STATISTICAL ASSESSMENT
OF
NATIONAL SIGNIFICANT INDUSTRIAL
USER NONCOMPLIANCE
REPORT
June 1992
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STATISTICAL ASSESSMENT
OF
NATIONAL SIGNIFICANT INDUSTRIAL USER NONCOMPLIANCE
Final Report
June 1992
Submitted to:
U.S. Environmental Protection Agency
Office of Wastewater Enforcement and Compliance
401 M Street, SW
Washington, DC 20460
Submitted by:
Science Applications International Corporation
7600-A Leesburg Pike
Falls Church, VA 22043
EPA Contract No.;6J-C8-0066, WA No. C-2-38 (E)
SAIC Project No. 01-0834-03-2162-000
and
EPA Contract No. 68-C8-0066, WA No. C-3-82 (E)
SAIC Project No. 01-0834-03-2209-500
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
1. THE PURPOSE OF THIS STUDY 1-1
1.1 INTRODUCTION 1-1
1.2 ORGANIZATION OF THIS REPORT 1-4
2. FINDINGS 2-1
2.1 SIU SNC 2-1
2.2 SIU NONCOMPLIANCE 2-2
2.3 SIU PERMIT EVALUATION 2-2
. 3. SELECTING STUDY SIUs 3-1
3.1 STATISTICAL SAMPLING PROTOCOL 3-1
3.2 SELECTION OF POTWs 3-2
3.3 SELECTION OF SIU FILES 3-5
4. SIU FILE EVALUATION PROTOCOLS 4-1
4.1 DEVELOPING AN SIU FILE REVIEW CHECKLIST 4-1
4.1.1 SIU Evaluations 4-1
4.1.2 SIU Permits Evaluation 4-3
4.2 FILE REVIEW DATA COLLECTION PROTOCOLS 4-4
5. QA/QC MEASURES 5-1
6. ANALYSIS OF THE STATISTICAL DATA 6-1
6.1 PREPARATION OF THE DATABASE 6-1
6.2 ADJUSTMENTS TO REFLECT SAMPLE POPULATION 6-1
6.3 DEVELOPMENT OF STANDARD ERRORS 6-4
6.4 DEVELOPING CONFIDENCE LEVELS 6-8
7. DISCUSSION OF STANDARD ERRORS 7-1
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LIST OF FIGURES
Page
FIGURE 1. STRATIFICATION OF U.S. INTO GEOGRAPHIC ZONES/AREAS . 3-4
FIGURE 2. STATISTICAL SAMPLING VARIATION 7-2
FIGURE 3. SIU PERMIT CONTENTS 7-4
FIGURE 4. POTW-TO-POTW VARIATION (CATEGORICALS) 7-5
FIGURE 5. POTW-TO-POTW VARIATION (NONCATEGORICALS) 7-6
LIST OF TABLES
TABLE 1.
TABLE 2.
Page
PROMULGATION DATES OF FEDERAL PRETREATMENT REQUIREMENTS . 1-3
ESTIMATED SIU TOTALS BY GEOGRAPHIC ZONE 7-8
LIST OF APPENDICES
APPENDIX A -
APPENDK B -
APPENDDC C -
APPENDIX D -
APPENDIX E -
APPENDIX F -
APPENDIX G -
APPENDIX H -
DEFINITION OF SIGNIFICANT NONCOMPLIANCE (SNC) FOR INDUSTRIAL
USERS
EPA SNC METHODOLOGY MEMORANDUM
FILE REVIEW CHECKLIST AND REVIEWER INSTRUCTIONS
SIU SNC/NONCOMPLIANCE LEVELS SUMMARY TABLE
SIU SNC/NONCOMPLIANCE, STANDARD ERRORS AND CONFIDENCE
LEVELS SUMMARY TABLE
COMPARISON OF SIU COMPLIANCE AND SIU PERMITS
CHECKLIST QUESTION RESPONSES
COMBINED CHECKLIST QUESTION RESPONSES
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LIST OF ACRONYMS
CFR Code of Federal Regulations
CIU Categorical Industrial User
EPA U.S. Environmental Protection Agency
IU Industrial User
mg/1 milligrams per liter
NA Not Applicable
ND Not Determined
POTW Publicly Owned Treatment Works
PPETS Pretreatment Permits and Enforcement Tracking System
QA/QC Quality Assurance/Quality Control
QC Quality Control
RNC Reportable Noncompliance
SAS Statistical Analysis Software
SE Standard Error
SIU Significant Industrial User
SNC Significant Noncompliance
TOMP Toxic Organic Management Plan
TTO Total Toxic Organics
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EXECUTIVE SUMMARY
BACKGROUND
The General Pretreatment Regulations [40 Code of Federal Regulations (CFR) Part 403] require
Control Authorities [States/Territories or Publicly Owned Treatment Works (POTWs)] to develop,
implement, and enforce comprehensive pretreatment programs to regulate industrial wastewater
discharges into POTWs. Thirty-sight states have pretreatment programs. Five others have elected to
operate state-run programs in lieu of requiring local programs.1 In the absence of an approved state
program, EPA assumes responsibility for running the pretreatment program. At the time of this study
(1991), there were 1,484 U.S. Environmental Protection Agency (EPA) approved POTW
pretreatment programs Nationwide and approximately 27,000 Significant Industrial Users (SIUs)
discharging to these POTWs. Once approved, local POTW programs are overseen by the Approval
Authority (EPA or approved State Agencies). Ultimate responsibility for this oversight rests with
EPA's Office of Wastewater Enforcement and Compliance.
As part of its oversight program, EPA has established criteria, known as Reportable
Noncompliance Criteria (RNC), to evaluate POTW pretreatment program implementation and
enforcement. One element of these criteria, "enforcement effectiveness," considers the Significant
Noncompliance (SNC) rate of SIUs. Section 403.8(f)(2)(vii) of the General Pretreatment Regulations
defines SIU SNC (see also Appendix A). On September 9, 1991, EPA issued a memorandum
clarifying procedures to calculate SIU SNC (see Appendix B).
To enable EPA to fulfill its oversight responsibilities, the Agency established a system, known as
the Pretreatment Permits Enforcement Tracking System (PPETS), to track POTW compliance with
their National Pollutant Discharge Elimination System (NPDES) permit and approved pretreatment
program. Data for this system are primarily obtained from POTW performance reports and POTW
interviews during audits and inspections conducted by State and Regional personnel.
EPA undertook this study to independently determine, with known statistical confidence, the level
of SIU SNC with pretreatment standards, and self-monitoring and reporting requirements. Since both
'Known as 403.10(e) States: Vermont, Connecticut, Mississippi, Alabama, and Nebraska.
EXECUTIVE SUMMARY
-------
die definition and calculation of SNC are newly promulgated (and in fact, postdate the study period),
this study serves as a baseline for identifying future SNC trends. Specifically, the results of this
study cannot be compared with PPETs data for the same period since the application of SNC at any
given POTW may have differed from the 1991 National methodology. EPA may repeat the study
from time to time as a means of independently verifying future data on the level of SIU SNC reported
by POTWs. Therefore, findings from this study on SNC rates are strictly baseline estimates mat can
be compared against future POTW estimates of SIU SNC only.
PURPOSE AND SCOPE OF THE STUDY
The purpose of the study was to establish an independent baseline against which to measure future
SNC trends using the definition promulgated in July 1990. With that in mind, the study evaluated
SNC that occurred in calendar year 1990, using the National SNC methodology distributed in
September 1991. Study results should not be used to judge the accuracy of past POTW reporting of
SIU SNC since past SNC determinations were not necessarily calculated using current Federal
regulations or the recent EPA methodology. The scope of the study included a population of 60
POTWs from which 640 SIU files were randomly selected for evaluation. The POTWs selected
represent all States except Alaska, Hawaii, and the State-run programs under 403.10(e).2 The study-
POTWs included small (1-19 SIUs), medium (20-75 SIUs) and large (>7S SIUs) programs.
Approximately 50 percent of the SIUs evaluated in the study are subject to National Categorical
Pretreatment Standards.
The study evaluated three aspects of the program during calendar year 1990: (1) the occurrence
of SIU noncompliance with local control mechanism (i.e., permit) requirements; (2) the occurrence of
SIU SNC with these same requirements; and (3) whether permits issued to SIUs which were effective
during calendar year 1990 included all limits (Federal, State and local) and monitoring/reporting
requirements required by regulation.3 Industry compliance was evaluated against permit requirements
rather than the Federal standards to be comparable with subsequent SNC determinations made by
2403.10(e) States: Vermont, Connecticut, Nebraska, Mississippi, and Alabama were not included in
the study as these States are not reported in PPETS.
3In some instances where questions arose, reviewers used additional information (such as permit
applications, sewer use ordinances, and meeting notes).
.. i EXECUTIVE SUMMARY
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POTWs implementing the program (and future PPETS data). SNC determinations were based on
EPA's regulatory definition promulgated on July 24, 1990, and the September 9, 1991, methodology.
This study was limited to a review of information contained in SIU files.
Since this study employed the new regulatory definition and methodology of SNC, its results can
not be compared with previously collected information. For example, since POTWs may or may not
have been using the same criteria as in this study to evaluate SNC, SNC rates determined in this
study and the SNC rates reported by POTWs will not match.
Additionally, no effort was made to determine whether SIUs returned to compliance during the
evaluation period. Therefore, the report does not quantify the universe of SIUs currently violating
pretreatment standards and requirements. Rather, it identifies the percent of SIUs which would have
been in SNC with EPA's current definition of SNC at some point during calendar year 1990.
Similarly, the study did not evaluate the enforcement response(s) taken by POTWs or State or Federal
Agencies in response to SIU SNC. Finally, it should be noted that violation of a discharge standard
by an SIU does not alone indicate that receiving waters are being impaired or degraded by that
industrial user.
METHODOLOGY
Prior to beginning the study, EPA established, as a goal, the identification of the National level of
SIU SNC with 95 percent confidence and a Standard Error (SE) of no more than ±5 percent. To
achieve this goal, five activities had to be undertaken:
1. Develop an appropriate statistical protocol for selecting the study-POTW and SIU populations.
The protocol employed a probability-based, two-phase file selection scheme that first selected
a specified number of POTW programs from the most current Agency list, and then selected
files at random from each chosen POTW.
2. Develop a checklist to evaluate local permits and SIU compliance with those permits. These
materials were field tested at 9 POTWs prior to the assessment and revised accordingly.
3. Implement full-scale file reviews on at least 600 SIUs at 60 study-POTWs between June and
September 1991.
4. Incorporate stringent Quality Assurance/Quality Control (QA/QC) protocols, including:
• A core group of trained inspectors to perform the file reviews
EXECUTIVE SUMMARY
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• Field quality assurance checks to ensure consistency of interpretation
• Cross-checks of the checklist information prior to data entry
• Double entry of all file review data to ensure accuracy in data entry operations.
S. Perform a statistical analysis of the results of the file reviews and evaluate the findings.
FINDINGS
The SE/Confidence Level results, SIU SNC findings, and permit evaluations are summarized
below. See Chapter 2 and Appendices D, E, F, and G of the report for more details on the findings
of the study.
Standard Error (SEVConfidence Level
The desired SE and confidence level were not achieved because: (1) the prestudy estimates of
SNC were much lower than the actual observations of the study; (2) the SNC rates from POTW to
POTW, both within and among the geographic areas studied, were highly variable; and (3) PPETS
estimates of SIUs at the study-POTWs proved inaccurate. Refer to Chapter 7 for a more complete
discussion of why the goal of 95 percent confidence and a SE of no more than ± 5 percent was not
achieved in the study.
The reader should note that the findings are presented first as the "most probable value" and
second as the 90 percent confidence interval. The rates at the lower end of the range have an
associated confidence level of 95 percent. For example, the finding that "35 percent of SIUs were in
SNC with discharge standards," means that the most probable value is 35 percent and there is 95
percent confidence that the SNC rate with discharge standards is at least 24 percent.
SIU SNC
These 1990 SIU SNC levels are based on four 6-month evaluation periods. Specifically, the
periods include the 6-month periods ending March 31, 1990; June 30, 1990; September 30, 1990; and
December 31, 1990. Therefore, determination of SNC required a review of 15 months of SIU data
(i.e., October 1, 1989, through December 31, 1990). The numbers presented indicate the percent of
EXECUTIVE SUMMARY
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SIUs identified in SNC at least once during the evaluation period. As such, these numbers are not
indicative of the SNC rate at any given point of time during 1990.
• 35 percent of SIUs would have been in SNC (as currently defined by EPA) with discharge
standards (categorical standards and local limits). There is 90 percent confidence the value
falls between 24 percent and 46 percent.
• 36 percent of SIUs would have been in SNC (as currently defined by EPA) with pretreatment
self-monitoring and reporting requirements. There is 90 percent confidence the value falls
between 20 percent and 52 percent.
• 54 percent of SIUs would have been in SNC (as currently defined by EPA) with discharge
standards and/or self-monitoring and reporting requirements. There is 90 percent confidence
the value falls between 32 percent and 75 percent.
• The study reveals no statistically significant differences between categorical SIU and
noncategorical SIU SNC rates for standards, monitoring/reporting, or overall
standards/monitoring and reporting.
SIU Permit Evaluation
This summary of the SIU permit evaluation is based on a review of SIU permits and applicable
data for the 12-month period starting January 1, 1990, and ending December 31, 1990. The findings
presented below should not be construed to indicate POTW compliance status since this study was not
designed for that purpose.
POTWs were legally responsible for implementation of local limits and categorical standards at
the time of the study. In contrast, some POTWs were not legally responsible for implementation of
some of the monitoring and reporting conditions since the General Pretreatment Regulations were
revised in 1988 and 1990 to include additional SIU monitoring and reporting requirements. A POTW
is not required to implement new regulatory requirements until its NPDES permit has been modified
to include those requirements and it is likely that NPDES permits for some of the study-POTWs had
not been revised prior to the study to require implementation of these new conditions.4
13 percent of SIU permits did not include all applicable local discharge standards. There is
90 percent confidence the value falls between 4 percent and 22 percent.
4NPDES permits are usually reissued/revised on a five-year cycle.
EXECUTIVE SUMMARY
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34 pa-cent of SIU pennits did not include all applicable categorical discharge standards.
There is 90 percent confidence the value falls between 14 percent and 53 percent.
Of those POTWs using self-monitoring, 64 percent of SIU pennits did not include all
applicable Federal self-monitoring requirements, including some for which the POTW may not
have been legally responsible. There is 90 percent confidence the value falls between 41
percent and 87 percent.
56 percent of SIU permits did not include all applicable Federal reporting requirements,
including some for which the POTW may not have been legally responsible. There is 90
percent confidence the value falls between 39 percent and 74 percent.
79 percent of SIU permits did not include at least one of the applicable Federal requirements
above (i.e., local limits, categorical discharge standards, and Federal self-monitoring
requirements and reporting requirements for which the POTW may not have been legally
responsible). There is 90 percent confidence the value falls between 56 percent and 99
percent.
The study reveals no apparent significant differences in the SIU SNC level based on the
completeness or accuracy of the local permit.
EXECUTIVE SUMMARY
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1. THE PURPOSE OF THIS STUDY
1.1 INTRODUCTION
The General Pretreatment Regulations [40 Code of Federal Regulations (CFR) Part 403] require
Control Authorities [States/Territories or Publicly Owned Treatment Works (POTWs)] to develop,
implement, and enforce comprehensive pretreatment programs to regulate industrial wastewater
discharges into POTWs. Thirty-eight states have pretreatment programs. Five others have elected to
operate state-run programs in lieu of requiring local programs.5 In the absence of an approved state
program, EPA assumes responsibility for running the pretreatment program. At the time of this study
(1991), there were 1,484 U.S. Environmental Protection Agency (EPA) approved POTW
pretreatment programs Nationwide and approximately 27,000 Significant Industrial Users (SIUs)
discharging to these POTWs. Once approved, local POTW programs are overseen by the Approval
Authority (EPA or approved State Agencies). Ultimate responsibility for this oversight rests with
EPA's Office of Wastewater Enforcement and Compliance.
As part of its oversight program, EPA has established criteria, known as Reportable
Noncompliance Criteria (RNC), to evaluate POTW pretreatment program implementation and
enforcement. One element of these criteria, "enforcement effectiveness," is a measure of the
Significant Noncompliance (SNC) rate of SIUs. Section 403.8(f)(2)(vii) of the General Pretreatment
Regulations defines SIU SNC (see also Appendix A). On September 9, 1991, EPA issued a
memorandum clarifying procedures to calculate SIU SNC (see Appendix B).
To enable EPA to fulfill its oversight responsibilities, the Agency established a system, known as
the Pretreatment Permits Enforcement Tracking System (PPETS), to track POTW compliance with
their National Pollutant Discharge Elimination System (NPDES) permit and approved pretreatment
program. Data for this system are primarily obtained from POTW performance reports and POTW
interviews during audits and inspections conducted by State and Regional personnel.
EPA undertook this study to independently determine, with known statistical confidence, the level
of SIU SNC with pretreatment standards, and self-monitoring and reporting requirements. Since both
3Known as 403.10(e) States: Vermont, Connecticut, Mississippi, Alabama, and Nebraska.
THE PURPOSE OF THIS STUDY
-------
die definition and calculation of SNC are newly promulgated (and in fact, postdate the study period),
this study serves as a baseline for identifying future SNC trends. Specifically, the results of this
study cannot be compared with PPETs data for the same period since the application of SNC at any
given POTW may have differed from the 1991 National methodology. EPA may repeat the study
from time to time as a means of independently verifying future data on the level of SIU SNC reported
by POTWs. Therefore, findings from mis study on SNC rates are strictly baseline estimates that can
be compared against future POTW estimates of SIU SNC only.
In establishing the baseline, the study evaluated three aspects of SIU (and POTW) performance
during calendar year 1990 using the definition promulgated in July 1990: (1) the occurrence of SIU
noncompliance with local control mechanisms (e.g., permits) requirements; (2) the occurrence of SIU
SNC with these same requirements; and (3) the consistency of SIU permits with Federal regulations.
EPA intentionally evaluated SIU compliance against permits (i.e., against pretreatment requirements
as imposed by the POTW) rather than the Federal standards, to be comparable to future SNC
determinations made by POTWs implementing the program (and future PPETS data). This was done
in recognition of the fact that evaluating compliance with Federal requirements (mainly categorical
standards) would be extremely difficult without the benefit of industrial site visits to determine
process operations, appropriate sampling locations, and the applicability of the combined wastestream
formula. The study approach ensured the results would be reflective of industry compliance with
POTW requirements as identified in POTW-issued permits.
One concern that arose during the planning of the study was that all POTW-issued permits might
not reflect the application of the Federal pretreatment requirements. To address this concern, the
study also identifies those Federal requirements not yet implemented by the POTW (see Appendix C,
page C-3). EPA stresses that the absence of these Federal requirements in local permits may not
constitute noncompliance on the part of the POTW since several of the requirements were not
promulgated until late 1988 and mid-1990 (see Table 1) and the POTW's NPDES permit may not
have required the POTW to implement these revisions at the time of the study.
THE PURPOSE OF THIS STUDY
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TABLE 1. PROMULGATION DATES OF FEDERAL
PRETREATMENT REQUIREMENTS
Federal Requirement
Local Limits
Categorical Standards
Periodic Reports
24-Hr Notification
30-Day Resampling
Sampling Frequency
Regulated Parameters
Sample Type
Analytical Procedures
Cite (40 CFR)
403.5(c) & 403.8(f)(i)(H)
403.6 & 403.8(00)00
403.12(e)'
403.1201)2
403.12(g)(2)
403.12(g)(2)
403.12(6)'
403.1201)2
403.12(e)1
402.12(g)(4)
403.12(g)(4)1
403.12002
Promulgation Date
January 28, 1981
January 28, 1981s
January 28, 1981
July 24, 1990*
October 17, 1988
October 17,1988
January 28, 1981
July 24, 1990*
January 28, 1981'
January 28, 1981
January 28, 1981
July 24, 1990*
'Categorical Industrial User requirements
^oncategorical Significant Industrial User requirements
This date reflects the promulgation date of the Federal pretreatment requirement requiring
general compliance with categorical standards. However, the actual compliance date for specific
standards is tied to the promulgation or repromulgation date of each categorical standard. For
example, the organic chemicals, plastics, and synthetic fibers industrial category was not
promulgated until November 5, 1987 with the RJ compliance date not to exceed three years later.
The reader should be aware that July 24, 1990, revisions to the General Pretreatment Regulations
specified minimum contents of SIU permits. Prior to this time, specific permit conditions were
not required.
THE PURPOSE OF THIS STUDY
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The study consisted of an examination of 1990 data for 640 SIU files at 60 POTWs and was
limited to a review of information contained in SIU files (for additional detail on the selection
process, see methodology described in Chapter 3). The evaluation was based on the permit(s)
effective during calendar year 1990. A checklist, developed as part of mis study, was used to gather
bom the SIU and POTW information for subsequent statistical analysis. Stringent Quality
Assurance/Quality Control (QA/QC) protocols were incorporated throughout all phases of the study to
ensure integrity of the data collected (for additional detail on QA/QC, see Chapter 5). This review
was conducted onsite at POTWs from June to September 1991.
As mentioned earlier, the study was intended primarily to measure the occurrence of SIU SNC
and SIU noncompliance. The study was not intended to:
• Identify POTW's that are failing to implement Federal pretreatment requirements
• Evaluate or verify past SNC determinations made by POTWs (since existing data are not
necessarily based on the new SNC definition and guidance)
• Indicate the specific reasons for both SIU SNC and SIU noncompliance with discharge
standards and monitoring/reporting requirements
• Indicate whether SIUs subsequently returned to compliance after SNC occurred
• Indicate the appropriateness of any enforcement actions taken by the POTW in response to SIU
noncompliance
• Provide a comparison to NPDES estimates of SNC
• Indicate a threat to water quality or frequency of plant inhibition
• Evaluate SIUs in 403.10(e) States and SIUs in cities without approved pretreatment programs.
1.2 ORGANIZATION OF THIS REPORT
The remainder of this report consists of six chapters. Chapter 2 summarizes the study findings
and conclusions. Chapter 3 describes the statistical considerations involved in this project and the
study design that was adopted. Chapter 4 describes the SIU file evaluation protocols including
development of the checklist, field testing and refinement of the checklist questions, and development
of field protocols to resolve discrepancies within the review process. Chapter 5 outlines QA/QC
measures taken before, during, and after the file review process to ensure data consistency and
THE PURPOSE OF THIS STUDY
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accuracy. A description of the statistical analyses performed on data generated as a result of die file
reviews is provided in Chapter 6. Finally, Chapter 7 presents a detailed explanation of the statistics
used in deriving study findings and conclusions.
THE PURPOSE OF THIS STUDY
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2. FINDINGS
The following study findings are presented in three groups: SIU SNC, SIU noncompliance, ?-.d
SIU permit evaluation. Note that the summaries represent only SIUs discharging to POTWs with
approved pretreatment programs. A summary table of SIU SNC levels, SIU noncompliance levels,
and the SIU permit evaluation is provided as Appendix D. SEs and confidence levels associated with
the summary tables are set out in Appendix E. Responses to individual checklist questions are
provided as Appendix G. Summary tables of the combination of questions to determine SNC
noncompliance levels for various types of program components (i.e., discharge and reporting or TTO
and non-TTO) are provided as Appendix H.
The reader should note that the findings are presented first as the "most probable value" and
second as the 90 percent confidence interval. The rates at the lower end of the range have an
associated confidence level of 95 percent. For example, the finding that "35 percent of SIUs were in
SNC with discharge standards," means that the most probable value is 35 percent and there is 95
percent confidence that the SNC rate with discharge standards is at least 24 percent.
2.1 SIU SNC
The 1990 SIU SNC levels are based on four 6-month evaluation periods. Specifically, the periods
include the 6-months ending March 31, 1990; June 30, 1990; September 30, 1990; and December 31,
1990. Therefore, determination of SNC required a review of 15 months of SIU data (i.e., October 1,
1989, through December 31, 1990). These results represent the universe of SIUs which would have
been in SNC with EPA's current definition of SNC.
• 35 percent of SIUs would have been in SNC (as currently defined by EPA) with discharge
standards. There is 90 percent confidence the value falls between 24 and 46 percent.
• 36 percent of SIUs would have been in SNC (as currently defined by EPA) with self-
monitoring and reporting requirements. There is 90 percent confidence the value falls between
20 and 52 percent.
• 54 percent of SIUs would have been in SNC (as currently defined by EPA) for violations of
discharge standards and/or monitoring/reporting requirements. There is 90 percent confidence
the value falls between 32 and 75 percent.
FINDINGS
2-1
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The study reveals no statistically significant differences between the SNC rates of categorical
SIUs and the SNC rate of noncategorical SIUs.
2.2 SIU NONCOMPLIANCE
The 1990 SIU noncompliance rates are based on a review of data for the twelve-month period
starting January 1, 1990,and ending December 31, 1990.
63 percent of SIUs violated at least one permit discharge standard. There is 90 percent
confidence the value falls between 47 and 79 percent.
46 percent of SIUs violated at least one sampling requirement. There is 90 percent confidence
the value falls between 33 and 59 percent.
67 percent of SIUs violated at least one reporting requirement (38 percent if lateness of
reporting is excluded). There is 90 percent confidence the value falls between 46 and 89
percent (between 28 and 48 percent if lateness of reporting is excluded).
81 percent of SIUs violated at least one pretreatment requirement (discharge or reporting).
There is 90 percent confidence the value falls between 57 and 100 percent.
The study reveals no statistically significant differences between the noncompliance rates of
categorical SIUs and the noncompliance rates of noncategorical SIUs for discharge, reporting,
or overall rates.
The study reveals no apparent significant differences in SNC or noncompliance levels, even where
the POTW had imposed incorrect (less stringent) requirements on SIUs. That is, the same SNC level
was observed where less stringent requirements were incorrectly set out in SIU permits (see Appendix
F for more detailed data on the differences in SIU compliance based on POTW implementation).
2J SIU PERMIT EVALUATION
The file review checklist contained four questions about the SIU's permit. These questions
attempted to discern whether the permits contained all local and categorical discharge standards and
Federal reporting and self monitoring requirements. Although some of the findings may reflect a
need for improved POTW implementation, the purpose of the study was to evaluate SIU permit
conditions to develop a baseline with the current Federal pretreatment program, irrespective of POTW
requirements. The study POTWs may not be in violation of Federal pretreatment standards if (1) the
required language is included in the POTW's Sewer Use Ordinance (SUO) and/or approved program
FINDINGS
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rather than the SIU permit or (2) the POTW's NPDES permit has not been reissued/modified to
reflect the current Federal requirements.
A POTW's approved pretreatment program requires it to develop and implement the pretreatment
program through specific language in its NPDES permit(s). Therefore, a POTW is not legally
accountable for implementation of ngw. regulatory pretreatment requirements until its NPDES permit
has been modified to include those requirements.
A chronological summary of events leading up to the study may help to clarify these points. In
October 1988, the Pretreatment Implementation Review Task Force (PIRT) changes to the General
Pretreatment Regulations Qocated at 40 CFR Part 403) were promulgated. In July 1990, the
Domestic Sewage Study (DSS) changes to 40 CFR Part 403 were promulgated. Recognizing that the
study period was October 1989 to December 1990, the results to these questions should not be
considered to be dispositive of POTW compliance status. Rather, the results are properly used as a
baseline against which future assessments of POTW compliance with pretreatment requirements can
be compared.
The study included an evaluation of four aspects of SIU permit contents: local limits, categorical
standards, self-monitoring, and reporting. The first two components, local limits and categorical
standards, were effective at the time of the study and POTWs were legally responsible for
implementation in 1990. In contrast, POTWs were not necessarily legally responsible for
implementing some self-monitoring and reporting requirements at the time of the study. The July 24,
1990, revisions to the General Pretreatment Regulations specify that ail SIUs are required to self-
monitor and submit periodic reports at least twice a year. Prior to that time, Federal regulations only
required categorical SIUs to meet this requirement. With respect to reporting, the requirement to
notify the POTW within 24 hours of becoming aware of a violation in self-monitoring data and to
repeat the sampling and analysis and submit the results of the repeat analysis within 30 days after
becoming aware of the violation were not necessarily in effect at all study-POTWs.
With these caveats in mind, a summary of the analysis of the 640 SIU permits is provided below.
Each rinding is followed by a brief discussion explaining the results in more detail.
FINDINGS
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FINDING 1:
• 13 percent of SIU permits did not include all applicable local discharge standards. There
is 90 percent confidence the value falls between 4 and 22 percent.
The finding that die POTW did not apply local limits can be attributed to one or more of die
following in approximately equal proportion: (1) POTW failure to apply a more stringent local limit
when a less stringent categorical standard was placed hi the permit, (2) POTW application of local
limits for conventional parameters that were identified as surchargeable pollutants in die POTW's
ordinance (with no threshold limits identified), (3) SIU discharges exceeded local limits but die permit
did not contain die applicable limit for that parameter, and (4) die nature of SIU process operations
indicated an obvious need for a specific local limit that was not included in die SIU permit (e.g., a
permit for an SIU blending zinc-based chemicals and discharging rinse waters to die POTW did not
contain die zinc local limit).
FINDING 2:
• 34 percent of SIU permits did not include all applicable categorical standards. There is
90 percent confidence the value falls between 14 and 53 percent.
The predominant reason for die lack of application of some categorical standards in SIU permits
(comprising approximately 60 percent of die total) was die failure of die POTW to include ajl
applicable categorical standards. Some POTWs may have espoused reasons for not limiting all
categorical pollutants. For instance, correspondence between die POTW and die industrial user
subject to categorical standards (CIU) regarding die non-use of pollutants or past sampling episodes
may have provided justification for not limiting an applicable categorical pollutant. However, 40
CFR 403.12(e) requires any CIU to submit a report indicating die nature and concentration of all
pollutants which are limited by such categorical pretreatment standards. The three pollutants most
often excluded from CIU permits were cyanide, silver, and total toxic organic pollutants (TTO).
In addition, several other, less frequent, problems are represented by die noncompliance numbers
presented above. Specifically: (1) failure to properly implement die 4-day average limitation, (2)
FINDINGS
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failure to properly implement the monthly average limitation, (3) failure to properly use the combined
wastestream formula (CWF), and (4) incorrect categorization of CIUs.
The deficiencies identified are typically easy to identify with the exception of the applicability of
the CWF and categorization of CIUs. These two deficiencies most often require an SIU site visit to
make the correct determination. As such, the deficiencies associated with the CWF and
categorization of CIUs identified in mis report represent those deficiencies which appeared to be
obvious inconsistencies with information obtained from the file review. For example, one SIU
submitted a permit application identifying the need for the combined wastestream formula at a given
sampling location, yet this requirement was not translated into the SIU's permit. The reader should
note that, in some cases, even this apparent POTW deficiency may be attributable to other
circumstances which could render the permit limitations correct (e.g., additional correspondence).
FINDING 3:
Of those POTWs using self-monitoring, 64 percent of SIU permits did not include all
applicable Federal self-monitoring requirements, including some for which the POTW
may not have been legally responsible. There is 90 percent confidence the value falls
between 41 and 87 percent.
These findings indicate whether the POTW was applying appropriate sampling frequencies,
required parameters, sample types, and analytical procedures. The two major concerns, each
occurring in about one-third of the permits, included improper sampling collection methods specified
by the POTW and failure to require sample analysis using 40 CFR Part 136 procedures.
With regard to sample types, the most frequently misapplied conditions were for pH, oil and
grease, and cyanide. In these instances, POTWs required composite samples rather than grab
samples. The reader should note that in many of these cases, the SIU correctly collected grab
samples even though the permit specified composite samples were to be taken.
The predominant problems associated with analytical procedures included: (1) not specifying
analytical procedures, (2) referencing that a certified lab must conduct the sampling and analysis (but
not requiring appropriate procedures), and (3) referencing "Standard Methods" as opposed to the EPA
FINDINGS
2-5
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analytical methods set out in 40 CFR Part 136. There were also instances when the POTW specified
inappropriate analytical methods.
FINDING 4:
• 56 percent of SIU permits did not include all applicable Federal reporting requirements,
including some for which the POTW may not have been legally responsible. There is 90
percent confidence the value falls between 39 and 74 percent.
The review determined that (1) over half of the SIU permits did not contain language requiring
the SIU to inform the POTW of discharge violations within 24-hours, (2) about 40 percent of the SIU
permits did not contain language requiring the SIU to resample within 30 days after a discharge
violation, and (3) approximately 20 percent of the SIU permits failed to require SIUs to report
measured or estimated flows as required by 40 CFR 403.12.
Many permits did not contain the 24-hour notification requirement or the 30-day resampling
requirement. The Federal pretreatment regulations including these requirements were promulgated in
1988 and NPDES permits may not have been revised to reflect these changes. This is described in
more detail in Section 4.1.2.
FINDING 5:
• 79 percent of SIU permits did not include at least one of the applicable Federal
requirements above (i.e., local limits, categorical discharge standards, and self-monitoring
and reporting requirements, some for which the POTW may not have been legally
responsible). There is 90 percent confidence the value falls between 56 and 99 percent.
The findings of this study indicate that a majority of SIU permits effective at the time of the
review did not contain all discharge standards and self-monitoring and reporting requirements in
1990. This does not reflect the overall health of POTW implementation, rather, these numbers
should be used as a baseline for future evaluations of POTW implementation. As such, trends in the
quality of SIU permits will be identifiable as similar studies are conducted in the future.
2 * i FINDINGS
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3. SELECTING STUDY SIUs
3.1 STATISTICAL SAMPLING PROTOCOL
The primary goal of this study was to establish a baseline estimate of National SIU SNC using the
new "SNC" definition and methodology for its use. More specifically, the study was intended to
provide a baseline for future evaluations of SIU compliance, POTW program effectiveness, and
EPA's information regarding SIU SNC with pretreatment standards, and self-monitoring and reporting
requirements. To accomplish this goal, a random, probability-based sample of SIU files were
selected for review at a predetermined number of POTW facilities.
Due to the large number and diversity of locations of every SIU, the study was conducted using a
probability-based sampling scheme. A probability sampling scheme allowed estimates of
noncompliance to be made with both a known range of error and known statistical confidence. Such
a sampling scheme can be designed to render results which are estimated to be accurate to within 5
percent of the actual value with 95 percent statistical confidence.
Within the wide range of available probability-based sampling methods, an algorithm for selecting
SIU files was developed that attempted to balance several competing objectives. These objectives
included: (1) design of a sample that allows estimates of overall noncompliance rates to within ±
five percentage points with a high degree of statistical confidence; (2) efficient use of the resources
available for the assessment; and (3) design of a practical sampling strategy that can be easily
implemented by field staff.
To meet the primary statistical objective of estimating both the noncompliance and SNC levels
with high confidence and a low degree of error, it was initially estimated that at least 500 SIU files of
the approximately 27,000 SIUs currently regulated by local pretreatment programs would need to be
selected and reviewed. However, the exact number of file reviews needed to achieve a particular
level of statistical confidence could not be precisely established prior to the site visits, since statistical
confidence depends, in large part, on the actual SIU noncompliance rates (which could not be
determined until after completion of the study). That is, the formula for calculating confidence
intervals includes the noncompliance/SNC rates and the number of files reviewed as the only two
variables in the equation. Therefore, best professional judgments were made of the probable range of
SELECTING STUDY SIUs
3-1
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the true noncompliance rates, based both on previous EPA estimates of SNC and on results of the
field test (described in Chapter 4) conducted in preparation for this study.
The minimum number of file reviews necessary to meet predetermined error ranges and
confidence intervals also depends on the type of probability design used to select the SIU files. The
best known type of probability-based sample is a simple random sample, akin to drawing names out
of a hat representing each of the existing 27,000 SIU files. There were a number of considerations
preventing the use of a simple random sample. First, a comprehensive list of all SIUs does not exist,
thereby making it impossible to choose a simple random sample of 500 SIU files. Second, the
number of regulated categorical and noncategorical industries at any given POTW change over time;
therefore, a complete list of SIUs would soon need updating and additional verification. Finally,
selecting a simple random sample of 500 files would mean that most files would probably be located
at different POTWs throughout the country.
In light of these considerations, a two-phase file selection scheme was developed that first selected
a specified number of POTW facilities from the most current list of such programs, and then selected
SIU files at random from each chosen POTW. This approach took advantage of the natural cluster of
SIU files at POTWs and minimized budgetary and travel expenses for field work. Estimates of the
percentage error in noncompliance levels and the statistical confidence associated with these estimates
were adjusted to reflect the nature of this sampling design (see further discussion in Chapter 6).
3.2 SELECTION OF POTWs
Based on existing data and the field test results, it was judged that at least 50 to 60 POTWs would
be needed to assess noncompliance with 90 to 95 percent statistical confidence and obtain a small (5
percent) error range. These POTWs were randomly selected from predetermined geographic areas.
At the time of the study, there were 1,484 approved POTW pretreatment programs. Since PPETS
did not contain information on the number of categorical and noncategorical SIUs at 157 POTWs,
these POTWs were excluded from the selection process, leaving a potential study universe of 1,327
POTWs.
SELECTING STUDY SIUs
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To maximize the accuracy of the survey results, the POTW selection was made with two primary
considerations in mind. First, a proportional geographic distribution of POTWs was established (see
Figure 1, on page 3-4). Second, a cross-section of SIU files from POTWs of different sizes (based
on the numbers of SIUs regulated by a particular POTW) was made. Since over 1,200 POTWs
report 20 or less SIUs and only 37 POTW programs report more than 100 SIUs, using an equal
distribution of POTW sizes is highly skewed. However, it was deemed important to include large
POTWs in the study since they govern the vast majority of SIUs. Therefore, the selection scheme
was designed to choose roughly an equal number of POTWs of each size, and the Study POTWs were
selected using a two-tiered, stratified random cluster sampling scheme. The tiered factors were
geographic location and POTW program size.
To ensure a geographically proportional distribution of POTWs, the continental United States was
divided into five geographic strata called zones, representing the West, Midwest, South, Northeast,
and Mideast. The study did not evaluate Alaska, Hawaii, or any of the U.S. Territories. Moreover,
the study did not evaluate SIUs located in Alabama, Mississippi, Connecticut, Nebraska, or Vermont,
since these 403.10(e) States regulate all SIUs directly without local POTW pretreatment programs.
The zones were chosen such that the numbers of POTWs and SIUs represented by each zone were
balanced as much as possible without blurring obvious geographic boundaries. Each zone consists of
7 or 8 smaller areas [i.e., typically a State, but in some cases representing half a State (e.g., Northern
California)]. These areas were also chosen so that the number of POTWs and SIUs across all areas
were balanced. Finally, areas were kept small enough to minimize travel for the field teams.
Clearly, most areas were left out of the sample using this approach. However, each area had a
known chance of being selected for the assessment. This allowed for the construction of accurate
estimates of noncompliance and an adjustment for the possible error associated with the sampling
design.
Two areas from each zone were randomly selected for the sample. Since each area contained a
cluster of POTWs, this stage of the selection process involved cluster sampling. Not all areas were
given an equal chance for selection. Rather, greater weight was given to those areas containing larger
numbers of POTWs. Such disproportionate probability sampling allowed a more precise and accurate
final noncompliance rate to be estimated from the sample data. The justification for this method is
that, for purposes of this study, the SIU compliance status is tied to the individual POTWs. By
SELECTING STUDY SIUs
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KEY
Q NORTHEAST
EH MIDEAST
E3 SOUTH
CD MIDWEST
E3 WEST
D STATE-RUN PROGRAMS
LOCATION OF STUDY-POTWS NOTED WITH A
FIGURE 1. STRATIFICATION OF U.S. INTO GEOGRAPHIC ZONES/AREAS
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sampling larger POTWs, the compliance status of more SIUs can be characterized than by selecting
smaller POTWs.
The second tier factor was POTW program size. The POTWs within each area were stratified
into three groups based on their number of SIUs. The first group consisted of all POTWs with 19 or
less SIUs; the second group consisted of POTWs with between 20 and 74 SIUs; and the last group
consisted of POTWs with 75 or more SIUs. The effect of grouping these POTWs was to ensure mat
larger POTWs were sampled with greater probability than smaller POTWs. As noted above, the
justification for using this weighted probability was the fact mat many of the Nation's SIUs are
located at large POTWs. If the large and small POTWs had an equal probability of being selected for
the study, the results could have been criticized for not being truly representative since few, if any,
large programs may have been evaluated.
Once the areas and groups were established, a prespecified number of POTWs were randomly
selected with equal probability from each size stratum within a selected area. The number of sample
POTWs selected from each geographic zone was proportional to the total number of POTWs in the ••
zone. Half of the POTWs were chosen from the first of the two selected areas, half were chosen
from the second. Within a given area, the sample POTWs were chosen at random and allocated as
equally as possible among the three size strata. As noted above, this was done to guarantee that some
large POTWs were selected. However, the degree of both stratification and oversampling were taken
into account during the statistical weighing of the data (see Chapter 6).
In general, the process of stratification serves to improve the accuracy of the statistical estimates
of noncompliance over that achievable through a simple random sampling of POTWs (see Cochran,
Sampling Techniques. 1977). Stratification is particularly helpful when actual noncompliance rates
differ significantly by geographic location and/or POTW program size.
3.3 SELECTION OF SIU FILES
Prior to conducting the site visit, the study-POTWs were requested to provide a list of all SIU
files. These lists designated each SIU as either a categorical or noncategorical SIU. The list of SIUs
was then subdivided into two lists - categorical SIUs and noncategorical SIUs. These two lists of
SIUs were then each randomly selected and ordered via an automated random number generator. The
SELECTING STUDY SIUs
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SIUs were reviewed by the field teams in the order selected by the computer. The number of files
reviewed consisted of the maximum number possible within 1 day's time at most POTWs and within
2 day's time at a few of the larger facilities. All SIU files were given an equal chance of selection
[i.e., the SIU files were selected and reviewed using a simple, random sample within each type of
SIU file (categorical and noncategorical)]. An equal number of categorical and noncategorical SIUs
were evaluated.
The statistical protocol used for this study is one example of many types of complicated
probability-based sampling designs, in this case involving multi-level stratification and subsampling.
The purpose of such a design is twofold: (1) stratified information about the sizes of POTWs and
numbers of SIUs in each geographic zone can be used to produce an accurate set of noncompliance
estimates; and (2) geographic stratification reduces the travel required. Without using a complex
probability-based design, the accuracy of the final noncompliance estimates could not be scaled to
acceptable levels.
Based on field test results, the anticipated accuracy of the sampling protocol was analyzed prior to
the field work under several different assumptions and scenarios. Under a complex sampling design,
prestudy predictions of this sort are subject to error and could not be guaranteed prior to collection of
the actual data. Still, by selecting 60 POTWs and reviewing 640 files, even under unfavorable
conditions, it was thought that the confidence level attached to the National estimates within ±5
percent sampling error should be at least 80 percent, while under mildly more favorable conditions,
the confidence level should climb to between 90 and 95 percent.
Approximately the same number of files were reviewed at each POTW. However, the actual
number of files examined varied slightly from location to location, partly because very small POTWs
did not possess the target number (ten) of files and partly because the field teams were able to review
files more quickly in some locations (e.g., where files were well maintained and organized) than
others.
SELECTING STUDY SIUs
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4. Sro FILE EVALUATION PROTOCOLS
The development of SIU file review protocols for the study was conducted in three stages:
(1) developing a review checklist; (2) field testing and refinement of the checklist; and (3) developing
QA/QC protocols. Each of these elements is discussed below.
4.1 DEVELOPING AN SIU FILE REVIEW CHECKLIST
The study assessed industry noncompliance with pretreatment requirements as implemented by the
POTW rather than independently evaluating noncompliance with all applicable Federal and local
standards. This approach ensured that the results would be truly reflective of industry compliance
efforts with local permit requirements and will be comparable to future POTW reporting.
The complete SIU file review checklist and accompanying instructions are set out in Appendix C.
The checklist is made up of two sections. Section A is comprised of 11 questions evaluating SIU
noncompliance with local permit requirements and Section B contains 4 questions assessing POTW
implementation of pretreatment standards and minimum monitoring and reporting requirements as
specified in 40 Code of Federal Regulations (CFR) Part 403. This latter Section B was used to
provide a context in which to better understand the SIU SNC results and to both determine a baseline
and identify trends in the contents of SIU permits.
4.1.1 SIU Evaluations
As noted above, Section A of the checklist assessed SIU noncompliance and SNC with discharge
and reporting requirements as established in the SIU's permit. Discharge violations were identified
through a direct comparison of permit limits (both daily maximum and long-term averages) to
monitoring results (both SIU self-monitoring and POTW monitoring). For purposes of
noncompliance, any exceedance or omission of permit requirements was considered to be a
noncompliance event. Upon identification of any single noncompliance event in calendar year 1990
(i.e., a 12-month period), the reviewer advanced to the rest of the checklist (i.e., determinations of
the extent of noncompliance or whether the noncompliance was resolved were not made).
The protocol for evaluating SNC was different. The National methodology requires POTWs to
assess SNC in 6-month periods. The National methodology specifies that these reviews be conducted
SIU FILE EVALUATION PROTOCOLS
4-1
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on a "rolling quartos" basis. Thus, files were reviewed for the 6-month periods ending March 31,
June 30, September 30, and December 31, 1990. Therefore, the period studied to evaluate SNC was
October 1, 1989, through December 31,1990 (i.e., IS months). All monitoring data (i.e., sampling
conducted by bom the POTW and SIU) were considered when evaluating SNC. Separate SNC
calculations were done for daily maximums and long-term averages. That is, all individual
monitoring results obtained in each 6-month period were compared with daily maximum limits to
determine SNC with daily maximum limits. The long-term averages were calculated from the data
and compared to the long-term average limits to determine SNC with these long-term average limits.
In some instances, the field staffs evaluation of SIU SNC with discharge standards may have
been inconsistent with the POTW's evaluation when the POTW implemented the same SNC definition
and methodology. For example, several POTWs identified absolute permit limits for Biochemical
Oxygen Demand (BOD) and Total Suspended Solids CTSS) even though the POTWs' SUO provides
for surcharges above those limits. The study identified exceedances of these limits as violations while
the POTW would have identified these exceedances as surchargeable exceedances (but not violations).
Discharge and reporting requirements for Total Toxic Organics (TTO) were evaluated separately
from other pollutant discharge and reporting requirements. This was because TTO requirements
[including certifications of compliance, analytical testing for a range of organic pollutants, and the use
of Toxic Organic Management Plans (TOMPs)] may be more confusing to POTWs and SIUs alike
and, thus, might be expected to have increased the rate of noncompliance (thereby skewing the results
to reflect primarily TTO noncompliance).6 As an example, an SIU subject to Federal metal finishing
categorical pretreatment standards must meet a daily average TTO limitation of 2.13 milligrams per
liter (mg/1). The POTW may elect to require the SIU to sample for those TTO pollutants expected to
be present; or the POTW may elect to require the SIU to submit a TOMP and certify (to the POTW)
twice a year that the SIU is not dumping toxic organics and is also following conditions of the
TOMP.
SIU compliance with self-monitoring and reporting requirements was evaluated based solely on
conditions in the permit. Reports evaluated included periodic reports, compliance schedule milestone
'Analysis showed that including TTO data did not significantly alter the overall noncompliance rate.
Therefore, the overall assessment of SIU noncompliance and SIU SNC includes the TTO evaluation.
SIU FILE EVALUATION PROTOCOLS
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reports, 24-hour violation notification reports, 30-day resampling reports, and any other reports
required by the permit. Each of these reports were evaluated for the presence of all required
pollutant and flow data, certification requirements, and signatory requirements. If any single item
was missing, that absence was identified as "reporting noncompliance."
An evaluation of the timeliness of the SIU reports was conducted separately from the evaluation
of compliance for reporting requirements. That is, submitting incomplete reports and failure to
submit a report at all were tracked separately from the submission of late reports since most SIUs
submit late reports at one time or another, and the overall assessment of noncompliance with
reporting requirements could be skewed. Similar to the TTO assessment, late reports did not
significantly alter the overall SIU noncompliance rate. Therefore, the overall SIU noncompliance rate
includes late reports as a component of the evaluation. For SNC, the evaluation was based solely on
those reports which were over 30 days late, as specified in the General Pretreatment Regulations.
4.1.2 SIU Permits Evaluation
Section B of the checklist evaluated SIU permits for consistency with Federal pretreatment
regulations existing at the time of the study. Each SIU permit was examined for the direct imposition
of pretreatment standards and self-monitoring and reporting requirements. The evaluation was based
solely on data in the SIU permits irrespective of the POTW's NPDES pretreatment requirements. As
such, disparities between the Federal regulations and the POTW's requirements do not necessarily
indicate POTW noncompliance.
Separate evaluations of the use of local limits and categorical standards as permit limits were
conducted. The primary objective of the local limits evaluation was to identify permits issued to
Categorical Industrial Users (CIUs) that did not apply more stringent local limits. For example, a
permit for a metal finisher that did not have an applicable, more stringent, local limit for zinc (i.e.,
only the less stringent categorical zinc limit appeared in the permit) was determined to be deficient.
SIU permits were also considered deficient where local limits were not being applied to
noncategorical SIUs when sampling data indicated that a local limit would have been appropriate.
For example, one facility packaging zinc-based chemicals routinely had levels of zinc in its discharge
that were higher than the existing local limit for zinc. However, the facility's permit did not include
SIU FILE EVALUATION PROTOCOLS
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the POTW's local limit for zinc. In this case, the SIU permit was identified as deficient. By
contrast, a permit issued to a food processor mat did not have local limits and sampling requirements
for toxic metals was not deemed to be deficient since the field staff could not determine the
appropriateness of toxic metals limitations without the benefit of an industrial site visit or toxic metals
sampling data.
The permit evaluation of categorical discharge standards was relatively straightforward. A permit
was determined to be inadequate if it did not include all applicable parameters or the standards were
misapplied to the CIU. For example, a facility subject to metal finishing standards was determined to
have an inadequate permit because TTO and cyanide were not included in the permit. In addition, a
facility that was required to sample at a location that included dilution flows was determined to have
an inadequate permit if the permit did not include language or calculations indicating that the
categorical standards had to be modified to reflect the dilution streams.
The consistency of SIU self-monitoring and reporting requirements was measured by comparing
permit conditions with minimum Federal requirements. Specifically, permits were identified as
deficient if SIUs were not required to sample and report at least twice a year (unless the POTW
performed the sampling in lieu of self-monitoring) for all regulated parameters as specified in the
Federal regulations. A permit was also considered deficient if it failed to require the appropriate
sampling techniques, 40 CFR Part 136 analytical procedures, 24-hour noncompliance notification, and
30-day resampling requirement.7
4.2 FILE REVIEW DATA COLLECTION PROTOCOLS
After development of a SIU file review checklist, additional protocols were needed to ensure the
success of the study. These protocols included contacting study-POTW personnel, preparation for site
visits, and methodologies for onsite review of SIU files.
Contact with the study-POTWs was made by telephone and correspondence. The purpose of the
study and the methodology employed for selecting POTWs were explained to POTW personnel.
The reader will note that some of these requirements reflect relatively recent changes to the General
Pretreatment Regulations and therefore, may not have been required as part of the POTW's program at
the time of the study.
SIU FILE EVALUATION PROTOCOLS
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POTW officials were asked to confirm the exact number and identity of SIUs discharging to their
systems (differentiating between the number of categorical and noncategorical SIUs). This
information was then used to conduct a random selection of SIU files to be reviewed onsite (see
Section 3.3).
Once at the POTW, industrial files were then examined according to the preselected random
order, alternating between categorical and noncategorical SIUs so that each reviewer reviewed both
types of files. Whenever five files, or multiples of five files, were reviewed at a given POTW, the
reviewers exchanged every fifth file for duplicate review as part of the established Quality Control
(QC) protocol. At POTWs with less than five SIU files, the reviewers each exchanged one file for
duplicate review. Any discrepancies identified through these duplicate reviews were discussed and
resolved. Typically, discrepancies related to differentiating between "No," "Not Applicable" (NA),
and "Not Determined" (ND) responses rather than discrepancies with the interpretation of what did or
did not constitute a violation. Such supporting comments were also reviewed for completeness and
adequacy (i.e., all NA and ND responses were explained in checklist notes.
Each onsite review team was provided copies of the Federal pretreatment regulations (including
the categorical standards), a list of EPA-approved analytical methods (40 CFR Part 136), and the
National methodology for determining SNC (see Appendix B). Team members met between POTW
site visits to discuss findings and to ensure the consistency of their reviews. Examples of issues
raised and resolved during these meetings included the following:
• Where SIU permits required compliance with a specific section of a local ordinance but were
not specific about the nature of the requirement, the inspection team evaluated industry
compliance against the ordinance requirement
• Where SIU self-monitoring reports did not indicate the analytical method used, Question
A(6)(iv) was answered as "ND"
After completion of each POTW site visit, data from the file review checklists were entered into a
computerized database to aid in the statistical analysis.
SIU FILE EVALUATION PROTOCOLS
L«J
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5. QA/QC MEASURES
To ensure the statistical integrity of the study, stringent QA/QC measures were incorporated into
both the data collection and data entry phases of the project. These QA/QC measures included:
• Training of a core group of inspectors to perform the industrial file reviews
• Involving these inspectors in the development of the final file review checklist and instructions
• Field testing the checklist before collecting data for the study
• Sending two inspectors on each site visit
• Performing field quality assurance checks to ensure consistency of inspector interpretations
• Cross-checking the data collected prior to data entry
• Double entering all data to ensure accuracy.
A core group of seven inspectors were selected based on their knowledge of the pretreatment
program and experience in performing POTW audits and inspections. These individuals underwent
further special training for this project. The training sessions outlined the study objectives, the types
of information to be collected, and potential difficulties in interpreting file data. In addition, the
review team met with EPA and again discussed the checklist and instructions in detail. These
discussions resulted in improvements in the phrasing of file review questions and ensured that each
inspector possessed an in-depth, consistent understanding of the meaning and scope of each question.
To further hone the checklist and train the inspectors, the study protocols were subjected to field
tests at 9 POTWs (approximately 50 SIU files) in the Washington, D.C., area. Issues arising from
these test inspections were discussed and resolved and the checklist and instructions were again
revised. Data collected during these tests are not included in the findings since the checklist and
review procedures were not final at the time of field testing (see also Sections 4.2 and 4.3).
Checklists were designed to provide a yes/no answer to several questions regarding SIU
noncompliance and SIU permit quality. Checklists were not designed for the inspector to identify the
specific types and frequencies of violations at any given SIU or POTW. Rather, inspectors were
encouraged to write notes on the checklist when questions arose regarding the interpretation of file
contents.
QA/QC MEASURES
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QC procedures were performed in the field to ensure that the two inspectors on each team
maintained consistency throughout the site visit. These procedures consisted of duplicate reviews of
every fifth file and cross-checking of answers. If the duplicate reviews resulted in any
inconsistencies, the reasons for the differences were identified and discussed, and a consistent
approach was men taken with all files reviewed at that POTW.
Most of the discrepancies which occurred involved uncertainties regarding the use of "No,"
"NA," or "ND," rather than between "Yes" and another response. Examples of such discrepancies
included the interpretation of the 24-hour violation notification when the SIU was in consistent
compliance (characterized as "NA"); and the interpretation of the SIU's failure to identify sample type
when its permit did not specify the type of sample (characterized as a "No" or "compliance"). All
similar questions of interpretation were marked for later discussion by the entire inspection team to
ensure consistency at other POTW site visits.
Upon completion of the file reviews, each inspector reviewed the other's completed forms. This
procedure checked both the completeness of each review and concurrence in the interpretation of any
questionable checklist answers. Finally, as part of the procedures for ensuring accurate data entry, all
information entered into the project database was double-entered to identify and eliminate keystroke
errors (see Chapter 6 for a discussion of the project database).
QA\QC MEASURES
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6. ANALYSIS OF THE STATISTICAL DATA
The following section documents the steps taken to analyze the SIU file data collected during
POTW site visits. Altogether, 640 SIU files at 60 POTWs were examined. Nearly 100 of these files
received duplicate reviews to maintain consistency between field team members.
6.1 PREPARATION OF THE DATABASE
Upon returning from each site visit, the core group of inspectors met to discuss findings and share
observations. The completed checklists were then coded and entered into a computerized database
using the Statistical Analysis Software (SAS) package. Once entered, the data were independently
checked, question by question, for internal consistency and incomplete responses. Entry discrepancies
were brought to the attention of the appropriate field team members for review and resolution.
Compilation of responses in the database did not require any assumptions or decisions. To
generate combined SNC rates of different types (e.g., overall SNC: both with discharge standards
and reporting requirements), the responses to some checklist questions were combined. Several new
variables were added to the database by combining the responses from two or more questions in this
way. However, the algorithm for combining questions was designed to generate an overall combined
response which was logically consistent with the individual questions.
More precisely, almost all questions contained four possible responses: In SNC=Y, Not in
SNC=N, Not Applicable=NA, and Not Determined=ND. The combined response for a pair of
questions was listed as "Y" if either individual question response was "Y." Barring that, if either
response was "ND," the combined response was listed as "ND." If neither of the first two conditions
were true, the combined response was listed as "N," unless both individual responses were "NA," in
which case the combined response was listed as "NA." For instance, the combined question for SNC
with discharge standards and/or reporting requirements was answered "Y" if SNC for discharge
standards and/or reporting requirements were identified.
63 ADJUSTMENTS TO REFLECT SAMPLE POPULATION
As explained in Chapter 3, SIU files were not selected with equal probability. Rather, the
selection probabilities were weighted to account for the complex sampling process which involved
ANALYSIS OF THE STATISTICAL DATA
-------
different levels of stratification of the population of POTWs and SIU files into groupings of
geography, size, and categorical verses noncategorical industries. Consequently, SIU files were more
likely to be selected from States with a disproportionate share of POTWs and also from POTWs
containing a larger number of SIU files (requiring appropriate weighting to account for these
probability-based selections). The results were not adjusted to account for SIUs in 403.10(e) States or
SIUs in cities without approved pretreatment programs.
Because SIU files were necessarily selected with unequal probabilities, simple averages of the
responses for each question would not represent the best or most accurate estimates of the National
SNC rates for the SIU population. Instead, a weighted average was developed for each question
reflecting the characteristics and stratification of the final sample. To construct these weighted
averages, two steps were necessary. First, sample weights had to be developed for each selected SIU
file based on its unique probability of inclusion in the database. Second, a weighted average called
the general Horvitz-Thompson Estimator was chosen from the statistical literature (Cochran, Sampling
Techniques. 1977, p. 259). The Horvitz-Thompson Estimator is known to be appropriate for
sampling designs with unequal probabilities of selection. It has the mathematical form
n,
where N is the total population size, n is the sample size, y; is the response of the ith SIU file in the
sample for a given question, and r-, is the probability of selection for the ith SIU file.
To actually develop the sample weights, the algorithm for selecting any given SIU file was
divided into three separate stages; each stage had a selection probability that contributed to the overall
selection probability. As noted in Chapter 3, the United States was divided into five geographic
zones, representing the Northeast, Mideast, South, Midwest, and West. From each zone, two areas
were selected with unequal probabilities depending on each area's relative share of the total number of
POTWs in that zone. If Wfc equals the number of POTWs in the hth zone and W^ equals the number
of POTWs in the kth area within zone,,, the probability of selecting the kth area is proportional to but
not quite equal to W^/Wk. More exactly, the first stage selection probability equals
ANALYSIS OF THE STATISTICAL DATA
-------
where index j in the last summation ranges over all areas in die nth zone.
In the second stage of selection, once zoneh and area* were chosen, the POTWs in each selected
area were divided into three size classes (small, medium, and large; indexed by the subscript 1) based
on the number of total SIU files housed at each facility. A small number of POTWs were chosen at
random (via a simple random sample) from each size class. As a simple random sample, each POTW
within the class had an equal chance of inclusion in the study. If Wu represents the total number of
POTWs in zone,,, area*, and size class,, and w^, equals the number of sample POTWs selected from
the stratum, the selection probability for the second stage equals the proportion of sample POTWs
among the total, or
AH
In the third and final stage, after specific POTWs were selected, all SIU files were divided into
two groups: categorical and noncategorical. SIU files were then selected via simple random
sampling from each group. For example, if the selected group was categorical files and subscript j
indexes POTW files, and if C^ equals the total number of categorical Mies at the chosen POTW and
CIHJ equals the sample number of categoricals selected, the third stage selection probability is the
fraction of all categorical SIUs at POTWj that were included in the sample, or
where index i ranges over the SIU files in the categorical group. More generally, the third stage
probability of selection is given by
where D (d) is indexed by C (c) or S (s) denoting categorical or noncategorical files respectively.
ANALYSIS OF THE STATISTICAL DATA
L«J
-------
The overall selection probability for a particular SIU file is computed as die product of the
selection probabilities for the three stages. The final expression is
_-0)v-(J) v-W
~"klc Uttf Uild,
It should be noted that all files of a certain type and located at a given POTW had the same selection
probabilities. However, the selection probabilities do vary across categoricals versus noncategoricals,
and POTW-to-POTW. Once the sample weights were assigned to the SIU files in the sample,
weighted averages of the question responses were constructed based on the Horvhz-Thompson
Estimator mentioned earlier.
63 DEVELOPMENT OF STANDARD ERRORS
This study was designed to produce SNC rate estimates accurate to within ±5 percent with a high
degree of statistical confidence. A key goal of the study was to compute Standard Errors (SEs) of the
National SNC and noncompliance estimates in order to assess the amount of sampling variability
inherent in the results.
A SE is an estimate of the precision of a given result. In this case, the SE was computed by
taking the sum of three basic sources of variability (i.e., each of the three stages of selection of the
study population). The first stage of selection was at the Zone Level, which consisted of stratified
random sampling of geographic areas weighted with unequal probabilities. The selection probability
attached to each geographic area is proportional to the number of POTWs contained within the area
boundary, meaning that areas with greater numbers of POTWs had a higher chance of being included
in the study than areas with lower numbers of POTWs. The variability associated with this stage of
selection can be described as "between-area" variation (i.e., variation in SNC rates from area to area)
within the zones.
The second selection stage was at the Area Level, which consisted of stratified simple random
subsampling of POTWs in selected geographic areas within each zone. The stratification at mis level
of the algorithm was by POTW size so that an approximately equal number of small, medium, and
large POTWs were selected within each geographic area. This source of variability can be described
as "between-POTW" variation (or variation in SNC rates from POTW to POTW) within selected
areas.
ANALYSIS OF THE STATISTICAL DATA
-------
The final stage of selection was at the POTW Level, consisting of stratified simple random
subsampling of SIU files within selected POTWs. At mis level, stratification was done by separating
categorical and noncategorical industries. SIU files were selected at random with equal probability
from each of the two file groups. Variability in this stage refers to "within-POTW" variation (or
variation in data from SIU file to SIU file).
The overall estimate of variability and, hence, the SE, is derived by summing these three
components using the standard formula for the sampling variance under multiple-stage probability-
based subsampling (see Cochran, 1977, p. 276):
where $ represents the quantity being estimated and each of the three terms on the right-hand side
corresponds to the components of variability associated with the first, second, and third selection
stages, respectively.
The actual SNC rate estimator used in this study, the Horvitz-Thompson Estimator previously
described, may be rewritten in the following form which is more amenable to computation of the SEs:
yfl7-=irr^*=i 2.4-1 ~i~~
T KU
where T represents the total estimated number of SIU files in the study universe for a given question,
YK equals the estimated total number of SNC responses in the kth geographic area of the hth zone,
and T,* represents the probability that the kth area in zone^ was selected for the study.
Heuristically, y'm represents a weighted National estimate of SNC that is stratified into five
geographic zones. An estimated total number of SNC responses is computed in each zone, these
totals are summed, and the final total is divided by the estimated number of SIU files in the study
universe to get National SNC rates.
ANALYSIS OF THE STATISTICAL DATA
-------
Because SIU file selections were made independently within each geographic zone, the sampling
variance (L*-» the square of the SE) may be estimated as
where the variance term for the total response in each specific zone is estimated by dividing it into
three parts corresponding to the different stages of the selection algorithm.
The first portion of the sampling variance represents between-area variation within zones.
Following the mathematical development in Cochran (1977, pp. 301 and 261), this component may be
estimated in general with the formula:
where «V represents the probability that the kth and k'th areas are both selected for the study from
and the area total Y,* for the kth area is estimated using the formula:
In this last equation, subscripts 1 and j index POTW size classifications and individual POTWs,
respectively. Also, quantity Y^ denotes the estimated total noncompliance response from the jth
POTW in size class, sampled from the kth area in zone^.
Since exactly two geographic areas were selected from each zone, the estimated between-area
variance component for the hth zone may be reduced to the formula:
4
The second component of sampling variance represents between-POTW variation within
geographic areas. By re-expressing the estimator for the total noncompliance response in zone^ as
the second variance component may be expressed as
ANALYSIS OF THE STATISTICAL DATA
-------
W
where Gb equals the total number of areas in geographic zone,, and ~y*m is the estimated average total
noncompliance response from any POTW of size class, selected from the kth area in zone*.
By applying Cochran's general formula for the variance of a sample average in a simple random
sample (1977, p. 26), the above variance component may be estimated as:
i
Note that estimated total response for the jth POTW is computed as
with Yhuj1 and Jhu/ denoting the simple within-POTW sample averages of SNC responses for
categorical and noncategorical SIU files, respectively, and C^ and S^ equalling the total numbers of
categorical and noncategorical files housed at the jth POTW.
The final component of sampling variance represents within-POTW variation (i.e., average
variation in compliance responses between SIUs at an individual POTW). Again using the
mathematical development of Cochran (1977, p. 301), this term may be estimated by the formula:
The variance at each individual POTWj is estimated by the equation
ANALYSIS OF THE STATISTICAL DATA
6-7
-------
By combining all three components of variance for each zone, the total sampling variance for
may be computed. Adding these separate results in the equation for the overall sampling
variance and taking the square root of the result leads to the final estimated SE for the National SNC
rate. Note that the foregoing mathematical development applies to overall rates of SNC for both
categorical and noncategorical SIUs. To get separate SEs for categorical files or noncategorical files,
the formulas have to be modified slightly to exclude one file type or the other depending on which SE
is being computed.
6.4 DEVELOPING CONFIDENCE LEVELS
Once the SEs are estimated, giving a measure of the precision of the National SNC rate estimates,
confidence levels must be constructed in order to attach a level of statistical certainty to the results.
A confidence level is a measure of the certainty of an estimated result. Confidence levels are
constructed by computing the quantity (estimated rate ± t*SE) where t represents a multiplicative
factor that varies depending on the confidence level desired. The confidence level gives an estimated
lower and upper bound on the true National SNC rate such that if the study were repeated 10 times,
each time collecting a new set of SIU files for review but in the same manner as this study, the
estimated SNC rate would be expected to fall within the range of a similarly constructed 90 percent
confidence level in 9 of those studies. For two-sided 90 percent confidence intervals, t would be
equal to 1.645. Once constructed, such a level offers 90 percent confidence that the true National
SNC rate falls somewhere between the lower and upper bounds of the estimated range.
It is important to note that, in the event the upper bound of the range is not of direct interest, the
confidence interval of the lower bound is 95 percent. That is, we can be 95 percent confident that the
true National SIU SNC rate exceeds the lower bound. The reason for this is that confidence intervals
rely on symmetry, thus, a 90 percent confidence interval represents the middle 90 percent of the
possible range of values with 5 percent of the values below this range and 5 percent above this range.
£_g i ANALYSIS OF THE STATISTICAL DATA
-------
7. DISCUSSION OF STANDARD ERRORS
As indicated above, Appendix E presents the estimates of SEs and associated confidence levels for
all items in the summary table of results given in Appendix D. A few comments may help to make
this table of SEs more comprehensible. For a given industry group (categorical, noncategorical, or
bom), the table in Appendix E lists five columns of numbers. The first column (headed "Y (%)")
lists the estimated rate of SNC as given hi Appendix D. Next to mis is the column headed "S.E.
(%)," which lists the estimated SE for each item in the table. These values were calculated according
to the method described in Chapter 6.
The final three columns list the level of confidence associated with a projection of a specified
amount of sampling error (i.e., ±5, ± 10, or ± 15 percent) attached to the final SNC rate estimate.
For example, there is 34 percent confidence that the true overall non-TTO SNC rate is within 5
percentage points on either side of the estimate listed in the first column of the table, but 62 percent
confidence that the true SNC rate lies with ± 10 percent of the estimated rate, and 81 percent
confidence that it is within ± 15 percentage points. As might be expected, the level of confidence in
a given result increases as the acceptable sampling error is increased.
The initial goal of this study was to arrive at sampling errors of at most ±5 percent with at least
80 percent confidence (see Chapter 3). The table in Appendix E clearly indicates that this target was
not met for many of the items in the assessment. In particular, the target was missed for the overall
SNC and noucompliance rates, where the findings gave only 35 and 22 percent levels of confidence
(respectively) that the maximum sampling error was 5 percentage points.
There are four principal reasons that the SE target was missed for some assessment items. First,
the estimated rates of SNC and noncompliance found during the study were much higher than had
been anticipated from previous EPA estimates or results of the prestudy field tests. In a study of this
kind, using a probability-based sampling algorithm, lower SNC rates are much easier to estimate with
a small degree of sampling error than higher rates, all else being equal.
Figure 2 shows two sets of simulated random data, each representing 500 trials of calculating the
SNC rate among 100 SIU files selected from the population at random. In one set of data, the SNC
rate was 10 percent, while hi the other, the SNC rate was 50 percent. As can be seen from the
DISCUSSION OF STANDARD ERRORS
-------
As a Function of Expected SNC Rate
o
09
cd
U
z
CO
/U
60
50
40
30
20
10
C
i i i i
•
• B • • m •
* * * * * •• •*•• * •• • • **•• * •**"••
• ""**• • • •• mm • • ••IB • •• • • •• •• • ••
1m m mm *m m *m m m m" * m 'mm*** mfrnf "*•• m'm mmm m'm mm m \ mmmmrn* m*m * m*mm mm * •
• • • • • • • m m mm m m • •• ••• • • mmm m m mm
m m mm m mm mm mm m mm m . m m m m mmm m m mm m mm mmm
i mmm mmt m m m m •• • • mmmm m m m mm m mm m i
• ••• M •• • •• • • • fmm^ ^^ mm m m m mm mmm mmmm
' ^m* • *~mmm ** ~m~ !"^**™ m m"~ m"*m "" m m * ^ »^?« • • • • * T«* "" m~ "~ "* * "
• • * m* ** .«" • •• ^ m^m ^ m m mm m * * * m^ *
~ \ * m m * —
mmm m
-
- m .-
• • • mm mmm mmm m m mm mm m mm mm m mm m mm m
mm m m m m ••••• • •• •• m* ••••• • •<
mm mmm •••••• •• » • •• •• •• ••• • m* m mm mm mmm m mm mmi
t-mm mm m mm m •••••• m m mm m m m mmm m mm mmm m m mmm mm mm m •••• mm • —
• • mmm* m mm m m mm m m m mm mm mm mm mmm mmm* mm mm m mm ••• • • •••
• • •• ••••• • ••• •••••• • • •
• •••• • ••
1 " 1 1 1
) 100 200 300 400 50
Trial Number
FIGURE 2. STATISTICAL SAMPLING VARIATION
7-2
DISCUSSION OF STANDARD ERRORS
-------
dashed limits set at ±5 percent on either side of the estimated SNC rate, the degree of sampling
variability in repeated trials of the study is much greater when the SNC rate is higher, leading to
wider range at the targeted confidence level. Therefore, the SNC rate range is not within 5
percentage points of the estimated SNC rate. Figure 3 is a graph of the estimated 90 percent
confidence levels for the overall results of the SIU permit section of the assessment. The widths of
these intervals steadily increase as the number of SIU permits with estimated deficiencies increases.
Of interest, the estimated rate of SIU permit deficiencies regarding local limits is approximately 10
percent. For this case, the estimated maximum sampling error is less than 5 percent with 90 percent
confidence, meeting the initial study target.
Second, the statistical results indicated a great deal more POTW-to-POTW variation than had
been anticipated prior to the study. In other words, there were wide swings between the estimated
rates of SNC and noncompliance from POTW-to-POTW. Figures 4 and 5 illustrate the results for
overall SNC rates at individual POTWs (among categorical and noncategorical SIUs, respectively).
Rather than generally reflecting SNC rates similar to the overall average, most POTW programs are
more accurately characterized as either a "good actor" or "bad actor." "Good actors" have relatively
low SNC rates, while "bad actors" evidence fairly high rates of SNC.
From a statistical standpoint, Figures 4 and 5 illustrate the difficulty in determining the overall
SNC and noncompliance rates to within a ±5 percent sampling error. The extreme differences from
POTW-to-POTW lower confidence in the targeted sampling error and result in wider-than-targeted 90
percent confidence levels associated with the estimated SNC and noncompliance rates. This
unanticipated result could have been avoided only by visiting a greater number of POTWs and
reviewing fewer SIU files at each POTW (thereby reducing the importance of the POTW-to-POTW
variation).
Third, as noted in Chapter 3, POTWs were visited in geographic clusters called areas. The two
areas that were chosen from each geographic zone sometimes exhibited large differences in estimated
SNC and noncompliance rates, again making it difficult to pin down the overall rate estimates with
the targeted precision. If the estimated SNC rates had been reasonably close from area to area, the
final 90 percent confidence range would have been significantly smaller.
DISCUSSION OF STANDARD ERRORS
-------
90% Confidence Intervals
£
(0
a
o
a
o
U
80
g 60
o
o
a.
CO
4-*
o 40
20
0>
CL,
co 0
Permit Conditions
FIGURES. SIU PERMIT CONTENTS
DISCUSSION OF STANDARD ERRORS
-------
100
80 -
60 -
u
CA
40
20
I I I I II I I I I I I I I I
Zonel
Zone 2 j Zone 3
ByPOTW
Zone 4 ZoneS
FIGURE 4. POTW-TO-POTW VARIATION (CATEGORICALS)
DISCUSSION OF STANDARD ERRORS
-------
100
80 1
£ 60 -
i
I
p 40
20
Zonel
Zone 2 j Zone 3
ByPOTW
Zone4 I ZoneS
FIGURE 5. POTW-TO-POTW VARIATION (NONCATEGORICALS)
DISCUSSION OF STANDARD ERRORS
-------
Finally, the estimated SEs were also affected by inaccuracies in the available counts of categorical
and noncategorical SIUs by POTWs. The sample selection algorithm was designed using SIU counts
obtained from PPETS. However, the study identified discrepancies between the reported counts given
by the study-POTWs and the actual counts of SIUs made by the field teams. Although the National
SIU count was not significantly different, the POTW-specific counts of CIUs and noncategorical SIUs
were often substantially different from the counts derived from PPETS. Therefore, an added level of
uncertainty was added in the confidence level/SE estimates.
Using the actual counts recorded by the field teams at the study-POTWs, it is possible to estimate
the population totals by geographic zone. These estimates are presented in Table 2 and compared to
the reported totals from PPETS. The results indicate that the overall estimated total of all SIUs in the
study universe differs from the reported total by less than 1 percent. However, the relative
differences for CIUs and noncategorical SIUs are 29 and 19 percent, respectively. Even larger
discrepancies are suggested on a zone-by-zone basis, ultimately leading to lower-than-targeted
confidence in the precision of the study results, particularly for the separate categorical and
noncategorical noncompliance rate estimates.
DISCUSSION OF STANDARD ERRORS
-------
TABLE 2. ESTIMATED SIU TOTALS BY GEOGRAPHIC ZONE
Overall
Northeast Zone
Mideast Zone
South Zone
Midwest Zone
West Zone
AllSIUs
Reported
26,796
5,485
7,692
5,702
1,956
5,961
pctimat^
27,373
3,598
12,459
4,762
3,151
3,404
CIUs
Reported
11,022
2,368
3,280
1,535
904
2,935
pjCtJTTjatl*^
14,462
1,921
6,703
2,313
2,007
1,519
Noncategorical SIUs
Reported
15,774
3,117
4,412
4,167
1,052
3,026
Pfitimatad
12,910
1,677
5,756
2,449
1,144
1,885
Reported: Numbers represent PPETS data.
Estimated: Numbers represent adjusted weighted data based on findings of the study.
DISCUSSION OF STANDARD ERRORS
-------
APPENDIX A
DEFINITION OF SIGNIFICANT NONCOMPLIANCE (SNC) FOR INDUSTRIAL USERS
-------
COMPLIANCE EVALUATION
SNC DETERMINATION
A. Chronic violations of wastewater discharge limitations
(66 percent or more of all measurements taken in a 6-
month period exceed the daily maximum or the long-
term average limit for the same pollutant parameter).
B. Technical Review Criteria (TRC) violations (33 percent
or more of all measurements taken in a 6-month
period exceed 1.2 times the limit for toxics or 1.4
times the limit for BOD, TSS, and O&G).
C Any other violation of an effluent limit that the
Control Authority determines has caused, either alone
or in combination with other discharges, pass through
or interference.
D. Any discharge that causes endangerment to human
health, welfare, or the environment, or causes the
POTW to exercise its emergency authority to halt or
prevent such discharge.
E Failure to meet a compliance schedule milestone date
or enforcement order within 90 days after the
scheduled date for starting construction, completing
construction, or attaining final compliance.
F. Reports that are more than 30 days late (e.g., BMRs,
90-day reports, periodic reports, and compliance
schedule milestone reports).
Q Failure to accurately report noncompliance.
R Any violation determined to adversely affect the
operation or implementation of the pretreatment
program. .,
[Pursuant to 40 CFR §403.8(f)(2)(vii) of the General Pretreatment Regulations]
A-l
-------
APPENDIX B
EPA SNC METHODOLOGY MEMORANDUM
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEF 9 1991
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Application and Use of the Regulatory Definition of
Significant Noncompliance for Industrial Users
FROM: Michael B. Cook. Directc
Office of Wastewater Enforcement "ancf Cor
TO: Water Management Division Directors. Regions I-X
Approved Pretreatment State Coordinators
Background;
On July 24, 1990, the Agency replaced the definition of "significant violation" with
the definition of "significant noncompliance" (SNC) [see 40 CFR 403.8(f)(2)(vii) and 55
Fed. Reg. 30082]. This change eliminated the inconsistencies which arose in applying the
significant violation criteria and established more parity in tracking violations committed by
industrial users. The definition of SNC parallels the Pretreatment Compliance Monitoring
and Enforcement Guidance (PCME) definition of SNC published in 1986.
This memorandum responds to several questions from States, publicly owned
treatment works (POTWs), and industry regarding the application of the SNC definition.
One frequently asked question is whether the time frame for determining SNC for technical
review criteria effluent violations is a static six month period (i.e., a fixed six month
calendar interval) or a rolling six month time frame (i.e.. the current day minus six
months). POTWs and industry have also inquired whether all data must be used to
calculate SNC. The following discussion is provided to promote consistency in the
application of this definition. Regions, States and POTWs should determine SNC in the
manner prescribed below.
Pretreatment POTWs are required to notify the public of significant industrial users
which meet the definition of SNC through publication in the newspaper. The POTW
should also use the SNC criteria as the basis for reporting an industrial user's compliance
status to the Approval Authority in its Pretreatment Performance Report. According to 40
CFR 403.12(i)(2), the POTW must report on the compliance status of its industrial
user universe at the frequency specified by the State or EPA National Pollution
Discharge Elimination System (NPDES) permit, but in no case less than once per
year. Finally, the definition of SNC is used to determine whether a formal enforcement
action against a user is warranted in accordance with the POTW's Enforcement Response
Plan (ERP).
B-l
fruwrf « KicycUd P aptr
-------
Aoplvine the Definition: Use of the Six Month Time Frame:
There are seven criteria set forth in §403.8(f)(2)(vii). Two of these criteria concern
violations evaluated over a six month rime frame. The Agency intends for Control
Authorities to evaluate these criteria on a rolling basis. The EPA's long established
practice in the NPDES program is to evaluate SNC for direct dischargers each quarter
using data from the previous six months. Similarly, Control Authorities should determine
SNC for their universe of industrial users on the same rolling quarters basis using fixed
quarters established by the Control Authority to correspond to its "pretreatment year" (e.g.,
March 31, June 30, September, 30 and December 31).
At the end of each quarter, POTWs and States are to evaluate their industrial user's
compliance status using the two criteria of the SNC definition which are evaluated on a six
month rime frame (i.e., the "A" and "B" criteria under the regulatory definition). Under
this system, each industrial user is evaluated for SNC four times during the year, and the
total evaluation period covers 15 months (i.e., beginning with the last quarter of the
previous pretreatment year through the end of the current year). When the POTW is
required to publish, it must list in the newspaper all industrial users which have been
identified as SNC during the previous year (i.e., the SNC criteria were met during any of
the previous four quarters).
If a facility has been determined to be in SNC based solely on violations which
occurred in the first quarter of the IS month evaluation period (i.e., the last quarter of the
previous pretreatment year) and the facility has demonstrated consistent compliance in the
subsequent four quarters, then the POTW is not required to republish the Industrial User
(IU) in the newspaper if the IU was published in the previous year for the same violations.
Use of Industrial User and POTW Data in Determining SNC;
Several POTWs have inquired whether all data, including Control Authority
sampling and industrial user self-monitoring, must be used in determining SNC. This
question arises from the concern that an industrial user may choose to conduct its sampling
efforts at times in which it knows that it is in compliance (e.g., during early morning start-
up or during.periods in which the industrial process is down). The concern is that use of
these unrepresentative data will allow the industry to craft its compliance status such that it
will never be in SNC
The regulation defining SNC clearly requires that all measurements taken in the
appropriate six month period must be used to determine a facility's SNC status. Therefore,
any and all samples obtained through appropriate sampling techniques which have been
analyzed in accordance with the procedures established in 40 CFR Pan 136 must be used
to determine whether the facility is in SNC
The General Pretreatment Regulations further state that periodic compliance reports
must be based on data obtained through appropriate sampling and analysis, and the data
must be representative of conditions occurring during the reporting period [403.8(f)(l)(iv)
B-2
-------
and 403.12(g)(3)]. The Control Authority must require that frequency and scope of
industrial user self-monitoring necessary to assess and assure compliance by industrial users
with applicable pretreatrnent standards and requirements.
The nature and scope of the sampling undertaken by an industrial user is under the
control of the Control Authority through the issuance of an industrial user permit. These
permits should specify the sampling locations and sample collection method necessary to
ensure that representative samples are obtained for all regulated waste streams. By
requiring industrial users to obtain representative samples, the Control Authority will ensure
that industrial users do not evade noncompliance through selective sampling of their
industrial processes.
Conclusion;
The Control Authority is required to screen all compliance data, whether generated
through industrial user self-monitoring or by the Control Authority, to identify any
violations of pretreatrnent requirements. Whenever there is a violation, the Control
Authority must take appropriate enforcement action, as defined in its ERP. After this
initial enforcement response, the Control Authority should closely track the industrial user's
progress toward compliance by increasing the frequency of user self-monitoring, increasing
the POTW's monitoring, or both.
When follow-up activity indicates that the violations persist or that satisfactory
progress toward compliance is not being made, the Control Authority is required to escalate
its enforcement response in accordance with the procedures established in its ERP. At a
minimum EPA expects POTWs to address SNC with an enforceable order that
requires a return to compliance by a specific deadline. When this enforceable order
involves a compliance schedule, the industrial user remains in SNC during the period of
the schedule (unless the facility returns to compliance prior to the end of the schedule). For
example, if the duration of the schedule is two years, the facility should be published in
both years. Of course, the POTW should explain in its publication that the violations have
been addressed with a formal enforcement action (similar to a "resolved pending" listing on
the Quarterly Noncompliance Report).
The definition of SNC provides a benchmark against which the compliance status of
an industrial user and the enforcement activities of POTWs can be measured. The concept
of significant noncompliance plays a pivotal role in the implementation and enforcement of
the National Pretreatment Program. In order for the definition to succeed, it is critical that
each Control Authority apply it on a consistent basis. If you have any further questions on
this issue, please feel free to call me at (202) 260-5850. The staff person familiar with
these issues is Lee Okster at (202) 260-8329.
cc: Cynthia Dougherty
Regional Water Compliance Branch Chiefs
Regional Pretreatment Coordinators
Lead Regional Pretreatment Attorneys
B-3
-------
APPENDIX C
FILE REVIEW CHECKLIST AND REVIEWER INSTRUCTIONS
-------
FILE REVIEW FORM
POTWNamc
SIU File:
Categorical Industry?
Section A: SIU COMPLIANCE WITH APPLICABLE DISCHARGE AND REPORTING
REQUIREMENTS
Indicate where the following statements apply to the file being reviewed:
1. The SIU has been in noncompliance (NQ with discharge
standards (other than for TTO).
Y
N
NA
ND
Comments:
2. The SIU has had noncompliance events that cannot be
described as minor exceedances and atypical of the
discharge.
Comments:
1'
N
NA
ND
3. The SIU has been in significant noncompliance (SNQ
with discharge standards (other than for TTO).
Comments:
Y
N
NA
ND
4. The SIU has been in NC with TTO discharge standards
Y
N
NA
ND
C
Comments:
5. The SIU has been in SNC with TTO discharge standards.
Y
N
NA
ND
Comments:
Reviewer:
(Rev. 6/27)
c-l
-------
FTTE REVTEW FORM Tconf fn^^)
6. The SIU has not met discharge sampling requirements far.
i) Sampling frequency
ii) Required parameters
iii) Sample type
iv) Analytical procedures
Y
Y
Y
Y
N
N
N
N
NA
NA
NA
NA
ND
ND
ND
ND
Comments:
i) Periodic reports (for reasons other than timeliness)
ii) 24 hour noncompliance notification
iii) 30 day resampling report
iv) Other (specify )
7. The SIU has been in NC with discharge reporting requirements (other than for TTO).
Y
Y
Y
Y
N
N
N
N
NA
NA
NA
NA
ND
ND
ND
ND
Comments:
8. The SIU has submitted late reports.
Comments:
Y
N
NA
ND
9. The SIU has been in SNC with reporting requirements.
Comments:
Y
N
NA
ND 1
10. The SIU has been in NC with TTO reporting requirements
(for reasons other than timeliness).
Comments:
Y
N
NA
ND
11. The SIU has been in SNC with TTO reporting requirements.
Comments:
Y
N
NA
ND
C-2
-------
POTWName:
FILE REVIEW FORM (continued)
SIUFile:
SECTION B: POTW PRETREATMENT PROGRAM IMPLEMENTATION STATUS
Indicate where the following statements apply to the file being reviewed:
1. The POTW is not applying local discharge standards.
Comments:
Y
N
NA
ND
2. The POTW is not applying all categorical discharge
standards.
Comments:
Y
N
NA
ND
3. The POTW is not implementing all Federal/local reporting
requirements.
i) Periodic reports (for reasons other than timeliness)
ii) 24 hour noncompliance notification
iii) 30 day resampling report
iv) Other (specify 3
Y
Y
Y
Y
N
N
N
N
NA
NA
NA
NA
ND
ND
ND |
ND
Comments:
4. The POTW is not implementing all Federal/local
self-monitoring requirements.
i) Sampling frequency
ii) Required parameters
iii) Sample type
iv) Analytical procedures
Comments:
Y
Y
Y
Y
N
N
N
N
NA
NA
NA
NA
ND
ND
ND
ND
P
P
P
P
Reviewer:
(Rev. 6727)
c-3
-------
REVIEWER INSTRUCTIONS:
Answers should be based solely on the file contents, not on information
provided by POTV personnel.
The checklist is designed such that "Yes" responses indicate problems.
Comments should be provided on the review form wherever a "NA" (not
applicable), or a "ND" (not determined) notation is used. Any qualifying
statements should also be provided in the comments section.
Evaluation of compliance should be based on data for calendar year 1990. The
evaluation of SNC should be conducted using data from the previous six months,
with evaluations being performed every quarter. Thus, SNC will be determined
for the six-month periods ending on March 31, June 30, September 30, and
December 31 of 1990.
Section A of the form provides documentation of SIU compliance with applicable
discharge and reporting requirements. Any question answered by "NA" or "ND"
must be clarified with comments.
Al The SIU has been in noncomplianee (NO with discharge standards (other
than for TTO).
Evaluate all pollutants for which the POTW is implementing discharge
standards. Compliance with TTO requirements (as opposed to other
surrogates or specific organic limits) are addressed as a separate
question below.
• "YES" •• if the reviewer notes any exceedance of applicable discharge
standards.
A2 The SIU has had noncomplianee events that cannot be described as minor
exceedances and atypical of the discharge.
• "YES" --if the reviewer determines that the frequency and magnitude of
noncomplianee(s) cannot be viewed as minor exceedances and atypical of
the discharge.
• "NO" --if the reviewer determines that the frequency and magnitude of
noncomplianee(s) are minor and atypical of the discharge from the
facility.
• "NA" --if the facility has always been consistently in compliance with
discharge standards through out the review period.
A3 The SIU has been in significant noncomplianee (SNC) with discharge
standards (other than for TTO).
Use the SNC determination guide (attached) to determine whether identified
discharge violations qualify for SNC. As with Al, evaluate all pollutants
for which the POTW is implementing discharge standards except requirements
for TTO.
A4 The SIU has been in NC with TTO discharge standards^
Note that TTO requirements may be imposed as a local limit in addition to
Federal categorical requirements. If a TTO limit is imposed as a local
C-4
-------
limit, use the POTW's definition for TTO in the assessment.
• "C" --if the industry is providing a certification of compliance with
TTO requirements in lieu of sampling data.
A5 The SIU has been in SNC with TTO discharge standards.
Self explanatory.
A6 The SIU did not meet sampling requirements for:
i) Sampling frequency
• "NA" •- if a reporting frequency is provided for in the permit but
not a sampling frequency
ii) Required parameters
Note that parameters may include flow and Ph.
iii) Sample type
• "YES" --if sample type is grab and composites are used, or vice
versa.
• "NA" --if the required sample type is not specified.
iv) Analytical procedures (see attached reference sheet for analytical
methods)
• "NO" -- if EPA-approved analytical methods are used.
• "NO" --if certification is provided that EPA-approved methods are
followed.
• "ND" -- if no information is provided regarding the analytical
procedures used.
A7 The SIU has been in NC with discharge reporting requirements.
• "NO" --if reports were due prior to the review period, regardless of
the fact that the SIU had still not achieved compliance with that
reporting requirement.
AS The SIU has submitted late reports.
• "YES" --if any report was late.
• "NO" --if all reports were on time.
• "ND" -- if the due date for a report is ambiguous.
A9 The SIU has been in SNC with reporting requirements.
Use the SNC determination guides to screen reporting violations
identified.
C-5
-------
Evaluate reporting requirements for all pollutants for which the POTW is
implementing discharge standards except requirements for TTO.
A10 The SIU has been i" NC with TTO reporting requirements.
Self explanatory.
All The SIU has been in SNC with TTO reporting requirements.
• "YES" --if reports are more than 30 days late.
C-6
-------
Section B assesses POTW program implementation relating to SIU discharge and
reporting requirements. It identifies POTW implementation deficiencies which
may allow the SIU to meet its permit conditions (as determined in Section A).
For example, if Section A states that a CIU is in compliance, but Section B
notes deficiencies in sampling and reporting requirements for seven Federally
regulated pollutants, the facility's compliance must be questioned since there
are no data to support a compliance determination for those requirements.
Bl The POTW is not applying local discharge standards.
This question is used to identify POTUs which are not applying local
limitations to the SIUs. Look at the control mechanism to answer this
question.
Question Bl provides additional insight into the answers to questions Al
through A6. For example, a facility identified in question Al as being in
complete compliance may have been in noncompliance for zinc, had the POTW
applied the zinc local limit to the SIU.
• "YES" -- if the POTW is not including any ordinance-based limit in
discharge permits. Note that the POTW need only include applicable
limits in the permit. The determination of appropriate local limits is
within the POTW's discretion. However, a facility subject to
categorical standards must also be subject to local limits for any
pollutants regulated by both local limits and categorical standards.
For example, a job shop electroplater subject to categorical standards
for lead must also be subject to the lead local limit, if such a limit
exists.1
» "YES" --if the facility is not enforcing ordinance-based limits or
local limits contained in discharge permits.
• "YES" --if the POTW is only implementing surcharges (as opposed to
local limits) for BOD and TSS if the POTW has absolute limits for BOD
and TSS.
• "NO" --if the POTW is implementing surcharges for BOD and TSS and has
no absolute limits for BOD and TSS.
• "NO" -- if the POTW is applying local limits.
• "NA" -- if the POTW has no local limits.
B2 The POTW is not applying all categorical discharge standards.
Question B2 provides additional insight into the answers to question Al
through A6. Federal categorical standards specify that CIUs must sample
and report analytical results for all regulated pollutants at least twice
per year. Sometimes POTWs make a judgement as to the pollutants that are
the "problem parameters" and only include the Federal limitations for
'THIS ONLY HOLDS IF THE LOCAL LIMIT IS MORE STRINGENT THAN THE CATEGORICAL
STANDARD OR IS ESTABLISHED FOR A DIFFERENT DURATION (E.G., INSTANTANEOUS).
C-7
-------
the "problem parameters" and only Include the Federal limitations for
those pollutants. The CIU nay be in violation of additional parameters,
unbeknownst to the CIU or FOTW, as compliance can only be determined
through evaluation of sampling data.
• "YES" --if the POTW is not correctly applying all categorical standards
for CIUs (including TTO) and/or not enforcing all the discharge
standards. Remarks on whether daily maxinums and long-term averages are
applicable and are applied correctly should be included on the
evaluation form.
• "YES" --if the FOTW is not applying all categorical standards for CIUs
(including TTO).
• "NO" -- if the POTW is regulating categorical industries for all
appropriate parameters (including TTO) and applying correct discharge
standards.
• "NA" --if there are only significant noncategorical users.
B3 The POTW is not implementing all Federal/local reporting requirements.
Question B3 provides additional insight into the answers to questions A7
through All. The question identifies POTW shortcomings in the
implementation and enforcement of both Federal and local reporting
requirements. The SIU is not responsible, nor should it be held as such,
if the POTW is not applying the reporting requirements specified in its
approved program. This is a POTW implementation and enforcement problem,
yet the SIU compliance status should be highlighted to mention that not
all program requirements were included in the permit.
• "YES" --if the POTW is not currently implementing and enforcing all
Federal/local reporting requirements.
• "NO" --if the POTW is correctly implementing and enforcing all
Federal/local reporting requirements.
• "NA" -- for the 24-hour notification and the 30-day resampling
requirements if the user is noncategorical. These requirements apply
only to categorical users.
• "NA" --if the SIU is subject to any Federal/local reporting
requirements.
B4 The POTW is-not implementing all Federal/local self-monitoring
requirements.
Question B4 provides additional insight into answers to questions Al
through A6. Responses to this question are similar to those in question
B3.
• "YES" --if the POTW is not currently implementing and enforcing all
Federal/local self-monitoring requirements.
• "NO" --if the POTW is correctly implementing and enforcing all
C-8
-------
Federal/local self-monitoring requirements.
• "NA" --if the SIU is not subject to any Federal/local self-monitoring
requirements.
• "P" -- if the POTW correctly monitors for the SIUs.
Note that the "implementation" in question in question A3 and A4 means
that the conditions were not included in the permit, or not enforced by
the POTW. For example, if the POTW includes a requirement to hold the CIU
to a monthly monitoring and reporting schedule but does not notify the SIU
when the SIU submits semiannual reports, this is an SIU problem as well as
a POTW problem and should be noted as such.
C-9
-------
APPENDIX D
SIU SNC/NONCOMPLIANCE LEVELS SUMMARY TABLE
-------
BIMMftY TABLE OF BIU FILE ASSESSMENT RESULTS
ALL SIU*
CATEGORICAL
SIU*
NON-CATEOORICAL
SlUi
NON-TTO COMPLIANCE RATES
Discharge Standard*:
we
Nan-Minor NC
SNC
Reporting Requirement*:
NC
Lit* Report*
SNC
Combined Discharge end Reportin|:
Overall NC Rate (lit* report* eieluded)
Overall NC R*t« (l*t« report* Included)
Ov*r*ll SNC R*t*
TTO COMPLIANCE RATES
Dleeharga Standard*:
NC1
SNC
Reporting Requirement*:
NC (lete report* not Included)
SNC
Combined Discharge *nd Reportln|:
Overall NC Rete
Overall SNC Ret*
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
Overell NC Rat* for OUchari* Standard*
Overall NC Reta for Reporting (lete report! eieluded)
Overall NC Rete for Reporting (lete report* Included)
Overall NC Rat* for Sampling Requlreatent*
Overall NC Rat*
Overall SNC Rate for Dl(charge
Overall SNC Ret* for Reporting
Overall SNC Rat*
SIU PERMIT EVALUATION
Not Include at leeit on* lot el Halt
Not Include at least one categorical itandard
Not Include ailnlBMai Federel reporting
Not Include (Union*) Federal *elf-t»nltorlng
Not Include et leaat one of the above condition!
Number
of POTHa
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
*P
to
to
to
to
to
to
to
to
to
to
Number
of N/A*
7
41
IS
1
ta
ft
0
0
2
479
439
37*
403
355
37*
7
1
0
112
0
18
ss
2
10
320
0
•2
Number
of SIU*
tJ3
399
t22
t3*
372
37«
t40
t40
t38
Itl
201
2tl
233
283
211
«33
t3*
6*0
328
440
t22
382
f38
630
320
6*0
338
»
(I)
t2.t
48.8
33.*
33. t
30.4
29.3
tS.4
77. T
30. t
10. t
5.1
23.1
2t.4
23.3
2t.l
t2.«
37.8
t7.3
4t.3
81.4
34.*
35. t
33.7
13.0
33. t
St. 4
t4.0
R
(S)
33.*
48.0
t2.4
34.4
3*. 3
tl.2
2t.8
14.1
40.7
30.1
38.2
t7.4
39.0
t3.5
SS.l
30.4
48.0
32.7
33. t
18. t
33.1
33. t
33.8
8t.3
63.9
42.3
31.3
ND
Ml
3.5
3.2
3.t
12.0
10.1
9.3
4.8
8.2
8.7
39.4
St. 7
*.«
14. t
11.2
18.8
t.7
14.2
20.1
•
10.0
10.8
10.3
O.t
2.3
1.3
4.7
Rubber
of SIU*
32*
310
323
932
314
310
333
333
332
130
173
21*
200
237
21*
32*
332
333
2*4
333
323
318
332
323
320
S33
2*3
T
Ct)
58.*
41.4
28.3
3*.
34.
32.
ts.
7t.
4*.
10.3
4.4
22.8
24. S
24.3
24.1
3*. 3
43.*
74.7
33.8
•1.2
2».»
40.3
33.3
13.3
33. t
37.1
ts.t
N
(I)
3*.
St.
70.
32.
38.
to.
31.
It.
43.
47.3
38.4
t7.7
39.8
t4.t
St.O
33.3
43.1
25.3
34.1
18. •
St. 7
49.8
34.7
8t.S
t3.9
42.5
32. «
ND
(I.)
1.4
2.3
1.7
7.3
.1
.0
.3
.«
.7
42.
37.
».
13.
10.
1*.
7.1
11.3
U.I
.
13.4
».7
*.*
0.3
2.3
0.4
3.8
R unbar
Of SIU*
304
28*
2*7
307
238
264
307
307
sot
31
28
42
33
48
42
304
307
307
234
307
2*7
264
sot
307
307
2tS
t
(S)
6t.5
St. 8
39.9
26.5
45.1
26.3
71.8
78.*
31. t
11.3
8.7
24.4
37. t
28.8
St. 2
6f.S
29.1
59.0
37.0
81.4
40.0
29.3
31.9
12.8
33.7
t4.3
N
(I)
27.*
3*. 3
34.4
36.5
40.8
tl.4
21. «
11.2
37.3
S*.
36.
ts.
34.
38.
30.
27.2
33.3
41.0
32.*
18.4
33.4
38.3
St.*
•6.2
42.0
29.8
ND
(I)
5.6
3.9
5.7
17.0
14.1
12.3
t.t
10.0
10.*
29.3
34. t
9.8
7.9
12.7
13.1
t.S
17.4
30.1
.
t.t
12.3
11.1
1.0
2.3
3.7
to
640
78.7 18.1
3.3
333
•2.1 13.«
2.2
307
74.8 20.8
4.4
"C" retpontei treeted e* "N" In *tetl*tlcel analyil*
"P" reiponiei treated •• "NA" In Itatlttleil analysis
-------
SIM1ARY TABLE OF SIU FILE ASSESSMENT RESULTS
HEADING KEY
NON-TTO COMPLIANCE RATES
Ditchers* 3t*nd*rdi:
HC * The SIU he* been in nonccmpllence with dlecherge etenderdt (other thui for TTO). (Section A, Queetlon 1)
Non-minor RC - The SIU hat hid noncompllanco evente thet cmnot be deeerlbed •• minor exeeedenee* wid atypical of the dlieherge. (Section A, Queetlon 2)
SNC • The SIU hee been In elgnlfleent noncompllence with dlecherge etenderde (other than for TTO). (Saetlon A. Quaatlon 3)
Reporting Requirements:
RC - Tha SIU haa bean In HC with dlacharia reporting requtremente (other than TTO or reeeone of tlmellneee). (Section A, Queetlon 7)
Lete Reporte - The SIU hee submitted lete report!. (Section A. Queetlon 8)
SNC - The SIU hee been In SNC with reporting requirement*. (Section A. Queetlon •)
Cabined Dlecherge end Reporting:
Overell NC Rete (lete report! excluded) - poneompllance rate beeed on combining Queatlona 1 and 7 of Section A for dlecherge etanderde and reporting
requirement*.
Overell NC Rat* (let* report* Included) - poneompllenc* rete bated on combining Queetlon* 1, 7, end • of Section A.
Overell SNC Rete - Significant noncompltenee rate beeed on combining Question* 3 and • of aectlon A on dtecherge (tanderde and reporting requirement*.
TTO COMPLIANCE RATES
Dlecherge Standard*:
NC • The SIU he* been In NC with TTO dlieherg* itandard*. (Section A. Queatlon 4)
SNC - The SIU he* been In SNC with TTO dlecherge etenderde. (Section A. Question 3)
Reporting Requirement*:
NC (lete report* excluded) - The SIU he* been In NC with TTO reporting requirement* (for reeeon* other than tlawllne**). (Section A. Queetlon 10)
SNC - Th* SIU hat been In SNC with TTO reporting requirement!. (Section A. Question 11)
Combined Dlecherge and Reporting:
Overell NC Rate - Noncompllenc* rete bated on combining Queatlon* 4 and 10 of Section A for dlicharge atendarde and reporting requirement*.
Overell SNC Rete - Significant noncompllanee rete beted on combining Queetlone 3 end 11 of Section A.
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
Overell NC Rete for Dlecherge - Noncompllanee rete b***d on combining Queatlona 1 and 4 of Section A for dlecherge itenderde.
Overell NC Rete for Reporting (lete report* excluded) - Noncompltenee rete beeed on Combining Queetlon* 7 end 10 of Section A for reporting requirement*.
Overall NC Rete for Reporting (let* reporte Included) - Roncompllence rete beeed on combining Queetlone 7, a, end 10 of Section A.
Overell NC Rete for Seapllng Requlremente - Noncompllence rete beeed on combining the lubperte of Queetlon 4 of Section A.
Overell NC Rete - Noncompllence rete beeed on combining Question* 1. 4, t, 7, 0 end 10 of Section A for dlecherge etanderde and reporting requirement* (TTO end
non-TTO).
Overell SNC Ret* for Dleeherge - Slgnlflcent nonconpllence rete beaed on combining Queetlon* 3 end 3 of Section A for dlecherge atenderde.
Overell SNC Rete for Reporting - Slgnlflcent noncompllence rete beeed on combining Queetlon* • and 11 of Section A for reporting requirement*.
Overell SNC Rete - Slgnlflcent noneompllence rete beied on combining Queatlona 3. 3, *.end 11 of Section A for dlecherge etenderde and reporting requirement* (TTO e>
non-TTO).
SIU PERMIT EVALUATION
Not Include et leeet one locel limit - The SIU permit did not Include et least one locel dleehargo etenderd (Saetlon B. Queetlon 1)
Rot Include et leeet one cetegorlcel etenderd - The SIU permit did not Include et leeet one categorical dleeherge etenderd (Section B. Queatlon 2)
Not Include minimum Federel reporting - The SIU permit did not Include minimum Federal reporting condltlone (Section B. Queetlon 3) •
Not Include minimum Federel eelf-monltorlng - The SIU permit did not Include minimum Federel eelf-monltorlng condition* (Section B. Queetlon 4)
Not Include et leeat on* of the ebove condition* - The SIU permit did not Include et leeat one of the above minimum Federel condition* (locel limit*, cetegorlcel
dlicherge etenderd*, minimum Federel aelf-monltorlng, end minimum Federel reporting)
-------
APPENDIX E
SIU SNC/NONCOMPLIANCE, STANDARD ERRORS AND CONFIDENCE LEVELS
SUMMARY TABLE
-------
STANDARD ERRORS AMD CONFIDENCE LEVELS FOR ESTIMATED RATIONAL COMPLIANCE RATES
ALL SIUi
Confidence Level(l)
Y S.E. for Error of:
(I) m til tlO« ±131
CATEOORICAL
SIU»
Confidence Lav*l(S)
T S.E. for Error of:
(I) Ul ±n ±101 ±131
NON-CATEGORICAL
SlUe
NON-TTO COMPLIANCE KATES
Dlscherge Standard*:
NC
Non-alnor NC
SNC
Reporting Raqulreawnt*:
NC
Let* Report*
SNC
Combined Dlschsrge end Reporting:
Overall NC Rete (let* report* excluded)
Overell NC Rete (late report* included)
Overall SNC Ret*
TTO COMPLIANCE RATES1
Dlscherge Stenderde:
NC2
SNC
Reporting Requirements:
NC (let* report* not included)
SNC
Combined Dlecherte end Reporting:
Overell NC Ret*
Overall SNC Rat*
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
Overall NC Rat* for Dlacherge Standerde
Overall NC Rat* for Reporting (lete report* excluded)
Overell NC Rat* for Reporting flat* report* included)
Overell NC Ret* tot Se»plln| Riqulraswnts
Overell NC Ret*
Overell SNC Rete tor Dl*ch*t|*
Overall SNC Rete for Reporting
Overall SNC Rat*
SIU PERMIT EVALUATION
Not include *t leett on* loeel Halt
Not Include et leett one categorical atandard
Not Include •Inlnun Federal reporting
Not include Minima Federel self-ennltorlng3
Not Include *t leait on* of the above condition*
•2. «
48.8
33.*
33.1
30.4
2*. 3
(8.4
77.7
30.1
10.
3.
23.
21.
23.
21.
(2.9
37.8
17.3
41.3
81.4
34.*
33.1
33.7
13.0
33. (
3(.4
14.0
•.4
7.4
(.3
(.3
13.2
11.1
11.2
14.3
13. (
3.3
3.0
(.2
(.7
7.1
(.7
9.7
(.0
13.1
8.0
14.8
(.3
9.8
13.0
3.3
11. 9
10.8
13.9
78.7
14.0
41
30
it
54
2*
33
33
27
2*
83
•0
38
34
32
34
3*
(0
30
47
24
3(
3*
30
(3
33
34
28
28
71
82
87
88
33
(3
(3
31
34
100
100
•0
84
84
84
70
•1
54
7*
30
87
(9
54
•4
(0
(3.
33
S3
89
•I
•a
•8
74
82
82
70
73
100
100
99
•7
•7
•7
88
99
73
•4
19
*8
88
73
100
7»
84
72
72
38.9
41.4
28.3
39.9
34.4
32.1
(3.3
74.7
49.7
10.3
4.4
22.8
24.3
24.3
24.1
3».S
43.1
74.7
33.8
81.2
29.»
40.3
10.1
1.7
3.3
10.3
10.8
14.(
12.2
17.1
13.2
.2
.7
.0
.2
.4
10.8
9.3
17.4
11.1
17.9
3.3
12.4
33.3 14.2
13.3
33.(
37.1
43.(
82.1
9.0
11.2
14.0
17.3
19.2
38
34
(4
37
21
27
32
23
21
83
88
12
(0
31
37
31
40
23
33
22
(3
31
28
42
34
28
22
21
(8
64
93
(7
41
31
39
44
49
99
100
92
91
84
88
(4
71
43
13
42
93
SB
32
73
(3
32
43
40
84
97
99
as
38
89
78
12
18
100
100
99
99
94
98
83
89
(1
82
(0
99
77
71
90
82
72
II
37
T
til
((.3
st.e
39.9
Zt.
49.
Zt.
M.
7$.
51.
11. S
s.f
24.4
37. •
28.8
34.2
((.3
2*.l
39.0
37.0
81. •
40.0
29.3
31.*
12.8
S3.?
(4.3
Confidence Level (I
S.E. for Error of:
II) ±31 ±101 ±131
13.0
12.3
11.0
3.0
10.2
10.1
12.3
13.8
13. *
3.1
3.1
10.4
13.7
8.3
10.3
13.0
3.7
11.2
8.*
13.7
11.0
10.0
13. (
4.3
0.0
8.*
11. *
30
32
33
«8
37
38
31
28
2*
(3
•8
37
2*
44
Si
30
(2
34
43
2*
33
38
2*
74
43
33
St
38
«4
•3
(7
(8
38
33
34
93
93
it
34
71
II
31
92
13
74
34
14
1*
34
»7
74
11
J
J
1
V
1
I
,
74.8
14.4
27
31
Stenderd errors for theie lt«ni not considered reliable yet due to large mssfcer of N/A raaponta*.
"C" responses treated a*
"P" response* treeted •*
•N" In stetlstlcel enelysle
•NA- In statistics! analysis
-------
APPENDIX F
COMPARISON OF SIU COMPLIANCE AND SIU PERMITS
-------
tmocraiuun BATES
DOM Bt STATUS OF fOTW MUMarTATIOB OT HUnUAIMR BRqOIHMBrrS
FOTW not applyln( loot dlacharg* limitation*
DC Rat* for Dlacharg* Standard*
SNC Rat* for Dlachatt* Standard!
FOTH applying local dlecharge llailtatlooa
NC Rat* for Discharge Standarda
SNC Rat* for Dlaeharfa Standarda
POTW not applying eatagorleal dlecharge atandarda
NC Rat* for Dlachart* Standarda
SNC Rat* tor Dlacharg* Standarda
POTM applying categorlcel dlacharg* atandarda
HC Rat* for Dlacharga Standarda
SNC Rat* for Dlacharge Standarda
POTW not intplaatantlng all reporting requirement*
NC Rat* for Dlacharga Standarda
SNC Rat* for Dlacharga Standarda
NC Rat* for Reporting Requirement*
SNC Rat* for Reporting Requlremente
FOTW |npl*n*ntlng all raportlng requirement*
NC Rat* for Diacharga Standarda
SNC Rat* for Dlacharg* Standarda
NC Rat* for Reporting Requirement*
SNC Rat* for Raportlng.Requirement*
FOTW not Implementing all aelf-Bonltorlng requirement*
NC Rat* for Dlaeharge Standarda
SNC Rat* for DUcharg* Standard*
NC Rate for Reporting Raquiremnta
SNC Rat* for Reporting Requirement*
Overall NC with aenpllng
POTW Implementing ell lalf-annltorlng requlrecent*
NC Rat* for Dlacharg* Standard*
SNC Rat* for Dlacharg* Standarda
NC Rat* for Reporting Requirement*
SNC Rat* for Reporting Requirement*
Overall NC with eaupllng
FOTW not Implementing periodic report requirement*
NC Rat* for Dlacharge Standarda
SNC Rat* for Dlacharge Standard*
NC Rate for Reporting Requirement*
SNC Rate for Reporting Requirement*
NC with perldlc report*
ALL SlOe
•wbor
ot iiirw*
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
Nuefcer
ot N/A*
3
3
3
14
1
3
2
4
2
10
1
It
4
7
.
3t
2
4
.
14
30
1
8
.
7
3
2
2
.
t
23
NuBber
ot Sill*
32
32
3t3
334
137
133
172
170
391
383
3*2
377
22t
223
230
1*4
330
328
332
318
302
186
17*
187
180
184
103
103
107
101
82
T
(II
73.7
34.2
70.0
30.*
tS.3
40.7
7*. 2
23.8
74.7
40.0
4t.S
31. t
ts.s
20.5
2t.S
33.8
45.4
34. *
43.3
SO. t
47.0
ft. 7
28.7
34.1
28.7
44.1
73.0
3*. 7
57.3
34. t
48. t
•
(II
18.8
53.7
23.7
tl.7
21.7
33.7
17.8
t*.8
20.2
30.0
34.7
3».»
30.*
73. t
47.4
tl.S
20.1
32. t
40.7
37.0
St.t
30.*
ts.s
40.3
t0. 7
36.4
20.1
30.7
22.4
S8.0
4*. 8
•D
(II
7.4
10.0
4.2
7.3
12.9
23.7
3.0
t.S
S.I
9.2
18.8
0.5
3.0
3.9
t.l
4.9
t.S
10.3
14.0
11. t
It. 4
2.4
t.O
17. t
2.t
17. t
t.O
9.3
20.3
7.3
1.7
CATtnOKICAL m
STO*
•uBfcw
of 810*
20
20
299
2*3
137
133
172
170
20*
204
209
204
lit
113
119
111
102
102
102
100
177
92
09
92
09
92
48
48
t9
t7
39
1
(II
83.1
22.4
74.0
30.0
ts.s
40.7
79.1
2S.0
79.0
41.2
51.7
32.8
t9.S
IS. 2
St. 2
st.o
t».7
S*.0
S2.2
St.t
31.7
ts.t
23.0
3*. 2
26. t
53.0
04.5
44.5
S0.3
34. t
38.*
ej
(11
11.1
tt.l
20.2
SO. 7
21.7
33.7
17.0
t*.e
14. «
44.2
20.5
fl.t
25.4
74.0
St. 7
5».l
23. t
45.7
S3. 4
53.4
S3.*
2*. 7
tS.0
43.2
t».4
31.2
10.3
47.4
1*.4
ts.s
tl.l
ID
(I)
5.8
11.5
3.9
11.2
12.*
23.7
3.0
t.S
1.3
12.7
1*.7
S.S
3.3
10.0
7.2
4.*
t.7
14.3
14. S
8.1
12.4
4.7
10.4
15. t
S.*
13.0
3.0
8.2
22.4
2.1
.
•uBfcer
of Sill*
32
32
244
23*
•
•
182
177
103
173
110
100
111
03
140
144
130
130
123
94
90
93
91
92
37
37
30
34
23
-CATEOaUCAL
sin*
T
(II
43.*
44.3
43.4
32.0
•
•
t*.4
30. S
40.1
30.0
40.8
24.3
13.2
30. t
tO. 7
33.7
37. 7
23. t
41.2
t7.9
33.7
29.0
30.8
38.0
48. f
29.7
33.2
34. t
70. t
•j
(II
23. S
47.0
32.3
45.4
•
•
27.1
St. 7
42.3
37.0
37.0
72. S
79.9
t4.t
33.1
tO. 2
40.0
to.t
37.3
32.1
44.7
51.3
48.0
41.7
40. t
37.0
20.7
44.4
14.3
•j)
(II
8.8
8.8
2.3
2.4
•
•
3.3
4.8
17.7
12.2
2.1
1.2
4.9
4.8
4.2
t.O
13.3
13.8
21.3
l.t
19. t
1.2
20.2
10.8
12.3
lt.1
19.0
7.0
-------
,UKK urn
DOM BT STATO3 OT POTW D*FL0«nATIOI OT PUTUU1
m CCoBtlBMd)
11
K*
Pom Implementing periodic report requirement*
NC Rat* for Dlscherg* Standard!
SNC Rat* for Diaeharg* Standard*
NC Rat* for Reporting, Requirement*
SNC Rat* for Reporting Requirement*
NC with perldlc report*
POTW not implementing 24-hour report raqulraatanta
HC Rat* for Discharge Standarda
SNC Rat* for Diacharge Standard*
NC Rat* for Reporting Requirement*
SNC Rat* for Reporting Requirement*
NC with 24 hour notification*
POTW Implementing 24-hour report requirements
NC Rete for Discherge Stenderds
SNC Rat* for Dlschsrg* Standarda
NC Rat* for Reporting Requirement*
SNC Rat* for Reporting Requirements
NC with 24 hour notification*
POTW not Implementing 30-day resampling requlrementa
HC Rat* for Dlschsrg* Standard*
SNC Rat* for Dlachsrge Stsndsrds
NC Rate for Reporting Requirement*
SNC Rat* tor Reporting Requirements
NC with 30 day ressapling report*
POTW Implementing 30-day resampling requlrementa
NC Rat* for Discharge Standard*
SNC Rete for Discharge Standard*
HC Rat* for Reporting Requirement*
SNC Rat* for Reporting Requirement*
NC with 30 day reaenpllng report*
its
POTW not Implementing other report r*qulr
NC Rat* for Discharge Standarda
SNC Rat* for Dlacharge Standards
NC Rat* for Reporting Requirement* .
SNC Ret* for Reporting Requirement*
NC with other reporting requirement
POTW implementing other report requirementa
NC Rate for Dlacharge Standards
SNC Rate for Dlacharge Standards
NC Ret* for Reporting Requirement*
SHC Rate for Reporting Requirements
NC with other reporting requirement
Number
of POTW*
(0
40
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
Number
of N/Aa
3
14
.
14
IS
3
.
8
1*8
2
8
.
*
38
8
10
303
2
3
.
7
SO
.
1
1
1
7
18
.
57
6
•umber
of 810*
473
462
476
460
461
231
228
231
223
33
262
2S6
264
2S3
206
334
326
334
324
31
143
142
14S
138
*S
11
11
10
10
10
620
60*
627
S70
621
ALL f
T
(I)
66.1
31J
38.4
31.]
16.]
74.
44.
SO.
33.
78.
72.
31.
42.
32.
26.
73.
40.
45.
31.
74.
70.
30.
47.
36.
33.
as.;
48.1
8*.!
42.1
2.
4».1
31.
36.:
32.1
0.'
IIU*
•
III
28. S
3*.*
47.3
41.0
82.2
20.1
44.8
43.3
32.2
3.4
23.7
60.*
33.0
64.5
30.*
21.7
50.2
38.0
38.3
13.1
24.0
61.0
40.3
60.2
62.0
8
» 14.
1 3.
> 43.
» *7.
» 23.
I 61.
I 4*.
) 40.
k **.
•D
(I)
4.6
8.
14.
7.
1.
3.
10.
4.
12.
IS.
4.2
7.4
24.5
2.*
43.1
3.0
*.7
16.1
f .8
12.8
5.1
8.2
12.4
3.3
4.3
14.8
37.1
5.7
12.1
•
5.1
7.*
14.0
7.3
0.1
C
•umber
of 810*
247
243
24*
242
246 .
127
127
127
124
21
146
143
147
144
113
174
171
174
171
1*
8*
8*
*0
87
64
10
10
*
*
*
31*
313
323
30*
318
ATOJG8U
SIDi
T
(I)
67. ft
2*. 8
47.1
33. ft
20.3
7*. 4
43.*
38.1
40.5
88.2
4*. 7
2*.f
48.0
32.3
28.4
75.0
40.8
51. t
35.7
80.3
71.2
2*.l
53.8
33.4
37.4
83.4
42. ft
87.8
48. ft
2.8
74. ft
2*. 8
43.8
33.8
0.3
[CM.
i
•
CII
23.3
35.*
38.7
3*.0
77.8
12.4
40.0
35.5
32.*
8.1
23.8
3*.l
30.7
42.8
33.5
18.0
43.*
33. ft
57.*
10.3
23.3
3*. 7
34.8
3*. ft
3*. 4
13.7
3.7
31.4
*7.2
1».7
3*. 4
41. ft
60.7
»*.S
•0
(I)
7.2
14.3
14.3
7.S
1.*
8.2
16.1
ft. 4
4.6
3.8
4.3
11.0
21.2
4.8
38.1
7.1
13.3
14.8
ft. 4
».l
5.3
11.2
11.4
3.0
3.2
14.4
41.7
4.5
,
•
3.7
10.7
14. ft
3.5
0.2
•08
Number
oC 810*
226
21*
227
218
213 •
104
101
104
**
12
lift
113
117
111
*1
ito
155
140
133
12
34
S3
55
51
31
1
1
1
I
1
301
2*4
304
261
303
-CATHBC
BIOi
I
(11
66.1
33.7
2*. 4
28.7
12.8
48.1
45.4
41.8
2*. ft
S».8
75.1
33.*
35.8
32.7
23.1
71. ft
3*. 2
s*. a
27.3
(1.1
70.3
33.7
37.3
38.1
24.7
100.0
100.0
100.0
.
•
44.3
32. ft
27. ft
2*. 8
0.4
•ICM.
i
•
ID
31.*
44.2
S4.7
63.3
87.1
2*. 4
30.7
32.8
31.3
•
21.2
42.*
33.7
66.4
27. ft
25.7
37.8
42.7
3*. 2
18.3
25.0
«3.0
48.8
61.1
66.*
.
t
100.0
31.
(2.
5*.
60.
*».
B
(I)
2.0
2.1
13.*
8.1
0.1
2.5
3.*
3.4
l*.l
40.2
3.7
3.2
28.4
0.4
4*. 2
2.7
3.8
17.3
13. S
20.4
4.5
3.4
14.0
0.8
4.4
.
_
100.0
•
4.4
4.7
13.4
0.1
-------
•OHOCKFLUMCE RATES
POTW not Implementing eempllng frequency requirement*
HC Rete for Diieherge Stendirdi
SHC Rete for Dlichcrge Stenderdi
HC Rete for Reporting Requirement*
SNC Rete for Reporting Requirement*
MC with templing frequency
POTW implementing *empllng frequency requirement*
HC Rete for Diicherge Stenderde
SRC Rete for Dlecherge Stenderdi
HC Rete for Reporting Requirement*
SHC Rete for Reporting Requirement*
HC with *emplln( frequency
fOTM not implementing required piremeter requirement*
HC Rete for Dlecherge Stendirdi
SHC Rete for Dlecherge Stenderdi
HC Rete for Reporting Requirement*
SHC Rete for Reporting Requirement*
HC with eenpllng of required pereme
POTW Implementing required peremeter requirement*
HC Rete for Olecherge Stenderdi
SRC Rete for Dlecherge Stenderd*
RC Rete for Reporting Requirement*
SHC Ret* for Reporting Requirement*
HC with eempllng of required perem*
POTW not Implementing temple type requirement*
RC Rete for Dleeherge Stenderdi
SRC Ret* for Diicherge Stenderdi-
RC Rete for Reporting Requirement*
SRC Rete for Reporting Requirement*
HC with type of cemple* collected
POTW Implementing lemple type requirement*
RC Rete for Diicherge Stenderdi
SRC Rete for Dlecherg* Stenderdi
HC Rete for Reporting Requirement*
SRC Ret* tor Reporting Requirement*
RC with type of eemplei collected
POTW not Implementing enelytlcel procedure requirement*
RC Rete for Dl*ch*rg* Stendirdi
SRC R*l* for Diicherge Stenderdi
RC Rete for Reporting Requirement*
SRC Rete for Reporting Requirement!
HC with inelyticel procedure! u**d
IM DUMB BY STATUS V* rUIW UVUmTHTIGB OT HETI
ALL am*
•umber
of POTWe
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60 .
60
60
60
60
60
60
60
60
60
60
60
60
40
•umber
of R/Ae
2
2
.
4
18
1
10
13
17
,
.
4
14
2
11
.
12
16
.
10
38
2
11
.
8
'
1
3
,
10
67
•umber
of 810*
3*
3*
61
S3
43
473
464
474
461
437
123
12S
123
121
111
404
3*3
404
3*4
388
1*1
1*1
1*1
181
133
318
30*
320
312
312
200
1*8
201
1*1
134
T
(II
36.*
33.1
44.2
40.0
43.8
67.6
34.2
42.3
30.4
13.1
34.3
33.4
40.3
30.6
41.0
70.6
34.2
43.3
31.4
12.1
41.3
34.4
44.0
31.2
18.4
6*. 2
34.3
40.3
2*. 3
17.3
46.3
33.7
42. S
2*. 4
18.3
• RD
(II (II
23.6 17.
46.0 20.
38.* 16.
3*. 2 20.
2*.0 3.
Humr wajaaamm (Comtimoed)
CATBOOUCAL IDB
SlOe
•umber
of SIUs
31
31
31
29
24
28.4 4.0 231
$7.8 8.0 248
43.0 14.
62.2 7.
86.0 0.
34.2 11.
48.7 17.
43.1 16.
30.0 1*.
37.3 1.
26.3 2.
39.7 6.
42.2 14.
43.3 3.
66.* 1.
231
248
248
92
92
92
90
87
169
186
189
184
166
31.8 6.7 103
34.1 11.3 103
43.3 10.3 103
33.2 13.4 103
43.6 13.* 80
27.4 3.4 164
S*.3 4.4 161
40.7 18.6 164
67.3 3.4 161
S8.9 23.8 164
24.9 6.8 9*
34.3 12.1 99
40.3 17.2 99
34.4 16.0 97
43.9 33.6 73
T
(II
69.2
41.4
34.2
37.1
33.1
49.7
33.3
48.1
31.9
12.9
39.3
33.4
42.3
33.4
33.6
73.4
33.1
32.0
33.1
14.9
47.0
36.3
37.2
38.4
17.1
69.2
33.0
40.2
28.4
18.2
49.4
33,9
49.7
37.3
22.3
I
(11
24.7
41.8
32.2
33.4
42.2
23.4
33.0
37.0
41.2
64.1
30.7
44. «
40.3
33.3
43.4
20.1
33.2
34.4
42.4
64.2
27.1
47.7
32.9
33.2
47. «
24.3
34.4
40.6
43.8
37,7
19.0
43.2
33.2
34.9
37.9
WO
(I)
4.1
14.7
13.4
7.3
4.7
4.8
13.3
14.9
4.9
1.0
10.0
17.7
17.2
11.4
0.8
4.3
11.4
13.3
4.3
1.0
3.9
13.8
9.9
6.3
13.3
4.3
10. «
19.0
3.4
24.1
11.4
21.0
17.1
7.6
19.8
•umber
Of SIO»
28
28
30
24
17
222
214
223
213
20*
33
33
33
31
24
213
20*
217
208
202
66
84
64
78
S3
134
146
134
131
148
101
99
102
94
41
-CATTOOKICAL
SIU»
T
(II
43.3
23.2
33.2
24.6
63.1
43.4
34.9
34.0
28.8
13.3
40.3
27.0
34.0
17.9
41.4
47.2
33.1
34.3
30.1
9.7
34.9
32.0
28.1
21.7
20.3
49.1
33.7
40.6
30.0
14.4
44.0
33.3
37.4
24.1
.14.7
•
(II
24.4
4*.*
44.9
42.7
8.9
33.6
43.1
49.3
43.4
83.9
44.0
34.4
30.7
40.7
34.4
31.1
43.3
48.3
44.4
89.2
37.3
41.8
40.6
33.2
42.7
30.2
42.1
40.4
48.8
40.2
29.0
40.7
43.1
34.0
33.1
m>
|i)
30.0
2*.*
1*.*
32.4
4.0
1.0
2.0
14.3
7.8
0.6
13.7
16.4
13.3
41.4
3.6
1.7
1.4
13.2
3.4
1.1
7.4
4.2
11.2
23.1
16.*
0.7
2.3
18.6
1.3
23.3
7.0
3.8
17.3
21.*
30.2
-------
MTTS 0009 DOW BT STATUS or ram DVIDOTATIO* or nrniAncn tajuimmra (Continued)
KM-CATBIOUCAL
AU. sioi _ siDe
ar BurfMir Rueber T • TO Rubber ¥10 Rubber T • 0
of POTMe of I/Km ot 8IP» III HI til PC 8IB» til 111 til of 8IO« »> 111 IH
POTW InplnMntlng •n*lytlc*l procedure r*qulr«Mnti
NC R.t. (or DUchtrg* Stindirdi 60 1 29« (4.2 32.8 2.» U4 (5.7 29.1 «.« 132 «2.2 37.1 0.7
SNC R«t« for DUch.ri* St*nd*rd.i «0 • 20* 31.7 «1.3 7.0 1«1 31. « 57. t 10.8 128 31.* «(.2 1.*
NC Rat* for lUportini R.qulr-i.nti 60 . 297 39.8 4S.9 14.3 1(4 4*. 8 39.2 14.0 133 30. S S4.9 14.7
SHC R»t« for Reporting R«quir«o»nti 60 7 290 29.1 67.3 3.6 161 30.0 64.4 3.4 129-' 27.9 71.4 0.7
KC vlth •nilrtiol procedure* ueed 60 IS 282 21.3 61.1 17.* 162 24. 9 58. « 16. < 120 IS. 9 «4.9 19.2
-------
APPENDIX G
CHECKLIST QUESTION RESPONSES
-------
A.I. THE StU HAS BEEN IN NC WITH DISCHARGE STANARDS (NON-TTO)
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuitoer
of POTUs
12
4
6
2
20
e
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
Of SIUS
112
17
75
20
190
63
82
45
149
40
58
51
70
15
25
30
112
18
58
36
633
153
298
182
T
(X)
77.5
89.7
66.9
81 .S
55.0
72.9
45.5
51.1
73.5
75.7
71.3
73.9
46.0
60.0
79.5
39.5
74.1
50.0
81.7
69.3
62.6
73.8
60.3
55.7
F
CX)
19.9
10.3
33.1
8.2
40.7
22.8
48.2
48.9
24.2
24.3
28.7
16.9
52.9
40.0
9.7
60.5
20.0
35.5
13.5
29.1
33.9
23.1
35.5
41.6
NO
2.6
0.0
0.0
10.3
4.3
4.3
6.3
0.0
2.3
0.0
0.0
9.3
1.1
0.0
10.9
0.0
5.8
14.5
4.8
1.6
3.5
3.1
4.2
2.7
Nimber
of SIUS
57
8
37
12
97
33
40
24
82
23
31
28
43
12
15
16
50
7
26
17
329
83
149
97
NON-CATEGORICAL
SIUS
T
(X)
85.9
80.8
79.6
97.5
42.9
75.0
17.7
59.7
72.7
80.4
60.8
81.3
53.0
58.3
73.2
50.0
71.3
28.6
83.4
56.9
58.9
73.6
45.3
64.7
r
(X)
14.1
19.2
20.4
2.S
55.2
18.9
82.3
40.3
25.0
19.6
39.2
9.3
46.5
41.7
20.2
50.0
26.9
57.1
16.6
43.1
39.6
22.8
54.5
34.0
ND
(X)
0.0
0.0
0.0
0.0
1.9
6.1
0.0
0.0
2.2
0.0
0.0
9.3
0.5
0.0
6.6
0.0
1.8
14.3
0.0
0.0
1.4
3.6
0.2
1.3
Nuifeer
Of SIUS
55
9
38
8
93
30
42
21
67
17
27
23
27
3
10
14
62
11
32
19
304
70
149
85
SIUS
T
(X)
67.7
100.0
56.6
43.5
66.6
70.8
76.5
45.7
74.3
71.2
81.9
67.0
33.8
66.7
85.2
21.4
76.4
60.9
80.2
80.7
66.5
74.0
75.2
45.7
f
(X)
26.6
0.0
43.4
21.8
26.8
26.7
10.2
54.3
23.4
28.8
18.1
23.8
64.1
33.3
0.0
78.6
14.4
24.5
10.8
16.1
27.9
23.3
16.5
49.9
•0
(X)
5.7
0.0
0.0
34.7
6.6
2.5
.13.3
0.0
2.3
0.0
0.0
9.2
2.2
0.0
14.8
0.0
9.1 '
U.5
9.0
5.1
5.6
2.6
8.3
4.4
T « TRUE STATEMENT
F * FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-l
-------
A.2. THE StU HAS HAD NONCOMPLIANCE EVENTS THAT CANNOT BE DESCRIBED AS MINOR EXCEEDANCES AND ATYPICAL OF THE DISCHARGE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SlUt
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuifeer '
Of POTUS
12
4
6
2
20
B
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nuner
Of SIUS
112
17
75
20
178
61
74
43
142
39
52
51
68
14
24
30
99
14
54
31
599
145
279
175
T
(X)
49.9
67.1
44.9
38.5
48.0
59.5
42.6
43.2
48.6
54.5
46.8
42.3
34.7
57.1
65.7
27.7
67.5
61.0
72.3
53.8
48.8
59.4
49.6
37.9
F
<*>
42.1
16.0
54.6
51.2
50.1
36.0
56.3
56.8
49.7
45.5
53.2
50.9
64.2
42.9
23.1
72.3
25.9
19.5
22.4
44.3
48.0
34.6
48.5
59.7
ND
(X)
8.0
16.9
0.6
10.3
1.9
4.5
1.1
0.0
1.7
0.0
0.0
6.8
1.1
0.0
11.3
0.0
6.7
19.5
5.2
1.9
3.2
5.9
1.9
2.5
Nuifeer
of SIUs
57
8
37
12
91
32
36
23
78
22
28
28
42
12
14
16
42
4
24
14
310
78
139
93
SIUs
T
(X)
54.5
66.0
53.4
45.5
31.4
52.2
13.2
47.5
49.1
56.7
56.8
26.1
37.1
58.3
57.4
31.3
58.5
25.0
65.1
47.5
41.4
55.3
35.1
37.7
F
(X)
41.1
19.2
46.6
54.5
66.3
41.5
86.1
52.5
47.4
43.3
43.2
59.8
62.4
41.7
35.5
68.8
39.4
50.0
34.9
52.5
56.1
38.5
64.4
60.3
ND
(X)
4.4
14.8
0.0
0.0
2.3
6.3
0.7
0.0
3.5
0.0
0.0
14.1
0.5
0.0
7.1
0.0
2.1
25.0
0.0
0.0
2.5
6.2
0.6
2.0
Nuifeer
of SIUS
55
9
38
8
87
29
38
20
64
17
24
23
26
2
10
14
57
10
30
17
289
67
140
82
NON-CATEGORICAL
SIUS
T
(X)
44.6
68.4
38.0
21.8
65.1
67.1
79.3
40.2
48.1
52.4
36.6
57.3
30.4
50.0
72.7
21.4
74.5
73.6
78.8
59.3
56.8
63.7
64.9
38.1
F
(X)
43.3
12.3
61.0
43.5
33.4
30.2
19.1
59.8
51.9
47.6
63.4
42.7
67.3
50.0
12.5
78.6
15.2
8.8
11.3
37.1
39.3
30.6
31.8
58.9
NO
(X)
12.1
19.3
1.0
34.7
1.5
2.7
1.6
0.0
0.0
0.0
0.0
0.0
2.2
0.0
U.8
0.0
10.3
17.6
9.9
3.6
3.9
5.7
3.3
3.0
ND
T * TRUE STATEMENT
F • FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-2
-------
A.3. THE SIU HAS BEEN IN SNC WITH DISCHARGE STANDARDS (NON-TTO)
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SHALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Number
Of POTUS
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Number
of SIUs
112
17
75
20
187
63
79
45
146
39
57
50
70
15
25
30
107
18
55
34
622
152
291
179
T
(X)
46.5
78.2
39.2
21.7
28.8
34.3
25.9
27.3
39.2
41.9
40.5
32.9
31.5
60.0
48.6
25.0
32.9
24.1
38.1
23.0
33.9
43.4
33.1
26.4
F
(X)
50.7
21.8
60.2
68.0
66.9
61.4
67.7
72.7
59.2
58.1
59.5
60.2
67.4
40.0
40.6
75.0
59.3
61.4
54.2
75.3
62.4
53.4
62.1
71.2
NO
(X)
2.9
0.0
0.6
10.3
4.3
4.3
6.4
0.0
1.7
0.0
0.0
6.8
1.1
0.0
10.9
0.0
7.8
14.5
7.7
1.7
3.6
3.1
4.8
2.4
Number
of SIUs
57
8
37
12
96
33
39
24
82
23
31
28
43
12
15
16
47
7
24
16
325
83
146
96
NON- CATEGORICAL
SIUs
T
(X)
42.9
70.0
48.5
12.5
20.8
36.0
8.2
30.4
30.3
30.2
38.3
16.9
35.9
58.3
40.4
31.3
22.7
14.3
28.9
7.0
28.3
40.9
22.7
24.6
F
(X)
57.1
30.0
51.5
87.5
77.3
57.9
91.8
69.6
66.3
69.8
61.7
69.0
63.6
41.7
53.0
68.8
75.4
71.4
71.1
93.0
70.1
55.5
77.1
73.5
NO
(X)
0.0
0.0
0.0
0.0
1.9
6.1
0.0
0.0
3.3
0.0
0.0
14.1
0.5
0.0
6.6
0.0
1.9
14.3
0.0
0.0
1.7
3.6
0.2
1.9
Number
of SIUs
55
9
38
8
91
30
40
21
64
16
26
22
27
3
10
14
60
11
31
18
297
69
145
83
SIUs
T
(X)
50.7
87.7
31.6
43.5
36.5
32.7
46.1
25.3
47.9
53.4
42.7
48.1
23.8
66.7
56.0
14.3
40.9
29.1
45.9
37.1
39.9
46.1
43.5
28.5
F
(X)
43.1
12.3
67.3
21.8
56.9
64.9
40.3
74.7
52.1
46.6
57.3
51.9
74.0
33.3
29.2
85.7
46.7
56.4
39.9
59.7
54.4
51.3
47.0
68.7
HO
CM
6.2
0.0
1.0
34.r
6.r
2.5
13.7
0.0
0.0
0.0
0.0
0.0
2.2
0.0
14.8
0.0
12.4.
14.5
14.2
3.2
5.7
2.6
9.5
2.9
T • TRUE STATEMENT
F > FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT I ON
G-3
-------
A.4. THE SIU MAS SEEN IN NC WITH TTO DISCHARGE STANDARDS
REGION
N. EAST
HID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
i AQTP
LAKUC
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
'LARGE
Nurtoer
Of POTWS
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
8
3
3
2
60
23
25
12
•Nunber
Of SIUS
41
10
19
12
28
9
'7
12
45
14
14
17
19
11
5
28
3
17
8
161
47
62
52
T
(X)
14.6
7.5
0.0
30.9
5.7
0.0
0.0
11.5
9.6
14.4
0.0
13.8
5.6
9.1
19.4
On
.0
16.0
0.0
15.7
31.6
10.6
8.2
5.3
17.6
F
(X)
52.7
43.5
58.6
57.3
38.8
71.6
10.4
27.5
57.7
62.3
67.8
33.8
31.2
27.3
40.3
n\
• J
62.1
100.0
66.5
0.0
50.1
56.3
57.3
37.3
NO
(X)
32.7
49.0
41.4
11.8
55.5
28.4
89.6
61.0
32.6
23.3
32.2
52.4
63.2
63.6
40.3
JUL T
DO. I
21.9
0.0
15.9
68.4
39.4
35.5
37.4
45.1
C
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Number
Of SIUS
29
6
12
11
24
7
7
10
34
10
11
13
19
11
5
24
2
14
8
130
36
49
45
T
(X)
15.5
0.0
0.0
33.8
3.4
0.0
0.0
7.4
12.7
23.7
0.0
12.6
5.6
9.1
19.4
On
• U
10.4
0.0
5.9
31.6
10.3
8.8
2.5
18.0
SIUS
F
(X)
53.0
51.5
54.6
53.3
38.1
57.1
10.4
40.7
47.1
46.2
56.7
34.1
31.2
27.3
40.3
MT
• £
65.2
100.0
78.8
0.0
47.3
48.2
54.9
40,1
ND
(X)
31.5
48.5
45.4
12.9
58.5
42.9
89.6
51.8
40.2
30.1
43.3
53.3
63.2
63.6
40.3
jut 7
OO. f
24.4
0.0
15.3
68.4
42.4
42.9
42.5
41.9
C
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Ninber
Of SIUS
12
4
7
1
4
2
0
2
11
4
3
4
0
0
0
4
1
3
0
31
11
13
7
NON- CATEGORICAL
T
(X)
11.6
25.0
0.0
0.0
11.8
0.0
0.0
20.0
3.3
0.0
0.0
16.5
0.0
0.0
0.0
39.1
0.0
62.6
0.0
11.5
6.8
15.2
16.0
SIUS
r
(X)
51.7
25.0
65.8
100.0
40.7
100.0
0.0
0.0
79.7
87.1
100.0
33.1
0.0
0.0
0.0
49.2
100.0
18.7
0.0
59.0
73.9
66.2
24.5
NO
(X)
36.7
50.0
34.2
0.0
47.4
0.0
0.0
80.0
17.1
12.9
0.0
50.4
0.0
0.0
0.0
11.7
0.0
18.7
0.0
29.5
19.2
18.6
59.6
C
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.
o-
0
ND «
T • TRUE STATEMENT
F • FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE
INFORATION
G-4
-------
A.5. THE SIU HAS BEEN IN SNC WITH TTO DISCHARGE STANDARDS
CATEGORICAL
ALL SIUS
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Number
of POTWs
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Number
of SIUs
49
10
27
12
38
13
8
17
S3
17
18
18
35
11
11
13
26
4
12
10
201
55
76
70
T
(X)
8.3
7.5
0.0
15.5
4.4
0.0
0.0
8.6
6.6
12.8
0.0
4.5
1.5
9.1
0.0
0.0
2.9
0.0
0.0
12.9
5.1
7.6
0.0
6.5
F
(X)
58.8
43.5
59.1
72.8
31.4
45.8
22.0
25.6
63.5
66.4
69.7
46.5
75.1
27.3
82.8
84.6
68.5
100.0
79.1
18.6
58.2
52.6
63.0
59.2
NO
(X)
33.0
49.0
40.9
11.8
64.1
54.2
78.0
65.8
29.9
20.8
30.3
49.0
23.4
63.6
17.2
15.4
28.6
0.0
20.9
68.6
36.7
39.8
37.0
34.4
Number
of SIUs
37
6
20
11
35
12
8
15
42
12
16
14
35
11
11
13
24
4
10
10
173
45
65
63
NON- CATEGORICAL
SIUS
T
(X)
7.3
0.0
0.0
16.9
2.3
0.0
0.0
4.9
7.7
20.3
0.0
0.0
1.5
9.1
0.0
0.0
3.3
0.0
0.0
12.9
4.4
7.2
0.0
5.2
F
(X)
60.8
51.5
56.3
70.2
34.1
41.3
22.0
33.7
58.2
53.9
65.3
51.5
75.1
27.3
82.8
84.6
67.4
100.0
79.5
18.6
58.4
48.4
60.2
63.6
NO
(X)
31.9
48.5
43.7
12.9
63.6
58.7
78.0
61.3
34.1
25.8
34.7
48.5
23.4
63.6
17.2
15.4
29.3
0.0
20.5
68.6
37.1
44.4
39.8
31.2
Number
of SIUS
12
4
7
1
3
1
0
2
11
5
2
4
0
0
0
0
2
0
2
0
28
10
11
7
SIUS
T
(X)
11.6
25.0
0.0
0.0
16.8
0.0
0.0
20.0
3.5
0.0
0.0
16.5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
8.7
8.7
0.0
16.0
F
(X)
51.7
25.0
65.8
100.0
16.2
100.0
0.0
0.0
78.4
87.7
100.0
33.1
0.0
0.0
0.0
0.0
77.0
0.0
77.0
0.0
56.7
66.8
77.6
24.5
•0
(X>
36.7
SO.O
34.2
0.0
67.0
0.0
0.0
80.0
18.2
12.3
0.0
50.4
0.0
0.0
0.0
0.0
23.0
0.0
Z3.0
0.0
34.6
24.5
22.4
59.6
ND
T • TRUE STATEMENT
F « FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT I ON
G-5
-------
*.6. THE SIU HAS SEEN IN NC WITH DISCHARGE SAMPLING REQUIREMENTS
REGION
N. EAST
HID EAST
SOUTH
.HID WEST
WEST
OVERALL
CATEGORICAL
ALL S1US
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Ntirber
of POTWs
12
4
6
2
20
a
a
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
of SIUs
100
12
74
14
138
SO
59
29
135
36
54
45
S3
14
9
30
102
15
53
34
528
127
249
152
T
(X)
57.7
66.5
53.8
56.9
39.6
32.1
40.3
48.1
58.0
63.4
46.9
70.6
25.1
35.7
56.3
. 22-4
61.1
60.6
59.2
68.3
46.3
46.8
47.5
44.3
F
(X)
22.7
16.1
15.4
43.1
30.1
39.2
27.1
23.9
23.8
19.2
33.0
13.6
73.4
64.3
0.0
77.6
30.1
22.5
33.6
24.3
33.6
31.3
27.2
44.3
NO
(X) '
19.6
17.4
30.8
0.0
30.3
28.7
32.6
28.0
18.2
17.4
20.1
15.8
1.5
0.0
43.7
0.0
8.7
16.9
7.1
7.4
20.1
21.8
25.3
11.4
NiSBber
Of SIUS
56
8
37
11
78
28
32
18
79
21
31
27
34
12
6
16
47
6
25
16
294
75
131
88
NON-CATEGORICAL
SIUs
T
(X)
66.1
63.6
70.2
63.6
54.2
27.5
60.7
80.0
60.0
69.6
44.9
73.2
30.9
25.0
50.0
31.3
57.7
66.7
53.3
68.4
53.8
44.9
57.8
55.7
f
(X)
21.6
21.6
8.5
36.4
31.5
43.4
32.0
9.3
22.3
6.2
42.0
9.8
67.5
75.0
0.0
66.8
32.8
16.7
37.9
23.7
34.1
32.9
31.2
39.0
NO
(X)
12.4
14.8
21.3
0.0
14.3
29.1
7.3
10.7
17.7
24.2
13.1
17.0
1.6
0.0
50.0
0.0
9.5
16.7
8.8
7.9
12.1
22.2
11.0
5.3
Nuifcer
of SIUS
44
4
37
3
60
22
27
11
56
15
23
18
19
2
3
14
55
9
28
18
234
52
118
64
SIUS
T
(X)
44.8
75.0
40.3
33.3
22.0
37.1
5.1
26.6
55.8
57.7
49.2
66.7
14.0
100.0
66.7
7.1
64.2
57.4
65.3
68.2
37.0
49.2
34.4
29.5
F
(X)
24.4
0.0
21.2
66.7
28.4
34.6
18.7
33.8
25.5
31.2
22.8
19.3
84.7
0.0
0.0
92.9
27.7
25.5
29.3
24.8
32.9
29.5
22.1
51.2
HO
(X)
30.9
25.0
38.5
0.0
49.5
28.3
76.2
39.6
18.7
11.1
28.0
14.1
.1.3
0.0
33.3
0.0
8.0
17.0
5.4
6.9
30.1
21.3
43.5
19.3
NO
T • TRUE STATEMENT
F « FALSE STATEMENT
» ANSWER COULD NOT IE DETERMINED FROM SIU FILE INFORATION
G-6
-------
A.6. THE SIU HAS BEEN IN NC WITH DISCHARGE SAMPLING REQUIREMENTS
i) SAMPLING FREQUENCY
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUs
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuitoer
of POTUs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
of SIUs
94
12
72
10
137
50
58
29
133
36
54
43
53
U
9
30
102
15
53
34
519
127
246
146
T
(X)
16.0
0.0
13.0
38.8
17.7
13.6
18.8
21.1
30.3
42.1
23.3
23.6
3.3
14.3
46.0
0.0
23.6
24.6
23.8
22.1
18.6
20.0
20.0
15.6
F
CX>
83.3
100.0
85.7
61.2
77.7
82.6
73.5
78.9
69.1
57.9
76.7
73.3
96.3
85.7
41.3
100.0
71.4
58.5
73.7
74.4
78.6
76.9
75.9
83.7
NO
(X)
0.7
0.0
1.3
0.0
4.6
3.8
7.7
0.0
0.6
0.0
0.0
3.2
0.4
0.0
12.7
0.0
5.0
16.9
2.4
3.6
2.8
3.1
4.2
0.7
Nuitoer
of SIUs
51
8
36
7
78
28
33
18
78
21
31
26
34
12
6
16
47
6
25
16
288
75
130
83
NON- CATEGORICAL
SIUS
T
(X)
15.9
0.0
9.1
40.6
22.9
5.7
26.1
42.7
31.4
47.6
19.3
30.4
2.3
8.3
33.3
0.0
17.0
16.7
19.8
7.0
19.5
14.8
21.7
20.5
F
(X)
84.1
100.0
90.9
59.4
75.9
90.2
73.9
57.3
67.4
52.4
80.7
64.6
97.7
91.7
66.7
100.0
77.7
66.7
75.4
93.0
79.2
82.5
77.5
78.8
NO
(X)
0.0
0.0
0.0
0.0
1.2
4.1
0.0
0.0
1.2
0.0
0.0
5.0
0.0
0.0
0.0
0.0
5.3
16.7
4.9
0.0
1.3
2.7
0.8
0.7
Nuifeer
of SIUS
43
4
36
3
59
22
26
11
55
15
23
17
19
2
3
14
55
9
28
18
231
52
116
63
SIUs
T
(X)
16.2
0.0
16.3
33.3
11.0
22.4
3.2
6.5
29.0
37.1
27.7
11.8
5.0
50.0
66.7
0.0
29.6
28.7
27.9
36.4
17.5
26.3
17.6
9.3
F
(X)
82.2
100.0
81.4
66.7
80.1
74.2
72.6
93.5
71.0
62.9
72.3
88.2
93.7
50.0
0.0
100.0
65.7
54.3
72.1
56.6
77.8
70.2
73.6
90.1
NO
(X)
1.6
0.0
2.4
0.0
9.0
3.4
. 24.2
0.0
0.0
0.0
0.0
0.0
1.3
0.0
33.3
0.0
4.7
17.0
0.0
6.9
4.8
3.6
8.8
0.6
ND
T * TRUE STATEMENT
F » FALSE STATEMENT
* ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-7
-------
A.6. THE StU HAS SEEN IN NC WITH DISCHARGE SAMPLING REQUIREMENTS
ii) REQUIRED PARAMETERS
POTU
REGION SIZE
N. EAST
MID EAST.
SOUTH
MID WEST
WEST
.OVERALL
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
CATEGORICAL
ALL SIUS
Nuifcer •
Of POTWs
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
• 25
12
Nuifeer
of SIUS
100
12
74
14
133
SO
55
28
133
36
54
43
53
14
9
30
102
15
53
34
521
127
245
149
T
(X)
26.5
41.1
25.1
15.4
21.2
9.1
19.5
40.7
13.9
9.7
14.4
20.5
18.7
28.6
56.3
15.8
29.6
38.0
31.3
16.3
21.3
16.6
22.2
24.2
f
(X)
71.4
58.9
71.7
82.6
74.6
88.8
72.6
59.3
84.0
86.5
85.6
76.3
80.8
71.4
31.0
84.2
67.4
45.1
68.7
81.9
75.9
80.1
73.7
75.0
NO
(X)
2.1
0.0
3.2
2.0
4.2
2.2
7.9
0.0
2.1
3.9
0.0
3.2
0.4
0.0
12.7
0.0
3.0
16.9
0.0 .
1.8
2.8
3.3
4.1
0.8
Nmber
of SIUS
56
8
37
11
75
28
30
17
78
21
31
26
34
12
6
16
47
6
25
16
290
75
129
86
SIUs
T
(X)
31.5
38.0
44.9
10.3
28.2
6.5
28.5
62.4
15.3
12.1
13.8
22.2
25.8
25.0
50.0
25.0
29.4
16.7
31.3
29.8
26.2
16.4
28.9
30.7
F
(X)
67.7
62.0
55.1
87.1
70.5
87.3
71.5
37.6
83.5
87.9
86.2
72.8
74.2
75.0
50.0
75.0
68.8
66.7
68.7
70.2
72.8
80.9
71.1
68.2
NO
(X)
0.8
0.0
0.0
2.6
1.3
4.1
0.0
0.0
1.2
0.0
0.0
5.0
0.0
0.0
0.0
0.0
1.9
16.7
0.0
0.0
1.1
2.7
0.0
1.1
Nuitoer
of SIUs
44
4
37
3
58
22
25
11 ,
55
15
23
17
19
2
3
14
55
9
28
18
231
52
116
63
NON-CATEGORICAL
SIUS
T
(X)
18.7
50.0
8.7
33.3
12.4
9.6
0.7
26.6
12.3
7.4
15.0
17.7
5.0
50.0
66.7
0.0
29.8
48.9
31.4
3.5
15.0
16.8
13.2
15.8
F
(X)
77.2
50.0
85.4
66.7
79.8
90.4
74.9
73.4
84.6
85.2
85.0
82.3
93.7
50.0
0.0
100.0
66.1
34.1
68.6
93.1
79.9
79.2
77.3
83.9
NO
(X)
4.1
0.0
5.8
0.0
7.8
0.0
24.4
0.0
3.0
7.4
0.0
0.0
1.3
0.0
33.3
0.0
4.0
17.0
0.0
3.5
5.1
4.0
9.5
0.3
T • TRUE STATEMENT
F » FALSE STATEMENT
ND • ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-8
-------
A.6. THE S1U HAS BEEN IN NC WITH DISCHARGE SAMPLING REQUIREMENTS
iii) SAMPLE TYPE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL .
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nurber
Of POTUS
12
4
6
2
20
B
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nuifeer
of SIUS
92
12
70
10
108
35
51
22
129
34
52
43
53
14
9
30
101
15
53
33
483
110
235
138
T
CX>
20.8
30.0
26.5
0.0
12.2
23.8
2.9
17.5
15.0
22.0
13.3
6.6
3.8
7.1
23.0
2.6
25.8
11.3
25.2
41.1
14.7
22.0
14.1
9.7
F
(X)
49.2
52.6
30.5
83.5
41.1
32.2
36.3
62.8
53.4
45.7
58.2
57.0
93.9
92.9
10.3
97.4
59.6
66.2
61.5
46.9
55.3
46.3
44.6
77.3
NO
(X)
30.0
17.4
43.0
16.5
46.6
43.9
60.8
19.7
31.6
32.3
28.5
36.5
2.3
0.0
66.7
0.0
14.6
22.5
13.3
11.9
30.0
31.7
41.4
13.0
Nurber
Of SIUS
50
8
35
7
58
19
26
13
78
21
31
26
34
12
6
16
47
6
25
16
267
66
123
78
NON- CATEGORICAL
SIUs
T
(X)
16.4
14.8
31.2
0.0
11.4
23.9
3.2
15.7
21.4
40.8
12.4
10.4
1.8
8.3
16.7
0.0
20.5
33.3
15.9
29.8
13.6
25.3
12.2
6.5
F
(X)
52.9
70.4
17.2
78.3
45.2
25.8
49.1
63.3
48.8
32.3
65.2
42.2
96.1
91.7
16.7
100.0
61.7
33.3
68.3
54.4
58.3
44.4
51.0
78.1
ND
(X)
30.7
14.8
51.6
21.7
43.5
50.3
47.8
21.1
29.9
26.9
22.4
47.4
2.1
0.0
66.7
0.0
17.8
33.3
15.8
IS. 8
28.0
30.3
36.8
15.4
Nuifier
of SIUs
42
4
35
3
50
16
25
9
51
13
21
17
19
2
3
14
54
9
28
17
216
44
112
60
SIUS
T
(X)
27.7
75.0
22.5
0.0
13.1
23.8
2.6
18.8
7.0
2.3
14.4
0.0
7.8
0.0
33.3
7.1
30.6
0.0
34.6
53.3
16.1
18.0
16.1
14.2
f
(X)
43.5
0.0
41.6
100.0
37.1
38.5
20.9
62.4
59.2
59.7
49.2
82.3
89.7
100.0
0.0
92.9
57.8
83.0
54.5
38.9
51.5
48.7
37.5
76.1
NO
28.8
25.0
35.9
0.0
49.8
37.8
76. S
18.8
33.8
38.1
36.4
17.7
2.S
0.0
66.7
0.0
11.6
17.0
10.8
7.8
32.4
33.3
46.4
9.7
T « TRUE STATEMENT
F « FALSE STATEMENT
NO » ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-9
-------
A.6. THE SIU HAS BEEN IN NC WITH DISCHARGE SAMPLING REQUIREMENTS
iv) ANALYTICAL PROCEDURES
REGION
N. EAST
MID EAST
SOUTH
MK> WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nusber
of POTWs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
. 25
12
Nuifeer
of SIUS
92
11
71
10
92
34
38
20
127
34
49
44
52
13
9
30
99
14
52
33
462
106
219
137
T
17.6
8.6
9.4
43.0
17.7
4.9
25.0
15.1
34.9
29.2
32.0
49.1
7.3
7.7
23.0
6.6
17.2
6.5
15.6
31.1
19.4
13.1
21.6
21.2
F
(X>
40.6
30.7
38.4
54.8
38.2
56.7
38.4
12.7
45.3
44.6
53.2
32.6
90.4
92.3
10.3
93.4
68.4
74.0
70.9
54.7
51.9
52.9
47.2
57.8
NO
(X)
41.8
60.7
52.2
2.2
44.0
38.3
36.6
72.2
19.9
26.2
14.8
18.4
2.3
0.0
66.7
0.0
14.5
19.5
13.5
14.1
28.7
33.9
31.2
20.9
NvjJber
Of SIUS
51
8
36
7 '
55
21
22
12
76
21
29
26
34
12
6
16
47
6
25
16
263
68
118
77
SIUS
T
-------
A.7. THE SIU HAS BEEN IN NC WITH OtSCHARCE REPORTING REQUIREMENTS (NON-TTO)
REGION
N. EAST
MID EAST
SOUTH
NIO WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuttoer
of POTUs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nuifeer
of SIUS
115
17
76
22
191
62
84
45
151
41
58
52
70
15
25
30
112
18
58
36
639
153
301
185
T
(X)
37.7
44.1
31.2
41.4
31.1
27.6
28.4
43.1
34.1
44.5
28.6
26.8
38.2
13.3
16.2
44.8
33.1
35.5
34.3
26.9
33.6
34.2
29.4
39.8
F
(X)
52.2
50.1
49.9
58.6
51.1
46.6
51.7
55.5
61.4
52.3
68.8
63.8
61.1
86.7
76.8
55.2
52.9
54.8
50.4
60.1
54.4
51.2
54.5
57.4
ND
(X)
10.1
5.8
18.9
0.0
17.8
25.8
20.0
1.3
4.5
3.3
2.6
9.3
0.7
0.0
7.0
0.0
13.9
9.6
15.3
13.0
12.0
14.6
16.2
2.8
Number
of SlUs
58
8
37
13
98
32
42
24
83
23
31
29
43
12
15
16
50
7
26
17
332
82
151
99
NON-CATEGORICAL
SIUS
T
(X)
50.9
66.0
38.9
50.7
40.2
37.1
36.7
60.1
35.9
35.3
30.2
45.9
42.0
8.3
25.8
50.0
26.2
14.3
29.9
21.1
39.9
37.8
34.9
50.1
F
(X)
43.3
34.0
45.1
49.3
49.1
42.1
55.0
36.4
59.5
57.6
64.6
54.1
57.5
91.7
67.7
50.0
64.0
85.7
59.4
66.0
52.6
50.7
56.2
48.2
ND
(X)
5.9
0.0
16.1
0.0
10.7
20.8
8.3
3.5
4.6
7.0
5.3
0.0
0.5
0.0
6.6
0.0
9.8
0.0
10.7
12.9
7.5
11.4
9.0
1.7
Nuifcer
of SIUS
57
9
39
9
93
30
42
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
SIUS
T
(X)
22.6
19.3
25.2
20.3
20.6
18.4
15.0
32.4
32.4
S2.4
27.0
8.5
31.4
33.3
7.4
35.7
38.7
46.4
38.1
32.3
26.5
30.5
22.7
28.3
f
(X)
62.5
68.4
53.7
79.7
53.4
51.0
46.4
67.6
63.2
47.6
73.0
73.2
67.5
66.7
85.2
64.3
44.0
39.1
42.6
54.7
56.5
51.7
52.4
67.6
HO
(X)
14.9
12.3
21.0
0.0
26.0
30.6
38.6
0.0
4.4
0.0
0.0
18.3
1.1
0.0
7.4
0.0
17.3
14.5
19.4
13.0
17.0
17.7
24.9
4.0
T » TRUE STATEMENT
F > FALSE STATEMENT
ND • ANSWER COULD NOT BE DETERMINED FROM SIU FILE IMFORATION
G-ll
-------
A.7. THE SIU HAS BEEN IN NC WITH DISCHARGE REPORTING REQUIREMENTS (NON-TTO)
i) PERIODIC REPORTS (FOR REASONS OTHER THAN TIMELINESS)
REGION
N. EAST
HID EAST
SOUTH
*ID WEST
WEST
OVERALL
CATEGORICAL
ALL S1US
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuifeer
Of POTUS
12
4
6
2
20
8
8
4
14
6
i
3
6
2
3
1
8
3
3
2
60
23
25
12
Hunter
of SIUS
95
12
73
10
155
46
73
36
132
36
53
43
65
15
20
30
105
17
54
34
552
126
273
153
T
(X)
33.2
45.8
17.2
53.2
30.4
21.6
27.3
47.8
16.6
20.3
6.5
30.3
10.3
13.3
16.6
9.2
17.1
5.1
18.6
23.0
24.0
22.5
20.7
30.4
F
(X)
66.8
54.2
82.8
46.8
65.7
76.1
66.9
50.8
80.7
75.8
93.5
63.4
89.3
86.7
78.5
90.8
80.8
84.8
81.4
75.3
73.5
74.5
76.3
68.2
ND
(X)
0.0
0.0
0.0
0.0
3.9
2.3
5.8
1.5
2.7
3.9
0.0
6.3
0.4
0.0
4.9
0.0
2.0
10.1
0.0
1.7
2.5
2.9
3.0
1.4
Nunber
of SIUS
52
8
37
7 -
91
27
40
24
78
21
31
26
42
12
14
16
46
6
24
16
309
74
146
89
SIUS
T
(X)
40.3
44.4
21.9
59.4
35.7
21.4
34.8
60.1
15.0
5.8
7.9
40.4
7.6
8.3
20.4
6.3
18.5
0.0
22.7
14.9
27.3
19.8
27.8
32.7
F
(X)
59.7
55.6
78.1
40.6
62.8
74.3
65.2
36.4
82.3
86.1
92.1
59.6
92.4
91.7
79.6
93.8
81.5
100.0
77.3
85.1
71.6
76.4
72.2
66.5
ND
(X)
0.0
0.0
0.0
0.0
1.5
4.3
0.0
3.5
2.7
8.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
3.8
0.0
0.9
Ntfflber
of SIUS
43
4
36
3
64
19
33
12
54
15
22
17
23
3
6
14
59
11
30
18
243
52
127
64
NON- CATEGORICAL
SIUS
T
(X)
22.2
50.0
13.2
33.3
21.4
21.8
2.9
38.5
18.3
33.6
4.9
14.8
15.3
33.3
11.4
14.3
16.1
7.3
15.1
30.1
19.3
25.9
8.7
27.4
F
<*>
77.8
50.0
86.8
66.7
70.5
78.2
72.3
61.5
78.9
66.4
95.1
69.2
83.6
66.7
77.1
85.7
80.3
78.2
84.9
66.7
76.2
72.2
83.2
70.5
ND
(X)
0.0
0.0
0.0
0.0
8.1
0.0
24.8
0.0
2.8
0.0
0.0
16.0
1.2
0.0
11.4
0.0
3.6
14.5
0.0
3.2
4.5
1.9
8.0
2.1
T » TRUE STATEMENT
F * FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-12
-------
A.7. THE SIU MAS BEEN IN NC WITH DISCHARGE REPORTING REQUIREMENTS (NON-TTQ)
ii) 24 HOUR NONCOMPLIANCE NOTIFICATION
CATEGORICAL
ALL SlUs
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
POTW
SIZE
SMALL
MEDIUM
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuitocr
Of POTUS
12
4
6
20
8
8
4
U
6
5
3
6
3
1
8
3
3
2
60
23
25
12
Number
of SIUs
29
3
26
67
28
38
1
56
23
18
15
19
8
11
80
13
39
28
251
67
129
55
T
(X)
35.8
66.7
27.0
3.S
8.1
1.3
0.0
50.8
53.3
44.3
55.7
91.7
10.3
100.0
27.2
27.8
32.6
9.3
27.7
27.0
15.6
67.2
F
(X)
12.7
0.0
16.4
45.3
10.2
61.4
100.0
43.4
46.7
47.4
29.5
5.2
56.3
0.0
40.2
40.5
33.5
61.2
37.4
23.8
48.7
23.3
ND
(X)
51.5
33.3
56.7
51.2
81.7
37.3
0.0
5.8
0.0
8.2
14.8
3.1
33.3
0.0
32.6
31.8
33.9
29.4
35.0
49.2
35.7
9.5
Number
of SIUs
14
2
12
41
16
24
1
38
14
13
11
13
5
8
33
5
15
13
139
37
69
33
NON- CATEGORICAL
SIUs
T
(X)
47.2
100.0
21.6
3.8
14.9
0.0
0.0
56.7
49.2
59.6
65.1
94.9
19.4
100.0
23.9
20.0
29.5
10.4
29.2
31.7
12.1
74.8
F
(X)
13.3
0.0
19.8
62.9
13.2
79.3
100.0
38.6
50.8
27.0
34.9
2.6
41.8
0.0
54.5
80.0
44.6
66.8
47.3
,27.9
64.3
22.0
ND
(X)
39.5
0.0
58.6
33.3
72.0
20.7
0.0
4.6
0.0
13.4
0.0
2.4
38.8
0.0'
21.6
0.0
25.9
22.9
23.5
40.3
23.7
3.3
Nuifeer
of SIUS
15
1
14
26
12
14
0
18
9
5
4
6
3
3
47
8
24
15
112
30
60
22
SIUS
T
(X)
26.3
0.0
30.4
2.9
0.0
5.7
0.0
42.4
57.5
19.8
33.1
80.7
0.0
100.0
29.5
31.4
35.0
8.4
25.1
22.0
21.6
48.2
F
(X)
12.3
0.0
14.2
3.8
6.6
1.1
0.0
50.3
42.5
80.2
16.5
14.1
72.9
0.0
29.9
22.1
25.0
56.3
21.5
19.3
21.8
26.7
NO
(X)
61.4
100.0
55 .4
93.3
93.4
93.2
0.0
7.3
0.0
0.0
SO. 4
5.2
27.1
0.0
40.6
46.5
40.0
35.2
53.3
58.7
56.6
25.1
ND
T « TRUE STATEMENT
F » FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INfORATION
G-13
-------
A.7. THE SIU HAS BEEN IN NC WITH DISCHARGE REPORTING REQUIREMENTS (NON-TTO)
iii) 30 DAT RESAMPLING REPORT
POTW
REGION SIZE
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
SMALL
MED1UN
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
CATEGORICAL
ALL SIU*
Nurtoer
of POTWs
12
4
6
20
8
a
4
U
6
5
3
6
3
1
8
3
3
2
60
23
25
12
• Nuitoer
of SlUs
19
1
18
21
7
13
• 1
58
20
23
15
18
7
11
21
9
10
2
137
37
71
29
T
(X)
24.0
0.0
27.7
13.6
70.1
3.9
0.0
27.1
19.6
32.6
29.5
85.6
0.0
93.4
43.0
44.4
44.5
0.0
31.1
37.2
15.4
71.3
F
CX)
62.9
100.0
57.1
69.0
14.9
77.8
100.0
67.9
80.4
62.2
55.7
10.1
48.7
6.6
46.6
33.3
55.5
50.0
57.9
55.2
70.2
24.3
NO
(X)
13.1
0.0
15.2
17.4
14.9
18.3
0.0
4.9
0.0
5.3
14.8
4.3
51.3
0.0
10.4
22.2
0.0
50.0
11.0
7.6
14.5
4.4
Nuifeer
Of SIUS
11
1
10
16
6
9
1
39
12
16
11
12
4
8
9
3
6
0
87
22
45
20
NON- CATEGORICAL
SIUs
T
(X)
30.8
0.0
40.2
14.1
66.7
4.7
0.0
29.7
33.0
23.9
34.9
94.9
0.0
100.0
35.0
33.3
35.5
0.0
32.7
44.9
12.3
78.6
F
(X)
69.2
100.0
59.8
80.5
16.7
91.9
100.0
66.1
67.0
65.8
65.1
2.7
51.9
0.0
65.0
66.7
64.5
0.0
63.2
48.1
83.0
21.4
NO
(X)
0.0
0.0
0.0
5.4
16.7
3.5
0.0
4.2
0.0
10.3
0.0
2.5
46.1
0.0
0.0
0.0
0.0
0.0
4.1
6.9
4.6
0.0
Nuifcer
of SIUs
8
0
8
5
1
4
0
19
8
7
4
6
3
3
12
6
4
2
50
15
26
9
SIUs
T
(X)
14.6
0.0
14.6
10.5
100.0
0.0
0.0
23.9
4.2
41.7
16.5
53.8
0.0
66.7
53.6
50.0
75.0
0.0
27.1
24.1
23.4
46.0
F
(X)
54.2
0.0
54.2
1.9
0.0
2.1
0.0
70.2
95.8
58.3
33.1
35.7
45.8
33.3
21.7
16.7
25.0
50.0
44.2
67.3
35.9
34.2
NO
(X)
31.2
0.0
31.2
87.6
0.0
97.9
0.0
5.9
0.0
0.0
50.4
10.5
54.2
0.0
24.4
33.3
0.0
50.0
28.6
8.7
40.7
19.8
T • TRUE STATEMENT
F « FALSE STATEMENT
NO > ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-14
-------
A.7. THE S1U HAS BEEN IN NC WITH DISCHARGE REPORTING REQUIREMENTS (NON-TTO)
iv) OTHER RESPONSES
REGION
N. EAST
MID EAST
SOUTH
NID WEST
WEST
OVERALL
CATEGORICAL
ALL SlUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuifeer
Of POTUs
12
4
6
2
20
8
8
4
u
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
N inter
of SIUs
115
17
76
22
186
62
82
42
151
41
58
52
69
15
24
30
112
18
58
36
633
153
298
182
T
(X)
0.3
0.0
0.6
0.0
3.2
0.0
6.6
0.0
0.0
0.0
0.0
0.0
0.8
6.7
0.0
0.0
0.3
0.0
0.0
1.6
1.5
0.3
3.3
0.1
F
(X)
99.7
100.0
99.4
100.0
88.6
100.0
76.3
100.0
100.0
100.0
100.0
100.0
99.2
93.3
100.0
100.0
99.7
100.0
100.0
98.4
94.9
99.7
88.4
99.9
NO
(X)
0.0
0.0
0.0
0.0
8.2
0.0
17.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.6
0.0
8.3
0.0
Nurtoer
of SIUS
58
8
37
13
93
32
40
21
83
23
31
29
43
12
15
16
50 '
7
26
17
327
82
149
96
NON- CATEGORICAL
SIUs
T
(X)
0.5
0.0
1.4
0.0
0.9
0.0
1.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
0.0
1.1
0.0
F
(X)
99.5
100.0
98.6
100.0
87.6
100.0
76.5
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
94.8
100.0
87.8
100.0
ND
(X)
0.0
0.0
0.0
0.0
11.5
0.0
21.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4.7
0.0
11.1
0.0
Nurfcer
of SIUs
57
9
39
9
93
30
42
21
68
18
27
23
26
3
9
U
62
11
32
19
306
71
149
86
SIUS
T
(X)
0.0
0.0
0.0
0.0
5.3
0.0
12.0
0.0
0.0
0.0
0.0
0.0
2.2
33.3
0.0
0.0
0.5
0.0
0.0
3.1
2.7
0.7
5.5
0.2
F
(X)
100.0
100.0
100.0
100.0
89.S
100.0
76.1
100.0
100.0
100.0
100.0
100.0
97.8
66.7
100.0
100.0
• 99.5
100.0
100.0
96.9
95.0
99.3
89.1
99.8
HO
CXI
0.0
0.0
0.0
0.0
5.3
0.0
12.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.4
0.0
5.5
0.0
ND
T * TRUE STATEMENT
F > FALSE STATEMENT
ANSWER COULD NOT 8E DETERMINED FROM SIU FILE
INFORAT ION
G-15
-------
A.8. THE SIU MAS SUBMITTED LATE REPORTS
REGION
N. EAST
HID EAST
SOUTH
MIC WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nutter
of POTWs
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
of SlUs
too
13
75
12
164
51
74
39
134
33
53
48
66
14
22
30
108
17
55
36
572
128
279
165
T
(X)
63.3
26.3
68.9
91.3
45.8
38.9
50.1
43.8
53.1
60.7
52.2
44.6
52.5
71.4
50.8
50.0
47.6
20.3
52.6
54.5
50.4
42.5
53.5
51.9
F
(X)
34.7
67.9
31.1
6.6
36.2
53.1
34.1
20.5
40.8
39.3
47.8
31.1
45.1
14.3
40.1
50.0
49.6
64.6
47.4
43.9
39.5
50.7
38.1
32.5
NO
(X)
2.0
5.8
0.0
2.1
18.0
8.0
15.8
35.7
6.2
0.0
0.0
24.3
2.4
14.3
9.0
0.0
2.9
15.2
0.0
1.6
10.1
6.8
8.4
15.5
Nuifcer
of SlUs
53
8
37
8
92
29
39
24
78
19
31
28
43
12
15
16
48
6
25
17
314
74
147
93
SIUS
T
(X)
59.9
29.6
58.6
91.6
5,4.0
39.7
56.7
65.2
54.6
63.8
42.0
65.2
54.1
75.0
55.6
50.0
48.4
16.7
52.1
53.7
54.4
45.0
54.2
62.2
F
(X)
39.2
70.4
41.4
5.6
32.2
50.7
27.8
20.9
43.6
36.2
58.0
28.0
44.7
16.7
U.4
50.0
51.6
83.3
47.9
46.3
38.5
49.6
36.5
33.0
NO
(X)
0.9
0.0
0.0
2.8
13.8
9.6
15.4
13.9
1.8
0.0
0.0
6.8
1.2
8.3
0.0
0.0
0.0
0.0
0.0
0.0
7.1
5.4
9.2
4.8
Nurfeer
of SIUS
47
5
38
4
72
22
35
15
56
14
22
20
23
2
7
U
60
11
30
19
258
54
132
72
NON-CATEGORICAL
SIUS
T
(X)
68.0
18.9
77.3
90.4
34.2
38.0
35.6
28.5
51.4
57.9
64.0
22.2
49.4
50.0
44.9
50.0
46.9
21.8
53.2
55.2
45.1
39.6
52.4
39.6
F
(X)
28.4
62.1
22.7
9.6
41.9
55.8
47.8
20.3
37.7
42.1
36.0
34.5
46.0
0.0
34.6
50.0
47.9
56.4
.46.8
41.7
40.8
51.9
40.4
32.0
NO
(X)
3.7
18.9
0.0
0.0
23.9
6.2
16.6
51.2
10.8
0.0
0.0
43.3
4.6
50.0
20.5
0.0
5.2
21.8
0.0
3.1
14.1
8.5
7.2
28.5
ND
T * TRUE STATEMENT
F * FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-16
-------
A.9. THE SlU HAS BEEN IN SNC WITH REPORTING REQUIREMENTS
REGION
N. EAST
NIO EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUs
POTU
SIZE
SHALL
MEDIUM'
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nirber
Of POTWs
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
NKnber
of SIUs
101
U
75
12
164
51
73
40
134
33
52
49
67
15
22
30
108
15
57
36
574
128
279
167
T
(X>
22.5
5.4
24.9
37.1
31.2
15.9
42.5
22.5
39.6
42.8
44.0
29.0
15.2
13.3
35.3
13.2
32.0
0.0
32.9
53.8
29.5
19.1
38.5
24.2
F
71.3
79.6
70.
62.
53.
80.
41.
49.5
53.2
57.2
56.0
44.2
83.7
80.0
60.2
86.8
66.0
88.7
67.1
44.6
61.2
75.7
52.6
62.5
ND
(X)
6.2
15.0
4.4
0.0
15.3
3.6
15.9
28.0
7.2
0.0
0.0
26.8
1.2
6.7
4.5
0.0
2.0
11.3
0.0
1.6
9.3
5.2
8.9
13.3
Number
of SIUs
53
8
37
8
91
29
38
24
76
19
30
27
43
12
15
16
47
5
25
17
310
73
145
92
NON- CATEGORICAL
SIUs
T
(X)
21.5
0.0
24.3
39.4
39.5
8.6
50.8
42.9
35.1
39.1
25.1
47.5
13.7
16.7
19.7
12.5
33.8
0.0
35.0
45.5
32.1
13.7
41.5
31.0
F
(X)
72.1
85.2
70.8
60.6
47.9
87.4
33.6
43.2
63.7
60.9
74.9
47.8
86.3
83.3
80.3
87.5
66.2
100.0
65.0
54.5
60.9
81.7
48.6
64.9
ND
(X)
6.4
14.8
4.9
0.0
12.6
4.0
15.6
13.9
1.2
0.0
0.0
4.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
7.0
4.6
9.9
4.1
Nunber
of SIUs
48
6
38
4
73
22
35
16
58
14
22
22
24
3
7
14
61
10
32
19
264
55
134
75
SIUS
T
(X)
23.7
15.3
25.4
30.1
19.5
24.1
24.8
8.0
44.2
46.2
66.2
11.8
17.9
0.0
55.1
14.3
30.6
0.0
31.2
61.5
26.3
25.3
34.1
16.2
F
(X)
70.3
69.5
70.7
69.9
61.4
72.8
58.6
53.9
42.6
53.8
33.8
40.9
78.7
66.7
34.6
85.7
65.9
84.3
68.8
35.4
61.4
68.8
58.4
59.6
HO
6.0
15.3
3.9
0.0
19.0
3.1
16.6
38.0
13.2
0.0
0.0
47.3
3.4
33.3
10.3
0.0
3.5
15.7
0.0
3.1
12.S
5.9
7.5
24. t
T s TRUE STATEMENT
F * FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SlU FILE INFORAT ION
G-17
-------
A.10. THE SIU MAS BEEEN IN NC WITH TTO REPORTING REQUIREMENTS (FOR REASONS OTHER THAN TIMELINESS)
REGION
N. EAST
MID EAST
SOUTH
MIP WEST
WEST
OVERALL
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Of POTWS
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
CATEGORICAL
ALL SIUS
Nuitoer
of SIUS
61
10
38
13
62
25
16
21
61
18
23
20
38
10
14
14
39
7
21
11
261
70
112
79
T
(X)
35.3
49.0
23.9
37.1
27.5
17.3
16.3
54.5
22.3
25.3
11.4
37.9
6.7
0.0
13.4
7.1
8.4
0.0
7.5
22.9
23.1
23.1
15.4
31.4
F
(X)
57.6
43.5
65.1
60.7
68.9
79.5
83.7
36.2
58.8
53.2
73.5
40.4
79.5
50.0
71.5
85.7
78.0
100.0
82.5
29.8
67.4
65.1
77.2
58.5
ND
(X)
7.1
7.5
11.0
2.2
3.7
3.2
0.0
9.3
18.9
21.6
15.1
21.7
13.8
50.0
15.1
7.1
13.6
0.0
10.0
47.3
9.6
11.8
7.4
10.1
Nuitoer
of SIUs
42
6
25
11
56
23
14
19
48
12
20
16
38
10
14
14
35
6
18
11
219
57
91
71
NON-CATEGORICAL
SIUs
T
(X)
38.3
48.5
22.9
44.1
26.7
19.5
16.7
56.4
24.9
23.3
13.7
50.7
6.7
0.0
13.4
7.1
7.8
0.0
5.8
22.9
22.8
22.3
15.0
31.5
F
(X)
56.4
51.5
64.1
53.3
69.1
76.9
83.3
30.4
56.6
52.4
68.1
37.3
79.5
50.0
71.5
85.7
76.2
100.0
82.7
29.8
67.7
66.7
77.0
58.2
ND
(X)
5.3
0.0
13.0
2.6
4.2
3.6
0.0
13.2
18.6
24.3
18.2
12.0
13.8
50.0
15.1
7.1
15.9
0.0
11.6
47.3
9.5
10.9
7.9
10.2
Nunber
of SIUs
19
4
13
2
6
2
2
2
13
6
3
4
0
0
0
0
4
1
3
0
42
13
21
8
SIUs
T
(X)
28.1
50.0
25.4
0.0
32.5
0.0
0.0
50.0
15.8
27.7
0.0
0.0
0.0
0.0
0.0
0.0
11.7
0.0
18.7
0.0
24.4
25.7
17.2
30.4
F
(X)
60.4
25.0
66.6
100.0
67.5
100.0
100.0
50.0
64.4
54.2
100.0
49.6
0.0
0.0
0.0
0.0
88.3
100.0
8.1.3
0.0
65.8
59.6
78.3
60.1
NO
(X)
11.5
25.0
8.0
0.0
0.0
0.0
0.0
0.0
19.8
18.1
0.0
50.4
0.0
0.0
0.0.
0.0
0.0
0.0
0.0
3.0
9.8
U.7
c.5
9.4
ND
T • TRUE STATEMENT
F * FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-18
-------
A.11. THE S1U HAS BEEN IN SNC WITH TTO REPORTING REQUIREMENTS
REGION
N. EAST
HID EAST
SOUTH
HID WEST
WEST
OVERALL
CATEGORICAL
ALL S1US
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nunber
of POTUs
12
4
6
2
20
8
e
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
of SIUS
60
10
37
13
56
20
16
20
57
17
21
19
36
10
12
U
26
3
12
11
235
60
98
77
T
34.7
56.5
28.7
22.9
32.0
28.8
19.7
55.3
27.8
37.3
17.4
29.7
6.8
0.0
15.8
7.1
U.2
0.0
13.4
22.9
26.4
34.3
20.5
26.7
f
63.0
43.5
67.2
74.9
47.4
66.9
43.4
35.6
56.9
47.7
71.2
47.2
79.3
50.0
66.5
85.7
62.6
100.0
68.9
29.8
59.0
55.3
57.7
63.1
NO
2.3
0.0
4.1
2.2
20.6
4.4
36.9
9.2
15.3
15.0
11.5
23.1
14.0
50.0
17.7
7.1
23.2
0.0
17.7
47.3
14.6
10.4
21.8
10.2
Number
of SIUs
42
6
25
11
52
19
14
19
45
11
19
15
36
10
12
14
25
3
11
11
200
49
81
70
NON- CATEGORICAL
SIUS
T
(X)
33.9
48.5
29.4
27.2
28.7
30.1
19.0
45.9
31.7
44.8
19.7
40.6
6.8
0.0
15.8
7.1
11.7
0.0
9.3
22.9
24.5
32.3
19.6
24.6
F
(X)
63.0
51.5
64.1
70.2
49.2
65.3
43.2
43.0
55.4
42.6
67.3
46.3
79.3
50.0
66.5
85.7
64.5
100.0
72.2
29.8
59.8
57.3
55.5
65.6
NO
(X)
3.2
0.0
6.5
2.6
22.1
4.6
37.8
11.1
12.9
12.6
13.0
13.1
14.0
50.0
17.7
7.1
23.8
0.0
18.6
47.3
15.7
10.3
24.9
9.8
Nimeer
of SIUs
18
4
12
2
4
1
2
1
12
6
2
4
0
0
0
0
1
0
1
0
35
11
17
7
SIUS
T
(X)
36.9
75.0
27.6
0.0
75.9
0.0
so.o
100.0
17.2
27.7
0.0
0.0
0.0
0.0
0.0
0.0
100.0
0.0
100.0
0.0
37.6
41.9
27.0
43.8
F
(X>
63.1
25.0
72.*
100.0
24.1
100.0
50.0
0.0 '
61.1
54.2
100.0
49.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
54.5
47.6
73.0
42.6
NO
(X)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
21.7
18.1
0.0
50.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
7.9
10.5
0.0
13.6
ND
T * TRUE STATEMENT
F « FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-19
-------
B.I. THE POTU IS NOT APPLYING LOCAL DISCHARGE STANDARDS
REGION
N. EAST
N1D EAST
SOUTH
NID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nirtwr .
Of POTUs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
-25
12
Number
of SIUS
113
16
76
21
188
60
84
44
150
41
57
52
69
15
24
30
110
18
56
36
630
150
297
183
T
(X)
16.9
42.1
5.9
8.1
19.1
9.0
25.7
14.9
2.5
2.2
0.0
6.8
4.4
20.0
0.0
2.6
9.4
14.5
6.9
13.5
13.0
13.1
15.7
6.7
F
(X)
82.1
57.9
94.1
87.9
80.6
91.0
73.8
85.1
96.7
95.6
100.0
93.2
95.6
80.0
100.0
97.4
88.6
75.9
93.1
84.9
86.3
85.6
84.1
90.7
NO
(X)
1.1
0.0
0.0
4.0
0.3
0.0
0.5
0.0
0.8
2.2
0.0
0.0
0.0
0.0
0.0
0.0
1.9
9.6
0.0
1.6
0.6
1.3
0.3
0.6
Nuifcer
of SIUS
56
7
37
12
95
30
42
23
82
23
30
29
42
12
14
16
48
7
24
17
323
79
147
97
SIUS
T
(X)
10.0
23.6
9.0
0.0
23.3
10.1
31.0
11.8
2.8
4.7
0.0
4.4
2.5
16.7
0.0
0.0
2.6
14.3
0.0
3.2
13.3
11.7
19.8
3.6
F
(X)
90.0
76.4
91.0
100.0
76.7
89.9
69.0
88.2
95.6
90.6
100.0
95.6
97.5
83.3
100.0
100.0
97.4
85.7
100.0
96.8
86.5
87.2
80.2
96.4
ND
(X)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.7
4'. 7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.3
1.2
0.0
0.0
Nunber
of SIUS
57
9
39
9
93
30
42.
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
NON-CATEGORICAL
SIUS
T
(X)
24.4
61.5
3.4
26.0
14.3
7.9
17.1
16.8
2.2
0.0
0.0
9.2
7.8
33.3
0.0
7.1
14.7
14.5
12.5
22.9
12.8
14.5
10.7
14.3
F
(X)
73.3
38.5
96.6
61.0
85.1
92.1
81.5
83.2
97.8
100.0
100.0
90.8
92.2
66.7
100.0
92.9
81.9
70.9
87.5
73.9
86.2
84.2
88.7
84.4
NO
(X)
2.2
0.0
0.0
13.0
0.6
0.0
1.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.4
14.5
0.0
3.1
1.0
1.4
0.6
1.3
NO
T « TRUE STATEMENT
F « FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-20
-------
B.2. THE POTU IS NOT APPLYING ALL CATEGORICAL DISCHARGE STANDARDS
CATEGORICAL
ALL SIUS
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Number
of POTUs
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Ninber.
of SIUs
54
5
37
12
95
33
38
24
79
23
31
25
42
12
14
16
50
7
26
17
320
80
146
94
T
(X)
36.1
34.6
58.0
12.5
29.6
30.4
23.5
52.6
31.9
38.4
24.6
34.9
34.1
100.0
65.1
18.8
52.1
100.0
31.6
92.7
33.6
42.6
29.4
33.1
F
(X)
60.2
46.0
42.0
87.5
70.1
69.6
76.0
47.4
64.0
50.6
75.4
65.1
65.9
0.0
34.9
81.3
35.0
0.0
49.5
7.3
63.9
52.8
67.7
66.9
ND
(X)
3.7
T9.4
0.0
0.0
0.3
0.0
0.5
0.0
4.1
11.0
0.0
0.0
0.0
0.0
0.0
0.0
12.8
0.0
18.9
0.0
2.5
4.6
2.9
0.0
Nuifeer
of SIUs
54
5
37
12
95
33
38
24
79
23
31
25
42
12
14
16
SO
7
26
17
320
80
146
94
SIUS
T
(X)
36.1
34.6
58.0
12.5
29.6
30.4
23.5
52.6
31.9
38.4
24.6
34.9
34.1
100.0
65.1
18.8
52.1
100.0
31.6
92.7
33.6
42.6
29.4
33.1
NOW
•CATEGORICAL
SIUS
f
(X)
60.2
46.0
42.0
87.5
70.1
69.6
76.0
47.4
64.0
50.6
75.4
65.1
65.9
0.0
34.9
81.3
35.0
0.0
49.5
7.3
63.9
52.8
67.7
66.9
ND
(X)
3.7
19.4
0.0
0.0
0.3
0.0
0.5
0.0
4.1
11.0
0.0
0.0
0.0
0.0
0.0
0.0
12.8
0.0
18.9
0.0
2.5
4.6
2.9
0.0
Nunber
of SIUs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
T
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
F
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
ND
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
NO
T - TRUE STATEMENT
F « FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE
INFORAT ION
G-21
-------
B.3. THE POTW IS NOT IMPLEMENTING ALL FEDERAL/LOCAL REPORTING REQUIREMENTS
REGION
N. EAST
MID EAST.
SOUTH
MID-WEST
WEST
OVERALL
CATEGORICAL
ALL SlUs
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuifeer '.
Of POTWS
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
• 25
12
Nutber
of SIUs
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
78.9
71.2
80. 5
84.7
51.8
72.2
32.1
75.7
46.7
48.6
38.3
57.1
45.5
66.7
17.1
46.1
75.8
42.2
80.9
88.2
56.4
63.7
46.7
65.3
F
(X)
13.8
23.0
15.8
0.0
48.2
27.8
67.9
24.3
53.3
51.4
61.7
42.9
53.4
33.3
72.7
53.9
22.6
48.2
19.1
11.8
42.3
34.7
52.5
32.8
ND
(X)
7.3
5. 8
3.7
15.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
0.0
10.1
0.0
1.6
9.6
0.0
0.0
1.3
1.5
0.7
1.9
Nifffcer
of SIUs
58
8
37
13
99
33
42
24
83
23
31
29
43
12
15
16
50
7
26
17
333
83
151
99
NON- CATEGORICAL
SIUS
T
(X)
97.1
100.0
96.5
95.1
47.3
68.1
30.3
81.9
47.4
49.3
49.6
41.0
55.0
66.7
19.7
56.3
68.8
0.0
73.5
96.8
57.1
65.5
45.5
69.3
F
(X)
1.3
0.0
3.5
0.0
52.7
31.9
69.7
18.1
52.6
50.7
50.4
59.0
44.0
33.3
67.2
43.8
31.2
100.0
26.5
3.2
42.5
34.5
54.2
29.9
ND
(X)
1.7
0.0
0.0
4.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
0.0
13.1
0.0
0.0
0.0
0.0
0.0
0.4
0.0
0.3
0.8
Number
of SIUs
57
9
39
9
93
30 .
42
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
SIUS
T
(X)
58.0
38.5
67.9
61.0
56.9
76.2
35.0
71.8
46.1
48.0
26.9
72.7
29.0
66.7
14.8
28.6
81.5
63.6
87.5
80.2
55.7
62.0
48.3
60.9
F
(X)
28.1
49.2
25.5
0.0
43.1
23.8
65.0
28.2
53.9
52.0
73.1
27.3
69.9
33.3
77.8
71.4
'15.6
21.8
12.5
' 19.8
42.0
34.9
50.5
36.0
ND
(X)
13.8
12.3
6.6
39.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
7.4
0.0
2.9
U.5
0.0
0.0
2.3
3.1
1.3
3.1
T * TRUE STATEMENT
F - FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFOSAT ION
G-22
-------
6.3. THE POTU IS NOT IMPLEMENTING ALL FEDERAL/LOCAL REPORTING REQUIREMENTS
i> PERIODIC REPORTS (FOR REASONS OTHER THAN TIMELINESS)
POTU
REGION SIZE
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
. SMALL
' MEDIUM
LARGE
CATEGORICAL
ALL S1US
Niflfeer
Of POTUS
12
4
6
2
20
8
8
t>
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Number
of SIUs
101
12
75
U
163
54
75
34
145
39
56
50
66
15
21
30
112
18
SB
36
587
138
285
164
T
(X)
43.3
17.4
39.3
76.0
26.5
25.2
20.8
41.7
8.9
0.0
5.5
27.6
10.3
33.3
13.2
6.6
5.0
0.0
7.7
0.0
20.6
16.0
18.4
28.0
F
(X)
54.7
74.6
60.7
24.0
73.5
74.8
79.2
58.3
91.1
100.0
94.5
72.4
89.3
66.7
82.2
93.4
93.4
90.4
92.3
100.0
78.9
82.2
81.5
72.0
NO
XX)
2.0
8.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
4.7
0.0
1.6
9.6
0.0
0.0
0.5
1.7
0.1
0.0
Number
of SIUs
56
8
37
11
91
30
40
21
80
21
31
28
42
12
14
16
50
7
26
17
319
78
148
93
SIUS
T
(X)
62.8
23.2
64.1
97.4
23.4
22.8
18.2
46.8
3.9
0.0
5.3
6.8
10.3
33.3
7.0
6.3
6.4
0.0
9.4
0.0
22.2
17.7
19.8
29.9
F
(X)
34.0
66.0
35.9
2.6
76.6
77.2
81.8
53.2
96.1
100.0
94.7
93.2
89.7
66.7
93.0
93.8
93.6
100.0
90.6
100.0
77.4
80.5
80.2
70.1
ND
(X)
3.2
10.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4
1.8
0.0
0.0
Umber
of SIUs
45
4
38
3
72
24
35
13
65
18
25
22
24
3
7
14
62
11
32
19
268
60
137
71
NON-CATEGORICAL
SIUS
T
(X)
13.5
0.0
19.2
0.0
31.5
27.7
29.0
38.1
13.4
0.0
5.8
47.3
10.4
33.3
20.5
7.1
3.9
0.0
6.2
0.0
18.5
14.2
16.1
25.7
F
(X)
86.5
100.0
80.8
100.0
68.5
72.3
71.0
61.9
86.6
100.0
94.2
52.7
88.5
66.7
69.2
92.9
93.2
85.5
93 .B
100.0
80.9
84.2
83.6
74.3
HO
(X)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
10.3
0.0
2:9
14.5
0.0
0.0
0.6
1.6
0.3
0.0
T = TRUE STATEMENT
F « FALSE STATEMENT
ND • ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-23
-------
8.3. THE POTU IS HOT IMPLEMENTING ALL FEDERAL/LOCAL REPORTING REQUIREMENTS
ii) 24 HOUR NONCOMPL1ANCE NOTIFICATION
REGION
N. EAST
MID EAST
SOUTH
MID. WEST
WEST
OVERALL
CATEGORICAL
ALL S1US
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuttoer
Of POTUS
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Number
of SIUs
99
13
64
22
132
47
58
27
US
41
54
SO
32
9
8
15
111
17
58
36
519
127
242
150
T
(X)
67.5
70.1
59.8
76.2
38.9
45.1
8.4
96.4
40.2
35.5
32.5
59.4
81.0
100.0
11.5
82.5
22.3
15.2
27.4
10.3
44.2
45.3
24.3
74.9
F
(X)
20.5
22.4
33.6
0.0
61.1
54.9
91.6
3.6
59.8
64.5
67.5
40.6
16.1
0.0
37.2
17.5
76.1
74.7
72.6
89.7
53.6
52.9
74.3
21.3
NO
(X)
12.0
7.5
6.6
23.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.8
0.0
51.3
0.0
1.6
10.1
0.0
0.0
-2-2
1.8
1.4
3.8
Nuitoer
of SIUs
55
8
34
13
75
26
32
17
82
23
31
28
22
7
5
10
49
6
26
17
283
70
128
85
NON-CATEGORICAL
SIUS
T
(X>
70.0
67.6
59.4
82.9
28.7
43.7
6.2
91.6
36.9
30.5
39.0
42.9
88.5
100.0
20.0
90.0
22.1
0.0
27.7
14.7
41.8
45.7
21.1
75.1
F
(X)
24.1
32.4
40.6
0.0
71.3
56.3
93.8
8.4
63.1
69.5
61.0
57.1
9.8
0.0
40.0
10.0
77.9
100.0
72.3
85.3
57.1
54.3
78.5
21.5
NO
(X)
5.9
0.0
0.0
17.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.7
0.0
40.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
0.4
3.4
Nuifeer
of SIUs
44
5
30
9
57
21
26
10
63
18
23
22
10
2
3
5
62
11
32
19
236
57
114
65
SIUS
T
(X)
63.6
75.8
60.1
61.0
55.4
46.5
15.8
100.0
43.4
39.8
24.8
75.0
59.3
100.0
0.0
60.0
22.5
21.8
27.1
6.2
47.5
44.9
29.6
74.7
F
(X)
14.8
0.0
26.6
0.0
44.6
53.5
84.2
0.0
56.6
60.2
75.2
25.0
34.6
0.0
33.3
40.0
74.6
63.6
72.9
93.8
48.8
51.3
67.2
21.0
NO
(X)
21.6
24.2
13.3
39.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
P.I
0.0
66.7
0.0
2.9
14.5
0.0
0.0
3.7
3.8
3.3
4.3
T * TRUE STATEMENT
t • FALSE STATEMENT
NO « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-24
-------
8.3. THE POTW IS NOT IMPLEMENTING ALL FEDERAL/LOCAL REPORTING REQUIREMENTS
iii) 30 OAT RESAMPLING REPORT
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Number
of POTUs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
Of SIUS
96
12
62
22
124
43
54
27
144
39
55
50
31
9
7
15
107
17
57
33
502
120
235
147
T
(X)
74.9
91.9
64.1
76.2
54.1
65.8
27.6
96.4
45.0
44.7
36.4
59.4
82.9
100.0
40.2
82.5
76.1
44.3
77.9
100.0
60.4
62.5
45.0
83.1
F
(X)
14.2
8.1
27.9
0.0
45.9
34.2
72.4
3.6
55.0
55.3
63.6
40.6
15.0
0.0
16.5
17.5
22.3
45.6
22.1
0.0
37.6
36.7
53.5
13.0
ND
(X)
10.9
0.0
8.0
23.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.1
0.0
43.3
0.0
1.7
10.1
0.0
0.0
2.0
0.9
1.5
3.9
Nunber
Of SIUS
54
8
33
13
70
24
29
17
81
22
31
28
22
7
5
10
47
6
25
16
274
67
123
84
NON-CATEGORICAL
SIUS
T
(X)
78.6
89.2
65.5
82.9
40.0
62.9
17.5
91.6
44.1
38.4
49.6
42.9
90.2
100.0
60.0
90.0
65.7
0.0
66.6
100.0
54.6
60.6
36.1
81.9
T
(X)
14.6
10.8
32.3
0.0
60.0
37.1
82.5
8.4
55.9
61.6
50.4
57.1
8.1
0.0
0.0
10.0
34.3
100.0
33.4
0.0
44.2
39.4
63.3
14.6
ND
(X)
6.7
0.0
2.3
17.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.7
0.0
40.0
0.0
0.0
0.0
0.0
0.0
1.2
0.0
0.6
3.4
Nimber
Of SIUS
42
4
29
9
54
19
25
10
63
17
24
22
9
2
2
5
60
11
32
17
228
53
112
63
SIUS
T
(X)
68.6
100.0
62.7
61.0
78.2
69.2
62.8
100.0
45.9
50.0
22.5
75.0
61.2
100.0
0.0
60.0
84.3
63.6
87.5
100.0
68.5
64.6
59.7
84.7
F
(X)
13.4
0.0
23.4
0.0
21.8
30.8
37.2
0.0
54.1
50.0
77.5
25.0
35.7
0.0
50.0
40.0
12.7
21.8
12.5
0.0
28.5
33.5
37.4
10.8
HO
(X)
18.0
0.0
13.9
39.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.2
0.0
50.0
0.0
3:0
14.5
0.0
0.0
3.0
1.»
2.9
4.4
T * TRUE STATEMENT
F * FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-25
-------
B.3. THE POTU IS NOT IMPLEMENTING ALL FEDERAL/LOCAL REPORTING REQUIREMENTS
iv) OTHER RESPONSES
REGION
N. EAST
MID EAST.
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nurtoer .
of POTWs
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
• 25
12
Nuifeer
of SIUs
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
3.3
10.3
0.6
0.0
0.3
1.2
0.0
0.0
3.5
2.9
5.4
1.4
6.2
0.0
0.0
7.9
0.6
0.0
0.0
3.5
2.0
2.9
0.9
3.0
F
(X)
96.7
89.7
99.4
100.0
99.7
98.8
100.0
100.0
96.S
97.1
94.6
98.6
93.4
100.0
96.1
92.1
99.4
100.0
100.0
96.5
97.9
97.1
99.0
97.0
NO
(X)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
3.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
Nuifcer
of SIUs
SB
8
37
13
99
33
42
24
83
23
31
29
43
12
15
16
50
7
26
17
333
83
151
99
NON-CATEGORICAL
SIUs
T
(X)
3.7
10.8
1.4
0.0
0.6
2.5
0.0
0.0
7.2
6.3
10.5
2.9
9.7
0.0
0.0
12.5
1.4
0.0
0.0
7.3
3.4
4.4
1.6
5.8
F
(X)
96.3
89.2
98.6
100.0
99.4
97.5
100.0
100.0
92.8
93.7
89.5
97.1
90.3
100.0
100.0
87.5
98.6
100.0
100.0
92.7
96.6
95.6
98.4
94.2
NO
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nuitoer
of SIUs
57
9
39
9
93
30
42
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
SIUs
T
(X)
2.8
9.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
"0.0
0.0
0.4
1.3
0.0
0.0
F
(X)
97.2
90.4
100.0
100.0
100.0
100.0
100.0
100.0
loo.b
100.0
100.0
100.0
98.9
100.0
92.6
100.0
100.0
100.0
100.0
100.0
99.5
98.7
99.8
100.0
ND
(X)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
7.i
0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.2
0.0
T • TRUE STATEMENT
F * FALSE STATEMENT
ND > ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-26
-------
B.4. THE POTU IS NOT IMPLEMENTING ALL FEDERAL/LOCAL SELF-MONITORING REQUIREMENTS
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL S1US
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE '
SMALL
MEDIUM
LARGE
Nirfeer
Of POTUS
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Number
of SIUs
102
12
75
15
144
56
62
26
143
38
54
51
63
14
19
30
106
16
55
35
558
136
265
157
T
(X)
60.1
83.9
66.6
25.7
72.8
88.5
49,5
93.3
31.4
16.6
39.6
40.0
93.2
100.0
17.1
100.0
61.3
78.7
63.6
38.3
64.0
69.2
52.5
74.6
F
(X)
37.0
8.1
31.5
74.3
27.2
11.5
50.5
6.7
53.2
71.5
51.1
30.0
0.7
0.0
8.1
0.0
36.2
5.3
36.4
61.7
31.3
25.5
43.4
20.4
NO
(X)
2.9
8.1
1.9
0.0
0.0
0.0
0.0
0.0
15.4
11.9
9.3
30.0
6.2
0.0
74.8
0.0
2.6
16.0
0.0
0.0
4.7
5.2
4.1
4.9
Nunber
of SIUs
53
8
37
8
74
28
31
15
80
21
31
28
39
12
11
16
47
6
25
16
293
75
135
83
NON-CATEGORICAL
SIUS
T
(X)
60.1
78.4
74.7
23.9
63.9
88.3
43.2
92.9
31.5
15.2
50.4
21.0
95.7
100.0
26.7
100.0
72.4
83.3
72.7
64.9
63.6
71.0
53.3
72.1
F
(X)
36.6
10.8
25.3
76.1
36.1
11.7
56.8
7.1
54.3
74.0
49.6
36.1
1.0
0.0
17.8
0.0
25.7
0.0
27.3
35.1
32.6
23.9
45.5
21.4
ND
(X)
3.3
10.8
0.0
0.0
0.0
0.0
0.0
0.0
14.2
10.7
0.0
43.0
3.2
0.0
55.5
0.0
1.9
16.7
0.0
0.0
3.8
5.1
1.2
6.5
Nutfeer
of SIUs
49
4
38
7
70
28
31
11
63
17
23
23
24
2
8
14
59
10
30
19
265
61
130
74
SIUs
T
(X)
60.2
100.0
60.1
29.9
83.4
88.8
64.2
93.5
31.3
17.7
27.6
57.5
88.5
100.0
9.1
100.0
52.2
76.5
55.2
15.6
64.5
67.4
51.5
77.3
F
(X)
37.5
0.0
36.4
70.1
16.6
11.2
35.8
6.5
52.1
69.5
52.7
24.4
0.0
0.0
0.0
0.0
' 44.7
7.8
44.8
84.4
29.8
27.3
40.5
19.4
NO
(X)
2.3
0.0
3.S
0.0
0.0
0.0
0.0
0.0
16.6
12.8
19.7
18.1
11.5
0.0
90.9
0.0
3.1
15.7
0.0
0.0
5.7
5.4
8.1
3.2
T « TRUE STATEMENT
F • FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-27
-------
8.4. THE POTW IS NOT IMPLEMENTING ALL FEDERAL/LOCAL SELF-NON I TOR INC REQUIREMENTS
i) SAMPLING FREQUENCY
REGION
N. EAST
MID EAST
SOUTH
MID
WEST
OVERALL
CATEGORICAL
ALL SIUs
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Wi/noer
of POTWs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25.
12
Njjtfcer
of SIUs
110
17
74
19
189
62
82
45
151
41
58
52
70
15
25
30
112
18
58
36
632
153
297
182
T
(X)
12.9
0.0
15.5
23.9
7.6
11.5
6.3
5.1
7.9
0.0
0.0
32.3
4.9
6.7
10.1
4.0
16.1
14.5
20.1
3.1
9.0
6.8
9.1
11.0
F
74.8
65.5
84.5
68.9
70.0
79.7
64.4
69.2
86.4
92.0
95.1
63.9
86.1
86.7
10.1
96.0
74.2
51.8
74.5
93.4
76.2
79.0
72.6
78.8
NO
(X)
1.7
5.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.7
0.0
6.8
0.0
2.4
14.5
0.0
0.0
0.6
1.9
0.2
0.0
P
(X)
10.5
28.8
0.0
7.2
22.3
8.8
29.2
25.7
5.8
8.0
4.9
3.8
8.3
6.7
72.9
0.0
7.3
19.3
5.4
3.5
14.2
12.3
18.1
10.2
Nunber
of SIUs
57
8
37
12
97
33
40
24
83
23
31
29
43
12
15
16
50
7
26
17
330
83
149
98
T
(X)
12.7
0.0
14.9
21.5
3.9
7.7
1.3
4.8
2.1
0.0
0.0
8.7
7.1
8.3
13.1
6.3
22.3
28.6
25.7
6.5
7.3
5.7
7.2
8.7
NON-CATEGORICAL
SIUs
F
(X)
80.8
89.2
85.1
66.5
82.3
79.8
93.0
55.5
92.3
87.5
100.0
86.7
87.2
91.7
13.1
93.8
68.9
28.6
71.4
86.2
83.2
81.6
87.3
78.9
NO
(X)
3.2
10.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
0.0
6.1
0.0
1.8
14.3
0.0
0.0
0.7
2.4
0.2
0.0
P
(X)
3.3
0.0
0.0
10.0
13.8
12.5
5.7
39.7
5.6
12.5
0.0
4.6
5.2
0.0
67.7
0.0
7.0
28.6
3.0
7.3
8.8
10.2
5.3
12.4
Nuw>er
of SIUs
53
9
37
7
92
29
42
21
68
18
27
23
27
3
10
14
62
11
32
19
302
70
148
84
T
(X)
13.2
0.0
15.9
29.9
11.2
.15.3
12.0
5.4
13.3
0.0
0.0
55.0
1.1
0.0
7.4
0.0
11.1
7.3
15.3
0.0
10.9
7.9
11.1
13.5
SIUS
F
(X)
67.8
38.5
84.1
70.1
58.3
79.
32.
77.
80.
95.
90.2
41.9
84.2
66.7
7.4
100.0
78.5
63.6
77.3
100.0
68.9
76.4
57.8
78.7
NO
(X)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
7.4
0.0
2.9
14.5
0.0
0.0
0.5
0.0
P
(X)
19.1
61.5
0.0
0.0
30.5
5.1
55.5
16.8
6.0
4.1
9.8
3.0
13.6
33.3
77.8
0.0
7.6
14.5
7.4
0.0
19.7
14.3
30.9-
7.7
T « TRUE STATEMENT
F * FALSE STATEMENT
NO • ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFOBAT ION
G-28
-------
B.4. THE POTU IS NOT IMPLEMENTING ALL FEDERAL/LOCAL SELF-MONITORING REQUIREMENTS
ii) REQUIRED PARAMETERS
POTW Number
REGION SIZE of POTWS
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
.SMALL
.MEDIUM
LARGE
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
CATEGORICAL
ALL SIUS
Nunber
if SIUS
111
17
75
19
189
62
82
45
151
41
58
52
70
15
25
30
112
18
58
36
633
153
298
182
T
(X)
14.9
5.8
29.5
0.0
14.8
13.4
9.7
27.3
12.3
6.6
5.3
32.1
53.2
73.3
13.3
55.4
29.3
37.3
30.7
17.2
20.8
15.4
15.7
33.3
F
(X)
69.8
59.7
70.5
80.8
62.9
77.8
61.0
47.0
81.9
85.4
89.8
64.1
38.2
20.0
10.1
44.6
60.9
28.9
64.0
79.3
64.1
70.5
66.2
55.1
ND
cx>
4.7
5.8
0.0
12.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
3.9
0.0
2.4
14.5
0.0
0.0
1.0
1.9
0.1
1.4
P
(X)
10.5
28.8
0.0
7.2
22.3
8.8
29.2
25.7
5.8
8.0
4.9
3.8
8.3
6.7
72.7
0.0
7.3
19.3
5.4
3.5
14.1
12.3
18.0
10.2
Nunfeer
of SIUS
57
8
37
12
97
33
40
24
83
23
31
29
43
12
15
16
50
7
26
17
330
83
149
98
T
(X)
20.2
10.8
46.1
0.0
16.0
19.0
7.5
35.5
11.1
7.0
10.5
17.8
81.7
83.3
19.7
87.5
40.2
42.9
41.0
35.8
28.4
21.4
18.8
47.6
NON-CATEGORICAL
SIUS
F
(X)
71.6
78.4
53.9
85.0
70.2
68.5
86.9
24.7
83.3
80.4
89.5
77.6
13.2
16.7
13.1
12.5
50.9
14.3
56.0
56.9
62.0
66.0
75.9
39.2
NO
(X)
4.9
10.8
0.0
5.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.8
14.3
0.0
0.0
0.9
2.4
0.0
0.8
P
(X)
3.3
0.0
0.0
10.0
13.8
12.5
5.7
39.7
5.6
12.5
0.0
4.6
5.2
0.0
67.2
0.0
7.0
28.6
3.0
7.3
8.8
10.2
5.3
12.4
Number
Of SIUS
54
9
38
7
92
29
42
21
68
18
27
23
27
3
10
14
62
11
32
19
303
70
149
84
T
(X)
8.7
0.0
16.2
0.0
13.6
7.7
12.3
22.2
13.4
6.1
0.0
45.9
3.2
33.3
7.4
0.0
20.5
34.5
21.6
0.0
12.9
9.3
12.5
17.1
SIUs
F
(X)
67.8
38.5
83.8
70.1
55.9
87.2
32.2
61.1
80.6
89.8
90.2
51.1
82.0
33.3
7.4
100.0
69.1
36.4
71.0.
100.0
66.3
75.0
56.5
73.0
NO
(X)
4.6
0.0
0.0
29.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
7.4
0.0
2.9
14.5
0.0
0.0
1.1
1.4
0.2
2.1
P
(X)
18.8
61 .5
0.0
0.0
30.5
5.1
55.5
16.8
6.0
4.1
9.8
3.0
13.6
33.3
77.8
0.0
7-*
14.5
7.4
0.0
19.7
14.3
30.7
7.7
T i TRUE STATEMENT
F « FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-29
-------
B.4. THE POTW IS NOT IMPLEMENTING ALL FEDERAL/LOCAL SELF-MONITORING REQUIREMENTS
Hi) SAMPLE TTPE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SlUt
POTW
SIZE
SHALL
NED I UN
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
1 AO^C
LAKUC
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Ninber
Of POTUS
12
4
6
2
20
8
8
4
14
6
5
3
6
2
3
8
3
3
2
60
23
25
12
NuiDer
of SIUS
109
17
73
19
189
62
82
45
151
41
58
52
70
15
25
Tn
30
112
18
58
36
631
153
296
182
T
(X)
31.8
59.7
30.8
0.0
36.1
51.2
29.2
30.9
13.5
7.9
6.4
33.4
81.8
26.7
6.3
32.7
51.8
31.2
20.4
36.6
40.4
25.3
49.4
F
(X)
52.8
5.8
69.2
80.8
42.5
41.3
41.6
46.2
68.6
82.0
79.8
30.6
8.4
66.7
6.3
59.2
24.1
63.4
76.1
46.5
46.2
54.7
35.0
NO
(X)
4.8
5.8
0.0
12.0
0.0
0.0
0.0
0.0
12.1
2.2
8.8
32.3
1.5
0.0
14.5
2.4
14.5
0.0
0.0
3.4
2.4
1.9
6.4
P
(X)
10.6
28.8
0.0
7.2
21.4
7.6
29.2
22.9
5.8
8.0
4.9
3.8
8.3
6.7
72.9
5.7
9.6
5.4
3.5
13.5
11.0
18.1
9.3
Nuifeer
of SlUs
56
8
36
12
97
33
40
24
83
23
31
29
43
12
15
1 A
ID
SO
7
26
17
329
83
148
98
T
(X)
36.9
78.4
36.8
0.0
40.5
54.8
37.0
25.8
6.5
6.3
4.0
10.9
82.3
25.0
13.1
i f\n n
lUw.U
36.2
42.9
35.1
35,8
39.9
44.3
30.4
49.2
SIUS
f
(X)
54.8
10.8
63.2
85.0
47.0
32.8
57.4
41.6
73.9
76.5
96.0
34.4
12.0
75.0
13.1
On
.U
56.7
28.6
61.9
56.9
48.5
42.7
64.1
32.3
NON-CATEGORICAL
SIUS
NO
(X)
4.9
10.8
0.0
5.0
0.0
0.0
0.0
0.0
14.0
4.7
0.0
50.1
0.5
0.0
6.1
Of\
. W
1.8
U.3
0.0
0.0
3.5
3.5
0.2
7.9
P
(X)
3.4
0.0
0.0
10.0
12.5
12.5
5.7
32.6
5.6
12.5
0.0
4.6
5.2
0.0
67.7
Oft
• U
5.3
14.3
3.0
7.3
8.1
9.5
5.3
10.6
Number
Of SIUS
53
9
37
7
92
29
42
21
68
18
27
23
27
3
10
62
11
32
19
302
70
148
84
T
(X)
25.9
38.5
26.2
0.0
31.9
47.4
20.5
34.1
20.1
9.2
8.9
55.0
80.9
33.3
0.0
inn n
luU.U
29.8
56.4
27.8
6.2
33.0
36.4
20.2
49.6
f
(X)
50.4
0.0
73.8
70.1
38.3
50.0
24.0
49.1
63.6
86.7
63.5
26.9
2.1
33.3
0.0
Of\
• w
61.1
21.8
64.7
93.8
44.5
49.8
45.3
38.0
NO
(X)
4.6
0.0
0.0
29.9
0.0
0.0
0.0
0.0
10.3
0.0
17.8
15.1
3.3
0.0
22.2
OA
.0
2.9
14.5
0.0
0.0
3.3
1.4
3.6
4.6
P
(X)
19.1
61.5
0.0
0.0
29.8
2.6
55.5
16.8
6.0
4.1
9.8
3.0
13.6
33.3
77.8
Of*
.0
6.1
7.3
7.4
0.0
19.2
12.4
30.9
7.7
NO
T = TRUE STATEMENT
F « FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
G-30
-------
B.4. THE POTU IS NOT IMPLEMENTING ALL FEDERAL/LOCAL SELF-MONITORING REQUIREMENTS
iv) ANALYTICAL PROCEDURES
CATEGORICAL
ALL SIUS
REGION
N. EAST
MID EAST
SOUTH
MID VEST
WEST
OVERALL
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuntoer
of POTUs
12
I
6
2
20
B
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nuttier
of SIUS
109
17
73
19
189
62
82
45
151
41
58
52
70
15
25
30
112
IB
58
36
631
153
296
182
T
(X)
19.1
9.0
37.1
0.0
42.8
68.3
14.1
70.1
23.5
8.7
31.3
33.6
12.8
86.7
6.3
2.6
33.0
37.3
36.3
17.0
31.1
43.2
23.9
30.5
F
(X)
49.1
11.5
56.8
80.8
35.8
24.1
56.6
7.0
S8.6
69.1
63.8
34.2
76.7
0.0
6.3
97.4
57.3
28.9
58.3
79.4
49.4
32.6
56.7
54.5
NO
11.4
8.5
24.6
0.0
32.1
58.0
7.6
57.9
22.9
6.3
46.4
8.7
15.7
100.0
13.1
0.0
30.3
28.6
33.0
22.0
24.7
40.2
20.6
16.7
SIUS
F
CX)
60.6
21.6
70.3
85.0
55.4
29.5
86.7
9.5
57.0
71.8
53.6
41.2
78.6
0.0
13.1
100.0
60.9
28.6
64.0
70.7
60.6
35.6
73.3
65.3
NO
(X)
24.6
70.0
5.1
5.0
0.0
0.0
0.0
0.0
14.5
9.4
0.0
45.6
2.2
0.0
28.8
0.0
1.8
14.3
0.0
0.0
6.7
14.0
1.4
7.3
P
(X)
3.4
0.0
0.0
10.0
12.5
12.5
5.7
32.6
5.6
12.5
0.0
4.6
3.5
0.0
44.9
0.0
7.0
28.6
3.0
7.3
8.0
10.2
4.7
10.6
Number
Of SIUS
53
9
37
7
92
29
42
21
68
18
27
23
27
3
10
14
62
11
32
19
302
70
148
84
NON-CATEGORICAL
T
(X)
28.1
9.6
47.1
0.0
53.2
78.9
21.4
77.8
24.0
10.9
16.0
57.5
7.8
33.3
0.0
7.1
35.1
41.8
39.2
12.5
37.8
46.2
27.2
45.9
SIUS
F
(X)
35.6
0.0
46.1
70.1
17.0
18.6
23.1
S.4
60.0
66.7
74.2
27.4
73.2
0.0
0.0
92.9
54.4
29.1
53.4
87.5
37.8
29.6
40.2
42.3
NO
(X)
17.2
28.9
6.8
29.9
0.0
0.0
0.0
0.0
10.7
18.4
0.0
15.1
12.0
0.0
81.5
0.0
2.9
14.5
0.0
0.0
5.8
10.4
3.5
4.6
P
(X)
19.1
61.5
0.0
0.0
29. e
2.6
ss.s
16.8
5.2
4.1
9.8
0.0
7.0
66.7
18.5
0.0
7:6
14.5
7.4
0.0
18.6
13.8
29.0
7.2
T * TRUE STATEMENT
F > FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
G-31
-------
OVERALL NON-IMPLEMENTATION Of PRETREATMENT REQUIREMENTS
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Mutter
Of POTWS
12
4
6
2
20
6
6
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
• Member
of SIUS
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
94.8
100.0
92.7
92.6
74.8
96.8
59.7
84.8
57.2
57.4
47.7
71.8
94.2
100.0
43.2
100.0
93.3
85.5
93.3
100.0
78.7
86.8
67.1
89.8
f
(X)
0.8
0.0
1.7
0.0
25.2
3.2
40.3
15.2
31.8
38.3
43.5
3.3
1.3
0.0
12.6
0.0
5.1
4.8
6.7
0.0
18.1
11.4
29.7
5.5
NO
(X)
4.4
0.0
5.6
7.4
0.0
0.0
0.0
0.0
11.1
4.4
8.8
24.9
4.5
0.0
44.2
0.0
1.6
9.6
0.0
0.0
3.3
1.8
3.2
4.7
Ninber
of SIUS
SB
8
37
13
99
33
42
24
83
23
31
29
43
12
15
16
50
7
26
17
333
83
151
99
NON-CATEGORICAL
SIUs
T
(X)
98.3
100.0
100.0
95.1
77.7
96.1
67.7
87.3
58.6
55.6
59.5
61.4
98.0
100.0
74.2
100.0
97.4
100.0
96.2
100.0
82.1
87.9
74.0
90.7
F
(X)
0.0
0.0
0.0
0.0
22.3
3.9
32.3
12.7
30.2
35.0
40.5
6.7
0.5
0.0
6.1
0.0
2.6
0.0
3.8
0.0
15.6
10.0
25.6
4.0
ND
(X)
1.7
0.0
0.0
4.9
0.0
0.0
0.0
0.0
11.2
9.4
0.0
31.9
1.5
0.0
19.7
0.0
0.0
0.0
0.0
0.0
2.2
2.2
0.5
5.3
Nunber
Of SIUS
57
9
39
9
93
30
42
21
68
18
27
23
27
3
10
U
62
11
32
19
307
71
150
86
SIUs
T
(X)
90.8
100.0
86.9
87.0
71.4
97.5
46.8
83.2
55.8
56.9
35.8
81.9
87.4
100.0
14.8
100.0
89.9
78.2
: 90.9
100.0
74.8
85.8
58.8
88.8
F
(X)
1.7
0.0
3.1
0.0
28.6
2.5
53.2
16.8
33.2
41.1
46.4
0.0
2.7
0.0
18.5
0.0
7.2
7.3
9.1
0.0
20.8
12.9
34.7
7.2
NO
(X)
7.5
0.0
10.0
13.0
0.0
0.0
0.0
0.0
11.0
0.0
17.8
18.1
9.9
0.0
66:7
0.0
2.9
14.5
0.0
0.0
4.4
1.4
6.6
4.0
ND
T * TRUE STATEMENT
F • FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT10N
G-32
-------
APPENDIX H
COMBINED CHECKLIST QUESTION RESPONSES
-------
NON-TTO COMPLIANCE RATES
OVERALL NC RATE (LATE REPORTS EXCLUDED)
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nirtser
of POTUs
12
4
6
2
20
8
6
4
U
6
5
3
6
2
3
1
B
3
3
2
60
23
25
12
Nirfeer
of SIUs
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
78.2
89.7
69.3
80.2
65.1
76.9
56.4
72.1
74.8
75.6
72.8
76.6
50.7
60.0
85.5
44.8
78.5
50.0
86.5
76.0
68.4
75.7
66.1
65.2
F
(X)
18.2
10.3
28.3
9.9
28.6
15.7
35.5
27.9
20.5
21.1
24.6
13.0
48.5
40.0
6.8
55.2
16.9
35.5
11.1
20.8
26.8
18.9
28.3
31.7
ND
(X)
3.7
0.0
2.5
9.9
6.3
7.5
8.0
0.0
4.8
3.3
2.6
10.4
0.8
0.0
7.7
0.0
4.6
14.5
2.4
3.2
4.8
5.4
5.6
3.0
ttuifcer
of SIUs
58
8
37
13
99
33
42
24
83
23
31
29
43
12
15
16
50
7
26
17
333
83
151
99
NON-CATEGORICAL
SIUS
T
(X)
88.0
80.8
84.9
97.6
57.6
77.7
43.9
79.9
74.7
81.2
61.7
86.5
54.0
58.3
85.9
50.0
71.9
28.6
83.4
60.1
65.3
75.1
56.9
70.8
F
(X)
12.0
19.2
15.1
2.4
37.7
12.5
52.5
20.1
20.1
11.7
33.1
11.3
46.0
41.7
14.1
50.0
25.6
57.1
16.6
36.6
31.4
18.0
40.1
28.7
ND
(X)
0.0
0.0
0.0
0.0
4.7
9.8
3.7
0.0
5.1
7.0
5.3
2.2
0.0
0.0
0.0
0.0
2.4
14.3
0.0
3.2
3.3
7.0
2.9
0.5
Nuifcer
Of SIUS
57
9
39
9
93
30
42
21
68
.18
27
23
27
3
10
14
62
11
32
19
307
'71
150
86
SIUs
T
(X)
67.0
100.0
57.0
40.7
73.9
76.0
76.5
67.2
74.8
70.8
84.0
67.0
45.0
66.7
85.2
35.7
83.8
60.9
89.2
90.6
71.8
76.4
77.3
59.0
F
(X)
K.I
0.0
38.6
26.8
18.0
18.8
8.6
32.8
. 20.8
29.2
16.0
14.6
52.8
33.3
0.0
64.3
9.9
24.5
6.2
6.2
21.6
19.8
13.9
35. \
m
(X)
7.9
0.0
4.4
32. 5
8.1
5.2
U.9
0.0
4.4
0.0
0.0
18.3
2.2
0.0
14.8
0.0
6.3
U.5
4.5
3.1
6.6
3.9
8.8
5.8
T « TRUE STATEMENT
F > FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-l
-------
NON-TTO COMPLIANCE RATES
OVERALL NC RATE (LATE REPORTS INCLUDED)
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Ninber
of POTUS
12
4
6
2
20
B
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nuifcer
of SIUs
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
88.4
89.7
88.7
86.4
73.8
81.9
67.7
79.0
82.2
82.2
84.2
79.2
71.2
80.0
92.3
67.1
80.6
50.0
88.3
81.1
77.7
80.8
76.9
76.3
F
(X)
7.9
10.3
8.8
3.7
12.4
12.5
14.9
5.7
14.1
17.8
15.8
5.7
27.2
13.3
0.0
32.9
14.8
35.5
9.3
15.7
14.1
15.2
13.0
15.0
ND
(X)
3.7
0.0
2.5
9.9
13.8
5.7
17.3
15.3
3.7
0.0
0.0
15.1
1.6
6.7
7.7
0.0
4.6
14.5
2.4
3.2
8.2
4.1
10.2
8.8
Nutter
Of SIUS
58
8
37
13
99
33
42
24
83
23
31
29
43
12
15
16
SO
7
26
17
333
83
151
99
NON-CATEGORICAL
SIUS
T
(X)
91.3
80.8
93.9
97.6
70.6
81.4
61.0
91.8
85.5
95.3
74.9
88.7
73.3
83.3
100.0
68.8
76.0
28. 6
87.2
67.5
76.7
82.1
70.8
81.7
F
(X)
8.7
19.2
6.1
2.4
16.0
12.5
20.1
4.8
13.9
4.7
25.1
9.1
26.7
16.7
0.0
31.3
21.6
57.1
12.8
29.3
16.7
14.2
17.9
16.9
ND
(X)
0.0
0.0
0.0
0.0
13.4
6.1
18.8
3.5
0.5
0.0
0.0
2.2
0.0
0.0
0.0
0.0
2.4
14.3
0.0
3.2
6.6
3.6
11.3
1.4
NiMber
Of SIUS
57
9
39
9
93
30
42
21
68
.18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
SIUs
T
(X)
85.2
100.0
84.6
61.0
77.6
82.3
78.4
71.0
79.1
70.8
93.7
70.0
67.5
66.7
85.2
64.3
84.4
60.9
89.2
93.8
78.9
79.4
84.2
70.2
F
(X)
7.0
0.0
11.0
6.5
8.2
12.5
6.6
6.3
. 14.2
29.2
6.3
2.4
28.1
0.0
0.0
35.7
9.4
24.5
6.2
3.1
11.2
16.1
7.0
12.8
HO
(X)
7.9
0.0
4.4
32.5
14.2
5.2
14.9
22.7
6.6
0.0
0.0
27.5
4.3
33.3
14.8
0.0
6.3
14.5
4.5
3.1
10.0
4.6
8.8
17.0
T « TRUE STATEMENT
F « FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT I ON
H-2
-------
NON-TTO COMPLIANCE RATES
OVERALL SNC RATE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nurtoer
Of POT US
12
4
6
2
20
6
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nuifeer
of SI Us
115
17
76
22
192
63
84
45
U9
40
58
51
70
15
25
30
112
18
58
36
638
153
301
184
T
(X)
56.4
78.2
48.5
45.0
49.8
42.5
56.0
43.7
57.3
57.4
59.5
53.7
40.1
60.0
62.6
34.2
47.1
24.1
51.1
53.8
50.6
51.1
54.9
43.0
F
(X)
38.9
21.8
46.7
45.1
35.8
52.0
29.6
30.0
39.3
42.6
40.5
32.2
58.7
33.3
33.6
65.8
47.1
61.4
44.1
44.6
40.7
44.8
35.9
44.9
NO
(X)
4.7
0.0
4.8
9.9
14.4
5.6
14.4
26.3
3.4
0.0
0.0
14.0
1.2
6.7
3.9
0.0
5.8
14.5
4.8
1.6
8.7
4.1
9.2
12.1
Nuifeer
of SIUs
58
8
37
13
99
33
42
24
82
23
31
28
43
12
15
16
50
7
26
17
332
83
151
98
NON-CATEGORICAL
SIUs
T
(X)
58.0
70.0
58.7
46.8
50.7
38.4
53.2
61.4
51.0
53.7
44.4
57.9
41.8
58.3
53.5
37.5
42.6
14.3
47.0
45.5
49.7
47.5
51.7
48.2
F
(X)
40.2
30.0
36.4
53.2
36.7
55.4
31.7
124.7
46.8
46.3
55.6
32.8
58.2
41.7
46.5
62.5
55.6
71.4
53.0
54.5
43.6
48.9
38.7
47.2
ND
(X)
1.8
0.0
4.9
0.0
12.7
6.1
15.2
13.9
2.2
0.0
0.0
9.3
0.0
0.0
0.0
0.0
1.8
14.3
0.0
0.0
6.7
3.6
9.6
4.7
Niflfeer
of SIUs
57
9
39
9
93
30
42
21
67
17
27
23
27
3
10
14
62
11
32
19
306
70
ISO
86
SIUS
T
(X)
54.5
87.7
40.4
40.7
48.9
46.5
60.5
32.5
63.5
61.0
74.7
49.9
37.3
66.7
70.8
28.6
50.7
29.1
54.6
61.5
51.6
54.8
58.8
37.3
F
(X)
37.*
12.3
54.8
26.8
34.7
48.5
26.2
33.4
31.9
39.0
25.3
31.7
59.5
0.0
21.8
71.4
40.2
56.4
36.3
35.4
37.5
40.7
32.5
42.3
NO
(X)
8.1
0.0
4.8
32.5
16.4
5.0
13.3
34.1
4.6
0.0
0.0
18.3
3.2
33.3
7.4
0.0
9.1
14.5
9.0
3.1
10.9
4.6
8.8
20.4
ND
T • TRUE STATEMENT
F » FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-3
-------
TTO COHPLIANCE RATES
OVERALL NC RATE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nurtoer
Of POTWs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nmber
of SIUs
65
10
42
13
68
27
19
22
67
23
23
21
39
11
U
U
46
8
24
14
285
79
122
84
T
(X)
41.4
56.5
22.9
51.4
27.2
16.3
15.5
56.1
23.2
24.5
11.4
40.8
8.5
9.1
19.9
7.1
17.2
0.0
17.1
36.5
25.3
24.2
16.7
35.8
F
CX)
50.4
36.0
63.5
46.5
67.3
77.7
81.7
34.9
56.4
55.7
73.5
28.7
75.2
27.3
65.1
85.7
70.5
100.0
74.3
22.9
63.5
61.6
74.5
52.9
NO
(k)
8.2
7.5
13.6
2.2
5.6
6.0
2.8
9.0
20.4
19.8
15.1
30.5
16.4
63.6
15.1
7.1
12.3
0.0
8.6
40.6
11.2
14.1
8.8
11.3
Ninber
of SIUs
46
6
29
11
60
24
17
19
51
15
20
16
39
11
U
14
41
6
21
14
237
62
101
74
NON- CATEGORICAL
SIUs
T
U)
43.8
48.5
21.4
61.0
25.9
18.9
15.9
56.4
27.5
28.2
13.7
55.9
8.5
9.1
19.9
7.1
12.8
0.0
8.6
36.5
24.5
23.8
15.1
35.9
F
(X)
49.3
51.5
61.7
36.4
67.6
74.2
81.2
30.4
55.5
53.6
68.1
32.1
75.2
27.3
65.1
85.7
72.9
100.0
81.6
22.9
64.6
62.7
75.5
53.8
ND
(X)
6.9
0.0
17.0
2.6
6.5
6.9
2.9
13.2
16.9
18.3
18.2
12.0
16.4
63.6
15.1
7.1
14.3
0.0
9.7
40.6
10.9
13.6
9.5
10.3
natter
of SIUs
19
4
13
2
6
3
2
3
16
8
3
5
0
0
0
0
5
2
3
0
48
17
21
10
SIUs
T
(X)
35.4
75.0
25.4
0.0
35.0
0.0
0.0
55.6
14.3
19.9
0.0
11.0
0.0
0.0
0.0
0.0
43.9
0.0
81.3
0.0
28.8
25.5
26.9
35.2
F
(X)
53.1
0.0
66.6
100.0
65.0
100.0
100.0
44.4
58.2
58.4
100.0
22.0
0.0
0.0
0.0
0.0
56.1
100.0
18.7
0.0
58.4
58.6
68.6
48.7
ID
-------
TTO COMPLIANCE RATES
OVERALL SNC RATE
CATEGORICAL
ALL SIUS
POTU
REGION SIZE
N. EAST
SMALL
MEDIUM
LARGE
MID .EAST
SMALL
MEDIUM
LARGE
SOUTH
SHALL
MEDIUM
LARGE
HID WEST
J SMALL
MEDIUM
LARGE
WEST
SMALL
MEDIUM
LARGE
OVERALL '
SHALL
MEDIUM
LARGE
Nunber
of POTWs
12
4
6
2
20
8
8
4
H
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nurber
of SlUs
65
10
42
13
61
22
18
21
64
22
21
21
38
11
12
15
33
5
15
13
261
70
108
83
T
(X)
35.8
64.0
26.7
22.9
31.6
26.4
19.0
57.1
26.9
33.3
17.4
28.5
7.6
9.1
15.8
6.7
13.0
0.0
10.1
29.9
26.1
33.9
19.2
27.1
F
(X)
56.6
36.0
56.2
74.9
42.5
61.5
42.5
23.6
S3.2
51.7
66.3
35.6
76.7
27.3
66.5
86.7
66.2
100.0
76.6
14.9
55.1
51.5
55.2
57.8
ND
(X)
7.6
0.0
17.1
2.2
25.9
12.1
38.4
19.3
19.9
14.9
16.3
35.9
15.7
63.6
17.7
6.7
20.8
0.0
13.4
55.2
18.8
14.6
25.6
15.1
NtMbcr
Of SIUS
46
6
29
11
55
20
16
19
49
14
19
16
38
11
12
15
31
5
13
13
219
56
89
74
NON- CATEGORICAL
SIUS
T
(X)
33.1
48.5
27.4
27.2
27.8
28.8
18.3
45.9
32.2
44.3
19.7
37.3
7.6
9.1
15.8
6.7
12.0
0.0
7.8
29.9
24.1
32.4
T8.6
24.1
F
(X)
S8.0
51. 5
49.8
70.2
43.7
58.1
42.4
29.8
52.2
46.2
61.8
42.6
76.7
27.3
66.5
86.7
65.1
100.0
76.5
14.9
56.0
52.7
52. 5
61.8
ND
(X)
8.9
0.0
22.7
2.6
28.5
13.2
39.3
24.3
15.6
9.5
18.5
20.1
15.7
63.6
17.7
6.7
22.9
0.0
15.7
55.2
19.9
14.9
28.8
14.1
Nunber
of SlUs
19
4
13
2
6
2
2
2
15
8
2
5
0
0
0
0
2
0
2
0
42
14
19
9
SIUS
T
(X)
42.7
100.0
25.4
0.0
69.6
0.0
50.0
100.0
15.3
19.9
0.0
11.0
0.0
0.0
0.0
0.0
23.0
0.0
23.0
0.0
36.2
38.8
22.7
47.5
F
rt)
53.1
0.0
66.6
100.0
30.4
100.0
50.0
0.0
55.2
58.4
100.0
22.0
0.0
0.0
0.0
0.0
77.0
0.0
77.0
0.0
50.6
47.8
72.2
30.7
NO
(X)
4.2
0.0
8.0
0.0
0.0
0.0
0.0
0.0
29.6
21.6
0.0
67.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
13.1
13.4
5.0
21.8
ND
T « TRUE STATEMENT
F * FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SlU FILE INFORAT ION
H-5
-------
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL NC RATE FOR DISCHARGE STANDARDS
REGION
N. EAST
NID EAST
SOUTH
•
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
•
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Ninber
Of POTUs
12
4
6
2
20
6
B
4
U
6
5
3
6
2
3
1
8
3
3
2
. 60
23
25
12
Ntirtoer
Of SIUS
112
17
75
20
190
63
82
45
149
40
se
51
70
15
25
30
112
18
56
36
633
153
298
182
T '
(X)
77.5
89.7
66.9
81.5
55. 0
72.9
45.5
51.1
74.8
79.2
71.3
73.9
46.0
60.0
79.5
39.5
74.8
50.0
81.7
72.8
62.9
74.6
60.3
56.0
r
CX>
16.3
5.8
29.1
6.4
38. 5
22.8
46.3
42.9
18.4
20.8
21.4
9.8
47.1
20.0
6.5
56.5
17.5
35.5
12.1
20.5
30.4
20.5
32.5
36.4
ND
(X)
6.2
4.5
4.0
12.1
6.5
4.3
8.1
6.0
6.9
0.0
7.3
16.3
6.9
20.0
14.0
4.0
7.7
14.5
6.2
6.7
6.7
4.9
7.2
7.6
Ninber
of SIUs
57
8
37
12
97
33
40
24
82
23
31
28
43
12
15
16
SO
7
26
17
329
83
149
97
NON- CATEGORICAL
SIUs
T
85.9
80.8
79.6
97.5
42.9
75.0
17.7
59.7
75.3
87.5
60.8
81.3
53.0
58.3
73.2
50.0
72.7
28.6
83.4
64.2
59.5
75.2
45.3
65.2
F
(X)
8.9
10.8
15.5
0.0
50.7
18.9
78.8
24.9
15.5
12.5
24.6
4.6
37.5
16.7
13.6
43.8
21.4
57.1
13.6
25.2
33.3
17.7
49.0
25.6
ND
5.2
8.5
4.9
2.5
6.4
6.1
3.5
15.4
9.2
0.0
14.6
14.1
9.5
25.0
13.1
6.3
5.9
14.3
3.0
10.6
7.1
7.0
5.7
9.2
Ntwber
of Slue
55
9
38
8
93
30
42
21
67
17
27
23
27
3
10
14
62
11
32
19
304
70
149
85
SIUS
T
(X)
67.7
100.0
56.6
43.5
66.6
70.8
76.5
45.7
74.3
71.2
81.9
67.0
33.8
66.7
85.2
21.4
76.4
60.9
80.2
80.7
66.5
74.0
75.2
45.7
F
(X)
24.9
0.0
40.2
21.8
26.8
26.7
10.2
54.3
21.1
28.8
18.1
14.6
64.1
33.3
0.0
78.6
14.4
24.5
10.8
16.1
27.2
23.3
16.0
48.4
HO
(X)
7.4
0.0
3.2
34.7
6.6
2.S
13.3
0.0
4.6
0.0
0.0
18.3
2.2
0.0
14.8
0.0
9.1
14.5
9.0
3.1
6.3
2.6
8.8
5.9
NO
T • TRUE STATEMENT
F * FALSE STATEMENT
ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT ION
H-6
-------
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL NC RATE FOR REPORTING (LATE REPORTS EXCLUDED)
CATEGORICAL
ALL S1US
REGION
N. EAST
HID EAST
SOUTH
MID WEST
WEST
OVERALL
POTW
SIZE
SMALL
MEDIUM
URGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nurber
Of POTWS
12
4
6
2
20
8
a
4
u
6
5
3
6
2
3
1
e
3
3
2
60
23
25
12
Nunber
Of SIUS
115
17
76
22
191
62
84
45
151
41
58
52
70
15
25
30
112
18
58
36
639
153
301
IBS
T
46.3
57.6
37.6
48.2
36.3
32.. 0
30.4
57.6
37.9
49.6
31.2
30.8
38.5
13.3
19.1
44.8
33.1
35.5
34.3
26.9
37.8
39.5
31.8
46.0
F
(X)
42.2
36.6
41.3
50.1
46.0
42.3
50.2
39.8
53.8
44.4
64.1
51.9
53.1
53.3
67.1
51.3
48.7
54.8
46.8
49.5
48.0
43.4
51.0
47.3
'NO
(X)
11.5
5.8
21.0
1.7
17.7
25.8
19.4
2.6
8.2
6.0
4.7
17.3
8.4
33.3
13.8
4.0
18.2
9.6
18.9
23.5
14.2
17.0
17.2
6.7
Nuifcer
of SIUS
58
8
37
13
98
32
42
24
83
23
31
29
43
12
15
16
SO
7
26
17
332
82
151
99
Slut
T
(X)
59.0
74.4
45.2
60.S
47.3
45.9
40.1
79.5
43.8
46.3
35.4
54.0
42.5
8.3
31.8
50.0
26.2
14.3
29.9
21.1
45.6
45.9
38.4
57.5
F
(X)
32. 5
25.6
33.8
37.1
42.1
33.3
52.S
13.9
46.2
40.8
SS.3
39.3
45.0
SO.O
47.5
43.8
54.5
85.7
51.7
44.0
43.1
37.7
50.7
34.8
ND
(X)
8.5
0.0
21.0
2.4
10.6
20.8
7.4
6.6
10.0
13.0
9.3
6.7
12.6
41.7
20.7
6.3
19.3
0.0
18.4
34.9
11.3
16.3
10.9
7.7
Ninber
of SIUS
57
9
39
9
93
30
42
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
NON-CATEGORICAL
SIUS
T
(X)
31.8
38.5
31.7
20.3
23.6
16.4
15.0
43.7
32.4
52.4
27.0
8.5
31.4
33.3
7.4
35.7
38.7
46.4
38.1
32.3
29.1
33.2
23.8
33.2
F
(X)
S3.4
49.2
*7.2
79.7
SO. 4
51.0
46.4
S6.3
61.0
47.6
73.0
64.0
67.S
66.7
85.2
64.3
44.0
39.1
42.6
54.7
53.5
49.0
51.4
61.3
0
CX)
14.9
12.3
21.0
0.0
26.0
30.6
38.6
0.0
6.6
0.0
0.0
27.5
.1.1
0.0
7.4
0.0
17.3
14.5
19.4
13.0
17.4
17.7
24.9
S.S
T » TRUE STATEMENT
F « FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFQRATION
H-7
-------
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL NC RATE FOR REPORTING (LATE REPORTS INCLUDED)
REGION
N. EAST
MID EAST
SOUTH
HID WEST
WEST
OVERALL
CATEGORICAL
ALL SlUs
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Ntrtser
Of POTUS
12
I
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nutter
of SIUs
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
79.9
65.5
86.6
84.7
57.9
62.5
S2.3
66.5
69.4
68.3
72.9
65.5
71.5
73.3
53.1
73.7
83.4
66.3
87.5
84.6
67.3
65.2
65.5
72.2
F
(X)
20.1
34.5
13.4
15.3
42.1
37.5
47.7
33. 5
30.6
31.7
27.1
34.5
26.5
26.7
46.9
26.3
16.6
33.7
12.5
15.4
32.7
34.8
34.5
27.8
NO
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nunber
of SIUs
SB
a
37
13
99
33
42
24
83
23
31
29
43
12
15
16
50
7
26
17
333
83
151
99
SIUs
T
(X)
94.4
89.2
97.8
95.1
67.1
67.3
60.0
96.S
76.9
79.6
67.3
88.7
74.4
75.0
67.7
75.0
80.5
57.1
85.5
78.0
74.7
73.8
68.6
85.6
F
(X)
5.6
10.8
2.2
4.9
32.9
32.7
40.0
3.5
23.1
20.4
32.7
11.3
25.6
25.0
32.3
25.0
19.5
42.9
14.5
22.0
2S.3
26.2
31.4
14.4
ND
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
NON- CATEGORICAL
Nunber
of SIUs
57
9
39
9
93
30
42
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
150
86
SIUS
T
(X)
63.2
38.5
77.7
61.0
47.2
57.6
40.0
47.5
62.3
58.5
78.5
43.2
66.4
66.7
39.8
71.4
85.8
70.9
89.2
90.6
59.0
56.6
61.7
57.3
F
(X)
36.8
61.5
22.3
39.0
52.8
42.4
60.0
52.5
37.7
41.
21.
56.
33.
33.
60.2
28.6
14.2
29.1
10.8
9.4
41.0
43.4
38.3
42.7
•0
(X)
0*
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
T • TRUE STATEMENT
F * FALSE STATEMENT
ND * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-8
-------
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL NC RATE FOR SAMPLING REQUIREMENTS
CATEGORICAL
ALL SIUS
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
N nicer
Of POT US
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
of SIUs
100
12
74
14
138
SO
59
29
135
36
54
45
S3
14
9
30
102
15
53
34
528
127
249
152
T
57.7
66.5
53.8
56. 9
39.6
32.1
40.3
48.1
S8.0
63.4
46.9
70.6
25.1
35.7
56.3
22.4
61.1
60.6
59.2
68.3
46.3
46.8
47.5
44.3
F
19.6
17.4
30.8
0.0
30.3
28.7
32.6
28.0
18.2
17.4
20.1
15.8
1.5
0.0
43.7
0.0
8.7
16.9
7.1
7.4
20.1
21.8
25.3
11.4
Nuitoer
of SIUs
56
8
37
11
78
28
32
IB
79
21 •
31
27
34
12
6
16
47
6
25
16
294
75
131
88
NON- CATEGORICAL
SIUs
T
(X)
66.1
63.6
70.2
63.6
54.2
27.5
60.7
80.0
60.0
69.6
44.9
73.2
30.9
25.0
50.0
31.3
57.7
66.7
53.3
68.4
53.8
44.9
57.8
55.7
F
(X)
21.6
21.6
8.5
36.4
31.5
43.4
32.0
9.3
22.3
6.2
42.0
9.8
67.5
75.0
0.0
68.8
32.8
16.7
37.9
23.7
34.1
32.9
31.2
39.0
NO
(X)
12.4
14.8
21.3
0.0
14.3
29.1
7.3
10.7
17.7
24.2
13.1
17.0
1.6
0.0
50.0
0.0
9.5
16.7
8.8
7.9
12.1
22.2
11.0
5.3
Ntnber
of SIUs
44
4
37
3
60
22
27
11
56
15
23
18
19
2
3
14
55
9
28
18
234
52
118
64
SIUS
T
(X)
44.8
75.0
40.3
33.3
22.0
37.1
5.1
26.6
55.8
57.7
49.2
66.7
14.0
100.0
66.7
7.1
64.2
57.4
65.3
68.2
37.0
49.2
34.4
29.5
F
(X)
24.4
0.0
21.2
66.7
28.4
34.6
18.7
33.8
25.5
31.2
22.8
19.3
84.7
0.0
0.0
92.9
27.7
25.5
29.3
24.8
32.9
29.5
22.1
51.2
NO
(XJ
30.9
25.0
58.5
0.0
49.5
28.3
76.2
39.6
18.7
11.1
28.0
14.1
1.3
0.0
33.3
0.0
8.0
17.0
5.4
6.9
30.1
21.3
43.5
19.3
T « TRUE STATEMENT
F > FALSE STATEMENT
NO * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORAT I ON
H-9
-------
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL NC RATE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuitoer
of POTWs
12
4
6
2
20
8
a
4
U
6
5
3
6
2
3
1
8
3 .
3
2
60
• 23
25
12
Nunber
of SIUs
115
17
76
22
192
63
84
45
151
41
58
52
70
15
25
30
112
18
58
36
640
154
301
185
T
(X)
91.4
94.2
91.4
88.1
75.8
86.2
68.6
80.9
85.6
82.2
88.5
86.2
77.5
86.7
96.1
73.7
89.9
71.1
94.8
89.7
81.4
85.3
79.5
80.9
F
(X)
8.6
5.8
8.6
11.9
24.2
13.8
31.4
19.1
14.4
17.8
11.5
13.8
22.5
13.3
3.9
26.3
10.1
28.9
5.2
10.3
18.6
14.7
20.5
19.1
NO
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Niflber
Of SIUS
SB
a
37
13
99
33
42
24
83
23
31
29
43
12
15
16
50
7
26
17
333
83
151
99
NON- CATEGORICAL
SIUs
T
(X)
96.8
89.2
100.0
100.0
73.6
87.5
62.2
96.5
89.2
95.3
82.7
90.9
78.2
83.3
100.0
75.0
87.7
57.1
94.0
85.3
81.2
87.8
74.2
87.2
F
(X)
3.2
10.8
0.0
0.0
26.4
12.5
37.8
3.5
10.8
4.7
17.3
9.1
21.8
16.7
0.0
25.0
12.3
42.9
6.0
14.7
18.8
12.2
25.8
12.8
NO
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nunber
of SIUs
57
9
39
9
93
30
42
21
68
18
27
23
27
3
10
14
62
11
32
19
307
71
ISO
86
SIUS
T
CX)
85.2
100.0
84.6
61.0
78.5
84.8
78.8
71.0
82.2
70.8
94.4
81.7
76.4
100.0
92.6
71.4
91.7
78.2
95.5
93.8
81.6
82.9
85.9
73.9
F
(X)
14.8
0.0
15.4
39.0
21.5
15.2
21.2
29.0
17.8
29.2
5.6
18.3
23.6
0.0
7.4
28.6
8.3
21.8
4.5
6.2
18.4
17.1
14.1
26.1
HO
(X)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
T • TRUE STATEMENT
F • FALSE STATEMENT
ND • ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-10
-------
IP?
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL SNC RATE FOR DISCHARGE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuitoer
of POTUs
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nunber
of SIUS
112
17
75
20
187
63
79
45
146
39
57
SO
70
15
25
30
107
18
55
34
622
152
291
179
T
49.4
78.2
39.2
33.3
29.1
34.3
25.9
28.6
40.8
45.4
40.5
34.5
31.5
60.0
48.6
25.0
33.6
24.1
38.1
26.7
34.9
44.3
33.1
28.8
f
(X)
41.4
17.3
50.0
54.6
61.4
58.9
64.2
59.0
49.3
46.2
52.2
49.2
58.2
20.0
34.5
67.0
53.2
61.4
50.4
55.1
55.1
47.7
56.9
59.4
NO
(X)
9.2
4.5
10.8
12.1
9.5
6.8
9.9
12.3
9.9
8.3
7.3
16.3
10.3
20.0
16.9
7.9
13.2
14.5
11.5
18.2
10.0
8.1
10.1
11.9
Ninber
of SIUs
57
8
37
12
96
33
39
24
82
23
31
28
43
12
15
16
47
7
24
16
325
83
146
96
SIUS
T
(X)
48.4
70.0
48.5
29.0
21.4
36.0
8.2
33.9
32.9
37.3
38.3
16.9
35.9
58.3
40.4
31.3
24.2
14.3
28.9
14.9
29.9
42.5
22.7
28.6
F
(X)
42.8
21.6
36.6
68.5
66.2
52.9
85.2
34.3
49.6
45.8
47.1
59.5
49.2
16.7
40.4
56.3
61.5
71.4
62.8
50.0
56.7
44.2
67.7
52.9
NO
(X)
8.8
8.5
14.9
2.5
12.5
11.1
6.6
31.9
17.6
16.9
14.6
23.7
14.8
25.0
19.2
12.5
14.2
14.3
8.3
35.1
13.4
13.3
9.6
18.6
Nurber
of SIUs
55
9
38
8
91
30
40
21
64
16
26
22
27
3
10
14
60
11
31
18
297
69
145
83
NON-CATEGORICAL
SIUS
T
(X)
50.7
87.7
31.6
43.5
36.5
32.7
46.1
25.3
48.6
53.4
42.7
51.2
23.8
66.7
56.0
14.3
40.9
29.1
45.9
37.1
40.0
46.1
43.5
29.0
F
(X)
39.7
12.
60.
21.
56.
64.
40.3
74.7
49.0
46.6
57.3
39.4
74.0
33.3
29.2
85.7
46.7
56.4
39.9
59.7
53.4
51.3
46.0
66.6
NO
(X)
9.6
0.0
7.4
34.7
6.7
2.5
13.7
0.0
2.3
0.0
0.0
9.4
2.2
0.0
U.8
0.0
12.4
U.5
14.?
3.2
6.6
2.6
10.5
4.4
T * TRUE STATEMENT
F • FALSE STATEMENT
NO * ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-ll
-------
COMBINED COMPLIANCE HATES FOR TTO AMD NON-TTO
OVERALL SNC RATE FOR REPORTING
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL S1US
POTU
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nuifeer
of POT Us
12
4
6
2
20
8
8
4 .
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Nutber
of SlUt
105
U
75
16
166
52
74
40
136
34
52
SO
67
15
22
30
108
15
57
36
582
130
280
172
T
m
35.9
40.8
30.0
41.9
37.4
20.6
45.7
38.1
45.0
48.6
49.5
33.6
18.6
13.3
38.7
17.1
32.7
0.0
32.9
57.3
35.6
28.1
41.7
32.2
F
(X)
57.5
44.3
65.6
56.2
47.5
74.4
38.5
36.2
46.4
51.4
48.2
37.6
72.8
46.7
52.5
78.9
62.3
88.7
63.4
37.6
53.6
64.0
48.4
53.2
NO
(X)
6.6
15.0
4.4
1.9
15.0
5.0
15.8
25.7
8.6
0.0
2.2
28.8
8.7
40.0
8.8
4.0
5.1
11.3
3.7
5.1
10.8
7.9
9.9
14.6
Nirtjer
of SIUs
57
8
37
12
93
30
39
24
78
20
30
28
43
12
15
16
47
5
25
17
318
75
146
97
NON-CATEGORICAL
SIUS
T
(X)
38.2
38.0
31.7
45.5
47.0
17.6
54.8
62.9
45.8
51.1
35.3
56.5
19.0
16.7
25.8
18.8
35.4
0.0
35.0
52.8
40.5
27.6
46.4
41.2
F
(X)
54.8
47.2
63.4
52.0
40.7
75.8
29.8
28.9
50.1
48.9
60.6
34.1
69.5
41.7
66.7
75.0
57.5
100.0
56.9
39.9
49.8
62.8
42.0
52.1
ND
(X)
7.0
14.8
4.9
2.5
12.2
6.6
15.4
8.2
4.1
0.0
4.1
9.3
11.5
41.7
7.6
6.3
7.1
0.0
8.1
7.3
9.7
9.6
11.6
6.6
Hatter
Of SIUS
48
6
38
4
73
22
35
16
58
14
22
22
24
3
7
14
61
10
32
19
264
55
134
75
SIUs
T
(X)
32.7
45.8
28.6
30.1
23.8
24.1
25.9
20.7
44.2
46.2
66.2
11.8
17.9
C.O
55. 1
14.3
30.6
0.0
31.2
61.5
29.3
28.8
35.1
21.5
F
CX)
61.3
39.0
67.5
69.9
57.2
72.8
57.6
41.3
42.6
53.8
33.8
40.9
78.7
66.7
34.6
85.7
65.9
84.3
68.8
35.4
58.5
65.3
57.4
54.4
M>
tt>
6.0
15.3
3.9
0.0
19.0
3.1
16.6
38.0
13.2
0.0
0.0
47.3
3.4
33.3
10.3
0.0
3.5
15.7
0.0
3.1
12.3
5.9 ~
7.5
24.1
T > TRUE STATEMENT
F « FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-12
-------
COMBINED COMPLIANCE RATES FOR TTO AND NON-TTO
OVERALL SNC RATE
REGION
N. EAST
MID EAST
SOUTH
MID WEST
WEST
OVERALL
CATEGORICAL
ALL SIUS
POTW
SIZE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
SMALL
MEDIUM
LARGE
Nimber
Of POTWS
12
4
6
2
20
8
8
4
U
6
5
3
6
2
3
1
8
3
3
2
60
23
25
12
Niiifeer
Of SIUS
115
17
76
22
192
63
84
45
149
40
58
51
70
15
25
30
112
18
58
36
638
153
301
184
T
59.2
82.7
50.8
46.7
S3 .3
45.5
58.0
51.4
61.1
60.5
62.1
60.2
43.5
60.0
65.5
38.2
48.3
24.1
51.1
60.8
53.7
54.0
56.8
48.5
F
33.4
17.3
38.2
43.4
32.0
47.7
26.8
24.5
34.4
39.5
35.9
24.6
49.5
13.3
27.1
57.9
41.9
61.4
40.5
29.0
35.8
40.3
31.8
38.0
ND
(X)
7.4
0.0
11.0
9.9
14.7
6.8
15.2
24.1
4.5
0.0
2.0
15.2
7.0
26.7
7.5
4.0
9.8
14.5
8.4
10.2
10.5
5.7
11.4
13.5
Nuiber
of SIUs
58
8
37
13
99
33
42
24
82
23
31
28
43
12
15
16
SO
7
26
17
332
83
151
98
NON-CATEGOftlCAL
SIUS
T
(X)
61.8
78.4
60.1
49.3
57.1
44.6
S6.S
81.4
57.7
60.0
49.7
68.0
47.1
58.3
59.6
43.8
45.5
14.3
47.0
60.1
55.3
53.2
54.7
58.2
F
(X)
32.7
21.6
25.0
50.7
29.7
46.8
27.1
10.4
37.8
40.0
46.3
20.1
43.8
16.7
32.8
50.0
44.0
71.4
45.3
22.0
34.7
39.9
32.1
34.6
ND
(X)
5.5
0.0
14.9
0.0
13.2
8.6
16.4
8.2
4.4
0.0
4.0
11.8
9.1
25.0
7.6
6.3
10.5
14.3
7.7
17.9
9.9
6.9
13.1
7.2
Nuifeer
of SIUs
57
9
39
9
93
30
42
21
67
17
27
23
27
3
10
14
62
11
32
19
306
70
150
86
SIUS
T
(X)
S6.1
87.7
43.5
40.7
48.9
46.5
60.5
32.5
64.3
61.0
74.7
52.9
37.3
66.7
70.8
28.6
50.7
29.1
54.6
61.5
51.9
54.8
59.3
37.8
F
(X)
34.1
12.3
48.6
26.8
34.7
48.5
26.2
33.4
31.2
39.0
25.3
28.7
59.5
0.0
21.8
71.4
40.2
S6.4
36.3
35.4
36.9
40.7
31.5
41.6
MO
(X)
9.7
0.0
7.9
32 .5
16.4
5.0
13.3
34.1
4.6
0.0
0.0
18.3
3.2
33.3
7.4
0.0
9.1
14.5
9.0
3.1
11.1
4.6
9.3
20.4
T • TRUE STATEMENT
F * FALSE STATEMENT
ND « ANSWER COULD NOT BE DETERMINED FROM SIU FILE INFORATION
H-13
------- |