State Comments on Frozen Data - 2022
EPA captures (or "freezes") aggregated state data yearly. These frozen datasets are used by the State Review Framework in their assessment of EPA and state enforcement of the Clean Air Act (CAA), Clean Water Act (CWA), and Resource Conservation and Recovery Act (RCRA).
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.
| State | Media | Comment |
|---|---|---|
| AK | CWA | In June, 2022, Alaska brought a new State database online, requiring multiple data entry for some metrics, and initiating flow for others at different times during the reporting period. The new database also consolidated data from multiple legacy sources, requiring reconciliation of discrepancies in some cases which did not allow Alaska to verify all 2022 data reported in ECHO by the time of data review. In the case of data caveats, efforts to analyze and reconcile data continue with staff and the contractor. Alaska continually trains staff on the use of the new State database as processes are solidified and bugs remedied; internal and external customer support is also provided. Alaska suggests the public contact State staff for assistance where discrepancies exist between data sources. The data is expected to be corrected during the 2023 reporting period, the first full year with the new database. |
| AK | CAA | ADEC previously submitted the ECHO validation on 2/22/22 included Caveat notes and submitted with flags. Since the validation period was extended, we were able to make adjustments in the databases and confirm our records are consistent EPA. Therefore, our previous comments/Caveats from 2/2/22 are now obsolete. |
| Al | CAA | As with every year, EPA's expected ACC records do not account for initial MSOP issuance. An ACC is tied to the issuance of the MSOP, therefore, one is not due until an ACC has been issued AND a year of operation under that permit has occurred. The following is a list of facilities affected by the data error: Kith Kitchens (AL0000000107700037) - the initial MSOP has not yet been issued, the first ACC is not yet due Tyler Union (AL0000000101500091) - the initial MSOP was issued on 2/1/2022, the first ACC will not be due until 4/1/2023 Southeast Forest Products (AL000000010050S014) - the initial MSOP has not yet been issued, the first ACC is not yet due Arrowhead Landfill (AL0000000110500003) - the initial MSOP was issued on 3/3/2023, the first ACC will not be due until 5/3/2024 Shelby County Commission (AL0000000111700068) - the initial MSOP has not yet been issued, the first ACC is not yet due Another issue with the data metrics is that when records are pulled for state only data, the data still included unresolved federal enforcement. This should not be reflected against the state as the state is unable to resolve it. Metric 1a5 lists two facilities with unresolved case files from EPA actions: Constellium (AL0000000103300006) - Unresolved EPA action with an HPV Day Zero of 11/1/2005 TVA (AL0000000107100008) - Unresolved EPA action with an HPV Day Zero of 12/03/1999 |
| AZ | CWA | Metric 1a4 - 2986 CGP not in Echo, 889 MSGP not in Echo and 40 DMGP not in Echo. 1e1 - Facilities with Informal Actions: 3 cases in AZURITE are not present in ECHO, possibly due to not being permitted facilities. City of Glendale West Area Water Reclamation Facility; Case 205188 Section 18 WWTP; Case 404139 Town of Gilbert - WTP; Case 391408 48 cases in AZURITE for general permits are not present in ECHO, possibly due to the permit category not being submitted. 2042 CSC, CASA GRANDE; Case 205059 20TH STREET - OSBORNE, LLC; Case 201255 570 ADIT WASTE/TAILINGS SENATOR HIGHWAY; Case 206942 CANYON TRAILS SOUTH; Case 204136 CENTERRA PHASE 1; Case 207026 CITY OF EL MIRAGE - WWTP; Case 203794 CITY OF PEORIA MS4; Case 201198 CITY OF TUCSON MS4; Case 203306 COCONINO COUNTY - WILLIAMS MAINTENANCE YARD; Case 206161 DAVIS MONTHAN AFB MS4; Case 205369 EAST LOTS 194TH ST AND MEWS; Case 203841 EL OESTE ESTATES; Case 204932 ENTRADA DEL RIO PHASE 4; Case 203852 FRESHLY FOODS; Case 205291 GLENDALE AUTO PARTS; Case 203887 GOLD PARADISE PEAK; Case 207463 GRACE COMMUNITY CHURCH; Case 206160 HOME2 SUITES; Case 204519 IMMEDIA; Case 206739 LIFE STORAGE MARANA; Case 202564 LUXE AT TOSCANA AT DESERT RIDGE; Case 207942 MERCY GILBERT OFFSITES; Case 203755 MISSION RANCH; Case 202259 MOBEST ETHANOL TERMINAL; Case 205248 MOUNTAIN RIDGE VIEWS; Case 203310 MOUNTAIN VIEW RANCH PARCEL B-D; Case 202258 NORTHERN ARIZONA UNIVERSITY MS4; Case 206489 PAGE MUNICIPAL AIRPORT; Case 206691 PARCEL #172-21-039A; Case 205088 PARCEL #304-91-975C; Case 204028 PARCEL AA AT MCCARTNEY CENTER; Case 207531 PARK 52 AT 202; Case 205341 PONDEROSA PARKWAY; Case 208152 QUALITY EMULSIONS LLC; Case 204716 ROYAL PLATING; Case 205869 SAN ARTES; Case 206765 SAN BELLARA; Case 206761 SOUTHERN ARIZONA VA MEDICAL CENTER MS4; Case 208685 STAKER & PARSONS CO; Case 206703 STRAWBERRY RIDGE PROPERTIES LLC; Case 205935 SUNDANCE MINE; Case 207283 THE LANDINGS; Case 204137 TIM'S LANDSCAPE CREATIONS; Case 207524 TOWN ALAMEDA; Case 207428 UNIVERSITY OF ARIZONA MS4; Case 201790 VALLEY VIEW; Case 205616 WEST DIRECT OIL - TUSCON; Case 205067 WILLIAMS YARD; Case 206159 1f1 - Facilities with Formal Actions: 1 case in AZURITE for general permits is not present in ECHO, possibly due to the permit category not being submitted. QUALITY EMULSIONS LLC; Case 204716, Docket D-01-22 1g3 - Facilities with Penalties: Houston Creek Landing WWTP had penalties assessed in a Consent Judgement that became effective September 22, 2022 (Docketed CV2022-12164). Attorney fees paid October 14, 2022. 5b3 - Number of inspected non-major individual or unpermitted facilities. USDOI BR - GLEN CANYON DAM & POWERPLANT AZ0026182 did not show up as inspected in ECHO(ICIS). Working to identify root cause and upload inspections to ICIS for GLEN CANYON DAM & POWERPLANT AZ0026182. 5b4 - Number of inspected non-major general permit covered facilities. Currently, ADEQ is not flowing inspections of non-major general permit covered facilities into ICIS. 7j1 - Number of major and non-major facilities with single-event violations reported in the review year. Currently ADEQ is not flowing single event violations into ICIS. Met with Windsor Solutions 2/15/2023. 7J3 Number of facilities with RNC/Category 2 noncompliance or effluent. single event, schedule violations open during the year is correct except AZ0023558 SRP - Santan Generating Station. Unable to identify why ECHO shows facility in RNC. |
| CT | CAA | Metric 1c1, facilities with a CMS Category of 80% Synthetic Minor that were identified as due for inspection, includes two facilities that were not due or required to be inspected during FFY 2022. The facilities are KING INDUSTRIES, INC. (CT0000000900104223) and SCAPA TAPE NORTH AMERICA (CT0000000900308899) Both facilities were inspected in FFY 2021 under COVID modified inspection guidelines coordinated with EPA and were not due for inspection. The path of data entry for these inspections through ICIS-Air were different than the full compliance evaluation (FCE) pathway for CMS required inspections due to the modified procedures and therefore are still appearing in the CMS as due for inspection. The data entry into ICIS-Air is correct and no change is available to remove these facilities from the count in Metric 1c1. |
| CT | CWA | Metric 1a4 - The number of active NPDES non-major general permits is erroneous. CT verified the registrations for non-Stormwater General Permit types. CT has not entered all Stormwater GP registrants into ICIS. Of the 2405 general permits listed in Metric 1a4, 2322 were for Stormwater GP registrations. The total registrations for Stormwater GPs should be 2,468: 1,662 Industrial and 315 No-exposure certifications; 358 Construction; 1 DOT MS4; and 132 MS4 (expired). CT did not verify if all the Stormwater GPs listed in Metric 1a4 were active in FFY2022 but it is suspected some were not. Note that Stormwater registrations erroneously show a status of expired or administratively continued because ICIS has not yet been updated. CT reissued the Industrial Stormwater GP and the Construction Stormwater GP, and those Master GPs have been updated in ICIS. CT is working on linking active registrations to their respective Master General Permits in ICIS. Metric 5a3 - Number of inspected major facilities. This metric is showing 23 facilities, but the accurate count should be 31. There were 2 additional NPDES Industrial and 6 additional NPDES Municipal desk audits (DSAs) that are not being counted in this metric but were part of CT’s approved Compliance Monitoring Strategies (CMSs). Metric 5b3 - Number of inspected non-major individual or unpermitted facilities. This metric is showing 22 facilities inspected. There was an additional 2 NPDES Municipal DSAs completed as part of the CMS. Metric 5b4 - Number of inspection non-major general permit covered facilities. CT performed 7 MS4 DSAs that were entered into ICIS but were not counted in this metric. US EPA has confirmed that the desk audits for MS4s should have been counted in the inspection metrics, but they were not because of an error in the metric logic. Metric 7j1 - Number of major and non-major facilities with single-event violations reported in the review year. The number of facilities with SEVs is correct. For CT0001341, Pharmacia & Upjohn Company, LLC, the number of SEVs should be 2, not 4. There are 2 SEVs entered in ICIS, but these are repeated on a second date in ECHO. Metric 7j2 - Number of 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 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 the facilities listed, CT did not confirm there are no violations where none are listed. For CT0001341, the number of SEVs should be 2, not 4. For CTRSW0016, the number of E90 violations should be 3, not 4: their aquatic toxicity test of 96% survival of D. Pulex on 3/2022 was not a violation. |
| CT | RCRA | Metric 1b1: A LQG CEI inspection was conducted at Rogers Corporation CTD001141167 in Rogers CT in FY2022 Metric 5b/5b1: A LQG CEI inspection was conducted at Rogers Corporation CTD001141167 in Rogers CT in FY2022 Metric 5d1 5.00E+05: Two VSQG inspections were inspected in FY 2O22. T&M Autobody CTD0059824474 in Uncasville and Apple Oil CTR00521666 in West Haven 5.00E+06: Two out of state transporters were investigated in FY 2022. Precision Industrial Maintenance in Schenectady, NY and liquid Environmental Solutions in Attleboro MA |
| DE | RCRA | Metric 1b1: A LQG CEI inspection was conducted at Rogers Corporation CTD001141167 in Rogers CT in FY2022 Metric 5b/5b1: A LQG CEI inspection was conducted at Rogers Corporation CTD001141167 in Rogers CT in FY2022 Metric 5d1 5.00E+05: Two VSQG inspections were inspected in FY 2O22. T&M Autobody CTD0059824474 in Uncasville and Apple Oil CTR00521666 in West Haven 5.00E+06: Two out of state transporters were investigated in FY 2022. Precision Industrial Maintenance in Schenectady, NY and liquid Environmental Solutions in Attleboro MA |
| DE | RCRA | Element 1b1 - CEI conducted on 4/27/22 at AWSM Solutions (DER000503300) appears in RCRAInfo, but does not appear in drill-down list in ECHO SRF data verification. The correct number of sites with an on-site inspection for this element is 57. Element 1c1 - Violations identified during 4/27/22 CEI at AWSM Solutions (DER000503300) appear in RCRAInfo, but do not appear in drill-down list in ECHO SRF data verification. The correct number of sites with new violations for this element is 40. Elements 1d1 and 1d2 - Letter of Warning for violations identified during 4/27/22 CEI at AWSM Solutions (DER000503300) appears in RCRAInfo, but does not appear in drill-down list in ECHO SRF data verification. The correct number of sites with with informal enforcement actions and the number of informal enforcement actions for these elements is 33. |
| DE | CAA | Metric 1a1 should be 48, Dassault was active major during FFY22. For some reason this facility showing up in Metric 1a4. Metric 1a2 should be 71, First State Investors was SM facility during FFY222. For some reason this facility showing up in Metric 1a4. Metric 1b5 should be 27 state FCEs. Delaware cannot verify EPA inspections, 2 of which show up in this metric total of 29. Metrics 1j1 and 1j2 should each increase by one. City of Dover McKee Road was an active major source during FFY22 for which a TVACC was due and it was received and reviewed during FFY22. |
| DE | CWA | DE0051047 - Working to correct the limit sets in ICIS, this facility does not have any non-compliance during the year. DE0050288 - There are no violations during the year for this facility and I have been unable to clear the non-compliance in ECHO. In ICIS, all quarters are showing as compliant for the review year. |
| FL | CWA | Florida has requested EPA manual overrides for the following data points (facilities/metrics). FLR05F614 A & A AUTO CENTER INC. 7j2 FL0160083 ESTECH, INC - AGRICOLA PLANT 7j3 FL0170909 MILLVILLE AWT FACILITY 7j3 FL0174441 BLACKS FORD WRF 7j3 FLA371912 FULL CIRCLE DAIRY, LLC 7j3 FLG915011 FLL AIRPORT T HYDRANT FUEL SYSTEM POJECT PHASE 1, 2 & 3 7j3 FLR05C066 BLOUNT ISLAND MARINE TERMINAL 7j3 FLR05G880 DAMES POINT MARINE TERMINAL 7j3 FLR05H589 DIVERSIFIED YACHT SERVICES 7j3 FLR05I440 IMPERIAL LIMESTONE MINE 7j3 FL0000051 FLORIDA MINE - TRAIL RIDGE 7j3 FL0020451 ST ANDREWS WWTF 7j3 FL0020532 ORMOND BEACH WWTF 7j3 FL0020541 CAPE CANAVERAL WRF 7j3 FL0021431 EDGEWATER, CITY OF 7j3 FL0026255 HOLLYWOOD SOUTHERN REGIONAL WWTF 7j3 FL0026611 FLAGLER BEACH WWTF 7j3 FL0027669 CHATTAHOOCHEE, CITY OF - WWTP 7j3 FL0027731 BONIFAY, CITY OF - WWTF 7j3 FL0034789 MID-COUNTY WWTP 7j3 FL0035181 WHITEHALL CONDOMINIUM ASSOCIATION, INC 7j3 FL0037966 ORLANDO/IRON BRIDGE REGIONAL WRF 7j3 FL0043923 CHEVRON PRODUCTS CO - PORT EVERGLADES TERMINAL 7j3 FLR05I174 BUILDING BLOCKS, INC 7j2 |
| FL | RCRA | Metric 1a2: Thirty-two of the 440 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 creating a data flag to remove cruise ships from the reporting Metrics. Metric 1a5: Thirty-three of the 361 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 creating a data flag to remove cruise ships from the reporting Metrics. Metric 10b5: An error was noted for Woodfield Distribution LLC (FLR000135863) in SNY evaluation with a timely enforcement report. The last update to ECHO shows the activity as being outside the established 360-day deadline. Our records and documents show that the SNC evaluation was completed prior to the 360-day deadline from day zero. The issue was corrected in our system, but confirmation of a successful correction will not be available until after RCRAInfo communicates with ECHO and after the data lock deadline. |
| GA | CAA | 1b5 and 1b6: Full Compliance Evaluations completed during FFY2022 should be based on the CMS status at the time that the FCE was completed. Several facilities changed classification after the fact and the data is reflecting their current CMS status. 1j2: This metric is poorly defined as it does not match the reality of which facilities are actually required to submit a Title V Annual Compliance Certification. It ignores all the non-major Title V facilities and includes major sources that are not Title V permitted facilities yet while they are still operating under their Construction permit and their initial Title V application is either not due yet or is still under review by the Permitting Program. This metric also seems to ignore its own definition at times. |
| GA | CWA | Metric 1a4: GAEPD has 25 NPDES general pesticide permits that have not flowed to ICIS from our data system. We are working on resolving this issue. Due to the implementation of electronic reporting in NetDMR beginning January 2023, as included in the reissued 2022 Industrial Stormwater General Permit (GAR050000), most industrial stormwater permit renewals that were received are being held from flowing to ICIS/ECHO in order to confirm the coding of the limits and limit sets for accurate data flow to NetDMR. As a result, the majority of permits are showing as expired in ECHO and will continue to until the information flow is completed. This is actively being worked on by EPD and the IT contractors. As of this writing, there are 2,144 Industrial Stormwater (ISW) permits still to be individually approved to restart this data flow. For Construction Stormwater permits, 23,181 NOIs have expired. These NOIs are covered under three general permits, GAR100001, GAR100002, and GAR100003. The permittees did not renew under the reissued permit nor submit a Notice of Termination (NOT). EPD is actively working to remind permittees who no longer need coverage to submit NOTs. Thus these 23,181, should not be included in the total number of general permits (metric 1a4). For Construction Stormwater permits, 30 NOIs have not flowed from our database to ICIS. We are working on resolving these issues. Metric 1e1: Industrial Stormwater had a data entry SOP gap which has been resolved. There are 6 informal actions which have not flowed correctly to ICIS/ECHO. Metric 1f1: ICIS updated to show assessed and collected penalty and is in the ECHO dashboard, however it is not listed on the metric spreadsheet that was downloaded for two Industrial Stormwater sites (GAIS0096 and GAIS13747). Thus, the numbers for the data verification aggregate for this metric do not match. Metric 1g3: ICIS updated to show assessed and collected penalty and is in the ECHO dashboard, however it is not listed on the metric spreadsheet that was downloaded for two Industrial Stormwater sites (GAIS0096 and GAIS13747). Thus, the numbers for the data verification aggregate for this metric do not match. Metric 5a3: GA0035807 completed inspection with reconnaissance with sampling on September 27, 2022. All information is in ICIS for this inspection; however, it does not show up on the ECHO 5a3 metric spreadsheet. This does show up in the ECHO dashboard when you search by facility ID. Metric 5b3: 7 Industrial Stormwater (ISW) evaluations on unpermitted facilities are in ICIS but not in ECHO; 1 (one) unpermitted facility on the list for Industrial Stormwater (ISW) is not an industrial stormwater facility but is in ICIS but not in ECHO. Metric 5b4: There are 98 construction stormwater follow-up inspections in ECHO but are missing from the data verification aggregate, thus affecting the total number of inspections that were completed. There are 11 construction stormwater inspections that are not flowing from our system to ICIS, and we are working on resolving this issue. This will affect the numbers on the data verification aggregate for the SRF metrics. There are 3 construction stormwater evaluations listed in ECHO but are missing from the data verification aggregate, thus affecting the total number of inspections that were completed. 85 Industrial Stormwater evaluations on permitted facilities flowed correctly; 1 (one) is neither in ICIS nor ECHO; 44 are in ICIS but not in ECHO. Metric 7j3: Wastewater Permits: GA0020168 there are no violations listed in ICIS and ECHO for 10/1/2021 to 09/30/2022. However, there is an SEV listed on the ECHO 7j3 metric spreadsheet, this is in error. GA0020974 there are 3 SEV violations in ICIS, did not flow to ECHO. All 3 are spill related. GA0021156 – 9 SEV violations in ICIS and 37 E90/D80 in ICIS, that are not indicated on the 7j3 metric spreadsheet. However, the 9 SEVs do appear to be in ECHO dashboard when you download the data. This is an error on ECHO metric spreadsheet. GA0021814 – 4 SEV violations listed on the 7j3 metric spreadsheet. There are 2 SEVs in ICIS and 2 listed in ECHO dashboard when you download the data. GA0035777 – 6 SEV and 8 E90 violations in ICIS, that are not indicated on the 7j3 metric spreadsheet. However, the 8 E90s do appear to be in ECHO dashboard when you download the data. This is an error on ECHO metric spreadsheet. During the period from October 1, 2021- September 30, 2022, GA0024147 should have a total of 152 SEVs. 1 "Permit Violation- Failure to submit Timely Permit Renewal Application" and 151 "WW SSO- Discharge to Waters" This does not match what is currently in the ECHO report. GA0035807 there are 10 SEVs in ICIS. There are 12 listed on the ECHO on the 7j3 metric spreadsheet. When looked in ECHO dashboard when you download the data two SEVs for November 2022 was listed under the 7-1-2022 to 9-30-2022. The November 2022 should be for the next fiscal year. GA0047759 there are 4 SEVs and 4 E90s listed in ICIS, that are not indicated on the 7j3 metric spreadsheet. However, the 4 SEVs do appear to be in ECHO dashboard when you download the data. This is an error on ECHO metric spreadsheet. Industrial Stormwater permits: Industrial Stormwater analyzed 1,259 automatically generated violations. Some of these were related to data flow issues from GEOS to GAPDES to ICIS and ECHO which occurred prior to the positioning of current staff. The Industrial Stormwater team corrected 915 such flow errors. MS4: Annual Report date received isn’t flowing to ICIS for the following permits, although received by EPD: GAG610015, GAG610002, GAG610033, GAG610062, GAG610064, GAG610065, GAG610082, GAG610097. EPD is continuing to troubleshoot a fix. GI/LID Plan date received isn’t flowing to ICIS for the following permits, although received by EPD: GAG610015, GAG610058, GAG610059, GAG610060 and GAG610097. EPD is continuing to troubleshoot a fix. The annual report submittal date is incorrect in ICIS for permit GAG610020. EPD will work on reflowing the accurate date. GAG610091 has 1 SEV that did not flow to ICIS. EPD will work with our contractor to reflow the appropriate information. GAG610085 has 2 SEVs that did not flow to ICIS. EPD will work with our contractor to reflow the appropriate information. |
| IA | CAA | Ram Development was listed as a minor source subject to enforcement. As noted Ram Development was operating as a Title V Major Facility when enforcement action occurred. Facility has since ceased operation, been marked as permanently closed, and has been removed from the CMS plan. |
| IA | CWA | The Iowa DNR continues to work with EPA and Windsor Solutions to improve the quality of data transmitted to EPA. 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. |
| ID | CAA | METRIC 1a4 - Facility 083-00127 changed from SM80 to B and dropped CMS status on 5/7/2021 (before FF7Y2022). This facility should not be included in this count. Data entered accurately. METRIC 1i7 - There are 29 stack test events entered in ICIS-Air that did not get captured in this metric. METRIC 1j2 - Fiber Care Baths 053-00051 does not yet have its TV permit yet (which is the permit that requires an ACC be completed) and therefore should not be included. METRIC 1e2 - Oak Valley Energy 031-00074 had an NOV issued on 12/16/2021 that is within FFY2022, yet is not captured. Data entered accurately. |
| IN | CAA | The Indiana Department of Environmental Management (IDEM) strives to ensure that CAA Compliance and Enforcement data that are posted to ECHO are timely and accurate, and IDEM is constantly working with the EPA to assure the accuracy of the information in ECHO. During the second half of FFY2022, the Indiana state government had two significant Oracle database server upgrades ongoing that involved and affected IDEM. Databases included in these upgrades are critically important to the ability of IDEM’s Office of Air Quality (OAQ) Compliance and Enforcement (C&E) Branch’s ability to upload data reflected in ECHO. Some data handling procedures, linkages, and mapping had to be modified to work properly with the server changes and affected the ability to upload all data in a timely manner. |
| IN | CWA | IDEM Office of Water Quality strives to ensure that the data posted to ECHO is timely, accurate and complete. Indiana is in the process of transitioning large groups of permits into Master General permit covered categories specifically storm water permits which significantly impacts the overall counts and percentages. IDEM OWQ also continues to work on expanding the data flow from state systems to ICIS-NPDES. |
| KY | CAA | Kentucky has verified the CAA data for FFY2022. Kentucky found that there are still data discrepancies between Kentucky’s TEMPO data base and ICIS-Air, and ICIS-Air and ECHO. Kentucky continues to work closely with U.S. EPA concerning data migration between TEMPO and ICIS-Air, however, data migration between ICIS-Air and ECHO is a U.S. EPA issue. Kentucky has informed U.S. EPA of all of the noted issues. |
| KY | CAA | JFC:The amount listed for Element 5 1h1, $996,037, is inaccurate due to how ICIS/ECHO store and report the data. For Enforcement Action KYJFCA200207975, two facilities under common ownership settled a case under one Order for $481,500. This is reported in ICIS under one order and linked to both facilities. The report in ECHO is displaying it for each facility and counting it twice in this report. |
| LA | CWA | 1f1 - Facilities with Formal Actions is elevated by 13 facilities. This metric looks at the Enforcement Action (EA) information and not the specific Final Order information under the EA. The extra facilities are linked to EA LA-WEAOA1900949 but the specific Final Orders including them were issued outside of the EPA FY2022. 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 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. |
| MA | CAA | Data Caveats for FFY2022 Data Verification - Massachusetts Metric 1a2 - Active Synthetic Minors - Massachusetts has multiple Synthetic Minor Classifications with increasingly lower thresholds. On 2/02/2022, 115 are open facilities with “SM80-R” Classification subject to scheduled inspection. Metric 1a4 - Other Active Facilities on CMS Plan - Several ACMS sources originally targeted for inspection in FFY 2022 were substituted for during the year (closures, etc.) Six ACMS sources targeted in FFY2021 were not removed from the CMS w/ proper backdating and so appeared active on the CMS for FFY 2022. Note to EPA Help Desk on 1/09/2022, remained unresolved. Metric 1b4 – Active Title V Facilities – Three Sources are open but have not yet received OP Permits yet (Bourne, Tanner, Salem Footprint.) Metric 1b5 - Number of CMS Majors - Many of these schedules have been conflated with inspection protocols adopted during COVID. The amended ACMS allowed off-site P CEOFF inspections in lieu of on-site FCE. Several sources are targeted for FCE in FFY2023. Metric 1b6 - CMS 80% Synthetic Minors - Partially conflated with FFY2020 - FFY2021 due to COVID interruptions in inspection cycles and allowed off-site PCEOFF. Metric 1b7 – Other CMS Minors - Partially conflated with FFY2020-FFY2021 due to COVID interruptions in inspection cycles and targets and allowed offsite PCEOFF inspections. Two sources (Salem State OKEEFE Campus and Trelleborg Hudson-Medical) are closed. One source deferred until FFY2023 (Mannheim.) Metric 1c1 - Facilities with an FCE - Per Covid-19 protocols and amended ACMS, ten PCE (offsite) PCEOFF were conducted in lieu of the targeted FCE. Metric 1c2 – Number of FCE - Per Covid-19 protocols and amended ACMS, ten PCE (offsite) were conducted in lieu of the targeted FCE. Metric 1i7 Number of Stack Tests - includes possible duplication of entry for two tests (Vicinity-Kneeland and Tisbury Towing) – on-site presence and report review. Metric 1d1 - Number of Facilities with FRV Identified - Due to end-of-year timing and case development, a number of cases for sources inspected in FFY2021 have FRVs identified in FFY2022, and FFY2022 in FFY2023. Metric 1j2– Number of Facilities with Reviewed TVACC - Since certain subject sources have not received their OPs, this number is less than OP-subject facility list. Element 3 - Violations - A number of FFY2022 inspections have resulted in enforcement actions commencing FFY2023; these appear in that timeframe/report. Element 4 - Enforcement - Historical inspections/violations at targeted FFY2022 facilities have resulted in high level enforcement actions commencing FFY2023; these appear in that timeframe/report. |
| MA | RCRA | Verification by MMH is for RCRAInfo Handler Universe Counts only |
| ME | CAA | 1j1 Pine Tree Landfill submitted an ACC in FY22 for calendar year 2021 because they were a Title V source for a few weeks in Jan 2021. 1j2 Dingley Press should have been on this list since they had an active Title V license in 2021 and did submit an ACC for that year. |
| MI | CAA | In general, the data in the US EPA's FY22 SRF report is consistent with data in the Michigan Air Compliance and Enforcement System (MACES) database except: 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 FY22. Metric 1a5: There were no State lead, minor source, HPV cases in Michigan in FY22. The state count should be zero. Metric 1i7: The total stack test count should be 302. Tests at MI00000000000B7287- Sturgis Municipal Power Plant, MI00000000000P1027 - DDP Specialty Electronic Materials US, MI00000000000N3044 - EMERALD GRAPHICS INC, and MI00000000000N1060 - BASF CORP were not included in the metric. |
| MN | CAA | 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 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. |
| MN | CWA | The Minnesota Pollution Control Agency (MPCA) has made all reasonable efforts 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 the ‘Wastewater Data Browser’ |
| MT | CWA | Cannot verify all in 1A4 metric. THERE ARE 2 STORMWATER CONSTRUCTION AUTHORIZATIONS NOT INCLUDED THAT NEED TO BE ADDED: MTR109768 - SOUTHWEST GA DEVELOPMENT issued 9/30/2022 MTR109815 - STILLWATER COUNTY FAIRGROUNDS issued 9/30/2022 ALL MTR300 AUTHORIZATIONS ARE AN OLD GENERAL PERMIT NUMBER FOR INDUSTRIAL AUTHORIZATIONS WE NOW USE MTR000000, MTR30000 AUTHORIZATIONS ARE NO LONGER USED OR A VALID NUMBER TO USE. |
| NC | CWA | 1a1: North Carolina is working with EPA to correct 1 permit mis-identified as a major in ICIS and 4 permits mis-identified as minors in ICIS; 1a3: North Carolina is working with EPA to correct 1 permit mis-identified as a major in ICIS and 4 permits mis-identified as minors in ICIS. 2 permits in ICIS do not exist in state database. (NCU000107 - BESSEMER CITY PRETREATMENT PGM related to WQCS00107 in the state's data system. NCU011119 Town of Colerain Related to permit WQ0011119 in ICIS.) ; 1b7: ECHO contained one permit that has been revoked by North Carolina. NC is unable to manually terminate NC0086053 permit it ICIS. NCS0000258 - should have been unterminated sometime after 04-13-2021. It was terminated again 09-20-2022. This will be resolved in next year's data pull ; 1b8: ECHO contained one permit that has been revoked by North Carolina. NC is unable to rectify the difference. The North Carolina data system has 26 permits that have permit limits but do not currently upload to ICIS as they have monitoring frequencies less than monthly.; 1g3: one action that will not be resolved at this time NCG07022 / DV-2022-0065. ; 5a3: North Carolina is working with EPA to correct two permits mis-identified as minors in ICIS and one permit mis-identified as a major in ICIS. ; 7j1: One erroneous violation in ICIS |
| ND | CAA | North Dakota recently acquired a new data system that interfaces with EPA’s ICIS-Air. Due to this, the quality of the data and timeliness of uploads to ICIS-Air and the Enforcement and Compliance History Online (ECHO) platform has improved dramatically. However, some staff are still new to the system and learning various operations which has caused some issues. Specifically, due to modifications made to a portion of the system, stack test data was not being reported to ICIS-Air as expected (Metric 1i7 – Number of Stack Tests). This error occurred in 2022 and was not identified until January 2023. Therefore, while the State continued to review stack tests and enter data into the internal data system in a timely manner, the days to report to EPA were shown to be significantly beyond the 120-day expectation for many of the stack tests. |
| NE | CAA | Metric 1a1: Omaha Air Quality Control Jurisdiction: Phillips Manufacturing Co; COMC LLC Headquarters; Exmark Manufacturing Co is a Low Emitter; Metric 1a2: Emerson Municipal Utilities is on Tribal Land and EPA jurisdiction; Constructors Inc and Ready Mix Concrete Company_Portable are in Lincoln Lancaster County Health Department Jurisdiction. Metric 1a4: CAMACO Columbus Manufacturing is a No Permit Required Source and should not be on a CMS plan. Metric 1a5: Neligh Electric Generation, Brehmer Manufacturing Inc, Farmers Cooperative, Omaha Steel Castings Co, and Ord Light and Water Dept do not have unresolved HPVs. Each of these facilities has had historical violations addressed and are determined in compliance in our internal system. Metric 1b4: Omaha Air Quality Control Jurisdiction: Phillips Manufacturing Co; COMC LLC Headquarters Low Emitter: Exmark Manufacturing Co; Global Equipment Company Inc Synthetic Minor: Nebraska City Power Plant No 1; Nebraska City Power Plant No 3 Metric 1b5: Global Equipment Company is a Low Emitter source and an FCE was not completed or due in FFY22 Metric 1b6: Siouxland Ethanol LLC was completed in FFY22 however is a Title V source. Eaton Corporation: The source was classified as a Low Emitter from October 5, 2010 - September 21, 2021. As such, an FCE was not due and not completed in FFY22. Lukjan Great Plains has been inactive since 12/12/2016 Emerson Municipal Utilities is on Tribal Land; EPA Jurisdiction CAMACO Columbus Manufacturing is a No Permit Required Source. An FCE was not completed or due in FFY22. Blue City Light and Water is a No Permit Required Source. An FCE was not completed or due in FFY21. Metric 1j2: Global Equipment Company Inc was not a Title V source in FFY22. The source has been a Low Emitter since 2019. Metric 1d1: A longstanding issue with our IIS system for FRV entry via batching has been identified and NDEE is working in partnership with EPA to correct. FRVs appear to be reporting correctly, however there is still an issue with resolution dates. Metric 1d2: A longstanding issue with our IIS system for FRV entry via batching has been identified and NDEE is working in partnership with EPA to correct. Metric 1e1: A longstanding issue with our IIS system for FRV entry via batching has been identified and NDEE is working in partnership with EPA to correct. Metric 1e2: A longstanding issue with our IIS system for FRV entry via batching has been identified and NDEE is working in partnership with EPA to correct. Metric 1f1: A longstanding issue with our IIS system for HPV entry via batching has been identified and NDEE is working in partnership with EPA to correct. HPVs appear to be reporting correctly, however there is still an issue with resolution dates. Metric 1f2: A longstanding issue with our IIS system for HPV entry via batching has been identified and NDEE is working in partnership with EPA to correct. HPVs appear to be reporting correctly, however there is still an issue with resolution dates. |
| NH | RCRA | Some sites listed as Large Quantity Generators may have ceased operating as a Large Quantity Generator and has not notified the State of New Mexico. Some Large Quantity Generator EPA ID#s may be duplicate facilities. NMED identified one such duplicate facility as EPA ID#s NMR000028951 and NMD069892594, which are at the same physical address. |
| NM | CAA | metric 1a2 Number of Active Synthetic Minor Facilities: During FY2022 Data Verification, the New Mexico Environment Department – Air Quality Bureau (NMED-AQB) determined that the number of Active Synthetic Minor facilities in ECHO is not correct. NMED-AQB is still in the process of correcting this metric. Metric 1b5: New Mexico is conducting ongoing review and research concerning resolution of errors resulting in incorrect Full Compliance Evaluation (FCE) due dates. New Mexico will calculate next FCE due dates and frequencies using the applicable Compliance Monitoring Strategy (CMS) schedule based on the most recent FCE date and current facility classification until the problem is resolved. Metric 1b6: New Mexico is conducting ongoing review and research concerning resolution of errors resulting in incorrect FCE due dates. New Mexico will calculate FCE due dates and frequencies using the applicable CMS schedule based on the most recent FCE date and current facility classification until the problem is resolved. Metric 1j2: Metric 1j2 data fields “TVACC_PLANNED_DATE” and “TVACC_PLANNED_FY” do not appear to be updating correctly and may include incorrect dates or no data. |
| OH | CAA | Metric 1a1 Number of Active Majors Six facilities incorrectly categorized as Major by USEPA in ICIS Air. Ohio is unable to correct this in ICIS Air. 68 facilities are included in the metrics list that are not major facilities nor were they major in FFY 2022. They are correctly categorized in the metrics list and in ICIS Air. Recent updates on 2/24/23 and 3/3/23 may have incorrectly caused it to appear that the facilities changed categories since the end of FFY 2023. Metric 1a2 Number of Active Synthetic Minors 96 facilities are included in the metrics list that are not SMTV facilities nor were they SMTV in FFY 2022. They are correctly categorized in the metrics list and in ICIS Air. Recent updates on 2/24/23 and 3/3/23 may have incorrectly caused it to appear that the facilities changed categories since the end of FFY 2023. Metric 1b4 Number of Active Title V Facilities See Metric 1a1. Seven facilities are incorrectly included in the metrics list but are categorized correctly both on the list and ICIS Air. Metric 1d1 Number of Facilities with an FRV Identified (Facility Count) Five facilities are incorrectly on the metrics list due to an incorrect FRV determination date in ICIS Air that was uploaded to ECHO. This is a known error. Metric 1d2 Number of Facilities with an FRV Identified (Facility Count) 26 facilities are incorrectly on the metrics list due to an incorrect FRV determination date in ICIS Air that was uploaded to ECHO. This is a known error. Metric 1e1 Number of Informal Enforcement Actions (Activity Count) Two facilities are incorrectly on list; correct in ICIS Air and metrics list. Metric 1e2 Number of Facilities with an Informal Enforcement Action (Facility Count) Three facilities are incorrectly on list; correct in ICIS Air and metrics list. |
| OK | CWA | Oklahoma Department of Environmental Quality Water Quality Division’s Federal Fiscal Year 2022 (10/01/2021-09/30/2022) State Review Framework The Oklahoma Department of Environmental Quality (Oklahoma DEQ) Water Quality Division has completed their data metric review of the CWA data on the State Review Framework (SRF) for Federal Fiscal Year (FFY) 2022. The following caveats and revision in metric values need to be added to Oklahoma DEQ-Water Quality Division’s FFY2022 SRF: 1. Oklahoma DEQ does not code into EPA’s ICIS-NPDES Production database the Construction Stormwater, Industrial Stormwater, General Total Retention Lagoons, State, or Unpermitted facility data (metric 1a4), inspections (metric 5b2 & 5b4), and enforcement actions (metric 7j1-7j3, 7k1, 1E1, & 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, State, or General Facilities. Major, Minor, and General discharge permits have their CEI, CSI, PCI, and Audit inspections coded into ICIS-NPDES. 4. Metric 1a3 Number of Active Non-Majors with Individual Permits revised value is 332. Forgan WWT (OK0066666) does not have a discharge permit. The facility is a total retention system, which was 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 system required data element). 5. Metric 1a4 Number of Active Non-Majors with General Permits revised value is 5212. Stormwater-Construction & Stormwater- Industrial permits are maintained in the Oklahoma DEQ's state database. During this period, there were 1683 Stormwater-Industrial and 3323 Stormwater-Construction permits. Oklahoma DEQ has permitted 206 General Discharge permits. The Oklahoma Department of Agriculture, Food & Forestry (ODAFF) is delegated to permit the general CAFO (OKG01) permits on the list. 6. Metric 1E1 Facilities with Informal Actions is revised to 56. There were 36 Majors, 18 Minors, 1 Unpermitted, and 1 General Discharge that received an Informal enforcement action. 7. Metric 1f1 Facilities with Formal Actions is revised to 199. The following number of facilities by Facility Type had a Formal Action: Major- 35 Minor- 85 Unpermitted- 16 General Discharge- 20 General Total Retention Lagoon (TRL)- 6 Industrial User- 4 Construction Stormwater- 5 MS4 Phase II-1 Industrial Stormwater -19 State- 8 8. Metric 1g3 Facilities with Penalties is revised to 22. In addition to what is listed for the metric, 1 penalty was given to Industrial Stormwater, 3 penalties to Unpermitted, 1 penalty to Construction Stormwater, and 2 penalties were General Total Retention Lagoons (TRL) facilities. Construction Stormwater, Industrial Stormwater, Unpermitted, and the General TRL facilities are maintained in a state database. 9. Metric 7j1 Number of major and non-major NPDES facilities with single event violations is revised to 45. Stormwater single event violations are maintained in a state database. 10. Metric 7j2 Number of Active facilities with SNC/Category 1 noncompliance is revised to 395 out of a permitted universe of 5212. Industrial Stormwater has 265 Industrial Stormwater facilities that were either greater than 30 days late submitting their DMRs/Annual Reports or their DMRs/Annual Report 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 during the year is 277 out of a permitted universe of 5212. There were 54 Stormwater facilities that were less than 30 days late in submitting their DMRs/Annual reports that were not entered into ICIS-NPDES, but were maintained a state database. 12. Metric 7k1 Major and non-major facilities in noncompliance revised value count is 672 out a universe of 5212 permitted universe. Major and non-major facilities in noncompliance revised percentage is 12.8%. 13. Metric 8a3 Percentage of active major and non-major facilities in SNC Category 1 noncompliance during the reporting year is 7.58%. 14. Metric 5a1 & 5a3 Inspection coverage of NPDES Majors is 95. A total of 95 facilities had a CEI inspection or a Routine inspection. 15. Metric 5b1 Inspection Coverage NPDES Non-Major individual facilities is 184. A total of 184 Non-Major NPDES Individual facilities had a CEI inspection or a Routine inspection. 16. Metric 5b3 Inspection Coverage-NPDES Non-Major individual or unpermitted facilities is 184 . 17. Metric 5b2 & 5b4 Inspection Coverage-NPDES Non-Majors with General Permits is revised to 1168. A total of 845 Stormwater -Construction, 231 Stormwater-Industrial, and 92 General NPDES Discharge facilities were inspected. General discharge permit CEIs are coded into ICIS-NPDES, but Stormwater routine inspections are maintained in the state's database. |
| OR | CWA | The following caveats apply to the FY2022 ICIS Frozen Dataset with respect to individual State Review Framework Metrics. Incorrect data will be remedied by March 30, 2023, in ICIS Production. If you have questions about the caveats listed below, please contact Martina Frey (martina.frey@deq.oregon.gov) or Ian Garner (ian.garner@deq.oregon.gov). Metric 1A4 - Number of active NPDES non-major general permits. A total of 710 general permit covered facilities (GPCFs) are not included in the FFY22 frozen dataset, as follows: Master General Permit ORG250100 Oregon Discharge Permit for Cooling Water/Heat Pumps (100-J) - one GPCF missing (ORG253619 Isovolta Inc.); Master General Permit ORG520900 Oregon Discharge Permit for Seafood Processing (900-J) - two GPCFs missing (ORG523527 Local Ocean Seafood, ORG523526 Pacific Seafood - Brookings); Master General Permit ORG614000 Oregon Stormwater Discharge Permit (4000) - 22 GPCFs missing (request list from data stewards); Master General Permit ORG690700 Oregon Discharge Permit for Suction Dredge Mining (700-PM) - 55 GPCFs missing (request list from data stewards); Master General Permit ORG87000E Oregon Discharge Permit for Pesticide Use in Irrigation Systems (2000-J) - three GPCFs missing (ORG87J004 Devils Lake Water Improvement District, ORG87J005 Langell Valley Irrigation District, ORG87 J003 Ridgeview Irrigation District); Master General Permit ORG872300 Oregon Discharge Permit for Pesticide Application (2300-A) - one GPCF missing (ORG870069 Willamette Riverkeeper); Master General Permit ORG6112CA Oregon Stormwater Discharge Permit (1200-CA) - 19 GPCFs missing (request list from data stewards); Master General Permit ORG6112Z0 Oregon Stormwater Discharge Permit (1200-Z) - four GPCFs missing (ORRZ00018 City of Hood River Wastewater Treatment Plant; ORRZ00019 Tri Lett Industries Inc; ORRZ00020 Standard Steel; ORRZ00022 Manzanita Transfer Station); Master General Permit ORR100000 Oregon Stormwater Discharge Permit (1200-C) - 603 GPCFs missing (request list from data stewards). Metric 5a3 - Number of inspected major facilities. Two inspections in state databases for FFY 2022 are not included in the FFY22 ICIS frozen dataset, as follows: OR0020346 Sweet Home STP on 9/9/2022 and OR0023876 South Suburban STP on 9/21/2022. Also, the inspection for OR0020788 Hood River STP on 5/3/2022 was a pretreatment audit; it was entered in the frozen database as a core program compliance inspection. Ten inspections have an incorrect actual end date. Metric 5b4 - Number of inspected non-major general permit covered facilities. Five stormwater non-construction inspections were included in the frozen dataset that are not in state databases, as follows: ORR221262 Santiam Lumber on 12/16/2021, ORR237043 Ultimate RB, Inc. on 12/14/2021, ORR237045 Wilbur-Ellis Company LLC, Woodburn on 12/15/2021, ORR603637 Cherry City Metals, LLC on 12/13/2021, ORR607180 Rick Franklin Corporation on 12/17/2021. Two stormwater construction inspections were not included in the frozen dataset, as follows: ORG707001 Mt. Hood Forest Products on 9/15/2022, ORG707005 Prairie Wood Products (ABN) on 6/15/2022. 57 stormwater non-construction inspections were not included in the frozen dataset (request list from data stewards). |
| PA | CWA | Nearly all of Pennsylvania’s NPDES permitted facilities required to submit electronic Discharge Monitoring Reports (eDMR) are using PADEP’s eDMR data system. PADEP continues to work with EPA to address complications in uploading portions of the data into EPA’s Integrated Compliance Information System (ICIS). NPDES permits starting with PAC (general construction stormwater) are only tracked in ICIS, not state systems. PAD (individual construction stormwater) permits are only beginning to receive attention regarding uploading data. PADEP’s data system does not differentiate between SNC/Category 1 and RNC/Category 2 noncompliance (categories 7j2 and 7j3). Instead, PADEP utilizes the QNCR and ECHO dashboards to closely track and monitor these facilities. Also, ICIS effluent violations will only exist in the state database if the violation is manually created in PADEP’s databases. They are not automatically generated. 1a2 Number of active NPDES major general permits: PADEP doesn't have major general permits. 1a3 Number of active NPDES non-major individual permits: PADEP’s number includes 895 Chapter 102 permits not in ICIS. 1b7 Number of active NPDES individual DMR filers: PADEP's number includes 3 permits in ICIS but not counted by the ECHO metric: PA0021709, PAS202211 and PAS202210. 1b8 Number of active NPDES individual DMR filers with permit limits in ICIS: PADEP has recently uploaded limits for a number of permits that previously didn’t have limits in ICIS. PADEP is very close to the goal of having all limits for DMR filers in ICIS. 1e1 Facilities with Informal Actions: PADEP's number includes 6 enforcements with known upload issues. 1g3 Facilities with Penalties: PADEP's number includes 1 penalty with known upload issues and 1 penalty in in ICIS but not counted by the ECHO metric: penalty for permit PA0027430. 5a3 Number of inspected major facilities: PADEP's number includes 45 inspections with known upload issues. 5b3 Number of inspected non-major individual or unpermitted facilities: PADEP's number includes 31 inspections with known upload issues and 1 just uploaded. 5b4 Number of inspected non-major general permit covered facilities: PADEP's number includes 4 inspections with known upload issues and 1 just uploaded. 7j1 Number of major and non-major facilities with single-event violations (SEVs) reported in the review year: PADEP has completed remapping PA SEV codes to current EPA SEV codes and is now uploading violations and enforcement according to the new mapping. However, ICIS only allows one SEV type per day so not all SEVs can be uploaded to ICIS. |
| PA | CAA | There are issues with the Inspection Metrics as well (1C1, 1C2, 1I7, 1J1 and 1J2), but there are too many to list. PA DEP has identified a potential mapping issue that may be causing these issues and is working to resolve it ASAP. |
| SC | CAA | 1a4: SC00020600199 – Siegwerk USA – Facility was SM-80 that closed 1/1/2016 SC00021400094 – Pinewood Site Custodial Trust – Pinewood Site was SM-80 that closed prior to 2002 1j1: SC00000400013 – Flexible Technologies Inc - TVACC received 1/27/2022, review complete 3/15/2022 SC00003600002 – USMC TC Parris Is - TVACC received 10/28/2021, review complete 12/17/2021 (now SM-80) SC00003600031 – Ulmer Brothers - TVACC received 8/23/2022, review complete 12/22/2022 (revisions required) SC00004600003 – Devro Inc – TVACC received 1/24/2022, review complete 2/23/2022 SC00004600003 – Hatteras Pools – TVACC received 5/16/2022, review complete 10/14/2022 (revisions required) SC00006400009 – GAF Materials Corporation - TVACC received 8/12/2022, review complete 11/16/2022 (revisions required) SC00011400031 – 3V Sigma USA Inc – TVACC received 2/14/2022, review complete n/a (review cannot be complete at this time, pending EPA decision) SC00017800045 – MacLean Power Systems – Newberry Plant – TVACC received 8/9/2022, review complete 10/21/2022 (revisions required) SC00019000286 – Fairfield Road Recycling – TVACC received 9/2/2022, review complete 10/21/2022 (revisions required) SC00024400005 – New-Indy Catawba LLC – TVACC received 8/12/2022, review complete 10/13/2022 (revisions required, held up pending EPA decision) 1e1 SC00021400147 – Continental Tires The Americas LLC – Duplicate informal action for uploading two day zeros, only one NOV mailed 1h1 SC00021400097 – WCC of Mayesville – Penalty was 5682.44 instead of 7000 (ICIS was updated, but SC database refreshed the update) |
| SD | CWA | 1. Any metric that has any SDPG#'s shall be removed from the count as these are Pretreatment metal finisher general permit covered facilities and the logic cannot remove them. 2. Stormwater Construction general permit covered facilities are not reflected in 1e1, 7j1, 7j2, 7j3 as these do not flow to ICIS yet. Please contact Stormwater Team Leader at (605) 362-3543 with any questions related to the Stormwater numbers. |
| TX | CAA | CAA Metric ID - Metric Name - Comments for ECHO (FFY22 CAVEAT) 1a1 - Number of Active Majors - ECHO shows 1,609 facilities as active that have voided permits. TCEQ is working to correct the status. 1a2 - Number of Active Synthetic Minors - TCEQ does not have a synthetic minor program. 1a3 - Number of Active Minors Subject to NESHAP Part 61 - TCEQ does not report the number of active minor facilities subject to the NESHAP program. 1a4 - Number of Active CMS Minors - TCEQ does not report the number of Active CMS Minors. 1a5 - Number of HPV Minors - TCEQ only reports HPV for major sources. 1a6 - Number of Minors Subject to Formal Enforcement - TCEQ only reports the number of Majors Subject to Formal Enforcement 1b4 - Number of Active Title V Facilities - TCEQ only reports Title V Majors. ECHO shows 994 facilities as active that have voided permits. TCEQ is working to correct the status. 1b5 - Number of CMS Majors - ECHO shows 97 facilities as having active permits where the permits have expired or been voided. TCEQ is working to correct the status. 1b7 - Number of Other CMS Minors - TCEQ does not report the number of Other CMS Minors. 1c1 - Number of Facilities with an FCE (Facility Count) - ECHO shows two facilities that are currently Minor Sources and should not be included in this measure. TCEQ is working to correct the status. 1c2 - Number of FCEs (Activity Count) - ECHO shows 16 FCEs at facilities where the permits have expired or been voided. TCEQ is working to correct the status. 1d1 - Number of Facilities with an FRV Identified (Facility Count) - TCEQ has identified 57 facilities with an FRV that were not reported to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1d2 - Number of Case Files with an FRV Identified (Activity Count) - TCEQ has identified 46 Case Files with an FRV that were not reported to ECHO due to limitations in data flow. TCEQ is working to correct the data flow. 1f1 - Number of Case Files with an HPV Identified (Activity Count) - TCEQ has identified 26 Case Files with an HPV that were not reported to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1f2 - Number of Facilities with an HPV Identified (Facility Count) - TCEQ has identified 23 Federally Reportable facilities with an HPV Day zero date that occurred during the federal fiscal year that were not reported to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1g1 - Number of Formal Enforcement Actions (Activity Count) - TCEQ has identified 93 Formal Enforcement Actions that were not reported to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1g2 - Number of Facilities with a Formal Enforcement Action (Facility Count) - TCEQ has identified 84 Facilities with Formal Enforcement Actions that were not reported to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1h1 - Total Amount of Assessed Penalties - TCEQ had a total amount of Assessed Penalties of $10,888,754. The difference of $4,771,003 is due to limitations in the data flow. TCEQ is working to correct the data flow. 1h2 - Number of Formal Enforcement Actions with an Assessed Penalty - TCEQ has identified 94 Formal Enforcement Actions with an Assessed Penalty that were not reported to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1i7 - Number of Stack Tests that occurred - Two stack tests were not sent to ECHO due to conflicts with multiple AFS numbers at a single site. 1j1 - Number of Facilities with a Reviewed TVACC - TCEQ has identified 1,855 additional facilities with a Reviewed TVACC that were not sent to ECHO due to limitations in the data flow. TCEQ is working to correct the data flow. 1j2 - Number of Facilities with TVACC Due - TCEQ has identified 24 records that were not sent to ECHO due to limitations with the data flow. TCEQ is working to correct the data flow. |
| TX | CWA | 1a1 - Number of active NPDES major individual permits - EPA’s count includes 16 major individual permits that were inactive because they were either expired or terminated. In addition, there are two permit numbers associated with the City of Houston Sims Bayou WWTP (South and North) which will be combined. TX0105058 (associated with Sims Bayou South WWTP) will be terminated once TX0062201 is issued. This application is pending with EPA. 1a3 - Number of active NPDES non-major individual permits - EPA’s count includes 327 non-major individual permits that were inactive because they were either expired or terminated. 1a4 - Number of active NPDES non-major general permits - EPA’s count includes 891 non-major general permits that were inactive because they were either expired or terminated. 1b7 - Number of active NPDES individual DMR filers - EPA’s count includes 8 individual permits that were inactive because they were either expired or terminated. In addition, there are two permit numbers associated with the City of Houston Sims Bayou WWTP (South and North) which will be combined. TX0105058 (associated with Sims Bayou South WWTP) will be terminated once TX0062201 is issued. This application is pending with EPA. 1b8 - Number of active NPDES individual DMR filers with permit limits in ICIS - TCEQ records reflect 2,611 DMR filers with permit limits. EPAs count of 2,620 includes 9 permits falling outside of the fiscal year 2022 date range. These permits are either in Expired or Terminated status in both TCEQ database and ICIS. EPA ID TX0105058 and TX0062201 are associated the City of Houston Sims Bayou WWTP (South and North portion, respectively), which were still under EPA delegation upon initial TPDES permit issuance by TCEQ. TX0105058 (associated with the Sims Bayou South WWTP) will be terminated once TX0062201 is issued. TCEQ does not know the issuance date as this application is still pending at EPA. 1f1 - Number of major and non-major facilities with formal enforcement actions concluded during the review year - The TCEQ issued formal enforcement actions against 7 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were formal actions issued against 5 construction general permits (TXR150025376, TXR15347A, TXR15751H, TXR15823G, TXR15HF90) with expired or terminated permit numbers were expired or terminated. There were formal actions issued against 2 (MSGP) Multi-sector General permits (TXR05BE46, TXR05X012) with expired permit numbers. 1g3 - Number of major and non-major facilities with penalties assessed during the review year - The TCEQ issued formal enforcement actions against 7 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were formal actions issued against 5 construction general permits (TXR150025376, TXR15347A, TXR15751H, TXR15823G, TXR15HF90) with expired or terminated permit numbers were expired or terminated. There were formal actions issued against 2 (MSGP) Multi-sector General permits (TXR05BE46, TXR05X012) with expired permit numbers. 5a3 - Number of inspected major facilities - Certain inspection activities for major facilities were not sent to ECHO due to limitations in the data mapping. 5b3 - Number of inspected non-major individual or unpermitted facilities - TCEQ had inspections for 91 non-major facilities that were not sent to ECHO due to limitations in the data mapping. 5b4 - Number of inspected non-major general permit covered facilities - TCEQ had 130 inspections for non-major facilities that were not sent to ECHO due to internal data errors, expired or terminated permits, or limitations in the data mapping. 7j1 - Number of major and non-major facilities with single-event violations reported in the review year - TCEQ had 160 major and non-major facilities with single event violations that were not sent to ECHO due to limitations in the data mapping. In addition, Sanitary Sewer Overflow (SSO) discharge information does not flow to ECHO. This information will flow to ECHO once EPA's NetSSO tool is implemented in Texas. |
| TX | RCRA | 1a1 - Number of operating TSDFs - ECHO data includes one facility that does not have any operating units and one facility that is a duplicate. 1a2 - Number of active LQGs - TCEQ’s total number of active LQGs is based on the 2019 BR LQGs. 1a5 - Number of BR LQGs - TCEQ’s total number of BR LQG's is based on the 2019 BR LQGs. 1b1 - Number of sites with on-site inspections - TCEQ has identified 29 facilities with on-site inspections that had errors or were not required to obtain an EPA ID and have not yet been uploaded into RCRAInfo. ECHO data included six facilities with a non-hazardous waste activity code that should not be included. 1c1 - Number of sites with new violations during review year - TCEQ has identified 11 facilities with new violations during the review year that had errors or were not required to obtain an EPA ID and have not yet been uploaded into RCRAInfo. ECHO data included one facility with a non-hazardous waste activity code that should not be included. 1c2 - Number of sites in violation at any time during the review year regardless of determination date - TCEQ has an approved alternative CMS that allows for the inspection of Small Quantity Generator, Conditionally Exempt Small Quantity Generator, Transporters, Non-Notifiers and Other RCRA Handlers to meet the Large Quantity Generator commitment. TCEQ data includes 176 sites with new violations cited during the review period and an additional 141 facilities which have or had outstanding violations cited prior to the review period. This brought the total number of facilities to 317. This includes 15 facilities that had errors or were not required to obtain an EPA ID and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads. The ECHO data includes two facilities with IHWOTH61 activity code which is a Non-hazardous Waste Code and should not be in this data. The true EPA count should be 302. 1d1 - Number of sites with informal enforcement actions - TCEQ has identified 24 facilities with informal enforcement actions during the review year that had errors or were not required to obtain an EPA ID and have not yet been uploaded into RCRAInfo. ECHO data included one facility with a non-hazardous waste activity code that should not be included. 1d2 - Number of informal enforcement actions - TCEQ has identified 22 facilities with informal enforcement actions that had errors or were not required to obtain an EPA ID and have not yet been uploaded into RCRAInfo. ECHO data included one facility with a non-hazardous waste activity code that should not be included. 1f1 - Number of sites with formal enforcement actions - TCEQ has identified 27 sites with formal enforcement 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. 1f2 - Number of formal enforcement actions - TCEQ has identified 30 formal enforcement 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 - TCEQ identified $659,803 in final penalties that could not be uploaded to RCRAInfo due to ongoing data flow issues or the facility not being required to have an EPA ID |
| UT | CWA | 1a1 Six permits are administratively continued that are effective. Delay in reissuance due to staff turnover. One permit (UT0000051) will not reissue a pending permit in ICIS without an error code. Error code was not resolved prior to data freeze. 1b8 One facility (UT0025755) has active permit coverage but has been idle (no discharge) since 2015. As they are not currently discharging, no limit set has been entered for this permit. 5b4 Three permit inspections not counted (UTR261515, UTR001057, UTR001058) are inspections linked to the facility as ICIS has continuing error where the permit status will not finish reissuance. |
| UT | RCRA | UTR000017640 - Hill Brothers Chemical - Rowley added in ICIS under RCRAInfo ID, but not showing up on the list for on-site inspections. Should be 5 on-site inspections total. |
| VA | CWA | 1a1 - VA0092975 (VIRGINIA DEPARTMENT OF TRANSPORTATION MS4) is stored in ICIS-NPDES and should have been included and counted. 1a4 - Storm Water Construction GP (SWC, VAR10xxxx) is not batch loaded into ICIS at this time, information listed for SRF FY22 is only a small portion of the SWC universe. |
| VA | RCRA | The items noted as caveats on the Data Verification page are due to a difference in the way EPA counts the metrics and the way VDEQ counts them. The data itself is not in error. For the Data Metric Analysis page, VDEQ would like to add these comments: For Metric 5a, Two-Year inspection coverage for TSDFs appears low because EPA Region 3 agreed to inspection some of the TSDFs that VA could not inspect. For Metric 5b, EPA counted 35 LQGs inspected, but DEQ counted 49: 7 were LQG before FY22/on FY22 inspection planning list for LQG's to be inspected; 6 were NRR/OCM inspections not counted by EPA. 49/256 = 19.14%. For Metric 5b1, EPA counted 32 LQGs inspected, but DEQ counted 49: 7 were LQG before FY22/on FY22 inspection planning list for LQG's to be inspected; 6 were NRR/OCM inspections not counted by EPA. 49/271 = 18.08%. Regarding the number of LQGs inspected, VDEQ has agreement with EPA Region 3 to inspect extra SQGs as part of our Alternate CMS (Compliance Monitoring Strategy). For Metric 2a, VDEQ has been working to close out the long-standing secondary violators (RTC violations where possible and close out enforcement cases); the current count is much lower now. For Metric 7b, the 161 count does not include but 13 facilities not Extracted to Public, and VDEQ's universe count is 297 (see Metric #1b1). 174/297 = 58.58%. |
| VT | RCRA | Number of sites with informal enforcement actions (Metric ID 1d1) and number of informal enforcement actions (Metric ID Id2) could not be verified due to recent additions to RCRA Info. |
| WA | CAA | My review and data verification is for the sources in the Eastern Region only. This is a subset of the sources in Washington State jurisdiction. Title V sources include: KINROSS GOLD CORP - Echo Bay PONDERAY NEWSPRINT CO BOISE CASCADE - ARDEN LUMBER BOISE CASCADE PLYWD BOISE CASCADE LUMBER VAAGEN BROS LUMBER AVISTA (KFGS) GAS TRANSMISSION NORTHWEST #8 GAS TRANSMISSION NORTHWEST #7 GUY BENNETT LUMBER D&L FOUNDARY & SUPPLY INC Synthetic Minor sources include: OATH HOLDINGS INCORPORATED DATA CENTER J R SIMPLOT MCCAIN FOODS USA TIDEWATER TERMINAL ANDEAVOR LOGISTICS OPERATIONS LAMB WESTON LAMB WESTON J R SIMPLOT BASIC AMERICAN FOODS LAMB WESTON REC SOLAR GRADE SILICON, LLC; TEREX/GENIE INDUSTRIES SGL COMPOSITES LLC COLUMBIA GRAIN |
| WA | CWA | For the 2022 SRF year, Ecology worked with EPA and Windsor Solutions to fix the dataflow from Ecology’s NPDES database (PARIS) to ECHO. Deficiencies in the dataflow have been fixed to the point that data is now regularly flowing to ICIS/ECHO once again. There are a few remaining inconsistencies concerning the measures related to Violations and Ecology has fixes pending for these issues. A majority of the violation inconsistency should be resolved by 4/1/2023. |
| WI | CAA | 1a2 Number of Active SMs: WI0000005505500005 Aztalan Bio is an active SM80 and should be in 1a2. WI0000005500900012 DE PERE FOUNDRY INC is an active SM80 and should be in 1a2. WI0000005500920810 GREEN BAY PACKAGING INC -FOLDING CARTON DIV is an active SM80 and should be in 1a2. WI0000005509500019 AMERY TECHNICAL PRODUCTS INC (AMTEC) is an active SM80 and should be in 1a2. 1b6 Number of CMS 80% Synthetic Minors: WI0000005510127697 REAL ALLOY RECYCLING INC - RACINE PLANT – closed/end dated April 2018 and should be removed from 1b6. 1b7 Number of Other CMS Minors: WI0000005510515697 THE DELONG CO became SM 11/2018, so it is non-CMS and should be removed from 1b7. WI0000005507308998 JARP INDUSTRIES INC became SM in 11/2019, so it is non-CMS and should be removed from 1b7. WI0000005500900038 THE C A LAWTON CO became SM 5/2021, so it is non-CMS and should be removed from 1b7. 1j2 Number of Facilities with TVACC Due: WI0000005510128533 SIO does not currently have an issued Title V permit requiring a TVACC be submitted. This facility should not be included in 1j2 until the Title V permit is issued. WI0000005513920337 Amcor Packaging has a 2023 date when this metric is looking through 9/30/2022. The date is outside of the metric's window. |
| WV | CWA | Division of Water and Waste Management Element 1 – Data Metric 1a4 There were 9,982 general permit registrations during the 2022 fiscal year. The 60 permit difference seems to come from the timing of issuance/closure of some of the general permits in the 2022 fiscal year. Metric 1f1 Unable to enter facility with formal enforcement action: 1 Element 2 - Inspections Metric 5b2 Unable to upload inspections of non-majors with general permits: 3 Element 3 - Violations Metric 7j2, 7j3, 7k1, and 8a3: 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 the ICIS system is converted into the ECHO system. This also resulted in inaccurate SNC/Category 1 and RNC numbers. WVDEP continues to identify and address issues leading to inaccurate SNC/Category 1 and RNC numbers/rates showing in ECHO. 2. WVDEP continues to address violations through formal enforcement when necessary, however, there are continued data issues with violations linked to orders not resolving in ICIS. In addition, new violations that are resolved through ongoing enforcement must be manually linked to the enforcement action as they occur. This manual linking is a cumbersome process that likely contributes to an artificially elevated noncompliance rate. Division of Mining and Reclamation Hydrologic Protection Unit Element 1 - Data Metrics 1e1, 1f1, and 1g3 WVDEP DMR has developed a computer function to allow the uploading of Formal Enforcement Actions to include penalties. Formal Enforcement Action data has begun to be placed in ICIS. WVDEP continues to identify and address issues leading to inaccurate SNC/Category 1 and RNC numbers/rates showing in ECHO. After this function has been proved the addition of Informal Enforcement Actions will be developed and tested. Element 3 - Violations Metric 7j2, 7j3, and 7k1 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. WVDEP DMR has recently been able to correct many instances where false SNC/Category 1 violations were shown for DMR Nonsubmittal. We are continuing to make corrections where they are identified. 2. 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 was 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. |
| WY | CWA | Metric 1f1: 3 formal actions were taken in FY22 but none have been resolved as of 1/10/23. Metric 5b3: WY records indicate 188 completed inspections for FY22. |