State Comments on Frozen Data - 2023
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 on the State Comments on Frozen Data page, where they are 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 | CAA | discrepancies with 1C1 and 1I7 Data element 2 section |
| 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: Alabama Pellets LLC (AL0000000109100020 - the initial MSOP has not yet been issued, the first ACC is not yet due), Southeast Forest Products Manufacturing LLC (AL000000010050S014 - the initial MSOP has not yet been issued, the first ACC is not yet due), Shelby County Commission (AL0000000111700068 - the initial MSOP has not yet been issued, the first ACC in not yet due), Kith Kitchens (AL0000000107700037 - the initial MSOP was issued on 6/1/2023, the first ACC is not due until 7/31/2024), Tyler Union Foundry Company (AL0000000101500091 - the initial MSOP was issued on 12/1/2022, the first ACC was not due until 1/30/2024), and Arrowhead Landfill (AL0000000110500003 -the initial MSOP was issued 3/3/2023, the first ACC is not due until 5/2/2024). Additionally, we saw several instances where an ACC review date fell in a different FY than the ACC due date, giving the illusion that an ACC had not been correctly accounted for even though reports were appropriately submitted and reviewed. |
| AZ | CAA | The following data point should have appeared in metric 1b6, AIRÂ AZ000196006 had an FCE on 10/25/22. The following facilities did not display ICIS data entry of TVACC entry, AIRÂ AZ00000004015Z2624 and AZ000232186. Metric 1j1 should reflect 57, a technical error could not tie the reviewed TVACC with the number of TVACC submitted in FY23, all TVACC entered in FY23 have been reviewed. |
| AZ | CWA | Element 1 - Data Metric 1a1 – Number of active NPDES major individual permits. - All permits are flowing to ICIS. 69 is correct. Metric 1a2 - Number of active NPDES major general permits. 0 is correct. Metric 1a3 – Number of active NPDES non-major individual permits. Houston Creek Landing AZ0025305 current permit not in ICIS. Metric 1a4 - Number of active NPDES non-major general permits - 6013 is correct. Metric 1b7 - Number of active NPDES individual l filers. AZ0025305 Houston Creek Landing WWTP. Currently working on issue to flow new permit requirements to ICIS. Metric 1b8 Number of active NPDES individual DMR filers with permit limits in ICIS. AZ0025216 - AZ0025305 Houston Creek Landing WWTP. Currently working on issue to flow new permit requirements to ICIS. Metric 1E1 - Facilities with Informal Actions - 26 is correct. Metric 1f1 - Facilities with Formal Actions. - Working on Data flow issue to flow Formal actions to ICIS. Metric 1g3 - Facilities with Penalties. Penalties paid 0. Element 2 – Inspections Metric 5a3 -Number of inspected major facilities. 30 is correct. Metric 5b5 - Number of inspected non-major facilities. 14 is correct. Element 3 – Violations Metric 7j1 -Number of major and non-major facilities with new single event violations that began during the review year. The number is correct although we are working to match up more ADEQ violation codes to EPA SEV codes. Metric 7j2a - Number of major facilities with SNC, or non-major facilities with Category 1 noncompliance. - 10 is correct. Metric 7j2b - Number of non-major GP facilities with Category 1 noncompliance. 0 is correct. Metric 7j3 - Number of facilities with RNC/Category 2 noncompliance or effluent, DMR reporting, single event, or schedule violations open during the year. - 95 is correct. |
| 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. |
| CO | CWA | 130 older active general permits are not in ICIS. 3 Data fixes will not happen before the data freeze due to needing tickets or more research |
| CT | CAA | 1. Data Metric 1b5 count should be 17. ICIS-Air facility records did not reflect minimum inspection frequency changes under Connecticut's Alternate Compliance Monitoring Strategy, Approved by EPA for FY23. The minimum inspection frequency was updated for 13 facilities, which were no longer due for an FCE in FY23. 2. Data Metric 1b6 count should be 1. There are two facility records (King Industries, Scapa Tapes) are still affected by inspection cycle during COVID where inspections were modified for health and safety precautions. In agreement with EPA the inspections were conducted off-site and recorded in ICIS-Air as PCEs rather than an on-site FCE which would renew the inspection clock. 3. Metric 1c2 count should be 20. There were two FCEs entered into ICIS-Air that have not made it into the ECHO data metrics prior to the data verification deadline. 4. Metric 1H2 count should be 8. An assessed penalty was entered into ICIS-Air for the formal enforcement action with NAUGATUCK WPCA/POTW. 5. The total for 1H1 should be $207,425. An assessed penalty was entered into ICIS-Air but not reflected in the total for the formal enforcement action with NAUGATUCK WPCA/POTW. |
| CT | CWA | 1a4 - The number of active NPDES non-major general permits is inaccurate due to a known internal business process. CT currently has 2,751 NPDES non-major general permit registrants. The discrepancy is refined to the NPDES Stormwater Construction General Permit. CT is a direct data entry state (meaning we enter all data manually into ICIS) and CT is working internally with our IT Support Team to batch upload registrations as they are received as data does not electronically flow from our state database to ICIS at a routine interval. As sites are inspected, staff enter the facility and inspection data elements into ICIS. CT is moving towards updating the number of Construction registrations in FFY25 following the renewal of the General Permit using a batch upload. 5a3 - Housatonic is REC in ICIS, CEI in metric. ICIS is correct, ECHO only differentiates Compliance Monitoring Activitiy Types as "Inspection/Evaluation" and "Offiste Record Review", and only identifies the Compliance Monitoring Type as "Base Program - Evaluation" or "Base Program - Desk Audit". 5b5 - Canton/CT0100072 and Newtown/CT0101788 are SSO inspections in ICIS.Both POTWs appear on metric as CEI due to ECHO Compliance Monitoring Activity Type being only "Inspection/Evaluation" or "Offsite Record Review". 7j1 - There were repeat SEV reporting on the 3560 in 6 inspection reports. The number of facilities with SEVs is correct. For permit numbers CT0004014, CT0003824, CT0030228, CT0003379, CT0026794, CT0003115, CT0002127, CT0030180, CT0000434, CT0000892, CT0030287 and CT0001341 the inspection identified multiple violations associated with a single SEV code(s) therefore internal documentation reflects greater number of SEVs than ICIS. Each permit had the following total number of individual violations noted; CT0004014-(7); CT0003824- (8); CT0030228- (5); CT0003379-(8); CT0026794-(15); CT0003115-(11); CT0002127-(33); CT0030180-(8); CT0000434-(13); CT0000892-(6); CT0030287-(10); and CT0001341-(6). |
| DE | CAA | Metric 1b6 is returning EPA data/info and is including it in the count, despite requesting state only metrics. This metric should be 18, not 19. Delaware did not conduct an FCE for Allan Myers Delaware, Inc. in FFY23, EPA apparently did. Delaware cannot verify EPA data. |
| FL | CWA | Florida has requested EPA manual overrides for the following data points (facilities/metrics). FL0040207 NOMA WWTP 7j3; FL0040291 CHARLOTTE COUNTY UTILITIES - EASTPORT WWTP 7j3 ; FL0040665 CITY OF CLEWISTON WWTP 7j3 ; FL0115231 NORMANDY RYZE LLC WWTF 7j3 ; FL0170909 MILLVILLE AWT FACILITY 7j3 ; FL0174696 PAUL CALCATERRA ALLIGATOR FARM 7j3 ; FL0021105 COCOA BEACH WRF 7j3 ; FL0021903 MILTON WWTF 7j3 ; FL0020541 CAPE CANAVERAL WRF 7j3 ; FL0020125 CITY OF WEWAHITCHKA "RICKY MCMILLION" WWTP 7j2 ; FL0020141 SANFORD/NORTH WWTF 7j2 ; FL0020907 BUNNELL, CITY OF WWTF 7j2 ; FL0026603 LARGO, CITY OF 7j2 ; FL0026611 FLAGLER BEACH WWTF 7j2 ; FL0A00032 HANGAR X 7j2 ; FL0032654 MARSH COVE WWTF 7j2 ; FL0038849 OCUD/EASTERN SUBREGIONAL WRF 7j2 |
| FL | RCRA | Metric 1a2: Forty of the 471 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-nine of the 533 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 5a: Late inspections are noted for (1) RTX Corporation âEUR" Pratt & Whitney Division (FLD001447952) and (2) Envirofocus Technologies LLC (FLD004092839) in Two-year inspection coverage for operating TSDFs. The late inspections were identified after FFY23 translation errors were remedied and the inspections were scheduled and completed before the end of CY2023. Metric 10a: An error was noted for THETA America Group LLC (FLR000220202) 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 resolution was completed prior to the 360-day deadline from day zero. The issue was corrected in our system but did not translate to RCRAInfo. A direct entry was made in RCRAInfo to correct the issue. Success of the RCRAInfo entry will not be available until after RCRAInfo communicates with ECHO, and not sure if this will happen before the data lock deadline. |
| GA | CWA | Metric 1a4: Due to a petition that was filed with Georgia EPD appealing the issuance of the 2023 Construction Stormwater General Permits, the 2023 Permits are stayed until the case is resolved. This means that, right now, the 2023 Permits are not in effect. The 2018 versions of the Construction Stormwater General Permits with originally a 7/31/2023 expiration date each specifically provide that they continue “in force and effect until a new general permit is issued, final and effective.” Georgia has identified an error that has resulted in an incorrect permit status for Construction Stormwater permits. We have identified issues and are working with our contractor for a correction. Metric 1e1: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Eight informal actions were taken for satellite systems which are not associated with any NPDES, LAS, or general permits. The enforcement actions flow to ICIS, however, the associated SEVs currently do not. EPD will work with EPA to resolve this issue. Industrial Stormwater (GAR050000) has retrained staff to resolve a gap in programmatic data entry processes. There are 4 informal actions which have not flowed correctly to ICIS/ECHO. Metric 1f1: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Eight informal actions were taken for satellite systems which are not associated with any NPDES, LAS, or general permits. The enforcement actions flow to ICIS, however, the associated SEVs currently do not. EPD will work with EPA to resolve this issue. ICIS has been updated for Industrial Stormwater (GAR050000) 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). Additionally, 3 sites with formal actions originating from EPA as opposed to from the state are in ICIS and ECHO. Thus, the numbers for the data verification aggregate for this metric do not match. Metric 1g3: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. ICIS has been updated for Industrial Stormwater (GAR050000) 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). Additionally, 3 sites with formal actions originating from EPA as opposed to from the state are in ICIS and ECHO. Thus, the numbers for the data verification aggregate for this metric do not match. Metric 5a3: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Metric 5b5: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Metric 7j1: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Industrial Stormwater (GAR050000) has retrained staff to resolve a gap in programmatic data entry processes. There are 7 single event violations which have not flowed correctly to ICIS/ECHO. Metric 7j1: Twenty-one spills from satellite systems have been entered into the State database. These systems are not associated with any NPDES, LAS, or general permits. EPD assigns a unique ID beginning with “GAU” to all satellite systems. These enforcement actions flow to ICIS, however, the associated SEVs currently do not. EPD will work with EPA to resolve this issue. Metric 7j2a: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Metric 7j2b: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. The MS4 permits for City of Walthourville (GAG610101) and Long County (GAG610064) are incorrectly showing only one quarter (Q2) with SNC. ICIS is missing Q3 SNC for violations that occurred in Q3. EPD will investigate and correct the data in ICIS. Industrial Stormwater (GAR050000) analyzed 838 automatically generated violations flagged as “significant noncompliance”; 276 of these were accurate and 562 have been corrected. The majority of these which were in error were related to data flow and coding issues within the state database which feed information to ICIS and ECHO. Significant progress has been made to correct these issues with the aid of Georgia’s database contractors; however, corrections are ongoing. Metric 7j3: General LAS permit GAG278000 has historic data which flows to ICIS, however current data is not flowing. This is a state-issued permit which is not required to flow to the federal system and EPD is working to have any incorrect historic data resolved in ICIS. Due to a flow issue with new permit ID GAG300103, permittee has been reporting DMR data under permit ID GA0046698 which is no longer active. Violation shown in ICIS under GA0046698 would not be a violation if reported under correct ID. EPD will review the data flow to correct this error. The MS4 permits for: Cordele GAG610022, Leesburg GAG610060, Varnell GAG610097, Hall County GAG610047, Jones County GAG610058 and Lee County GAG610059 are showing incorrect quarters of RNC and PSVs. All these permittees are compliant. EPD will work toward correcting the data flow. Flowery Branch (GAG610039) and Lowndes County (GAG610066) are showing an incorrect PSV and quarters in RNC; these two permittees submitted required documents on-time. Staff will work to correct the data in ICIS. City of Savannah (GAS000205) is showing an incorrect SEV. However, the 7j1 metric is correct by not listing Savannah as having an SEV in FFY 2023. GAG610092 City of Stockbridge, and GAG610071 Murray County: EPD has not located their Stormwater Management Programs, resulting in EPD being unable to determine if ICIS is correctly showing that a violation exists. EPD is working with the permittee to clarify document location and will update ICIS if needed. GAG610093 City of Temple – quarters in RNC are correct; however, EPD has not located their Stormwater Management Program, resulting in EPD being unable to determine if ICIS is correctly calculating the PSV. EPD is working with the permittee to clarify document location and will update ICIS if needed. For the remaining 72, and City of Savannah, ICIS is incorrectly calculating the number of quarters in RNC and/or the number of PSV. EPD will work toward identifying the discrepancies and correcting the information. Industrial Stormwater (GAR050000) is aware of 1,816 automatically generated violations flagged as “reportable noncompliance”. 189 of these have been evaluated and are undergoing corrections; 76 are accurate. The remainder are still being evaluated across state and federal database for both coding and data flow issues. Significant progress has been made to correct these issues with the aid of Georgia’s database contractors; however, corrections are ongoing. |
| GA | CAA | Metrics 1b5 and 1b6 improperly exclude facilities where an FCE was completed during the year prior to it being removed from the CMS due to shutdown. For Metric 1i7, two tests that were attributed to GA0000001324700047, PRATT PAPER (GA), LLC should be for GA0000001324700037, PRATT PAPER (GA), LLC. We are fixing the data on our end. Metric 1j2 is so poorly defined that it is not worth verifying, specifically that it defines the source universe as facilities that were CMS major in the previous year instead of those that were Title V. |
| ID | CAA | 1B5 - Count should be 20 instead of 19. * Amalgamated Sugar Twin Falls, 083-00001, should be included because the FCE due date is 10/1/2022, which falls in FFY23. 1B6 - Count should be 7 instead of 9. * Rupert Cogen, 067-00012, should not be included as it's CMS removal date is 3/29/2018. However, the removal was entered late - on 2/13/2024. * Washington County Road & Bridge, 777-00279, should not be included as it's FCE was conducted 9/2/2021, which is in FFY21. However, this FCE was entered late - on 2/13/2024. 1I7 - Count should be 78 instead of 64. There are 14 tests not captured that have been verified were entered into ICIS- Air accurately: 1) ID000A1625296 for Sorrento 027-00071 2) ID000A1607169 for Treasure Canyon Calcium 041-00007 3) ID000A1634445 for DP-AP#1 Big Sky Dairy 047-00022 4) ID000A1610104 for Gem State Process'g 067-00038 5) ID000A1611520 for Peak Sand & Gravel 777-00376 6) ID000A1606180 for Bryant Smith 777-00515 7) ID000A1640676 for Sunroc dba Depatco 777-00572 8) ID000A1611535 for Western Construction 777-00625 9) ID000A1642890 for Sunroc dba Depatco 77-00630 10) D000A1634246 for Brett Price 777-00637 11) ID000A1614309 for Rock Crushing 777-00648 12) ID000A1631357 for Basin Resources 777-00654 13) ID000A1612776 for BJ Rees's Ent. 777-00654 14) ID000A1618778 for Western Construction of Lewiston 777-00657 1J2 - Count should be 49 instead of 50. Fiber Care Baths, 053-00051, should not be included because their TV program applicability did not even start until 1/22/2024, which is after FFY23. 1E1 - Count sound be 29 instead of 20. The following NTCs/WLs verified in ICIS-Air accurately, but not captured: 1) 017-00032 COFFELT FUNERAL SVCS, CRO-NTC-2022.0011, 10/25/2022 2) 055-00125 JMAC RESOURCES, CRO-NTC-2022.0013, 11/10/2022 3) 777-00376 PEAK SAND & GRAVEL, CRO-NTC-2022.0012, 11/16/2022 4) 777-00654 BASIN RESOURCES, CRO-NTC-2023.0003, 7/25/2023 5) 777-00375 WOODS CRUSHG & HAULG, CRO-NTC-2023.0004, 7/26/2023 6) 777-00577 F B CRUSHING, PRO-NTC-2022.0006, 10/20/2022 7) 053-00011 HILEX POLY CO., TFRO-NTC-2023.0002, 5/15/2023 The following NOVs were entered in ICIS-A but not captured: 8) 001-00299 Guerdon Enterprises NOV issd 6/2/2023 9) 011-00033 Grain Craft NOV issd 7/12/2023 1E2 - Count should be 28 instead of 19. 1) 2 Facilities with NOVs in ICIS-Air but not captured 2) 8 Facilities with NTCs in ICIS-Air but not captured Same facilities & actions as listed in 1E1 caveat. |
| IN | CAA | The Indiana Department of Environmental Management (IDEM) strives to ensure that CAA Compliance and Enforcement data that is posted to ECHO is timely and accurate, and IDEM is constantly working with the EPA to assure the accuracy of the information that makes its way to ECHO. While we successfully upload data into ICIS in a timely manner, there are always some errors that prevent the air compliance data from being totally accurate. In addition, based on our current business practices and the development and gathering of evidence, timely entry of all stack testing and enforcement data into the ICIS database is not always possible. Due to staffing changes in key data management positions, limited Air Program resources, issues with the data node, and changes in sourcesâEUR(tm) permit types, IDEM is aware that some data for Federal Fiscal Year 2023 may not have been uploaded as expected during the monthly electronic data transfer (EDT) processes. We have made recent progress in diagnosing and addressing some of the more persistent data upload errors, but some of these issues were still outstanding at the end of the data verification period and continue to be addressed by IDEM. IDEM will continue to work with EPA to ensure that CAA Compliance and Enforcement data is timely, complete, and accurate in ICIS-Air beyond the frozen SRF dataset. |
| KS | CAA | After reviewing the 2023 data set for Kansas, there are a couple of facilities that need to be removed form 1A5 and 1A6: For 1A5 – Number of HPV Minors • Remove 2057022 LaFarge Midwest – Fredonia - the CAO was terminated and the status in ICIS-Air states “Closed” as of 3/2/2011 (KS000A0000202050702200118) 1A6 – Number of Minors Subject to Formal Enforcement (prior 3 fiscal years) • Remove 1730099 Advantage Products (CA-Lite Screen) – AO terminated 11/25/2019 and states “Resolved” in ICIS-Air (KS000AAO00010) • Rep Kansas Gathering 1250097 should not be listed and needs to be removed. The CAO was terminated 8/19/2020 and the status in ICIS-Air states “Resolved” (KS000ACAO0046) |
| LA | CWA | 7j2b – Number of non-major GP 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 | Metric 1a1 " Number of Active Majors " ESSENTIAL POWER (MA0000002504200117) ended operations/closed in FFY 2022 but the closure was addressed in FFY 2023. Metric 1a2 âEUR" Active Synthetic Minors - Massachusetts has multiple Synthetic Minor Classifications with increasingly lower thresholds. On 2/28/2024, 234 are open facilities with âEURoeSM80âEUR Classification subject to scheduled inspection. Metric 1a4 âEUR" Other Active Facilities on CMS Plan âEUR" Several ACMS sources originally targeted for inspection in FFY 2023 were substituted for during the year (closures, etc.) Super Brush (MA0000002504201245) and SALEM STATE (MA0000002511901115) are incorrectly identified and were addressed as able in ICIS. Classification changes for ST GOBAIN (MA0000002511800505) and TOWERS at CHESTNUT HILL (MA0000002511900922) resulted in removal of source from CMS in FFY 2023. Metric 1b4 âEUR" Active Title V Facilities âEUR" ESSENTIAL POWER is closed per above. EXXON MOBIL closed in FFY 2023. Metric 1b5 â EUR" Number of CMS Majors âEUR" Many of these schedules have been conflated with inspection protocols adopted during COVID. The amended ACMS allowed off-site PCEOFF inspections in lieu of on-site FCE. Several other sources are targeted for FCE in FFY2024. Metric 1b6 âEUR" CMS 80% Synthetic Minors âEUR" Similarly, partially conflated with FFY2020 âEUR" FFY2021 due to COVID interruptions in inspection cycles and allowed off-site PCEOFF. HOLY CROSS reclassified below SM80 and dropped off CMS. AIRLOCK LLC facility CLOSED. Metric 1b7 âEUR" Other CMS Minors - Partially conflated with FFY2020-FFY2021 due to COVID interruptions in inspection cycles and targets and allowed offsite PCEOFF inspections. Includes two MAJ sources without issued Operating Permits. Metric 1d âEUR" Number of Facilities with FRV Identified - Due to end-of-year timing and case development, a number of cases for sources inspected in FFY2022 have FRVs identified in FFY2023, and FFY2023 in FFY2024. Metric 1e âEUR" Number of Informal Enforcement Actions âEUR" MA issued a number of Notices of Non-Compliance (NON) to sources that were not âEURoefederally-reportableâEUR facilities in FFY 2023, including some that were targeted in previous FFY but which had been removed from the Alternative CMS for FFY 2023. Metric 1j2âEUR" Number of Facilities with Reviewed TVACC âEUR" ESSENTIAL POWER closed FFY2022, no report due. Since certain subject sources have not received their OPs, this number is less than OP-subject facility list. Element 3 âEUR" Violations âEUR" A number of FFY2022 inspections have resulted in enforcement actions commencing FFY2023; these appear in that timeframe/report. Similarly, FFY 2023 inspections may trigger violations/enforcements in FFY 2024. Element 4 âEUR" Enforcement - Historical inspections/violations at targeted FFY2022 facilities have resulted in high level enforcement actions commencing FFY2023; these appear in that timeframe/report. Similarly, FFY 2023 inspections may trigger violations/en forcements in FFY 2024. PENALTIES: Massachusetts conducts multi-media inspections and enforcement actions. Final review of penalties and partitioning to other media (HW) took place on 2/28/24 (after last chance to review ICIS changes in ECHO before data freeze.) |
| ME | CWA | Element 1 - Data 1b7: There is a known issue with retaining the G3A code. We continually re-enter this code for several facilities in ICIS. The code “going missing” is a known issue to ICIS support staff. |
| MI | CAA | In general, the data in the US EPA's FY23 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 FY23. Metric 1a5: There were no State lead, minor source, HPV cases in Michigan in FY23. The state count should be zero. Metric 1a6: The number of formal enforcement actions at minor sources should be 11. A technology project is currently in process to implement improved CAA data collection methods and data flow capabilities to ICIS-Air. |
| MO | CAA | 1a1- MO0000002907100156 - 1/29/2007 State determined no P70 required because the facility demonstrated that the design capacity is less than the 2.5 million cubic meters that requires a P70 permit. No operating permit since 2001. (EPA still has classified as Major Emissions) MO0002909900016 - Duplicate facility. Data Moved Here: MO0000002909900016 1a4- MO0000002904500026 - Reclassified OP as of 5-30-2018;CP-NOP, please remove CMS from facility. Not active on CMS during FFY2023. MO0000002906900014 - Facility is inactive, no production for a few years. Should be removed from CMS. Not active on CMS during FFY2023. MO0000002909700058 - As of 8/23/2021, no longer active on CMS. Not active on CMS during FFY2023. MO0000002910100002 - Went from Title V to SM-80 on 2-8-2017. No OP required as of 6/11/21 (Please remove CMS). Not active on CMS during FFY2023. MO0000002914300012 - No longer active on CMS as of 9-29-2022 concurrence request terminating OP. Not active on CMS during FFY2023. MO0002902900053 - No OP ever issued, please remove from CMS. Not active on CMS during FFY2023. MO0002918600065 - No OP ever issued, please remove from CMS. Not active on CMS during FFY2023. 1a5 – MO0000002900700040 - Unresolved HPV is from 2007 from what I can tell. The facility has been closed since Dec. 2020. 1b4 – MO0002909900016 - Duplicate facility. Data Moved Here: MO0000002909900016 1b7 – MO0000002914300012 - No longer active on CMS as of 9-29-2022 concurrence request terminating OP. Please remove CMS. 1j2- MO0002909900016 - Duplicate facility. Data Moved Here: MO0000002909900016 |
| MT | CWA | ADDED NPDES GROUP OF FREQUENT DMR FILERS IN 1B7 METRIC THESE WERE NOT SHOWING IN THE NPDES DATA GROUP CHOSE CORRECT STATUS WON'T UPDATE IN ECHO UNTIL SATURDAY 3/2/2024 MT0000248 MT0000477 MT0000485 MT0020303 MT0028321 MT0031437 MT0031551 |
| NC | CWA | Although North Carolina indicates disagreement or discrepancies in association with a variety of the metrics within the data verification, almost all observed differences are minor. Some have been resolved through updates of data in the data systems and/or the upload of corrected information from the state. The areas of greatest potential for disagreement exist within the metrics concerning the numbers of facilities in SNC or Category 1 noncompliance and those with RNC or Category 2 noncompliance. North Carolina does not use those criteria or classifications in its evaluations of violations and/or facilities in noncompliance. Therefore it cannot provide an accurate evaluation of the EPA determinations. It is is believed that the number associated with metric 7j3 - the number of facilities with RNC/Category 2 noncompliance, etc. could be too high in reality due to issues associated with the upload of data from NC's data system to ICIS. The result of the ICIS evaluation m ay calculated correctly, but may be made erroneous due to insufficient data. Comments have been provided within the table for each metric. |
| ND | CAA | Some generators that are listed as Large Quantity Generators may have failed to provide update to the State of New Mexico that they are no longer generating hazardous waste, or that they may no longer be generating large quantity generators.EPA ID# NMR000028357 was registered incorrectly at the wrong address, and was not properly registered as a short-term Large Quantity Generator. The actual address for the Speedway location is 19384 Highway 85, not 19364 Highway 85. EPA ID# NMR000028951 was determined to be a duplicate EPA ID# and has now been merged in the database with the preexisting EPA ID#. The correct EPA ID# for this facility is NMD069892594. |
| NH | RCRA | NH uses HazWIMS state database for number of "active LQGs". For Informal enforcement actions, NHDES has an additional 26 counts for Reports of Hazardous Waste Inspections (RCRAInfo code 111) for a total of 33 informal enforcement actions. |
| NM | RCRA | Some generators that are listed as Large Quantity Generators may have failed to provide update to the State of New Mexico that they are no longer generating hazardous waste, or that they may no longer be generating large quantity generators.EPA ID# NMR000028357 was registered incorrectly at the wrong address, and was not properly registered as a short-term Large Quantity Generator. The actual address for the Speedway location is 19384 Highway 85, not 19364 Highway 85. EPA ID# NMR000028951 was determined to be a duplicate EPA ID# and has now been merged in the database with the preexisting EPA ID#. The correct EPA ID# for this facility is NMD069892594. |
| NM | CAA | Metric 1a5 A number of minor facilities with High Priority Violations (HPVs) that are entered correctly into EPA’s ICIS-Air, are not reflected in the ECHO database. Metric 1a6 A number of minor facilities with formal enforcement actions (e.g. Compliance Orders) that are entered correctly into EPA’s ICIS-Air, are not reflected in the ECHO database. Also, a number of Compliance Orders reflected as being issued in 2023 in ECHO were issued in 2020. Metrics 1d1 and 1d2 A facility and case file with a Federally Reported Violation (FRV) identified in ICIS-Air is not reflected in ECHO. Metric 1f1 and 1f2 A case file and a facility with an HPV zero date that occurred during the federal fiscal year that is identified in ICIS-Air but is not reflected in ECHO. Metric 1h1 The total amount of assessed penalties during the federal fiscal year that is reflected in ECHO is not correct |
| OH | CAA | Metric 1a1 Number of Active Majors 83 facilities are included in the metrics list that are not major facilities nor were they major in FFY 2023. They are correctly categorized in the metrics list and in ICIS Air. There were 4 facilities that were incorrectly placed in the Active Majors list: OH0000000247030013 Avon Lake Power Plant was permanently shutdown on 4/1/2022. OH0000000243160009 Eastlake Substation has had a PBR classification since at least 6/1/2022. OH0000000701000070 Ershigs FRP Production Facility (DP&L-STUART) was permanently shutdown on 5/9/2022. OH0000000278062007 Priority Excavation Services, LLC has had an Operating status of "Not Installed" since 8/15/14. Facility also has an incorrect facility ID. OH0000000278082023 is the correct facility ID in the STARS2 system. (OH0000000278062007 does not match any Ohio EPA facility ID.) There were an additional 2 facilities with incorrect Facility IDs: OH0000000575010146 Norcold has an incorrect Ohio EPA Facility ID. The correct facility ID is OH0000000375010146. (OH0000000575010146 does not match any Ohio EPA facility ID.) OH0000000575010161 Klinger Thermoseal has an incorrect Ohio EPA facility ID. The correct facility ID is OH0000000375010161. (OH0000000575010161 does not match any Ohio EPA facility ID.) Metric 1a2 Number of Active Synthetic Minor Facilities 93 facilities are included in the metrics list that are not Synthetic Minor facilities nor were they Synthetic Minor in FFY 2023. They are correctly categorized in the metrics list and in ICIS Air 36 facilities were not in included in the metrics list. The facilities are correctly categorized in ECHO as SM80 facilities: Metric 1a6 Number of Minors Subject to Formal Enforcement 1 facility not in the metric list: OH0000000684005004 Skye Metal Recovery Inc 66 (State Findings and Orders) Resolved pending milestones. Begin date 6/7/18; final action date 3/12/20 Metric 1d1 Number of Facilities with an FRV Identified (Facility Count) 27 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. 19 facilities not included in metric that did have an FRV in FY2023 due to an incorrect FRV determination date in ECHO. This is a known error. Metric 1d2 Number of Case Files with an FRV Identified (Activity Count) 46 FRVs 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. 28 facilities not included in metric that did have an FRV in FY2023 due to an incorrect FRV determination date in ECHO. This is a known error. Metric 1j1 Number of Facilities with a reviewed TVACC WIN Waste Innovations of Seneca County (Fac ID 0374010199) was not included in the metric list. The TV Certification was reviewed on 4/29/2022 and was marked as intermittent comply. |
| OK | CWA | The following caveats and revision in metric values need to be added to Oklahoma DEQ-Water Quality Division’s FFY2023 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 5429. Stormwater-Construction & Stormwater- Industrial permits are maintained in the Oklahoma DEQ's state database. During this period, there were 1768 Stormwater-Industrial and 3403 Stormwater-Construction permits. Oklahoma DEQ has permitted 206 General Discharge permits. The MS4 Phase 2 universe was 52. 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 73. There were 43 Majors, 25 Minors, 3 Unpermitted, and 2 Construction Stormwater that received an Informal enforcement action. 7. Metric 1f1 Facilities with Formal Actions is revised to 180. The following number of facilities by Facility Type had a Formal Action: Major- 37 Minor- 75 Unpermitted- 24 General Discharge- 17 General Total Retention Lagoon (TRL)- 4 Industrial User- 7 Construction Stormwater- 9 MS4 Phase II-1 Industrial Stormwater -4 State- 2 8. Metric 1g3 Facilities with Penalties is revised to 28. In addition to what is listed for the metric, 5 penalty was given to Industrial Stormwater, 3 penalties to Unpermitted, 4 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 48. Stormwater single event violations are maintained in a state database. 10. Metric 7jb2 Number of non-major GP with Active facilities with SNC/Category 1 noncompliance is revised to 48 out of a permitted universe of 5429. Industrial Stormwater has 22 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 242 out of a permitted universe of 5429. There were 17 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 340 out a universe of 5429 permitted universe. Major and non-major facilities in noncompliance revised percentage is 6.2%. 13. Metric 8a3 Percentage of active major and non-major facilities in SNC Category 1 noncompliance during the reporting year is 2.1%. 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 | CAA | 1a1: Actual is Major Sources is 102. Three sources are no longer Majors. OREGON DOOR COMPANY OR0000004101900008, OWENS CORNING FOAM INSULATION, LLC - OR0000004105109537 and ZIEMAN MANUFACTURING COMPANY - OR0000004107100026. 1a5: Two sources not captured as permits are in draft. 1. SCHNITZER STEEL INDUSTRIES, INC. 2. HOLLINGSWORTH & VOSE FIBER COMPANY. 1a6: Should be Zero. DEQ has determined that the source is a minor source. We have communicated that determination to GRM, and EPA confirmed. The case has been removed from the HPV list. 1j1 EPA has approved ODEQâEUR(tm)s Alternative CMS schedule. |
| OR | CMA | ICIS-NPDES data for non-major general-permit-covered facilities includes 36 CAFO permits managed by the Oregon Department of Agriculture that have not been updated to reflect renewals or terminations. All other data categories accurately reflect state data systems. |
| PA | CWA | With the exception of 12 permits, all of Pennsylvania’s NPDES permitted facilities required to submit electronic Discharge Monitoring Reports (eDMRs) are using PA DEP’s eDMR data system. Pennsylvania is in the process of renumbering general permits for industrial stormwater (PAG-03s). In this process, the old permit is terminated in ICIS and a new permit is issued with a new permit number. Due to this process, several metrics including Active NPDES non-major general permits, Active NPDES individual DMR filers, Active NPDES individual DMR filers with permit limits in ICIS, Facilities with informal actions, Facilities with formal actions, etc. are greatly inflated. PA DEP expects the changeover to be completed during FFY 2024. Construction stormwater individual permits under Chapter 102 (permit numbers including “PAD”) are being uploaded but the cleanup effort for past permits is excessive. Construction stormwater general permits (permit numbers including “PAC”) are tracked only in ICIS, not state systems. Data for these permit types is being actively addressed by PA DEP program staff. Effluent violations generated by ICIS will not exist in the state database unless the violations have been manually generated. They do not automatically generate in state systems. If those violations are manually created in state databases, they will duplicate violations that are ICIS-generated. 1a1: Number of active NPDES major individual permits No comment 1a2: Number of active NPDES major general permits PA DEP does not issue major general permits. 1a3: Number of active NPDES non-major individual permits PA0013463: This permit was in the process of being downgraded to a minor during the year causing a mismatch in major/minor status. Downgrade has now been issued and state and federal databases are now in agreement. 1a4: Number of active NPDES non-major general permits No comment 1b7: Number of active NPDES individual DMR filers 1b8: Number of active NPDES individual DMR filers with permit limits in ICIS PA0275646: Is a DMR filer based on the type of permit but has no monitoring requirements and therefore, no limits. PA0090522: Cannot register for to use PA DEP’s eDMR system until a renewal permit is issued, no limits in ICIS. PA0042579: Previously unable to register for PA DEP’s eDMR system. A renewal was just issued in January. PA DEP is actively working to get the permit registered for electronic submission. PAR232244: Not registered for eDMR system. Will issue enforcement. 1e1: Facilities with Informal Actions No comment 1f1: Facilities with Formal Actions No comment 1g3: Facilities with Penalties No comment 5a3: Number of inspected major facilities No comment 5b5: Number of inspected non-major facilities Trouble uploading 5 inspections due to change in permit number. 7j1: Number of major and non-major facilities with new single-event violations that began during the review year No comment 7j2a: Number of major facilities with SNC, or non-major IP facilities with Category 1 noncompliance 7j2b: Number of non-major GP facilities with Category 1 noncompliance 7j3: Number of facilities with RNC/Category 2 noncompliance or effluent, DMR reporting, single event, or schedule violations open during the year PA DEP’s data systems do not differentiate between SNC/Category 1 and RNC/Category 2 noncompliance. PA DEP utilizes the QNCR and ECHO dashboards to closely track and monitor those facilities. |
| PA | CAA | PA DEP moved to Oracle Cloud Client, which caused unforseen issues within the PA DEP Data Systems. One of the issues was the OpenNode system that PA DEP uses to transfer data to EPA, triggered a mass deletion request to ECHO. PA DEP is the process of restoring the data to ECHO, but will not get it fully restored before the data freezes on 3/1/2024. |
| SC | CAA | 1a4 Number of Other Active Facilities on CMS Plan Incorrect/Deficiency* SC00020600199 Facility has been operating under SOP since 1/1/2016 1a6 Number of Minors Subject to Formal Enforcement Correct, Clarification* SC00099000762 Previously operated under SC00006000057; CO occurred under SC00006000057 1j2 Number of Facilities with TVACC Due Incorrect/Deficiency* SC00008200091 First ACC due 11/14/2023 for the reporting period of 10/1/2022-9/30/2023. TV Effective date: 10/1/2022 Incorrect/Deficiency* SC00013600050 First ACC due 2/14/2024 for the reporting period of 1/1/2023-12/31/2023. TV Effective date: 1/1/2023 |
| SD | RCRA | Correction for Number of Active LQGs list: SD had 34 active LQGs under state jurisdiction at the close of FY 2023. We assume Rosebud PHS (SDE000220186) is a tribal entity on tribal land and therefore under federal jurisdiction. The Active LQG list is otherwise accurate. |
| SD | CWA | 1. The following metrics (1a4 and 5b5) contains permits with SDLG#'s and shall be removed from the count as these are Biosolids general permit covered facilites and the logic cannot remove them. 2. The following metrics (1a4, 1e1, 5b5, 7j2b, and 7j3) contains permits with SDPG#'s and shall be removed from the count as these are Pretreatment SIU's for the metal finisher general permit covered facilites and the logic cannot remove them. 3. Stormwater Construction general permit covered facilities are not reflected in metrics 1e1, 7j1, 7j2a, 7j2b and 7j3 as this information does not flow to ICIS yet. |
| TX | CWA | 1a1: TCEQ Number, 709. TCEQ records reflect 709 Active permits classified as majors. EPAs count of 729 includes 19 permits falling outside of the fiscal year 2023 date range and 1 permit in Admin Continued status. These 19 permits are either in Expired or Terminated status in both the TCEQ database and ICIS. EPA ID TX0062201 in Admin Continued status is associated with the City of Houston Sims Bayou WWTP which was under EPA delegation upon initial TPDES permit issuance by TCEQ. TCEQ does not know the issuance date as this application is pending at EPA. This information is based on an ECHO data pulled on January 29, 2024. 1a2: TCEQ Number, 0. No caveat. 1a3: TCEQ Number, 2,410. TCEQ records reflect 2,410 minors. EPAs count of 2,758 includes 348 permits falling outside of the fiscal year 2023 date range. These permits are either in Expired or Terminated status in both the TCEQ database and ICIS. This information is based on an ECHO data pulled on January 29, 2024. 1a4: TCEQ Number, 53,222. TCEQ records reflect 53,222 general permits. EPAs count of 60,463 includes 7241 general permits falling outside of the fiscal year 2023 date range. These permits are either in Expired or Terminated status in both the TCEQ database and ICIS. This information is based on an ECHO data pulled on January 29, 2024. 1b7: TCEQ Number, 2,664. TCEQ records reflect 2664 DMR filers. EPAs count of 2,666 includes 1 expired permit that falls outside of the fiscal year 2023 date range and 1 permit in Admin Continued status. EPA ID TX0062201 in Admin Continued status is associated with the City of Houston Sims Bayou WWTP which was under EPA delegation upon initial TPDES permit issuance by TCEQ. TCEQ does not know the issuance date as this application is pending at EPA. This information is based on an ECHO data pulled on January 29, 2024. 1b8: TCEQ Number, 2,628. TCEQ records reflect 2,628 DMR filers with permit limits. EPAs count of 2,652 includes 23 permits falling outside of the fiscal year 2023 date range and 1 permit in Admin Continued status. These 23 permits are either in Expired or Terminated status in both the TCEQ database and ICIS. EPA ID TX0062201 in Admin Continued status is associated with the City of Houston Sims Bayou WWTP which was under EPA delegation upon initial TPDES permit issuance by TCEQ. TCEQ does not know the issuance date as this application is pending at EPA. This information is based on an ECHO data pulled on January 23, 2024. 1e1: TCEQ Number, 1,230. Data verification performed with ECHO data from 1.23.24 and was confirmed. 1f1: TCEQ Number, 156. The TCEQ issued formal enforcement actions against 156 facilities. There were actions against 2 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were formal actions issued against 2 construction general permits (TXR15214F & TXR15354C) in which the permit numbers were expired or terminated and do not exist in the federal data base. The TCEQ completed the ICIS upload of active construction general permits on 09/27/18. 1g3: TCEQ Number, 156. The TCEQ issued formal enforcement actions with penalties against 156 facilities. There were actions against 2 facilities that do not appear in ECHO due to data flow constraints. Specifically, there were formal actions with penalties issued against 2 construction general permits (TXR15214F & TXR15354C) in which the permit numbers were expired or terminated and do not exist in the federal data base. The TCEQ completed the ICIS upload of active construction general permits on 09/27/18. 5a3: TCEQ Number, 351. 2 facilities that received an inspection did not flow due to withdrawn or expired NPDES IDs. 2 facilities that received an inspection did not flow due to restrictions in the NPDES flow logic. 5b5: TCEQ Number, 1,703. 38 of the investigations are associated to facilities that are Major WW permittees. These investigations should not be included in 5b5. 16 of the investigations in ECHO were associated to NPDES IDs which did not receive an investigation. 81 investigations are not included in ECHO as the EPA ID is either cancelled, expired, inactive, or pending. 1 investigation has an active EPA ID that is in the TIDEN error flow with a code of CM041 which indicates the permit ID isn't in ICIS. 7j1: TCEQ Number, 1,381. TCEQ determined that 13 investigations in ECHO resulted from follow-up investigations and should not be included in the FFY23 count. TCEQ had 362 major and non-major facilities with single-event violations (SEVs) that were not sent to ECHO due to investigation errors that failed flow requirements. Additionally, Sanitary Sewer Overflow (SSO) discharges do not flow to ECHO. TCEQ found 349 facilities with at least 1 SSO event that were not already counted towards the SEV total. SSO discharge information will flow to ECHO once EPA's NetSSO tool is implemented in Texas. 7j2a: TCEQ Number, 435. Data verification performed with ECHO data from 1.23.24 and was confirmed. 7j2b: TCEQ Number, 296. No caveat. 7j3: TCEQ Number, 1,906. Data verification performed with ECHO data from 1.23.24 and was confirmed. |
| TX | CAA | 1a1. TCEQ number 1356. ECHO shows 1,460 facilities as active that are associated to voided permits. TCEQ is working to resolve the issue by updating internal database information relating to permitting. 1a2. TCEQ does not have a synthetic minor program. 1a3. TCEQ does not report the number of active minor facilities subject to the NESHAP program. 1a4. TCEQ does not report the number of active CMS minors. 1a5. TCEQ only reports HPV for major sources. 1b4. TCEQ number 1393. TCEQ only reports Title V major sources. ECHO shows 810 facilities that are associated to voided permits. 1b5. TCEQ number 778. ECHO shows 43 additional facilities as having inactive AFS numbers or associated to minor sources. A list of AFS numbers was sent to EPA for data correction in early FY24. To date, data correction is still pending. 1b7. TCEQ does not report the number of Other CMS Minors. There has been no change in EPA data from last year for this metric. 1c1. TCEQ number 653. TCEQ has identified 9 facilities that did not flow to ECHO due to internal data issues. Additionally, two investigations (1889037 and 1896126) in ECHO data did not appear in TCEQ data due to data entered in TCEQ database incorrectly. Will work with regions to update investigations (typecodes and checklists do not match). 1c2. TCEQ number 672. ECHO shows 17 additional investigations that were not included in TCEQ's data, due to inaccurate information within TCEQs data. 1i7. TCEQ number 391. 30 Stack Test Reports did not flow to ECHO due to TCEQ data issue which will be corrected for future flows. 1j1. TCEQ number 1125. 710 facilities flowed to ECHO properly as intended. TCEQ has identified 415 facilities with reviewed Title V Annual Compliance Certifications that did not flow to ECHO due to missing or inaccurate data in TCEQ databases. These issues will be corrected for future flows. ECHO data includes 28 additional facilities that are either inactive or classified as minor sources that should have not flowed. 1j2. TCEQ number 1188. 1006 facilities flowed to ECHO as intended. ECHO data includes 124 additional facilities. 25 facilities are either inactive or classified as minor sources. These should have potentially not flowed at all. TCEQ has identified 182 additional facilities with reviewed Title V Annual Compliance Certifications that did not flow to ECHO due to missing, inaccurate, or lack of data in our databases. These issues will be corrected for future flows. |
| TX | RCRA | 1a5. TCEQ number 1329. TCEQâEUR(tm)s total number of BR LQG's is based on the 2019 BR LQGs. 1b1. TCEQ number 12. TCEQ has identified 312 facilities with on-site inspections. This included 26 facilities that had translation errors and have not yet been uploaded into RCRAInfo. There was one investigation that was completed by the EPA that was included in the ECHO data that was not in the State Database. 1c1. TCEQ number 186. TCEQ has identified 186 facilities with new violations during the federal fiscal year of review. This included 14 facilities that had translation errors and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads. There was one investigation that was completed by the EPA that was included in the ECHO data that was not in the State Database. 1c2. TCEQ number 339. TCEQ has identified 339 facilities that have or had open violations during the federal fiscal year of review. This includes 19 facilities that had errors and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads. There was one investigation that was completed by the EPA that was included in the ECHO data that was not in the State Database. 1d1. TCEQ number 150. TCEQ has identified 150 facilities with informal enforcement actions during the federal fiscal review year. This includes nine facilities that had translation errors and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads. There was one investigation that was completed by the EPA that was included in the ECHO data that was not in the State Database. 1d2. TCEQ number 172. TCEQ has identified 172 informal enforcement actions during the federal fiscal review year. This includes 11 facilities with 14 informal enforcement actions that had translation errors and have not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads. There was one investigation that was completed by the EPA that was included in the ECHO data that was not in the State Database. 1e1. TCEQ number 5. TCEQ has identified 5 facility identified as a SNC during the federal fiscal review year. This includes four facilities that were identified as SNC in the State database but not in RCRAInfo and one facility that had a translation error and has not yet been uploaded into RCRAInfo. TCEQ continues to improve functionality to ensure complete and accurate data uploads. 1f1. TCEQ number 19. Two sites are not flowing to ECHO due to issues with customer or program associations. These will be resolved in future flows. 1f2. TCEQ number 22. Formal enforcement action for two sites is not flowing to ECHO due to issues with customer or program associations. These will be resolved in future flows. 1g. TCEQ number $531,150. Penalties related to two sites with formal enforcement are not flowing to ECHO due to issues with customer or program associations. These will be resolved in future flows. |
| UT | CWA | Utah Division of Water Quality State being verified: UT Media being verified: CWA Data Caveats: 1a1: Permits UT0025348, UT0024392, and UT0000051 are effective. Corrections in progress. UT0000051 has an ICIS error where EDT reissuance is stuck on "Pending." 1a3: 141 total individual non-major permits. Multiple biosolids permits are not being counted as they were created as a general or associated permit type, correction in progress. 25 UTR permits are master general permit types, rather than individual. Correction in progress. UT0025879 has been changed to a general permit, correction in progress. Permits UT0020061, UT0020966, UT0025950, UT0025968, UT0026026 are effective, corrections to fix status are in progress. 1e1, 1f1, 1g3: Basic enforcement data present. SOP being drafted, enforcement action and penalties will be updated. 5b5: 558 total non-major inspections. 21 inspections not counted by the SFR app. Two Biosolids are missing (UTL000051 & UTL021920) as the permit type is an associated permit record, correction in progress. 19 MSGP No Exposure (UTNX permit p refix) inspections not counted by the SRF app are entered into ICIS correctly. 7j1: SEV SOP and entry guidance ongoing. Current data up to date. |
| VA | RCRA | The RCRAInfo Data Verification metrics are correct for Virginia, with informational comments added for 1d1 and 1d2. |
| VA | CWA | 1a4 (Number of active NPDES non-major general permits) The initial batch upload of the active Storm Water Construction (SWC) GP was deployed to ICIS-NPDES on 09/28/23; permits terminated and moved to history in VAâEUR(tm)s state system (CEDS) between 10/01/22 and 09/27/2023 were excluded from the flow as they were no longer active. Metric 1a4 does not necessarily reflect the entire universe of SWC. 1e1 (Facilities with Informal Actions) As of 03/01/24, Storm Water Construction (SWC) Informal Actions are yet to be developed. Metric 1e1 includes all required NPDES permit types except the informal actions issued to SWC. 5a3 (Number of inspected major facilities) Inspections conducted for major facilities include CEI and Sampling. Reconnaissance inspection is not part of Metric 5a3. 5b5 (Number of inspected non-major facilities) The "Desktop Audit" of Nutrient Trading GP (VAN), the "Audit" of MS4 GP (VAR04), and the "Other" of Storm Water Industrial GP (VAR05), were excluded from ICIS upload. As of 03/01/24, the compliance monitoring batch flow of the Storm Water Construction GP (VAR10) is yet to be developed. 7j1 (Number of major and non-major facilities with new single event violations that began during the review year) As of 03/01/24, SEVs of VAG25, VAG40, VAG64, VAG75, VAG83, VAG84, VAR04 GPs are being re-mapped due to State system (CEDS) table changes. SEVs associated to these permit types will be added once the re-development is complete. |
| WA | CAA | Port Townsend Paper Corporation caveat: July 17, 2023, Power Boiler Stack Test emission results are reported as passing, but there may be a new determination that this test was invalid. We are currently trying to obtain more information from source. |
| WA | CWA | Elements 1 & 2 - The data in ECHO is consistent with WA State Department of Ecology’s (Ecology) Permitting and Reporting Information System (PARIS) database for these CWA metrics. The only caveat is that there is a small percentage of data that is absent from ICIS/ECHO. Ecology Staff are working to resolve dataflow related issues preventing these records from flowing to EPA. Element 3 – Metric 7j1 is consistent with the data in Ecology’s PARIS database for single-event violations. The remaining metrics show inconsistency with Ecology’s data, particularly around violations calculated by EPA’s ICIS database related to DMR non-receipt. Ecology is working to resolve a bulk of these false violations and implementing validations in PARIS to prevent creating further false violations. PARIS validations implemented in FY2023 show improvements in preventing false DMR non-receipt violations. As an additional data quality measure, ICIS violations are being reviewed regularly and compared to Ecology’s records to assure consistency across the two systems. |
| WI | CAA | The following ICIS IDs do not belong in 1.a.1. for Wisconsin because they were not major during the federal fiscal year, they were/are synthetic minor: WI0000005510514454 ; WI0000005507900288 ; WI0000005500900012 ; WI0000005513300034 ; WI0000005500510833 ; WI0000005505300031 ; With respect to 1.b.5: ; - WI0000005507112107 BROADWIND HEAVY INDUSTRIES single sourced with 436121070, FCE in FFY22 and scheduled for FY24 ; - WI0000005507900125 MATERION ADVANCED CHEMICALS INC. moved to an SM permit on 2/8/23, dropped from FCE list ; - WI0000005503305666 3M - MENOMONIE PLANT CMR completed 10/6/23, fell into FY24 |
| WV | CWA | Metric 1a4: There were 10,118 general permit registrations during the 2023 fiscal year. The 57 permit difference seems to come from the timing of issuance/closure of some of the general permits in the 2023 fiscal year. Metrics 1f1 and 1g3: WVDEP was unable to upload seven Formal Actions. One additional Formal Action/Penalty (EQT Production Company Order No. 10049) is associated with state only permits (WVR311550, WVR311507, WVR311600, and WVR311617), and WVDEP does not upload penalties or formal actions on state only permits. Metric 5b5: WVDEP was unable to upload twenty-one inspections. Nineteen of these inspections are associated with multi-sector “No Exposure” permits. The inspection for PPG Industries Inc (WV0110051) is associated with a fly ash landfill, and those permits are not uploaded by WVDEP to EPA. WVDEP was also unable to upload the Menard Inc (WVR110677) inspection due to feed issues. Metrics 7j2a, 7j2b, 7j3, 7k1 and 8a3: Problems with data conversion from the West Virginia data system to the ICIS system have 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 continues to identify and address issues leading to inaccurate SNC/Category 1 and RNC numbers/rates showing in ECHO. Division of Mining and Reclamation Hydrologic Protection Unit Metric 1e1: 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 proven the addition of Informal Enforcement Actions will be developed and tested. Metrics 7j2a, 7j3, and 7k1: 1. Problems with data conversion from the West Virginia data system to the ICIS system have 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. 3. A Ransomware Attack occurred in August 2023 at a testing laboratory causing an increase in SNC related to DMR nonsubmittal in 3rd and 4th quarter 2023. |