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Please see the attached comments on ICIS documents.

If you have any questions, please contact me at the number below.

Leah J. Krafft

Wyoming Department of Environmental Quality

Water Quality Division, WYPDES Program

Permitting Program Supervisor

(307)777-7093 - phone

(307)777-5973 - fax

June 1, 2007

Sandy Johnson

EPA Region 8 

1595 Wynkoop Street

Denver, CO 80202-1129

RE: ICIS-NPDES Policy Statement and WW SNC Policy

Dear Sandy:

Thank you for the opportunity to review and provide comments on the Draft ICISNPDES Policy Statement and the Draft WW SNC Policy. The Wyoming 

Department of Environmental Quality, Water Quality Division would like to offer 

the following comments for your consideration.

ICIS-NPDES Policy Statement

Data Entry Protocols

The statement proposes that all data should be entered into ICIS-NPDES within 

30 days of the event or action. For most activities, such as inspections or permit 

conditions, this can be accomplished within the proposed timeframe. However, 

for entering DMR data, this is unrealistic. As an example, the State of Wyoming 

has 869 activity permits for the coal bed methane industry. These permits have 

6689 active outfalls associated with them. All of these permits require the DMRs 

to be submitted semi-annually; with a DMR due date of February 15th and August 

15th of each year. Considering the number of permits and outfalls there are, you 

can imagine the number of DMRs that would have to be entered into ICISNPDES. It is requested that the time line associated with entering DMR data be 

increased to 120 days.
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Ensure ICIS-NPDES data entry or transfer of those RIDE for which WENDB 

equivalents exist in PCS

It is not accurate or reasonable to assume that all RIDE for which WENDB 

equivalents exist in PCS will be entered for all facilities and should be available in 

ICIS-NPDES vary early in the transition period. Currently, there are many 

WENDB data elements that the State of Wyoming does not enter. The reasons 

data are not being entered into these fields vary from resource constraints to lack 

of data. It is anticipated that these same constraints will also be a reality for the 

new RIDE for ICIS-NPDES. It is suggested that the Transition Plans have the 

flexibility to allow the states to negotiate with EPA Regions to identify specific

RIDE elements that can be realistically entered into ICIS-NPDES. This will help 

to eliminate the potential tension between the States and EPA when each state’s 

performance is evaluated thought the FRS process. 

National Targets

The National Targets for DMR Limit Sets, Limits and DMRs for individual and 

general permits are unclear. It appears that the National Target for individual 

non-majors is 50 % of active permits and 25% of general permits. Again, just 

using the example described above, to enter limits and DMR data for 430 permits 

by September 2008 or within four months after migration to ICIS-NPDES is 

unrealistic. It is suggested that the states negotiate with the region to identify a 

reasonable percentage of limits and DMR data that should be entered into ICISNPDES. This proposal recognizes workload constraints within each state and 

establishes realistic goals that can be achieved. 

Entering Facility Latitudes/Longitudes

Entering facility latitudes and longitudes by the required National Target of 

December 2008 for individual non-majors and December 2009 for General 

permits will not be achieved by the State of Wyoming. Currently, the state does 

not have locational data for many individual permits and does not require this 

information to be submitted in the NOI for most non-major general permits. In 

most cases, this information would not be available until the general permits were 

renewed. 

Proposed RIDE

Facility Latitude and Longitude Fields

As suggested in previous letters, it is suggested that these fields be eliminated as 

a RIDE. It is not practical to enter this information for many operations in 

Wyoming, such as a large oil field, where there is not a discrete facility but rather 

many wells located in a field.
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Permitted Features, Application Design Flow and Actual Design Flow

Many times, the design and actual flow is only identified on the facility level rather 

then the individual outfalls. It is suggested that these be eliminated as a RIDE 

and utilize similar fields on the facility level. 

Inspection, Enforcement and No Discharge Codes

Please provide additional clarification for the various Inspection, Enforcement

and No Discharge Codes.

Enforcement Sensitive Information

The policy does not address how to handle enforcement sensitive information.

WW SNC Policy

It is appreciated that the definition of SNC for stormwater is flexible to allow 

states to utilize it in specific instances. However, clarification should be provided 

on how Region 8 will interrupt this definition. By understanding the Region’s 

interpretation, there will be less potential for disagreements on potential SNC 

designations and enforcement actions. 

If you have any questions, please contact me at 307-777-7093.

Sincerely, 

Leah J. Krafft

WYPDES Permitting Supervisor

Water Quality Division
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