--------------------------------------------------------------------------------
MEMORANDUM

TO:		POTW Study Record

FROM:	Kara Edquist, ERG

DATE:	December 29, 2017

SUBJECT:	Development of Draft POTW Screener Questionnaire Mailing List

EPA's Office of Water is continuing a multi-phase study of nutrient removals and related technology performance of publicly owned treatment works (POTWs). As part of this study, EPA is planning to conduct an initial voluntary questionnaire as a census of POTWs in the U.S. as described and defined in the Information Collection Request (ICR) supporting statement associated with this study. In support of this study, and at EPA's direction, ERG developed a draft respondent mailing list for POTWs located in the U.S. and its territories using the sources listed in Table 1-1.
This memorandum documents the draft mailing list sources. The draft mailing list is included in the docket. This draft mailing list will continue to be updated as additional information is received from publicly-available data sources. ERG included all facilities that could be POTWs and any valid addresses for the POTW in the mailing list. The list, therefore, could include POTWs with the same National Pollutant Discharge Elimination System (NPDES) permit numbers that are identified with different names or POTWs that may have multiple NPDES permit numbers. EPA is soliciting public input to improve the accuracy of this mailing list. EPA will continue to improve the mailing list based on public input and discussions with stakeholders.
Data Sources
ERG used the following data sources to compile the mailing list: 

 California Waterboards  -  On March 28, 2017, California Water Resources Control Board provided a list of POTWs with NDPES permits.
 New Jersey, EPA Region 2  -  On November 28, 2016, EPA received a list of POTWs in New Jersey from EPA Region 2.
 Integrated Compliance Information System - National Pollutant Discharge Elimination System (ICIS-NPDES)  -  ERG downloaded the universe of facilities recorded in the ICIS-NPDES database on March 27, 2017, August 28, 2017, and again on December 3, 2017.
ERG used NPDES permit numbers as the main facility identifier because it is the most commonly used identifier across all data sets. However, there are some limitations to this approach:
Facilities may be duplicated in the mailing list if NPDES permit numbers are updated (e.g., the mailing list has both an old and new NPDES permit for the same facility). Additionally, some facilities may have multiple permits.
       
Permits not within EPA's target population may be inadvertently included. Though ERG removed permits not applicable to the study (e.g., stormwater permits) where identified, the mailing list may include unintended recipients.

Identifying and Verifying Addresses 
ERG used the following data sources to obtain mailing addresses associated with NPDES permit numbers.
ICIS-NPDES Address Contact - Contains addresses for all contacts (e.g., permittee, owner) reported in ICIS-NPDES. ERG matched this list to the master list of facilities by NPDES permit number to incorporate known addresses for the facilities. This resulted in duplicate entries for a number of facilities, sometimes with the same address, other times with multiple different addresses.
Federal Registry Service (FRS)  -  Contains addresses for facility contacts. ERG downloaded data from FRS, matched on NPDES permit numbers, and added in addresses for facilities that did not have a valid address in the mailing list.
Permit Compliance System (PCS)  -  Stakeholders noted discrepancies between ICIS-NPDES records and records from PCS, an older version of the system. As such, ERG downloaded data from PCS, matched to NPDES permit numbers, and added in addresses for facilities that did not have a valid address in the mailing list.
Though a facility may have an address listed in these sources, the address may not be a valid U.S. Postal Service (USPS) address. ERG sent addresses through a third-party address verification service to determine if an address is mailable. The verification service used only verifies that the address matches a USPS-deliverable address and does not verify if the address is correct or current. Stakeholders in Region 7 noted that micro-communities (e.g., villages, townships) often have no official city hall, and clerks work from their homes and often use their home addresses. Therefore, as staff changes occur, mailing address updates may lag within data systems. In addition, USPS has closed a significant number of rural post offices; therefore, addresses with post office boxes may no longer be valid in towns that have lost their post offices.
Table 1-1 summarizes the mailing list data sources presented in the order ERG used to compile the mailing list. ERG is continuing to update the mailing list to remove duplicate or incorrect entries as they are identified.

Table 1-1. Data Sources used in POTW Mailing List
                                  Data Source
                     DATA_SOURCE (as seen in Mailing List)
                          Date of Data Collection [a]
                              Source Description
Baseline Population
California
CA_Major_POTW_032817
March 28, 2017
List from California Waterboards containing major POTWs.
New Jersey
NJ_ActivePermit_112816
November 28, 2016
List from EPA Region 2.
ICIS-NPDES
ICIS_FACILITY_032717 
March 27, 2017
Universe of facilities in ICIS-NPDES, narrowed to targeted population. See Section 1.2 for further detail.
ICIS-NPDES
ICIS_FACILITY_082817
August 28, 2017
Updated universe of facilities. Compared to mailing list and added new NPDES records and general permits (see Section 1.2.2). ERG did not compare addresses between the March 31, 2017 and August 28, 2017 downloads.
ICIS-NPDES
ICIS_FACILITY_120317
December 3, 2017
Updated universe of facilities. Compared to mailing list and added new NPDES records and general permits (see Section 1.2.2). ERG did not compare addresses between the downloads.
Addresses
ICIS-NPDES Contact
ICIS_ADDRESS_CONTACT_033117; ICIS_ADDRESS_CONTACT_082817
March 31, 2017; August 28, 2017
All contact address associated with a facility included in the ICIS system. Matched to facilities. 
FRS
FRS_HQ_061817; FRS_LQ_061817; FRS_POB_061817;
FRS_Mail_061817
June 18, 2017
Additional address source. 
PCS
PCS_Mailing _052517
May 25, 2017
Additional address source.
[a] Data collection dates are included because these data are continually updated and changed, particularly in the ICIS-NPDES and FRS databases. Therefore, any changes made or reported to these databases after that time will not be reflected in this mailing list. 

ICIS-NPDES Data Processing
The mailing list should include all POTWs that are currently operating. Within the ICIS-NPDES database, there are three fields that ERG used to distinguish a facility as a POTW and as currently operating: facility type indicator, permit status code, and SIC code.
Facility Type Indicator  -  ICIS-NPDES includes records for unique NPDES permit numbers and assigns each record as "POTW", "NON-POTW", and "FEDERAL" based on facility characteristics (U.S. EPA, 2017). ERG included all records with a Facility Type Indicator of POTW. ERG also reviewed facilities assigned a facility type indicator of NON-POTW and SIC code 4952 (Sewerage Systems) to determine if other facilities could be added (see Section 1.2.1). In addition, ERG reviewed information to identify general permits to include (see Section 1.2.2). 
    
      The POTW/NON-POTW classification is updated occasionally in ICIS-NPDES. Therefore, classifications identified during one data download may not be the same as classifications obtained during a previous download. ERG reviews these updates following every download and adds facilities to the mailing list as appropriate. 

Permit Status Code  -  ICIS-NPDES classifies NPDES permits as "effective," "pending," "administratively continued," "expired," "terminated," and "not needed." ERG excluded NPDES permits labeled "terminated" and "not needed" from the mailing list. It is important to note permit status is not a required field for these ICIS-NPDES data (i.e., the field could be blank for some facilities). 

NON-POTW Classification Investigation
ERG investigated the Facility Type Indicator and determined some permits labeled as NON-POTW and SIC Code 4952 may still be within the study's scope. Table 1-2 summarizes the NPDES permits ERG added to the mailing list by reviewing state websites or individual permits. ERG recognizes this analysis may have inadvertently added facilities not within the study scope if the sample permits investigated did not fully represent the group as a whole (e.g., a group determined to have domestic dischargers also includes MS4 permits).
Table 1-2. NON-POTW Additions
                                     State
                               NPDES Identifier
                                 Reference [a]
Kansas
KS0
NA
Maryland
MD0
NA
Minnesota
MN0
NA
Michigan
MI0
NA
Ohio
OH0
http://www.epa.ohio.gov/portals/35/permits/OHIO_NPDES_Permit_Contact_Info.xls
Pennsylvania
PA0
http://www.portal.state.pa.us/portal/server.pt
Virginia
VA0
NA
Washington
WA0
www.ecy.wa.gov/programs/wq/pstoxics/Phase2POTWData20091013.xls
[a] ERG reviewed the reference noted to determine if the permits noted as NON-POTW with SIC code 4952 in ICIS-NPDES could potentially be POTWs. If no reference is identified, ERG personnel reviewed individual permits and determined if a pattern emerged.
This investigation was done in mid-2016 with an older ICIS-NPDES download. Due to the time required to investigate individual facilities, this analysis has not been replicated with newer ICIS-NPDES downloads. 
General Permits
ERG reviewed each available state and Regional EPA website to determine the applicable general permits that should be added to the mailing list (i.e., those that cover POTWs). ERG also utilized a NPDES General Permit Web Inventory hosted by EPA. Table 1-3 shows general permits that ERG determined were within the study scope and added to the mailing list. Some groups may have already been included in the mailing list because they are considered a POTW (see Facility Type Indicator above), but others were considered NON-POTW at the time of the download.
Table 1-3. List of General Permits
                                     State
                                General Permit
                                Description [a]
                                    Source
Alaska
AKG573000
Secondary treatment
http://dec.alaska.gov/Water/WPSdocs/AKG572000_docs.pdf
Alaska
AKG572000
Small lagoon
http://dec.alaska.gov/Water/WPSdocs/AKG573000_docs.pdf
Arizona
AZG010002
Domestic wastewater discharge 
http://legacy.azdeq.gov/environ/water/permits/download/gpmd.pdf
Arizona
AZGP10001
Domestic wastewater discharge
http://legacy.azdeq.gov/environ/water/permits/download/gpid.pdf
Colorado
COG589000
Domestic wastewater treatment facilities with various discharge criteria.
http://ceae.colorado.edu/~silverst/cven5534/589000%20CDPES%20permit%20form.pdf
Colorado
COG588000

https://www.colorado.gov/pacific/sites/default/files/WQ_COG588000-PERMIT.pdf
Colorado
COG587000
Tribal lagoon permit
--
Illinois
ILG580
Domestic wastewater discharge
http://www.epa.state.il.us/public-notices/2013/lagoon-general-npdes-permit/permit-ilg580.pdf
Illinois
ILG582
Small flow
http://www.epa.state.il.us/public-notices/2013/lagoon-general-npdes-permit/permit-ilg582.pdf
Louisiana
LAG530000
Sanitary wastewater with various applicable flow classes. 
http://www.deq.louisiana.gov/portal/portals/0/permits/lpdes/pdf/lag53%2012-1-12.pdf
Louisiana
LAG540000

http://www.deq.louisiana.gov/portal/portals/0/permits/lpdes/pdf/lag540000%202013.pdf
Louisiana
LAG560000

http://www.deq.louisiana.gov/portal/portals/0/permits/lpdes/pdf/lag560000%20final%20permit%20class%20iii%20sanitary%20discharge%20general%20permit.pdf
Louisiana
LAG570000

http://www.deq.louisiana.gov/portal/portals/0/permits/lpdes/general%20permits%20word/class%20iv%20general%20permit%20final.pdf
Massachusetts
MAG580000
Small flow
http://www.epa.gov/region1/npdes/permits/potw/POTWGP-2011.pdf
Michigan
MIG580000
Stabilization lagoon
http://www.michigan.gov/documents/deq/wrd-npdes-generalpermits-MI580000_446067_7.pdf
Michigan
MIG570000
Secondary treatment
http://www.michigan.gov/documents/deq/wrd-npdes-generalpermit-MIG570000_491979_7.pdf
Minnesota
MNG580000
Stabilization lagoon
https://www.pca.state.mn.us/sites/default/files/wq-wwprm9-10.pdf
Montana
MTG580000
Domestic wastewater discharge
http://deq.mt.gov/wqinfo/MPDES/pdfs/LagoonGP-FINAL.pdf
Montana
MTG589000
Indian Country lagoons
https://www.epa.gov/sites/production/files/2016-01/documents/mtg589xxx2015lgppermitfinalnov12.pdf
New Hampshire
NHG580000
Small flow
http://www.epa.gov/region1/npdes/permits/potw/POTWGP-2011.pdf
North Dakota
NDG589000
Indian Country lagoons
https://www.epa.gov/sites/production/files/2016-01/documents/ndg589xxx2015lgppermitfinalnov12.pdf
North Dakota
NDG420000
Domestic mechanical/package plant
http://www.ndhealth.gov/wq/wastewater/permits/ndg42per20130101f.pdf
North Dakota
NDG320000
Small lagoons discharging to different state classified waters
http://www.ndhealth.gov/wq/wastewater/permits/32000per20091001f.pdf
North Dakota
NDG220000

http://www.ndhealth.gov/wq/wastewater/permits/22000per20140401f.pdf
North Dakota
NDG120000

http://www.ndhealth.gov/wq/wastewater/permits/12000per20140401f.pdf
Oklahoma
OKG58
Municipal lagoons
http://www.deq.ok.gov/wqdnew/opdes/municipal/general_permits/okg58.pdf
Pennsylvania
PAG-04
Small flow
http://www.elibrary.dep.state.pa.us/dsweb/get/document-100482/3800-pm-bpnpsm0093d%20sample%20permit.pdf
South Carolina
SCG570000
Domestic wastewater discharge
http://www.scdhec.gov/environment/docs/scg570000.pdf
South Dakota
SDG589000
Indian Country lagoons
https://www.epa.gov/sites/production/files/2016-01/documents/sdg589xxx2015lgppermitfinalnov12.pdf
Utah
UTG589000
Indian Country lagoons
https://www.epa.gov/sites/production/files/2016-01/documents/utg589xxx2015lgppermitfinalnov12.pdf
West Virginia
WV0103110
Small flow
http://www.dep.wv.gov/WWE/permit/general/Documents/Sewage%20GP.pdf
Wyoming
WYG589000
Indian Country lagoons
https://www.epa.gov/sites/production/files/2016-01/documents/wyg589xxx2015lgppermitfinalnov12.pdf
a Note: "Small flow" and other descriptors may mean different things as determined by the issuing state. Generalized descriptions are listed here to provide details on why permit is an appropriate addition.
State Contact Lists
Though EPA considers ICIS-NPDES to represent the most current and complete data set nationally identifying POTWs, stakeholders have noted that state systems may have more current information. Therefore, EPA solicited assistance from the Association of Clean Water Administrators (ACWA) to gather facility lists and contact information from its members. Table 2-1 lists those states that responded to the request and the information they provided. Responses varied in detail, but most documents had at least a facility name and contact name where available. The information provided by the states is included in the docket.

             Table 2-1. States that Responded to ACWA 2017 Request
                               Data Source/State
                               Date Received [a]
                                Fields Included
                                       
                                       
                              NPDES permit number
                                   State ID
                                 Facility Name
                              Mailing Address [b]
                              Contact Information
                                       
                                       
                                       
                                       
                                       
                                       
                                     Name
                                  Affiliation
                                     Email
                                     Phone
Alabama
7/28/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       X
                                       X
                                       
Alaska
7/14/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       
Connecticut
6/26/2017
                                       
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       

7/12/2017
                                       
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       

11/15/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       X
                                       X
                                       X
Delaware
7/26/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       
Florida
7/12/2017
                                       X
                                       
                                       X
                                       X
                                       X
                                       
                                       X
                                       X
Hawaii
6/26/2017
                                       
                                       
                                       X
                                       
                                       
                                       
                                       X
                                       
Indiana
7/23/2017
                                       X
                                       
                                       X
                                       X
                                       X
                                       
                                       X
                                       X
Iowa
7/10/2017
                                       X
                                       X
                                       X
                                       X
                                       
                                       
                                       
                                       X
Kansas
7/28/2017
                                       X
                                       X
                                       X
                                       
                                       
                                       
                                       X
                                       
Kentucky
7/14/2017
                                       X
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Michigan
8/9/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       X
                                       X
                                       
Minnesota
7/26/2017
                                       
                                       X
                                       
                                       
                                       X
                                       
                                       X
                                       X

11/27/2017
                                       X
                                       X
                                       X
                                       
                                       X
                                       
                                       X
                                       X
Missouri
7/12/2017
                                       X
                                       
                                       
                                       X
                                       
                                       
                                       X
                                       
Montana
7/10/2017
                                       X
                                       
                                       X
                                       
                                       
                                       
                                       X
                                       

11/15/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       
Nevada
7/28/2017
                                       X
                                       X
                                       X
                                     X [c]
                                       X
                                       X
                                       X
                                       X
New Jersey
7/12/2017
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
New Mexico
7/13/2017
                                       X
                                       
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
Ohio
7/24/2017
                                       X
                                       X
                                       X
                                       
                                       X
                                       
                                       
                                       X
Oklahoma
6/26/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       
Oregon
7/25/2017
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
Pennsylvania
7/5/2017
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X

12/21/2017
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
Rhode Island
7/10/2017
                                       
                                       
                                       X
                                       X
                                       
                                       
                                       X
                                       

7/11/2017
                                       X
                                       
                                       X
                                       
                                       
                                       
                                       X
                                       
South Dakota
7/21/2017
                                       
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       

11/15/2017
                                       X
                                       
                                       X
                                       X
                                       X
                                       
                                       
                                       X
Utah
7/10/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       X
                                       X
                                       
Vermont
7/11/2017
                                       
                                       
                                       X
                                       
                                       
                                       
                                       X
                                       

11/1/2017
                                       X
                                       
                                       X
                                       
                                       
                                       
                                       X
                                       
Virginia
7/28/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       X
                                       X
                                       X

11/16/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       X
                                       X
                                       X
Washington [d]
7/28/2017
                                       X
                                       
                                       X
                                       
                                       X
                                       
                                       X
                                       
a Dates are included because these data may be continually updated and changed. Therefore, any changes made or reported to these databases after that time will not be reflected in this mailing list.
[b] Mailing Address includes Street Address, City, State, and zip.
[c] No zip code included.
[d] Regions (Southwest, Northwest, Central, Eastern) were provided on separate tabs with varying levels of details. Noted here are only those that all four regions had in common.
References
    U.S. EPA, 2017. U.S. Environmental Protection Agency. Discharge Monitoring Report (DMR) Pollutant Loading Tool: Glossary of Terms. Available online at: https://cfpub.epa.gov/dmr/glossary.cfm
