State Comments on Frozen Data - 2020

1. Two sources listed in metric 1a5 (# of HPV minors) are on this list due to federal enforcement actions, not state enforcement actions. AL0000000103300016 - Constellium and AL0000000107100008 - TVA Stevenson Mill. This should not be part of the state metrics since states cannot resolve the HPV.

2. Several sources that are major sources that do not yet have an MSOP (T5 Permit) are in their initial year of their MSOP are listed as though an ACC was expected; however, one is not yet even due. This is a repeated issue with every data verification and should be fixed. It is a false metric otherwise.

3. Several sources have ACCs due on the cusp of the FY (just prior to 9/30 or just after 9/30) and, depending on when submitted, it can fall into either FY, even if timely. The system of forcing data into a fiscal year does not accommodate such instances. If the ACC is due on 10/3 of a given year, and the source submitted one year on 9/18 and the next year on 10/1, it looks as though they did not submit for one year when that is incorrect.

Jefferson County Local Control Area: There continues to be a problem with ICIS and ECHO not getting the total sources correct and old ones that were closed are still showing up.

Metrics 1a1, 1a2, 1a3, 1b7, 1b8, 1e1, 5a3, 5b3, 5b4 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.

Incorrect/Deficiency 1a4 - Number of active NPDES non-major general permits.

Review of the general permit covered facilities in ICIS-NPDES found 4337 (instead of 4327) NPDES permit facilities since ARR156441, ARR156451, ARR156457, ARR156464, ARR156465, ARR156467, ARR156473, ARR156474, ARR156477, ARR156483 were active 10/01/2019 through 09/30/2020 in ICIS-NPDES, but not in ECHO.

Incorrect/Deficiency 1f1 - Facilities with Formal Actions.

Review of Formal Enforcement Actions in ICIS-NPDES found 68 (instead of 69) NPDES permit facilities with new Formal Enforcement Actions in FY2020 as of 03/11/2021. One facility for Formal Enforcement Action AR-9825 is linked to two NPDES IDs was counted twice in ECHO even though the two NPDES IDs (ARR001881 & ARU500192) have the same facility FRS ID 3601204581.

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 FY2020 as of 03/09/2020. One facility with one penalty from 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.

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 14 (instead of 17) NPDES permit facilities with new single event violations in FY2020 as of 03/11/2021. The following were inadvertently included in the ECHO Data Metrics: AR0022187, AR0022292 & AR0047279 are linked to false 04/30/2020 N/A (E90) DMR, Limited Numeric Effluent single event violations that are not available by state users in the ICIS-NPDES database, and should not be counted in this metric. Arkansas contacted ICIS User Support to request that these violations be removed, but they have not removed them as of 03/12/2021.

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 518 (instead of 525) 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 FY2020, 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). EPA Region 6 has closed these events in ICIS-NPDES, but not in time for the final data refresh in ECHO.

Data Caveats: 1a3: Rico Landfill is no longer permitted. It is waived due to being below the threshold for an air quality permit. Is an active operation but without air permit it should not be in this list.

1a2: AIR AZ00000004777Z2715 GREEN WASTE SOLUTIONS LLC Permanently closed in 08/19/2019. AIR AZ00000004015Z2617 ADVANTAGE BOATS Closed 02/22/2018. Both dates entered recently, past the freeze dates.

1a2: Facility data was incorrectly added after discovering 2 sources with the same name. AIR AZ000166099 was recently added and is the correct active source for Pass Canyon data after 11/29/2016. AIR AZ000000130210 Northern Improvement Co Pass Canyon Plant Permanently Closed 06/18/2020 and last data was entered on 11/29/2016. All data was moved over to AZ000166099 but some are older data from before FY20.

1a2: AIR AZ000000144288 BLACK DIAMOND MATERIALS C&S PLANT #1 permanently closed on 05/26/2018, FY data in 2016 is missing in ICIS as it is past the freeze date. 1a2: Several Sources were originally entered in as SM80s but after state data base research they are only minor and should not be on the CMS list. The Sources are the following: AIR AZ000000157022 OWENS PIT, SHOW LOW, ARIZONA, AIR AZ000000157380 CEMEX C&S GLOBE PLANT, AIR AZ000000157538 1405 MINE.

1a2: AIR AZ000000156972 THORNTON MATERIAL SOURCE is temporarily closed on 05/24/2017 after moving out of state.

1g1: AIR AZ00000004015Z1913 MOHAVE VALLEY LANDFILL entered a Consent Order effective 02/06/2020 missing in sheet.

1g1: AIR AZ000166099 Pass Canyon entered a Consent Order effective 02/07/2020 missing in verification page.

1a2 and 1a1: Personnel changes resulted in 41 sources not added within 60 days that should have been in the system between the years 2016-2019. CMS list was updated to remove inactive sources but several new Title X and SM80s were not added until this 2020FY. Meaning these 41 sources may not contain all data between 2016-2019 due to data freeze. These 41 sources do however contain all applicable FY 20 data after discovering the issue.

1a1 Number of active NPDES major individual permits: AZ0020524 City of Phoenix 91st Ave is missing from this metric for Arizona but is in ICIS. EPA written permit. City of Phoenix 91st Ave shows up in this metric if you select Agency as EPA.

1a2 Number of active NPDES major general permits: Permits not flowing into ICIS yet. Working to resolve the issue. Should be 5 permits not zero. Currently the 5 permits in ICIS show the permits as being expired. This is not correct. The 5 permits should be active under Administratively Continued. NOTE: Those 5 permits will be moving to Individual Permits, so future maybe be zero permits for Infrequent Discharger and Minor Discharger.

1a3 Number of active NPDES non-major individual permits: AZ0025224 USDA FS - APACHE SITGREAVES NF - BLACK MESA RANGER DISTRICT and AZ0025941 ARIZONA SOILS COMPOST FACILITY are terminated in ICIS, but still show active in 1a3 metric. Because the facilities were active during EPA FY 2020 ECHO correctly shows on metric 1a3 active list.

1a4 Number of active NPDES non-major general permits: Permits not flowing into ICIS yet. Working to resolve the issue. Should be 3,000 active permits. The 207 permits showing are for expired or terminated permits and would not be considered active.

1b7 Number of active NPDES individual DMR filers: AZ0020524 City of Phoenix 91st Ave is not counted as a state permit because EPA wrote the permit and is not reflected in the state numbers.

1b8 Number of active NPDES individual DMR files with permit limits in ICIS: AZ0020524 City of Phoenix 91st Ave is not counted as a state permit because EPA wrote the permit and is not reflected in the state numbers.

1e1 Facilities with informal actions: General Permits are not flowing.

1f1 Facilities with formal Actions: Missing two formal actions (general permit and MOU for Nogales International Wastewater Treatment Plant)

1g3 Facilities with penalties: Missing penalty data for Nogales International Wastewater Treatment Plant. Data not uploaded to ICIS.

5b3 Number of inspected non-major individual or unpermitted facilities: AZ0024201 City of Tucson Lakeside Park Lake is in pending status and was not complete this fiscal year.

7j1 Number of major and non-major facilities with single event violations in the review year Arizona is not flowing Single-Event Violation data

7j2 Number of facilities with SNC/Category 1 noncompliance Data flow issues with the AZ0020231 Town of Gila Bend WWTP is causing inconsistencies between ICIS and Azurite. Only should show violations in Q3 and Q4. AZ0025151 City of Mesa Southeast Water Reclamation Plant should not be shown as SNC. SNC designation appears to be due to a non-receipt violation. All required monitoring was submitted to ADEQ.
AZ0025607 Nogales International Wastewater Treatment Plant SNC designation for effluent violations is incorrect. Deficiencies are for exceedances in the influent prior to the treatment plant. AZMW24279 Data is not flowing for High County Pines II.

7j3 Number of facilities with RNC/Category 2 noncompliance or effluent, single event, or schedule violations open during the year.

AZ0025305 Houston Creek Landing WWTP DMR data is inconsistent with data in ICIS. Only showing violations in Q3 and Q4 in Azurite.

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.

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. While CT confirmed ICIS has violations posted for those listed, 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. For CT0020630, Mystic Marinelife Aquarium, the SEV count should be 6 instead of 5. ICIS did not allow one of the SEVs to be entered. ICIS did not allow use of the same SEV code more than once for the same inspection date.

2020 SRF Connecticut Caveats 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. Connecticut 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.

Metrics 5b: For FFY2020 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. However, because of COVID-19, DEEP was unable to conduct onsite LQG CEI inspections but did develop an offsite LQG Questionnaire (an onsite CEI checklist equivalent). These inspections were recorded in RCRA INFO as Non–Financial Record Reviews (NRR’s). The following LQG offsite inspections recorded as NRR’s for FFY2020 are: TTM PRINTED CIRCUIT GROUP CTD00065206, CARTEN FUJIKIN CTD981207715, CT GALVANIZING CTD046233003, WESLEYAN UNIVERSITY CTD983895624, DYMAX OLIGOMERS AND COATINGS CTDO98114598, BARDEN CORP /SCHAFFER AEROSPACE CTD0001163732, GOODRICH CORP/DANBURY MISSION TECHNOLOGIES CTD043211903, METROPOLITAN DISTRICT CTP000033396, MOSSBERG O F & SONS CTD001454701. The following FFY2020 pre C0VID-19 LQG onsite CEI inspections were not on the SRF database: HENKEL LOCTITE CORP CT5000001123 and TIMKEN AEROSPACE TRANSMISSIONS CTD001141407.

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). In addition to the TSD inspections recorded on the SRF database, DEEP for FFY2020 conducted 2 offsite TSD questionnaire inspections and recorded them in RCRA INFO as NRR’s. They are Hamilton Sundstrand CTD001145341 and Clean Harbors CTD000604488.

Metric 1g: The penalty amount reported includes the total penalty component offset by the performance of Supplemental Environmental Projects.

Five active major facilities in ICIS are not reflected in ECHO: Medstar Georgetown University Hospital (DC0000001100117111), The DC Veterans Affairs Medical Center (DC0000001100100041), AOC - House Office Buildings Jurisdiction (DC0000001100180501), AOC - Library Buildings and Grounds, and AOC - Capitol Building (DC0000001100180503). The three AOC facilities are the most recent additions to our list of active major facilities. DOEE received and reviewed 41 TV ACCs.

DOEE is currently working on automating data transfer into ICIS to ensure more timely and accurate updates to facility information.

Metric 1a2: Forty-one of the 431 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 385 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.

Two stack tests were missing for GA0000001329300027 Edward L. Addison Generating Plant, but should be available in ICIS-Air soon. There was a mixup to which source those tests were assigned.

The metrics for number of major sources, synthetic minor sources, Title V source, etc. should be stopped on September 30, 2020, but are not, which causes the count to artificially include sources that were not active during FFY2020.

Metric 1j2 is very poorly defined in that it does not match the reality of what Annual Compliance Certifications are actually expected. It includes CMS major facilities instead of Title V facilities, ignoring the fact that not all Title V facilities are major and not all major facilities are Title V. Several regulations require non-major sources to obtain Title V permits; therefore, they are required to submit ACCs even though they are not CMS major. New major facilities operating under a construction permit are not required to apply for a Title V permit until 12 months after startup; therefore, they may be CMS major for some time before receiving a Title V permit and are not required to submit an ACC. Finally, ACCs are based on calendar years, so basing the timeframe on the previous federal fiscal year misses the start and end dates by three months.

Metrics 1a4 – Georgia has identified an error that has resulted in an incorrect permit status for several the expired Construction Stormwater permits. These permits are “administratively continued” in ICIS and should be set to “expired”. We have identified the issue are working with our contractor for a correction to the EDT flow.

Metric 5a1, 5b1, and 5b2 – Georgia has identified additional inspections completed for our active facilities that did not transfer via EDT and will be correcting the data transfer errors.

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.

METRIC 1A4 - There are 2 non-major Title V facilities that the metric did not pick up. They are: 039-00020 IRWS, CMS start date of 5/24/2019, 031-00046 Milner Butte Landfill, CMS start date 4/24/2012

METRIC 1J1 - There 2 facilities that the metric did not pick up. They are: 045-00004 Northwest Pipeline, Caldwell, ACC reviewed 1/31/2020, 055-00044 Kootenai County Farm Landfill, ACC reviewed 8/24/2020

METRIC 1J2 - There is one facility missing: 055-00044 Kootenai County Farm Landfill, ACC planned date 7/30/2020 There is one facility that the metric should not have captured: 055-00047 Foam Molders, ACC planned date is 1/30/2021 (outside of FFY2020)

In general, the data in the US EPA's FY20 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 FY20.
• Metric 1a4: These sources were later identified as minor sources but may have been on the original FY20 CMS Plan. Metric 1a5: There were no State lead, minor source, HPV cases in Michigan in FY20. The state count should be zero.

The Minnesota Pollution Control Agency has made all reasonable effort to verify and correct the data presented in the ECHO State Review Framework (SRF) environment.

This has been 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 IDEA/OTIS/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 the data be accessed through our ‘What’s in my Neighborhood’ website.

In addition, the SRF Metrics may not accurately reflect Minnesota’s performance on enforcement due to a conflict between federal standards for data transparency and State of Minnesota data practices laws. Under Minnesota law, the outcome of a compliance evaluation or enforcement action is not public until it is final, nominally defined as the later of the final execution of a compliance or enforcement instrument or the exhaustion of all available appeals. As a result of Minnesota law and the mechanisms by which the federal program systems publish data to public systems, Minnesota cannot share information on certain in-process compliance evaluations and responses.

Metric 1a2: The 60 sites listed are correct except RCRAREP verification shows that the following are LQGS during FY2020 but they are not. They became LQG's during the dates below:

Miller Property LQG - 11/18/2020, BASF Wilbur-Ellis - 10/18/2020, Geneva Wood Pharm - 1/5/2021, MSU Billings - 2/17/2021, Nutrien Solution - 11/18/2020

Ohio EPA identified the following errors and issues during the data verification process. The most significant issues were with metrics 1a2 and 1i7. These will require further follow up to determine the cause of the errors. Listed below are the problems that were identified, by metric:

• 1a1 There were seven facilities that were incorrectly categorized in ICIS Air and will need to be corrected by USEPA. Ohio EPA will provide USEPA with a list of the facilities to be corrected by USEPA.
• 1a2 There were 78 active minor facilities include in the metric list. Five facilities could not be corrected by Ohio EPA in ICIS Air and will need to be corrected by USEPA. Ohio EPA will provide USEPA with a list of the facilities to be corrected by USEPA.
• 1b4 Schneller LLC (Facility #OH0000001667040015) default classification is major; facility became SMTV 01/23/2015. USEPA will need to correct in ICIS Air. All other errors were corrected by Ohio EPA.

1i7 This metric appears to be incomplete. All data in the list is verified but there are tests at 143 facilities that appear in both Ohio EPA's STARS2 database and ICIS but is not in this metric list. Ohio EPA will provide USEPA with a list of the facilities that have had a stack test in FFY 2020 but that are missing from this metric.

1d1 The FRV Determination date was corrected in ICIS Air for 17 facilities so they appear in the right FFY.

1d2 The FRV Determination date was corrected in ICIS Air for 19 facilities so they appear in the right FFY.

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) 2020. The following caveats and revision in metric values need to be added to Oklahoma DEQ-Water Quality Division’s FFY2020 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, MS4 and General permits have their CEI, CSI, PCI, and Audit inspections coded into ICIS-NPDES.
4. Metric 1a4 Number of Active Non-Majors with General Permits revised value is 5,407. Stormwater-Construction & Stormwater- Industrial permits/authorizations are maintained in the Oklahoma DEQ's state database. During this period, there were 1840 Stormwater-Industrial and 3373 Stormwater-Construction permits/authorizations. Oklahoma DEQ-WQD has permitted 144 General Discharge permits/authorizations and 49 MS4 Phase II permits/authorizations. The Oklahoma Department of Agriculture, Food & Forestry (ODAFF) is delegated to permit the general CAFO (OKG01) permits on the list.
5. Metric 1A3 State number of Active NPDES Non-Major Permits is revised to 341. Permit number OK0077777 and OK0066666 are total retention permits that had to be entered due to the EPA’s database logic requiring the NPDES permit number of the POTW for the Industrial user permit.
6. Metric 1 g3 Facilities with Penalties is revised to 18. OKP003086 was not listed and the facility had a penalty of $15,000.00.
7. Metric 1e1 Facilities with Informal Actions is revised to 72. The following number of facilities by Facility Type had an Informal Action:
Major: 43
Minor: 19
Industrial User: 9
Municipal TRL: 1
8. Metric 1f1 Facilities with Formal Actions is revised to 160. The following number of facilities by Facility Type had a Formal Action:
Major: 24
Minor: 73
Unpermitted: 4
Satellite: 1
General Discharge: 17
General Total Retention: 2
Industrial User: 8
Construction Stormwater: 13 MS4 Phase II: 1
Industrial Stormwater: 16
Municipal TRL: 1
9. Metric 7j1 Number of Major and Non-Major NPDES facilities with single event violations is revised to 97. The following Stormwater facilities should be included in the list:
OKR1022282 Dodson Properties 2 LLC
OKR1023237 Prestige Hotels (Facility 30252 – ECO 19-187)
OKR1025971 Dequasie Development
OKR1027457 G&W Property (Facility 27457 - ECO 19-188)
OKR1027792 A&T Development (Facility 27792)
OKR1028064 Duit Construction (CO 19-102)
OKR1028080 DHD Corp/Morgan Crossing (CO 19-213 [JH])
OKR1028315 Duit Construction (CO 19-102)
OKR1028448 Duit Construction (CO 19-102)
OKR1029147 Braddock Dev. Co.
OKR1029433 Kolb Grading
OKR1030293 Key General
OKR109502 Will Properties LLC
OKR050804 Safety Kleen Systems
OKR050205 W & W Steel LLC
OKR050224 January Environmental Services Inc.
OKR050289 Cargill Feed & Nutrition
OKR050292 Del City Pickup Parts
OKR050671 Durant Iron & Metal, Inc.
OKR051241 Schwarz Asphalt LLC
OKR051339 Beeline Used Auto Parts
OKR052033 Cars Plus Auto Salvage
OKR052207 R&T Salvage & Used Cars
OKR052745 Altus Municipal Authority
OKR053238 Halliburton Energy Services
OKR053256 Lawton-Ft. Sill Airport
OKR053332 Burford Corporation
OKR053629 Downing Wellhead Equipment
OKR053639 Heartland Auto Parts

10. Metric 7j2 Number of Active facilities with SNC/Category 1 noncompliance is revised to 417. Industrial Stormwater has a total of 500 Facilities who are DMR filers, of which 265 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.
11. Metric 7j3 Number of Active Facilities with RNC/Category 2 Noncompliance for effluent, single event, compliance schedule, or permit event violations open during the year is 336. There were 29 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. In addition, there were 64 Stormwater Industrial facilities with DMRs less than 30 days late and were submitted after the due date.
12. Metric 7k1 Major and Non-Major facilities in Noncompliance revised value count is 746 out a universe of 5,407 permitted Facilities.
13. Metric 5a1 & 5a3 Inspection Coverage of NPDES Majors is revised to 80.
14. Metric 5b2 & 5b4 Inspection Coverage-NPDES Non-Majors with General Permits is revised to 1048. A total of 891 Stormwater -Construction, 113 Stormwater-Industrial, 7 General MS4 Phase II, 77 Industrial No Exposure and 37 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.

ICIS-NPDES data for individual major and non-major permits are accurate according to state databases. ICIS-NPDES data for non-major general-permit-covered facilities could not be updated by the time of the data freeze to reflect 536 approvals and 1,111 terminations of general permit coverage that Oregon DEQ granted during the last two quarters of FFY2020. The correct number of active, non-major general-permit-covered facilities is 2,374.

Because the inventory was out-of-date at the time of the data freeze, Oregon DEQ was not able to record 27 inspections of general-permit-covered facilities that occurred during FFY2020. Oregon DEQ performed 123 inspections of non-major general-permit-covered facilities during FFY2020.

Nearly all of Pennsylvania’s National Pollutant Discharge Elimination System (NPDES) permitted facilities required to submit electronic Discharge Monitoring Reports (eDMR) are now using PA DEP’s eDMR data system. PA DEP continues to work with EPA in addressing complications in uploading a portion of the data into EPA’s Integrated Compliance Information System (ICIS). PA DEP’s 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 State Review Framework (SRF) Report. The Mining Program is new to electronic reporting and continues to address various complications with its reporting and uploading processes. Additionally, NPDES permits starting with PAC, PAD, PAV, PAX, and PAL are only tracked in ICIS, not state systems.

PA DEP’s data system does not currently differentiate between SNC/Category 1 and RNC/Category 2 noncompliance (categories 7j2 and 7j3) at this time. Instead, DEP utilizes the QNCR and ECHO dashboards to closely track and monitor these facilities. Also, ICIS effluent violations will only exist in state database if the violation is manually created.

1a1 Number of active NPDES major individual permits EPA 406 – PA 404 The 2 missing permits are MS4 permits for Philadelphia & Allentown. Not a discrepancy. MS4 individual majors do not have a separate major fee category, so do not get pulled with the PA report. Not a discrepancy.

1a2 Number of active NPDES major general permits PA doesn't have major general permits.

1a3 Number of active NPDES non-major individual permits EPA 6380 – PA 4292 EPA's numbers include 11 PAC and 1030 PAD permits that PA doesn't count, plus 107 permits terminated during the FY. In addition, EPA's list contains 1143 Mining permits. PA's numbers include 130 inactive permits (permits that are still pending or not yet issued; permits that were canceled, denied, waived or withdrawn), 1 permit number change, 64 permits issued after the end of the Federal Fiscal year 2020 (FY), and 8 that are in ICIS but were not pulled by ECHO in the 1a3 category.

1a4 Number of active NPDES non-major general permits EPA 12483 – PA 5849 EPA’s number Includes 5794 PAC, 21 PAD and 2 PAV/PAX. 171 terminated permits and 910 mining permits. 27 permit number changes. PA’s number includes 241 inactive permits and 50 permits issued after end of the FY.

1b7 Number of active NPDES individual DMR filers EPA 3598 – PA 3427 EPA's numbers include 1 PAD, 68 terminated permits and 393 mining permits. PA's numbers include 94 inactive permits: 3 permits in ICIS but not pulled in the ECHO list; 104 SFTF permits; and, 90 permits issued after end of the FY.

1b8 Number of active NPDES individual DMR filers with permit limits in ICIS EPA 2852 – PA 2605 EPA's numbers include 251 Mining permits. PA's numbers include 4 recent permits uploaded to ICIS. In addition, there are 1364 Mining IP permits without limits in ICIS.

1e1 Facilities with Informal Actions

EPA 665 – PA 656

EPA's numbers include 14 PAC/PAD facilities that PA doesn't count and 1 permit that was terminated during the FY. PA's numbers include 1 septage hauler permit, 4 inactive permits, and 1 Case in Progress. This enforcement action type has been removed as an option in the state database moving forward.

1f1 Facilities with Formal Actions

EPA 176 – PA 176

1g3 Facilities with Penalties

EPA 107 – PA 104

EPA's numbers include 5 PAC/PAD facilities that PA doesn't count. 2 penalties did not get uploaded to ICIS; PA DEP is working to resolve the issue. PA’s electronic data transfer (EDT) crosswalk mapping to ICIS needs to be updated to reflect the current compliance and enforcement codes in ICIS.

5a3 Number of inspected major facilities

EPA 344 – PA 353

PA's numbers include 1 inspection type Reconnaissance without Sampling (ROS) which is not counted by EPA in this metric. 8 additional inspections were just re-uploaded and are showing in ICIS but not yet in ECHO.

5b3 Number of inspected non-major individual or unpermitted facilities

EPA 2635 – PA 2389

EPA's numbers include 228 PAD permits that PA doesn't count, plus 46 permits terminated and 1 expired during the FY. PA's numbers include 16 permits that were renumbered during the FY, 6 that are pending or withdrawn, one inspection just created in 2021 and not yet uploaded to ICIS, and 2 that will not currently upload to ICIS due to PA’s need to update EDT crosswalk mapping to ICIS.

5b4 Number of inspected non-major general permit covered facilities

EPA 3021 – PA 2230

EPA's numbers include 735 PAC and 6 PAD permits that PA doesn't count, plus 75 permits terminated and 2 expired during the FY. PA's numbers include 4 inspection records recently created and not yet uploaded, 5 inactive permits, plus 11 permits where the NPDES ID number changed during the FY. In addition, 3 inspections will not currently upload due to PA’s need to update EDT crosswalk mapping to ICIS.

7j1 Number of major and non-major facilities with single-event violations reported in the review year.

195 SEVs are not in ICIS. Not all SEV types are being uploaded. The issue was identified with the SEV batch upload process during the FY2019 data verification. We are working on correcting this issue. Additionally, ICIS only allows one SEV type per day so not all SEVs can be uploaded to ICIS.

1a1: SC00002000135-Should be under CM for FFY 2019
SC00006400070-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

1a2: SC00099000093 - Facility closed; operating under new permit number as of 7/15/2016. Cannot closeout in SC database as the permits are linked and will closeout new permit. SC00099000273 - Facility closed; operating under new permit number as of 10/2/2015. Cannot closeout in SC database as the permits are linked and will closeout new permit.

1a3: (Not Applicable) SC00019000021 (Missing the following) SC00000800041 - A, H SC00004200029 - A, FF SC00004200059 - A, MM SC00004200089 - A, FF, MM SC00004600029 - A, E SC00006000007 - A, E SC00009000002 - A, FF, V SC00013400107 - A, M SC00013800017 - A, J, FF, V SC00016800043 - A, E SC00018600004 - A, FF SC00018600005 - A, FF, V SC00021800031 - A, M

1a4: SC00010400083 - Facility not in SC database; Facility has been closed since 10/01/2006.
SC00015600273 - Facility becomes TV 4/1/21; operating under cons permit.
SC00018800077 - Facility becomes CM 4/1/21; operating under MI permit.
SC00020600199 - Facility has been operating under SOP since 1/1/2016
SC00021400094 - Facility not in SC database.

1b4: SC00015600273 - Facility becomes TV 4/1/21; operating under cons permit.

1b6: SC00000400032 - Facility closed 7/2/2015; should not be on list. Updated ICIS.
SC00010400083 - Not In SC database.
SC00012000304 - Now SC00012000306 - This permit is not active.
SC00012000504 - Merged with another permit
SC00018600094 - Closed since 6/29/16 - Updated ICIS
SC00018800077 - Facility becomes CM 4/1/21; operating under MI permit.
SC00020600012 - Closed since 6/7/16 - Updated ICIS
SC00020600199 - Facility is operating under MI permit
SC00099000060 - Facility closed on 8/31/2016 -Updated ICS
SC00099000339 - Closed 6/29/2016

1i7: SC00004200030 - Source Test on 8/13/20
SC00012000207 - Source Test on 9/24/20
SC00020600097 - Source Test 8/20/20

1j2: SC00002000135 - TV became effective 1/1/20, first TVACC due by 2/14/21

1a1 - Number of Active Majors - Texas Commission on Environmental Quality (TCEQ) records indicate there were 1,129 active Title V Major facilities in FFY20. Enforcement and Compliance History Online (ECHO) records contain facilities that are not active Title V permits (1042 counts) or not major sources (261 counts). TCEQ has removed miscounted sites from ECHO. 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 with documented violations of 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 (FFY21).

1a5 - Number of HPV Minors - An HPV is only applicable to a Major Source; therefore, there should not be any HPVs associated to a Minor Source. While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1a6 - Number of Minors Subject to Formal Enforcement - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1b4 - Number of Active Title V Facilities - Texas Commission on Environmental Quality (TCEQ) records indicate there were 1,447 active Title V facilities in FFY20. Enforcement and Compliance History Online (ECHO) records contain facilities that are not of active Title V permits (761 counts). TCEQ has removed miscounting sites from ECHO. ECHO will not show the updated list of facilities until the following fiscal year (FFY21).

1b5 - Number of CMS Majors - TCEQ records show that there were 644 Title V major facilities with an FCE conducted in FFY20. ECHO has 155 counts that have a Next FCE Due Date being out of the time range of FFY20. Also, ECHO has 33 counts with the wrong FCE due dates.

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 644 Title V major facilities where FCEs were conducted in FFY20. TCEQ is reviewing the records. ECHO data includes two IDs that don't appear in TCEQ data, and TCEQ data contains four IDs that don't appear in ECHO data.

1c2 - Number of FCEs (Activity Count) - ECHO data contains five duplicate Evaluation IDs.

1d1 - Number of Facilities with an FRV Identified (Facility Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1d2 - Number of Case Files with an FRV Identified (Activity Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1e1 - Number of Informal Enforcement Actions (Activity Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1e2 - Number of Facilities with an Informal Enforcement Action (Facility Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1f1 - Number of Case Files with an HPV Identified (Activity Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1f2 - Number of Facilities with an HPV Identified (Facility Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1g1 - Number of Formal Enforcement Actions (Activity Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1g2 - Number of Facilities with a Formal Enforcement Action (Facility Count) - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1h1 - Total Amount of Assessed Penalties - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1h2 - Number of Formal Enforcement Actions with an Assessed Penalty - While TCEQ & ICIS-AIR data flows have been enhanced, there appears to be some errors with the data flow from TCEQ. Therefore, the TCEQ is working with the EPA to correct these issues. The FFY 2021 data should be closely more aligned with the ECHO data next year.

1i7 - Number of Stack Tests that occurred - The ECHO data reflects stack test reviews at Title V major facilities only. Only stack tests for Title V major facilities are required to be reported and are currently uploaded to ICIS-Air. TCEQ does not have a mechanism to log all stack tests that occurred, only those investigated.

1j1 - Number of Facilities with a Reviewed TVACC - TCEQ records show that there were 1103 Title V major facilities where TVACCs were reviewed in FFY20. 409 Facilities didn't upload to ICIS-Air because the facility has a permit status other than Active.

1j2 - Number of Facilities with TVACC Due - TCEQ records indicate there were 1,447 Title V facilities with TVACC due in FFY20. TCEQ was able to reconcile TCEQ and ECHO records to identify 1,024 facilities that appear in both data sets. ECHO records contain 92 facilities that are not active Title V permits. TCEQ has removed miscounted sites from ECHO. ECHO will not show the updated list of facilities until the following fiscal year (FFY21). TCEQ records contain 89 additional facilities that are not active Title V permits, and 249 that have a pending permit status. TCEQ is updating this information in state and federal databases.

1a1 - Number of active NPDES major individual permits - TCEQ records show that there were 708 permits classified as active NPDES major individual permits. EPA’s count of 726 included 17 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 4, 2021.

1a3 - Number of active NPDES non-major individual permits - TCEQ records show that there were 2178 active NPDES non-major individual permits. EPA’s count of 2478 included 300 permits that fell outside the fiscal year date range. Based on ECHO data pull from January 4, 2021.

1a4 - Number of active NPDES non-major general permits - TCEQ records show that there were 39,625 active NPDES non-major general permits. EPA’s count of 40,134 included 509 that fell outside the fiscal year date range. Based on ECHO data pull from January 4, 2021.

1b7 - Number of active NPDES individual DMR filers - TCEQ records show that there were 2738 active NPDES individual DMR filers. EPA’s count of 2744 included 8 permits that were expired and 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 4, 2021.

1b8 - Number of active NPDES individual DMR filers with permit limits in ICIS - TCEQ records show that there were 2573 active NPDES individual DMR filers with permit limits in ICIS. EPA’s count of 2581 included 8 permits that were expired and outside of 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 4, 2021.

1f1 - Number of major and non-major facilities with formal enforcement actions concluded during the review year - The TCEQ issued formal enforcement actions against 198 facilities. There were actions against 9 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were 8 formal actions against storm water facilities in which the permit number was expired and does not exist in the federal data base. The TCEQ completed the ICIS upload of active construction general permits on 09/27/18 and multi-sector general permits on 10/02/18. There was also 1 formal action taken against a facility that did not flow to ICIS. The reason why it did not flow is being researched by our contractor.

1g3 - Number of major and non-major facilities with penalties assessed during the review year - The TCEQ issued formal enforcement actions with penalties against 198 facilities. There were actions against 9 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were 8 formal actions against storm water facilities in which the permit number was expired and does not exist in the federal data base. The TCEQ completed the ICIS upload of active construction general permits on 09/27/18 and multi-sector general permits on 10/02/18. There was also 1 formal action taken against a facility that did not flow to ICIS. The reason why it did not flow is being researched by our contractor.

5a3 - Number of inspected major facilities - TCEQ has 32 facilities that count towards this measure that are not on the EPA’s list. This is due to the investigations being conducted prior to the updated data flow and an investigation missing the EPA ID. These facilities will be updated to ensure they flow.

5b3 - Number of inspected non-major individual or unpermitted facilities - TCEQ has 13 facilities that count towards this measure that are not on the EPA’s list. This is due to the investigations being conducted prior to the updated data flow, incorrect ID entered, or miss-classified as a major facility. These facilities will be updated to ensure they flow.

5b4 - Number of inspected non-major general permit covered facilities - TCEQ continues to improve the dataflow to ensure that all applicable General Permitted Facilities are properly accounted for. The FFY21 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 - While TCEQ & ICIS-NPDES data flows have been enhanced, internal errors within TCEQ prevent some investigations from flowing. Additionally, ICIS-NPDES restrictions continue to prevent some investigations occurring on the same date for the same facility to flow. Methods to correct these issues continue to be worked on by both TCEQ and EPA. The FFY21 TCEQ data should align more closely with ECHO data next year.