CAFO are not yet transmitted to ICIS, therefore, not included in metric 1f1.
5b4 (Number of inspected non-major general permit covered facilities) - Records for MS4, industrial storm water, construction storm water, and CAFO are not yet transmitted to ICIS, therefore, not included in metric 5b4.
7j1 (Number of facilities with single-event violations reported in the review year) - The unauthorized by-pass and unpermitted discharge via collection system events occurring on the same day are counted as two separate events in VA's data system but as one same event in ICIS. Records for MS4, industrial storm water, construction storm water, and CAFO are not yet transmitted to ICIS, therefore, not included in metric 7j1. 
CAA
Washington
 
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.
AIR WA0000005301500003 was a Single Major Title V Source for three separate facilities located in Longview (Nippon, NORPAC, and Weyerhaeuser) until June 18, 2019.
RCRA
The number of active LQGs is similar between Washington State's TurboWaste data system and RCRAInfo. We are investigating how to correct the differences and have closer correspondence between the two systems. This is challenging given the systems' differing data requirements and the constant change in the handler universes.
West Virginia CWA Element 1
Data Metric 1a4: 9,924 general permit registrations during 2019 fiscal year. There are a number of older permits that haven't been reissued that are not in ICIS data, this will be addressed during next reissuance to determine if these permits are still active. Metrics 1b7 and 1b8: WV0000108 - Kincaid Enterprises - Facility is closed but has ongoing legal issues.
Metrics 1f1 and 1g3: WVDEP does not upload penalties or formal actions on state only permits.
Element 2 - Inspections
Metric 5b3: Water inspections not uploaded due to feed issues: 4.
Metric 5b4: GP inspection not uploaded due to feed issue: 1;
Element 3 -Violations
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. In addition, WVDEP has determined that there are instances where inaccuracies have occurred and are still occurring as the data submitted to ICIS system is converted into the ECHO system. This also resulted in inaccurate SNC/Category 1 and RNC numbers. Division of Mining and Reclamation; Hydrologic Protection Unit;
Metrics 1f1 and 1g3: At this time Formal Actions and Penalties are not uploaded into ICIS. A computer function is being developed to allow input of this data at this time.
Metric 7j2: 1. 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. In addition, WVDEP has determined that there are instances where inaccuracies have occurred and are still occurring as the data submitted to ICIS system is converted into the ECHO system. This also resulted in inaccurate SNC/Category 1 and RNC numbers. 2. Parameter 00545 (Settleable Solids) is typically a conditionally monitored limit only required during a rainfall event. WVDEP has not historically required DMR coding as conditional for these limits. The absence of this data has led to many invalid non-receipt violations being generated. While we have worked to manually administratively resolve these violations, there may be some that not been corrected. We are currently working to enhance our electronic submission system and a compliance bulletin has been issued to industry to begin placing the appropriate NODI code for this parameter when applicable. 3. While the limit data that is currently being fed from our internal systems to ICIS is believed to be accurate, there is a large amount of older limit set data from previous years that were fed with incorrect initial reporting date requirements and incorrect reporting frequencies. Much of this data is now considered historical as permits have since been reissued and can no longer be readily corrected. Identifying and correcting existing data is an extremely detailed and time-consuming process due in part to the fact that our system does not directly handle deletion and replacement through our exchange node.
CAA
Wisconsin
 
  • 1a4 Other active facilities on the CMS plan. Metric result 3 Correct number 1. Two of these three facilities should not be included in category 1a4.
    • WI0000000005506101: I have previously requested that this facility listing be deleted. The facility is correctly updated under WI0000005506101674. This listing should not be in 1a4.
    • WI0000005507900039: This listing should also be deleted. This does not reflect an actual facility and should not be included in 1a4.
  • 1b5 Number of CMS Majors Metric result 166. Correct number 164. Brillion Iron Works; WI00000051500013, Dairyland Power Coop-Seven Mile Creek; WI0000005503500045 These two facilities had closed in fact prior to FFY19 but had not been properly updated in ICIS. I have now closed and correctly dated both. They were included in this metric as requiring inspection. Counts of FRVs and Informal Enforcement Actions: due to a problem with our transfer program we have under-reported for metrics related to FRVs and informal enforcement actions. (There are no HPV cases or HPV violations missing.) These will eventually be transferred to ICIS but for the purposes of verification I want to report these corrections to metric numbers.
  • 1d1 Facilities with an FRV reported: metric result is 23, correct number is 30 (7 are missing). 1d2 Case files including an FRV: metric result is 24, correct number is 31 (7 are missing).
  • 1e1 Number of informal enforcement actions: metric result is 31, correct number is 36 (5 are missing).
  • 1e2 Facilities with an informal action: metric result is 29, correct number is 33 (4 are missing).
CWA 1a2, 1a4, 5b4: In the state of Wisconsin all general permits for EPA purposes in ICIS/ECHO are classified as minor. Wisconsin does not currently store the majority of general permit data in ICIS.
1a3: Total 1,112.
1b7: Total 749. There are a number of facilities that are erroneously active/missing in ECHO. Efforts to update facility numbers in ICIS to the current total in Wisconsin's state database are underway.
1e1, 1f1, 1g3: As part of Wisconsin's stepped enforcement process all NOVs and formal actions against permittees are managed by the Bureau of Law Enforcement. The Environmental Enforcement (EE) program's records are kept electronically in data management systems that do not have the capabilities to transfer data to ICIS-NPDES. 5a3: Total 76.
5b3: Total 159. CEI, 38 Lab, 94 CAFO;
7j1, 7j2, 7j3: The WDNR is in the process of updating our current ICIS-NPDES data flow to more accurately represent the states collected eReporting rule required data into ICIS-NPDES. Until the ICIS-NPDES data flow is fully corrected, information presented through the dashboard will likely not be complete, current, and/or accurate. For complete and current information on regulated parties in Wisconsin, we suggest that data be accessed through our ICIS/NPDES Data Steward, Taylor Steager.

Top of Page