MEMORANDUM

TO:		Public Record for the NPDES Electronic Reporting Rule
		EPA Docket Number EPA-HQ-OECA-2009-0274 (www.regulations.gov)	

FROM:		Carey A. Johnston, P.E.
            USEPA/OECA/OC
            ph: (202) 566 1014
            johnston.carey@epa.gov

DATE:		3 July 2014

--------------------------------------------------------------------------------
SUBJECT:	Notes from State Technical Workgroup Meeting (12 June 2014) [DCN 0140]
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Overview 

      This was the thirteenth meeting for the EPA-state technical workgroup, which is discussing key issues related to the proposed NPDES Electronic Reporting Rule (eRule). These discussions are informing the forthcoming supplemental Federal Register notice and they will continue beyond the publication of the supplemental notice to help EPA address state comments. EPA participants will include the OECA eRule Team as well as representatives from EPA's Office of Water and Office of Environmental Information. Technical workgroup members are listed below in Tables 1 and 2. The agenda for this meeting is also provided below. EPA is summarizing the notes from these discussions for the docket in order to provide transparency on EPA's outreach during the rulemaking process. The OECA eRule team will also be available for any other stakeholder group that would like to discuss the eRule. 
      
Meeting Notes
      
     EPA (Mr. Carey Johnston) started the meeting by reminding state participants that in addition to raising questions during the technical workgroup meetings, states can email their questions on the proposed rule (including the data elements) to EPA. Questions on all aspects of the proposed rule can be sent to Mr. Johnston. Mr. Johnston then asked teleconference participants to focus on the Collection System Information, Combined Sewer System Information, and Sewer Overflow Inspections and Events Reports. The source of these data elements includes NPDES permit applications and Notices of Intent (NOI) (see 30 July 2013; 78 FR 46094-46096), State or EPA inspections of sewer overflow events (Page 46102), and Sewer Overflow Event Reports (Page 46112).  
     
     Mr. Johnston started the technical discussion by reading the name of each data element along with the corresponding data description and regulatory or policy citation. After reading about five to ten elements at a time, Mr. Johnston asked for input from the technical workgroup. Below are some questions and comments from the technical workgroup. The first set of data elements discussed were the Collection System Information data elements (Page 46094), which are derived from individual NPDES permit applications or NOIs (general permit covered facilities).
     
* Florida noted that there are no combined sewer systems in their state. They asked how they would complete the Collection System Information data elements. Mr. Johnston noted that these data elements apply to both separate sanitary sewer systems and combined sewer systems. He also noted that states should report "0%" for the Percentage of Collection System That is a Combined Sewer System data element when the collection system is entirely a separate sanitary sewer system. 
   
* Arkansas (Mr. David Ramsey) had a question on how these data elements would apply to a satellite sewer collection system. Municipal satellite collection systems are sanitary sewers owned or operated by a municipality that convey sewage or industrial wastewater to a POTW that has a treatment plant owned or operated by a different municipality. These types of facilities do not typically have their own NPDES permit. Mr. Johnston noted that the NPDES permit applicant will use the Collection System Information data elements to individually identify the different sewer collection systems (including satellite collection systems) that are covered by the NPDES permit. Mr. Johnston provided an example of how a POTW seeking NPDES permit coverage would provide each data element separately for each sewer system covered by the permit to the state. See Figure 1. 

* A state participant asked how POTWs should calculate Percentage of Collection System That is a Combined Sewer System. Specifically, the state participant asked if this percentage was to be calculated by miles of pipe or service population. Mr. Johnston noted that the regulations do not specify a particular method. Several state participants noted that EPA should identify a calculation method for this data element to provide clarity and national consistency.

* A state participant asked if EPA is planning on updating its NPDES forms to match the data elements in Appendix A. EPA (Ms. Jackie Clark) responded that EPA will update its forms to match the data in Appendix A.

* ECOS (Ms. Beth Graves) asked EPA has a budgeted upgrades to ICIS-NPDES to accommodate all the data elements in Appendix A. Mr. Johnston noted that OECA is planning to upgrade ICIS-NPDES and that EPA will provide this workgroup with an update within the next few months.

Mr. Johnston then continued the technical discussion by reading the name of each data element associated with Combined Sewer System Information (Page 46095). There were no suggestions or comments on these data elements. Mr. Johnston then continued the technical discussion by reading the name of each data element associated with Sewer Overflow Inspections (Page 46102). Below are some questions and comments from the technical workgroup. 

* A state participant asked if EPA could modify the existing "Twenty-four hour reporting" requirement in 40 CFR 122.41(l)(6). Currently these regulations state: "The permittee shall report any noncompliance which may endanger health or the environment. Any information shall be provided orally within 24 hours from the time the permittee becomes aware of the circumstances." [emphasis added] The state participant suggested that it would be better if EPA did not specify "orally" and instead left the notification mechanism up to the authorized state NPDES program. 
   
   Washington state noted that they would like the option of having the immediate notification be an electronic notice and not an oral report. Florida noted that they have a 24-hour hotline to report sewer overflows. They noted that it may not be possible to electronically report these twenty-four hour reports if the POTW has lost power due to a large disaster (e.g., hurricane).
   
   Mr. Johnston first noted that these twenty-four hour reports are not identified for conversion to electronic reporting in the proposed NPDES Electronic Reporting rule. Mr. Johnston also noted that any state that would like to change the requirement for "oral notice" to "immediate notice" for these twenty-four hour reports should make this suggestion in their comments on the forthcoming supplemental notice. Mr. Johnston further noted that this provision, Twenty-four hour reporting, is intended to provide the authorized NPDES program with immediate notification of non-compliance that "may endanger health or the environment" and that this provision was written before the wide adoption of the Internet.
   
* Arkansas (Mr. David Ramsey) noted that their inspectors usually identify the street intersection where a sewer overflow has taken place, not the latitude and longitude as is listed in Appendix A. Mr. Johnston noted that it may be possible for EPA to take standardized street address data and convert it to a longitude and latitude
   
* Alabama noted that EPA's enforcement initiative on sewer overflows often requires compliance monitoring and reporting through enforcement actions. These data are often submitted on paper and are above and beyond the permit requirements. The state participant suggested that the eRule Team coordinate with EPA's enforcement staff on these reporting requirements from enforcement actions and the reporting requirements from the eRule. 
   
Mr. Johnston then continued the technical discussion by reading the name of each data element associated with Sewer Overflow Events Reports (Page 46112). Below are some questions and comments from the technical workgroup.

* New York asked about how receiving waterbody data will be reported. Mr. Johnston noted that it is EPA's plan on have these data be reported in a standardized way such that the sewer overflow can be linked to a particular waterbody on the National Hydrography Dataset (NHD). He noted that simply providing a text field with the receiving waterbody name is not sufficient to uniquely identify a waterbody. Mr. Johnston gave the example that there are 84 waterbodies with the name "Pigeon Creek" in the U.S. official list of geographic names (Geographic Names Information System  -  GNIS). See Table 1. Given that receiving waterbody names are not unique, Mr. Johnston noted that simply providing the name of the receiving waterbody does not automatically located the waterbody on a map. He noted that it is important that the electronic reporting tool capture the unique location of the receiving waterbody. Mr. Johnston noted that Appendix A collects permitted feature (e.g., outfall) latitude and longitude, which can be systematically mapped to the NHD. However, since SSOs can occur at any point in a collection system (i.e., SSOs should not be allowed under an NPDES permit) it is important that the receiving waterbody name be reported in a way to link it to the NHD.
   
* Oklahoma asked if there was a de minimus threshold for reporting sewer overflow spills. Tenessee noted that EPA should include a de minimus threshold for reporting sewer overflow spills and New Jersey noted that if there is a de minimus threshold that this threshold should be clearly stated. 

* Tennessee noted that most sewer overflow events are related to storm events and asked if EPA considered adding a data element related to inches of precipitation. Mr. Johnston noted that EPA did consider adding a data element on the Sewer Overflow Events Report that collected inches of precipitation. He noted that EPA proposed the following data element, Dry or Wet Weather Occurrence for Sewer Overflow, which EPA intended to use for inspection and enforcement targeting. Mr. Johnston suggested that states include their preference with respect to collecting inches of precipitation data in their comments on the forthcoming supplemental notice.  

* Washington state asked EPA if it would be involved in the future enhancements of ICIS-NPDES. Mr. Johnston noted that EPA would involve the states in any future enhancements of ICIS-NPDES.

* A state participant suggested that data elements in Appendix that are not in ICIS-NPDES means that these data elements are new reporting requirements. Mr. Johnston noted that there is a distinction between what is in ICIS-NPDES and what is required in EPA regulations. Mr. Johnston noted the OECA eRule Team started the development of Appendix A from EPA's existing regulations. The OECA eRule Team worked with NPDES program experts from the Office of Water, Office of General Counsel, and EPA Regions to develop Appendix A. He noted that the purpose of Appendix A is to ensure that there is consistent and complete reporting nationwide, and to expedite the collection and processing of the data, thereby making it more timely, accurate, complete, useful, and transparent for everyone. He noted that The EPA technical workgroups used the following process to create Appendix A: (1) Identify current candidate reports and information from states and NPDES regulated entities that are practical to standardize and electronically process, and have important value to the permitting, compliance and enforcement program, and the public; (2) Identify the required data elements for each candidate data flow and report based on the CWA or existing EPA regulations or policy; and (3) Minimize the number of data elements to create efficiencies without losing the utility of the data. 
   
*  ECOS (Ms. Beth Graves) asked EPA if it accounted for state information technology system upgrade costs. Mr. Johnston noted that EPA did account for these upgrade costs (see Section 1.4.2, 3.4.4, and 4.7). 

After the meeting EPA received questions from the Kentucky Energy and Environment Cabinet and the New Jersey Department of Environmental Protection. See Attachments 1 and 2.

Next Steps
      
      The next technical workgroup meeting is June 19th. 
     State Technical Workgroup Meeting  -  NPDES Electronic Reporting Rule
                                 12 June 2014



      1pm		Introduction/Roll Call 

      1:10	Discussion of Sewage Collection System, Combined Sewer System, and Sewer Overflow Data from Individual Permit Applications and NOIs, Inspections, and Sewer Overflow Event Reports

      2:00		End of Call
      
      
Quick Reminder
   *    The technical workgroup is not a formal decision-making body. The workgroup is expected to develop, research, and evaluate options for consideration by EPA and state senior management.
   
   *    There are no formal quorum rules for the workgroup. Scheduled teleconferences will proceed with whichever workgroup members call in to participate.

   *    There will be no formal voting or consensus of the workgroup. Instead, the workgroup is expected to try to develop recommendations reflecting their various perspectives, not achieve consensus.

   *    Summaries of the workgroup's discussions will be prepared for and reviewed by the workgroup, for presentation to EPA senior management and other states and the rulemaking record. The discussions summaries will outline the major elements of the discussions, areas of agreement and any dissenting views.


Table 1: State Technical Workgroup Members

                                 Main Contact
                             State or Organization
                              Main Contact Email
                         State/Org. Present? (Yes/No)
                                 Sean  Rolland
                                     ACWA
                             srolland@acwa-us.org
                                      No
                                 Karen Lechner
                                      AK
                           karen.lechner@alaska.gov
                                      No
                                 Christy Monk
                                      AL
                             cvm@adem.state.al.us
                                      Yes
                                 Eric Cleckler
                                       
                          ecleckler@adem.state.al.us
                                       
                                  Glenda Dean
                                       
                             gld@adem.state.al.us
                                       
                                 Teresa Marks
                                      AR
                            marks@adeq.state.ar.us
                                      Yes
                                   Pat Goff
                                       
                             goff@adeq.state.ar.us
                                       
                                   Mo Shafii
                                       
                            shafii@adeq.state.ar.us
                                       
                                 Karen Bassett
                                       
                           bassett@adeq.state.ar.us
                                       
                                 David Ramsey
                                       
                            ramsey@adeq.state.ar.us
                                       
                                Ellen Carpenter
                                       
                          carpenter@adeq.state.ar.us
                                       
                                Wendy LeStarge
                                      AZ
                           lestarge.wendy@azdeq.gov
                                      Yes
                                 Robin Belley
                                       
                            belley.robin@azdeq.gov
                                       
                                  David Lelsz
                                       
                            lelsz.david@azdeq.gov;
                                       
                                  Andy Putnam
                                      CO
                           andrew.putnam@state.co.us
                             goff@adeq.state.ar.us
                                      Yes
                                 Elisa Willard
                                       
                           elisa.willard@state.co.us
                                       
                                 Bob Zimmerman
                                      DE
                         robert.zimmerman@state.de.us
                          stephanie.bower@state.de.us
                                      No
                                  Beth Graves
                                     ECOS
                               bgraves@ecos.org
                                      Yes
                                  Chris Klena
                                      FL
                         chris.m.klena@dep.state.fl.us
                                      Yes
                              Jessica Kleinfelter
                                       
                      jessica.kleinfelter@dep.state.fl.us
                                       
                                 Edward Smith
                                       
                        edward.c.smith@dep.state.fl.us
                                       
                               Frances Carpenter
                                       
                       frances.carpenter@dnr.state.ga.us
                                       
                               Frances Carpenter
                                      GA
                       frances.carpenter@dnr.state.ga.us
                                      Yes
                                 Tom Easterly
                                      IN
                             teasterl@idem.in.gov
                              ckoontz@idem.in.gov
                                      No
                               Jeremy Chenevert
                                       
                             jcheneve@idem.in.gov
                                       
                                 Ed Dillingham
                                      KS
                            edillingham@kdheks.gov
                                      No
                             Shelly Shores-Miller
                                       
                              sshoresm@kdheks.gov
                                       
                                Shawn Hokanson
                                      KY
                             shawn.hokanson@ky.gov
                                      Yes
                                 Ruth Wallace
                                      MO
                            ruth.wallace@dnr.mo.gov
                                      Yes
                              Christopher Miller
                                       
                            epermitting@dnr.mo.gov
                                       
                                  Tamara Dahl
                                      MN
                            tamara.dahl@state.mn.us
                                      No
                                 Greg Jackson
                                      MS
                         greg_jackson@deq.state.ms.us
                                      No
                                  John Murphy
                                    NEIWPCC
                              jmurphy@neiwpcc.org
                                      No
                                 Jason Lonardo
                                      NJ
                         jason.lonardo@dep.state.nj.us
                                      Yes
                                 Julio Collazo
                                       
                         julio.collazo@dep.state.nj.us
                                       
                                 Robert Wither
                                      NY
                          rewither@gw.dec.state.ny.us
                                      Yes
                                 Joseph DiMura
                                       
                          jxdimura@gw.dec.state.ny.us
                                       
                             Shellie Chard-McClary
                                      OK
                       shellie.chard-mcclary@deq.ok.gov
                                      Yes
                                  Roy Walker
                                       
                             roy.walker@deq.ok.gov
                                       
                                 David Pruitt
                                       
                            david.pruitt@deq.ok.gov
                                       
                                 Jim Billings
                                      OR
                         billings.jim@deq.state.or.us
                                      Yes
                                 Sean Furjanic
                                      PA
                               sefurjanic@pa.gov
                                      No
                                Kent Woodmansey
                                      SD
                          kent.woodmansey@state.sd.us
                                      Yes
                                   Tim Flor
                                       
                             tim.flor@state.sd.us
                                       
                                Albert Spangler
                                       
                          albert.spangler@state.sd.us
                                       
                               Lawrence Bunting
                                      TN
                           lawrence.bunting@TN.gov  
                                      Yes
                                  Kim Wilson
                                      TX
                           kim.wilson@tceq.texas.gov
                                      No
                                 Lynley Doyen
                                       
                          lynley.doyen@tceq.texas.gov
                                       
                               Kimberly Shepard
                                       
                        kimberly.shepard@tceq.texas.gov
                                       
                                 Jeff Studenka
                                      UT
                              jstudenka@utah.gov
                                      No
                                 Jerome Brooks
                                      VA
                        jerome.brooks@deq.virginia.gov
                                      No
                                  Phani Eturu
                                       
                         phani.eturu@deq.virginia.gov
                                       
                                Stephen Bernath
                                      WA
                              sber461@ecy.wa.gov
                                      Yes
                                  Nancy Kmet
                                       
                              nkme461@ecy.wa.gov
                                       
      
Table 2: EPA Technical Workgroup Members

                                     Name
                                  EPA Office 
                                     Email
                               Present? (Yes/No)
                                   Lisa Lund
                                  OECA/OC/IO
                               lund.lisa@epa.gov
                                      No
                                John Dombrowski
                                 OECA/OC/ETDD
                            dombrowski.john@epa.gov
                                      No
                                  Andy Hudock
                                 OECA/OC/ETDD
                             hudock.andrew@epa.gov
                                      No
                                Rochele Kadish
                                 OECA/OC/ETDD
                            kadish.rochele@epa.gov
                                      No
                                Carey Johnston
                                 OECA/OC/ETDD
                            johnston.carey@epa.gov
                                      Yes
                                 Jackie Clark
                                  OW/OWM/WPD
                             clark.jackie@epa.gov
                                      Yes
                                  Roy Chaudet
                                 OEI/OIC/IESD
                              chaudet.roy@epa.gov
                                      No
                                 Chuck Freeman
                                 OEI/OIC/IESD
                            freeman.charles@epa.gov
                                      No
                                 Aditi Prabhu
                                    OGC/WLO
                             prabhu.aditi@epa.gov
                                      No
                                 David Apanian
                                   Region 4
                             apanian.david@epa.gov
                                      No
                                Mohammed Billah
                                  OW/OWM/WPD
                            billah.mohammed@epa.gov
                                      Yes
                                  Glynis Hill
                                 OP/ORPM/PRAD
                              hill.glynis@epa.gov
                                      Yes







Table 1: Example Showing the Importance of Linking the Receiving Waterbody Name to a Specific Location
GNIS Name
                                    GNIS ID
                                     Class
                                    County
                                     State
                                   Latitude
                                   Longitude
                                   Elevation
                                GNIS Entry Date
Pigeon Creek
                                    156883
                                Populated Place
                                    Butler
                                      AL
                                    313928N
                                   0863026W
                                      394
                                   4-Sep-80
Pigeon Creek
                                    124713
                                    Stream
                                    Clarke
                                      AL
                                    313131N
                                   0873633W
                                      10
                                   4-Sep-80
Pigeon Creek
                                    124714
                                    Stream
                                    Jackson
                                      AL
                                    345913N
                                   0861459W
                                      781
                                   4-Sep-80
Pigeon Creek
                                    155196
                                    Stream
                                    Conecuh
                                      AL
                                    312043N
                                   0864213W
                                      141
                                   4-Sep-80
Pigeon Creek
                                     53359
                                    Stream
                                     Logan
                                      AR
                                    350955N
                                   0940336W
                                      535
                                   30-Apr-80
Pigeon Creek
                                     53360
                                    Stream
                                    Madison
                                      AR
                                    360042N
                                   0935410W
                                     1,220
                                   30-Apr-80
Pigeon Creek
                                     53361
                                    Stream
                                    Baxter
                                      AR
                                    362405N
                                   0922151W
                                      699
                                   30-Apr-80
Pigeon Creek
                                     73069
                                    Stream
                                     Scott
                                      AR
                                    345956N
                                   0934803W
                                      919
                                   30-Apr-80
Pigeon Creek
                                     73070
                                    Stream
                                   Crawford
                                      AR
                                    353638N
                                   0941049W
                                      673
                                   30-Apr-80
Pigeon Creek
                                     73071
                                    Stream
                                     Scott
                                      AR
                                    345259N
                                   0940842W
                                      653
                                   30-Apr-80
Pigeon Creek
                                     32891
                                    Stream
                                     Gila
                                      AZ
                                    340414N
                                   1111028W
                                     4,252
                                   8-Feb-80
Pigeon Creek
                                     32892
                                    Stream
                                    Yavapai
                                      AZ
                                    341804N
                                   1114212W
                                     2,710
                                   8-Feb-80
Pigeon Creek
                                     32893
                                    Stream
                                   Greenlee
                                      AZ
                                    331607N
                                   1091144W
                                     4,094
                                   8-Feb-80
Pigeon Creek
                                    234460
                                    Stream
                                    Amador
                                      CA
                                    383234N
                                   1205053W
                                      843
                                   19-Jan-81
Pigeon Creek
                                    234461
                                    Stream
                                     Glenn
                                      CA
                                    392603N
                                   1223010W
                                      984
                                   19-Jan-81
Pigeon Creek
                                    247459
                                    Stream
                                    Tulare
                                      CA
                                    360236N
                                   1184431W
                                     1,588
                                   19-Jan-81
Pigeon Creek
                                    264716
                                    Stream
                                    Shasta
                                      CA
                                    410955N
                                   1215929W
                                     4,173
                                   19-Jan-81
Pigeon Creek
                                    272961
                                    Stream
                                    Tulare
                                      CA
                                    362049N
                                   1184507W
                                     4,245
                                   19-Jan-81
Pigeon Creek
                                    187784
                                    Stream
                                   La Plata
                                      CO
                                    373807N
                                   1074128W
                                     8,241
                                   13-Oct-78
Pigeon Creek
                                    288801
                                    Stream
                                      Bay
                                      FL
                                    302011N
                                   0854937W
                                       3
                                   19-Oct-79
Pigeon Creek
                                    288802
                                    Stream
                                    Nassau
                                      FL
                                    304651N
                                   0815817W
                                       3
                                   19-Oct-79
Pigeon Creek
                                    320507
                                    Stream
                                  Meriwether
                                      GA
                                    325325N
                                   0843035W
                                      614
                                   25-Sep-79
Pigeon Creek
                                    329200
                                    Stream
                                    Fannin
                                      GA
                                    344526N
                                   0841150W
                                     1,854
                                   25-Sep-79
Pigeon Creek
                                    329201
                                    Stream
                                    Dawson
                                      GA
                                    342600N
                                   0840801W
                                     1,204
                                   25-Sep-79
Pigeon Creek
                                    460132
                                    Stream
                                 Pottawattamie
                                      IA
                                    411911N
                                   0955314W
                                      961
                                   30-Apr-79
Pigeon Creek
                                    460133
                                    Stream
                                     Scott
                                      IA
                                    413249N
                                   0902635W
                                      564
                                   30-Apr-79
Pigeon Creek
                                    460134
                                    Stream
                                   Appanoose
                                      IA
                                    403736N
                                   0924455W
                                      840
                                   30-Apr-79
Pigeon Creek
                                    415652
                                    Stream
                                  Williamson
                                      IL
                                    374309N
                                   0890155W
                                      404
                                   15-Jan-80
Pigeon Creek
                                    415653
                                    Stream
                                   Jefferson
                                      IL
                                    382214N
                                   0884530W
                                      446
                                   15-Jan-80
Pigeon Creek
                                    415654
                                    Stream
                                     Pike
                                      IL
                                    394242N
                                   0911551W
                                      449
                                   15-Jan-80
Pigeon Creek
                                    415655
                                    Stream
                                   Iroquois
                                      IL
                                    403536N
                                   0875107W
                                      646
                                   15-Jan-80
Pigeon Creek
                                    415656
                                    Stream
                                   Marshall
                                      IL
                                    405804N
                                   0892528W
                                      456
                                   15-Jan-80
Pigeon Creek
                                    441114
                                    Stream
                                    Steuben
                                      IN
                                    414100N
                                   0851600W
                                      912
                                   14-Feb-79
Pigeon Creek
                                    441115
                                    Stream
                                  Vanderburgh
                                      IN
                                    375938N
                                   0873421W
                                      344
                                   14-Feb-79
Pigeon Creek
                                    500585
                                    Stream
                                   Edmonson
                                      KY
                                    371534N
                                   0861520W
                                      433
                                   20-Sep-79
Pigeon Creek
                                    500586
                                    Stream
                                    Johnson
                                      KY
                                    375118N
                                   0825647W
                                      761
                                   20-Sep-79
Pigeon Creek
                                    500587
                                    Stream
                                   Anderson
                                      KY
                                    380506N
                                   0850109W
                                      755
                                   20-Sep-79
Pigeon Creek
                                    500588
                                    Stream
                                     Ohio
                                      KY
                                    372500N
                                   0865031W
                                      397
                                   20-Sep-79
Pigeon Creek
                                    1627918
                                    Stream
                                  St. Helena
                                      LA
                                    304329N
                                   0905020W
                                      95
                                   4-Jun-80
Pigeon Creek
                                    634850
                                    Stream
                                    Calhoun
                                      MI
                                    421632N
                                   0850433W
                                      860
                                   14-Apr-80
Pigeon Creek
                                    634851
                                    Stream
                                    Allegan
                                      MI
                                    424204N
                                   0854854W
                                      650
                                   14-Apr-80
Pigeon Creek
                                    724326
                                    Stream
                                     Dent
                                      MO
                                    372736N
                                   0914100W
                                      935
                                   24-Oct-80
Pigeon Creek
                                    724327
                                    Stream
                                   Buchanan
                                      MO
                                    393848N
                                   0944342W
                                      820
                                   24-Oct-80
Pigeon Creek
                                    724328
                                    Stream
                                    Marion
                                      MO
                                    395126N
                                   0913857W
                                      554
                                   24-Oct-80
Pigeon Creek
                                    738761
                                    Stream
                                     Ralls
                                      MO
                                    Unknown
                                    Unknown
                                      718
                                   1-Apr-90
Pigeon Creek
                                    751578
                                    Stream
                                    Ripley
                                      MO
                                    364135N
                                   0910159W
                                      486
                                   24-Oct-80
Pigeon Creek
                                    788851
                                    Stream
                                  Silver Bow
                                      MT
                                    454802N
                                   1122359W
                                     6,083
                                   4-Apr-80
Pigeon Creek
                                    992181
                                    Stream
                                     Swain
                                      NC
                                    353232N
                                   0831602W
                                     2,247
                                   17-Jun-80
Pigeon Creek
                                    1014386
                                    Stream
                                     Swain
                                      NC
                                    352131N
                                   0832633W
                                     2,195
                                   17-Jun-80
Pigeon Creek
                                    832100
                                    Stream
                                     Dixon
                                      NE
                                    422242N
                                   0964054W
                                     1,220
                                   9-Mar-79
Pigeon Creek
                                    832101
                                    Stream
                                    Dakota
                                      NE
                                    422005N
                                   0962421W
                                     1,073
                                   9-Mar-79
Pigeon Creek
                                    960372
                                    Stream
                                   Jefferson
                                      NY
                                    434547N
                                   0754839W
                                     1,581
                                   23-Jan-80
Pigeon Creek
                                    1867464
                                Populated Place
                                    Summit
                                      OH
                                    410639N
                                   0814022W
                                     1,040
                                   15-May-00
Pigeon Creek
                                    1044430
                                    Stream
                                    Summit
                                      OH
                                    410258N
                                   0813600W
                                      961
                                   12-Jul-79
Pigeon Creek
                                    1057921
                                    Stream
                                    Vinton
                                      OH
                                    391231N
                                   0824247W
                                      591
                                   12-Jul-79
Pigeon Creek
                                    1066893
                                    Stream
                                    Jackson
                                      OH
                                    391002N
                                   0824555W
                                      594
                                   12-Jul-79
Pigeon Creek
                                    1076627
                                    Stream
                                    Gallia
                                      OH
                                    384137N
                                   0822806W
                                      807
                                   12-Jul-79
Pigeon Creek
                                    1096628
                                    Stream
                                    Latimer
                                      OK
                                    345452N
                                   0950245W
                                      522
                                   18-Dec-79
Pigeon Creek
                                    1101583
                                    Stream
                                   Le Flore
                                      OK
                                    343849N
                                   0943233W
                                     1,040
                                   18-Dec-79
Pigeon Creek
                                    1125368
                                    Stream
                                     Polk
                                      OR
                                    445143N
                                   1234050W
                                      942
                                   28-Nov-80
Pigeon Creek
                                    1132179
                                    Stream
                                   Tillamook
                                      OR
                                    452254N
                                   1233449W
                                      732
                                   22-May-86
Pigeon Creek
                                    1135534
                                    Stream
                                    Lincoln
                                      OR
                                    444154N
                                   1233933W
                                      361
                                   1-Nov-91
Pigeon Creek
                                    1183708
                                    Stream
                                    Chester
                                      PA
                                    401200N
                                   0753448W
                                      102
                                   2-Aug-79
Pigeon Creek
                                    1183709
                                    Stream
                                     Berks
                                      PA
                                    402939N
                                   0755815W
                                      295
                                   2-Aug-79
Pigeon Creek
                                    1183710
                                    Stream
                                  Washington
                                      PA
                                    401155N
                                   0795508W
                                      728
                                   2-Aug-79
Pigeon Creek
                                    1199936
                                    Stream
                                   Sullivan
                                      PA
                                    412737N
                                   0761923W
                                     1,729
                                   2-Aug-79
Pigeon Creek
                                    1297437
                                    Stream
                                    Greene
                                      TN
                                    361533N
                                   0825504W
                                     1,109
                                   19-May-80
Pigeon Creek
                                    1297438
                                    Stream
                                    Greene
                                      TN
                                    360435N
                                   0825545W
                                     1,138
                                   19-May-80
Pigeon Creek
                                    1382498
                                    Stream
                                    Sabine
                                      TX
                                    311316N
                                   0935115W
                                      203
                                   30-Nov-79
Pigeon Creek
                                    1444348
                                    Stream
                                    Sanpete
                                      UT
                                    392324N
                                   1113452W
                                     5,502
                                   31-Dec-79
Pigeon Creek
                                    1444349
                                    Stream
                                     Juab
                                      UT
                                    393337N
                                   1114954W
                                     5,502
                                   31-Dec-79
Pigeon Creek
                                    1479321
                                    Stream
                               Lynchburg (city)
                                      VA
                                    372653N
                                   0791027W
                                      512
                                   28-Sep-79
Pigeon Creek
                                    1486198
                                    Stream
                                     Wise
                                      VA
                                    365348N
                                   0824728W
                                     1,614
                                   28-Sep-79
Pigeon Creek
                                    1507420
                                    Stream
                                   Snohomish
                                      WA
                                    475812N
                                   1221352W
                                       7
                                   10-Sep-79
Pigeon Creek
                                    1510354
                                    Stream
                                    Skagit
                                      WA
                                    482553N
                                   1221156W
                                      253
                                   1-Oct-90
Pigeon Creek
                                    1528854
                                    Stream
                                    Pierce
                                      WA
                                    470026N
                                   1214207W
                                     2,749
                                   1-Aug-90
Pigeon Creek
                                    1571360
                                    Stream
                                     Grant
                                      WI
                                    424628N
                                   0904937W
                                      686
                                   29-Aug-80
Pigeon Creek
                                    1571361
                                    Stream
                                    Jackson
                                      WI
                                    441222N
                                   0903913W
                                      902
                                   29-Aug-80
Pigeon Creek
                                    1571362
                                    Stream
                                  Trempealeau
                                      WI
                                    442159N
                                   0911817W
                                      804
                                   29-Aug-80
Pigeon Creek
                                    1571363
                                    Stream
                                    Barron
                                      WI
                                    453643N
                                   0913430W
                                     1,201
                                   29-Aug-80
Pigeon Creek
                                    1571364
                                    Stream
                                    Ozaukee
                                      WI
                                    431350N
                                   0875858W
                                      650
                                   29-Aug-80
Pigeon Creek
                                    1544813
                                    Stream
                                    Wyoming
                                      WV
                                    373522N
                                   0814124W
                                     1,132
                                   27-Jun-80
Pigeon Creek
                                    1549518
                                    Stream
                                     Mingo
                                      WV
                                    374724N
                                   0822104W
                                      600
                                   27-Jun-80
Pigeon Creek
                                    1552473
                                    Stream
                                    Mercer
                                      WV
                                    372008N
                                   0805702W
                                     1,693
                                   27-Jun-80
Source: http://geonames.usgs.gov/


      Attachment 1: Comments from Kentucky Energy and Environment Cabinet
I listened in on the ACWA/ECOS/EPA Technical WG Meeting on NPDES Electronic Reporting Rule conference call yesterday afternoon, and have some comments and questions. I am not the usual person for Kentucky that participates in these calls. I am in the section that oversees the CSO, SSO, and collection system programs. 
1. For the Compliance Monitoring Activity (Sewer Overflows Inspections and Audits) section of Table 2 on page 46102, our section does CSO and SSO program inspections, but not inspection of individual discharge events. Would our programmatic inspections use these data elements? Or is there a different set of data elements that we would use?
EPA Response: The data elements on Page 46102 are specific to state or EPA inspection of individual sewer over flow events.

2. For Compliance Monitoring Activity (Data Elements Specific to Sewer Overflow Event Reports) on page 46112, I believe that these fields only apply to SSOs, bypasses, and non-compliant CSOs. Can you clarify if that is the case? I didn't hear anything on the call that said that, although page 46029 of the preamble differentiates between non-compliance CSOs that are to be reported per 122.41(l)(6) and (7) and compliant CSOs that are to be reported on DMRs.
   
EPA Response: The Sewer Overflow Events Report data elements are related to non-compliant sewer overflow events.
   
3. In December 2013, I was on a webinar with Mo Billah and OECA. On that call it was discussed that the compliant CSOs are to be reported on DMRs, but that netDMR currently only takes a single value (max, min, total, average, etc.) for each reporting period, and not information on each discharge event. On the call it was said that netDMR would be modified to accept each CSO event. Is that still the plan?  Are those modifications to be part of this rule? There is nothing in the Federal Register notice that discusses it. 
EPA Response: EPA will upgrade its electronic reporting tools (NetDMR, NeT) to allow for sewer overflow event reporting.
   
4. Since a non-compliant CSO discharge is usually from a permitted CSO outfall that should already be entered as a Permitted Feature in ICIS, should these data elements include listing the Permitted Feature? The Permitted Feature already includes lat/long and receiving water name and code.

EPA Response: EPA has latitude and longitude data on CSO outfalls and can work with states to upload these data as outfall locations (permitted features) in ICIS-NPDES. 

5. ICIS has the ability to find the nearest receiving water from WebRIT based on an entered lat/long for Permitted Features. Can that ability be used for these data elements too?

EPA Response: EPA is planning to incorporate a feature in its electronic reporting tools that allow for the capture of the unique location of the receiving waterbody. 

   Attachment 2: Comments from New Jersey Department of Environmental Protection
                                         
From: Jason Lonardo <Jason.Lonardo@dep.nj.gov>
Sent: Tuesday, July 1, 2014 1:21 PM
To: Johnston, Carey
Cc: 'srolland@acwa-us.org'; 'bgraves@ecos.org'; Janice Brogle <Janice.Brogle@dep.nj.gov>; Julio Collazo <Julio.Collazo@dep.nj.gov>; Nancy Kempel <Nancy.Kempel@dep.nj.gov>; Andrew Doyle <Andrew.Doyle@dep.nj.gov>; Pilar Patterson <Pilar.Patterson@dep.nj.gov>
Subject: ACWA/ECOS/EPA Technical WG Meeting on NPDES Electronic Reporting Rule

Hello Carey,

In following up on our conference calls, please accept the following document outlining some of NJ's comments/concerns regarding the data elements related to Basic Permit Information and CSS/CSOs.  

If you have any additional questions, please don't hesitate to contact me.

Thanks.

Sincerely,

Jason

*************************************************************************************
Jason T. Lonardo, Environmental Scientist 2                              Jason.Lonardo@dep.nj.gov
NJDEP: Division of Water Quality                                              Tel #:  (609) 292-4396
Mail Code 401-02B                                                                  Fax #:  (609) 984-2147
401 East State Street, P.O. Box 420                                          www.state.nj.us/dep/dwq
Trenton, NJ  08625-0420

*************************************************************************************



    <See attached PDF file for NJDEP comments and EPA's responses.>
