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Known Data Problems

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Overview | Primary Data Alerts | Air | Clean Water | Hazardous Waste | Drinking Water | Abbreviations

Overview

EPA manages a series of national information systems that include data flowing from staff in EPA and state/tribal/local offices. These data streams arrive into national systems in many ways. For example, some jurisdictions maintain their own databases, and then upload their data sets into EPA's systems. Others directly enter information into EPA systems, while in some cases, states/tribes/localities provide information on paper that EPA enters in the systems. Given this fairly complex set of transactions, occasional problems occur with the migration of data into the national systems. This page is meant to explain known data quality problems with larger sets of data. Concerns have been identified by EPA or state environmental agency staff. Where analysis indicates that data were not reported to EPA, ECHO users may want to contact the appropriate state environmental agency for information.

EPA places a high priority on ensuring the integrity of information in the national enforcement and compliance databases. Despite the confidence EPA has in the data, even a very small error rate means that some incorrect data will be apparent due to the large amount of information on the site and the technical issues described above. Please see About the Data for more information.

Additional data quality information may be available:

For errors on a particular facility report, please use the error correction process. To report large-scale problems with data, please send details via the Contact Us form.

Primary Data Alerts

*** DATA QUALITY ALERT ***
CWA penalty data may be incomplete for facilities in states that were recently migrated to Clean Water Act - National Pollution Discharge Elimination System. These newly migrated states include AZ, IA, KS, ME, MS, NC, ND, NJ, OR, SC, VA, VT, WA, WV and WY. For both WA and WY, only the EPA issued permits are impacted (State data for WY and WA is not available yet). EPA plans to fix this problem with the February IDEA refresh. This issue does not impact the ECHO State Dashboards or Comparative Maps.

EPA has identified a number of broad-scale data issues that may impact the completeness, timeliness, or accuracy of data shown in ECHO. These issues are highlighted below, and are also included in the following Air, Water, Hazardous Waste, and Drinking Water sections.

New Jersey CWA Data Please note that New Jersey is not supplying EPA with required data about its Clean Water Act program as it has not converted to ICIS-NPDES. EPA has copied New Jersey's data from the old PCS system as of November 29, 2012. This allows users to see the list of regulated facilities and associated historical activities, however, subsequent state activities are not being reported.
Wyoming CWA Data Wyoming data will begin flowing data to ICIS-NPDES in February or March of 2013. Data from Wyoming will be unavailable until that time.

Vermont CWA Data PCS contains a significant number of Discharge Monitoring Report non-receipt violations for Vermont. State records confirm high compliance rates for facility DMR submittals but delays in data entry and data transmittal to PCS cause them to be flagged for non-receipt. Similarly, compliance schedule reporting violations are often listed erroneously because of the lag time between receipt and data entry. For questions about CWA data in VT, please contact Ginny.Little@state.vt.us
Washington CWA Data A number of EPA-authorized CWA NPDES facilities in Region 10 do not have up-to-date permit limits entered in PCS. In April 2010 Washington launched its new data system Permit and Reporting Information System (PARIS). PARIS is unable to communicate with PCS or ICIS-NPDES; however, it is anticipated that by November 2012, PARIS will be flowing data to ICIS-NPDES. The public can access and search PARIS. (Updated November 2011)
Clean Air Act Compliance Status and Violations ECHO provides a High Priority Violator flag that signals when more serious compliance problems have been identified. This on/off flag does not provide details about alleged violations. However, ECHO also provides violation/compliance status data, which provides some detail about the nature of alleged violations. Violation status data should always be reported when a High Priority Violator determination is made, and should also be reported for many violations that do not rise to the level of High Priority Violations. It is possible for specific violations to be resolved (ended) while the High Priority Flag remains on. EPA's review of the data in ECHO indicates that the High Priority Violator flag is normally reported by states. EPA's review of the violation status data, namely the CAA subprogram violated and the pollutant in violation, indicates that errors of omission exist in many states. These errors of omission could leave the ECHO user with the impression that a facility has no violations, when in fact, violations have been determined. The information below is provided to inform ECHO data users about whether to expect to see violation status data in ECHO reports. Violation data appear to be missing or incomplete in AK, AZ, CA, FL, HI, ID, MO, MT, NE, TN, WA, WY. The following states/territories report a limited amount of violation data: CT, MS, TX. The following states/territories report some violation data: AL, CO, DC, ME, MA, NH, NJ, NM, UT. The following states/territories frequently report violations: AR, DE, GA, IA, IL, IN, KS, KY, LA, MD, MI, MN, NC, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, VA, VI, WI, WV. Due to a small number of regulated sources, EPA's analysis for ND and VT was inconclusive in regard to violation reporting. EPA is working with the states to improve the consistency of reporting CAA violations. ECHO users interested in CAA violation data within a state that infrequently reports CAA violation status to EPA's national database may consider researching other available information (for example, state Web sites or state-published information). (Based on FY2010 data.)
SDWA Violation Data Drinking water data shown in ECHO are based on violations reported by states to EPA's Safe Drinking Water Information System. EPA is aware of inaccuracies and underreporting of some data in this system. We are working with the states to improve the quality of the data. For more information, see the SDWIS home page.

Air

General
  • In some circumstances, states enter their CAA data quarterly. Thus, there could be a two- to three-month lag in posting this information in ECHO.


  • ECHO provides a High Priority Violator flag that signals when more serious compliance problems have been identified. This on/off flag does not provide details about alleged violations. However, ECHO also provides violation/compliance status data, which provides some detail about the nature of alleged violations. Violation status data should always be reported when a High Priority Violator determination is made, and should also be reported for many violations that do not rise to the level of High Priority Violations. It is possible for specific violations to be resolved (ended) while the High Priority Flag remains on. EPA's review of the data in ECHO indicates that the High Priority Violator flag is normally reported by states. EPA's review of the violation status data, namely the CAA subprogram violated and the pollutant in violation, indicates that errors of omission exist in many states. These errors of omission could leave the ECHO user with the impression that a facility has no violations, when in fact, violations have been determined. The information below is provided to inform ECHO data users about whether to expect to see violation status data in ECHO reports. Violation data appear to be missing or incomplete in AK, AZ, CA, FL, HI, ID, MO, MT, NE, TN, WA, WY. The following states/territories report a limited amount of violation data: CT, MS, TX. The following states/territories report some violation data: AL, CO, DC, ME, MA, NH, NJ, NM, UT. The following states/territories frequently report violations: AR, DE, GA, IA, IL, IN, KS, KY, LA, MD, MI, MN, NC, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, VA, VI, WI, WV. Due to a small number of regulated sources, EPA's analysis for ND and VT was inconclusive in regard to violation reporting. EPA is working with the states to improve the consistency of reporting CAA violations. ECHO users interested in CAA violation data within a state that infrequently reports CAA violation status to EPA's national database may consider researching other available information (for example, state Web sites or state-published information). (Based on FY2010 data.)
Louisiana In some circumstances, Clean Air Act enforcement actions taken by the state of Louisiana have been reported to EPA in duplicate (meaning that one enforcement action and penalty will appear twice on ECHO reports). Louisiana is working to correct this information. (Updated October 2011)
Mississippi Based on July 2007 EPA comprehensive state data review of FY05 data, some violations that occur at facilities are not reported to the national system. Based on July 2007 annual analysis of national system data, EPA believes this applies to FY06-07 data, as well. Mississippi Department of Environmental Quality is intensively reviewing the compliance and enforcement process and is developing a Process Improvement Plan that addresses all aspects of MDEQ's compliance and enforcement processes in all media. The Plan will include revision of the existing business processes where necessary, documentation of the revised business processes, development of associated SOPs, and development of a comprehensive training plan. The complete process will take 18 to 24 months to complete. However, MDEQ is committed to implementing the revised process for each aspect as it is developed.
New York ECHO provides a listing of Full Compliance Evaluations (FCEs) under the CAA program. Normally an FCE consists of an on-site inspection preceded by a preparatory review of other compliance information that is submitted by the facility. While many states report FCEs on an ongoing basis as they are completed throughout the year, some states report all or most of their completed FCEs at the end of the fiscal year. NY reports the majority of its FCEs toward the end of the fiscal year. This is allowable under EPA policy, so does not indicate a data problem. However, when looking at facility reports for facilities in this state, keep in mind that on-site inspections may have been conducted, but may not have been reported to the national database yet. (Updated October 2011)
Texas Due to an extensive data cleanup project in Texas, Texas Clean Air Act (CAA) data were not updated from June-September 2006. Significant improvements are reflected with the October 2006 data update. However, corrections to several data flows (e.g., formal enforcement actions, stack tests, etc.) occurred during the November-January timeframe, and corrections to source classification will be completed by September 2007. (Updated August 2007)

Clean Water

General

Penalty Data - Many states do not report penalty data to the national system. It is not an EPA requirement that CWA penalty data be reported, so this does not indicate a data quality problem. Users should be aware that the relevant state (or in some cases, EPA Region) would need to be contacted for this information. (Updated October 2011)

Single-Event Violations - The bulk of violations shown for CWA-NPDES major facilities result from the automatic calculation of compliance status performed by the national program database (PCS or ICIS-NPDES) by comparing the permitted limits with the monthly effluent measurements supplied by the facility. Other CWA violations, such as those detected by facility inspections, are called "single-event violations." EPA has included single-event violations in the ECHO site, but notes that only a small number of EPA regions and states are putting these data in the system. EPA is working on this issue so that the database can be fully populated in the future.

Locational Information - The NPDES Missing Lat/Long (pdf, 48KB) table provides state-by-state percentages of missing lat/long data for individual non-major facilities and outfalls. Without this locational information, 303d Listed Impaired Waters analysis cannot be done.

Universe Data - EPA national systems currently do not have data on the entire universe of NPDES regulated facilities. In particular, permit and monitoring data from many construction stormwater sites are not in ICIS. (Posted November 2011)
Arizona
  • During federal FY08, ADEQ did not populate EPA's Permit Compliance System (PCS) database with enforcement information. This means that information about compliance and enforcement in Arizona is not available in national databases, or the ECHO website. (Arizona reported July 2009)

  • State of Arizona v. Johnson International resulted in a $12 million CWA settlement and State of Arizona v. Kiewit Western Co. resulted in an $80,000 CWA settlement. Both were completed during FY08 and resulted from storm water violations under the CWA. (Arizona reported July 2009)
California For California, the ICIS-NPDES database contains a significant number of Discharge Monitoring Report late-reporting violations showing as N = RNC/Category II - reportable non-compliance. In most cases, the reports were actually submitted by the discharger and entered in the legacy system, PCS, on a timely basis. Due to the reporting requirements in California, the report due dates exceeded that of most states and resulted in the data system incorrectly identifying late-reporting violations in the legacy system. (Updated October 2011)
Colorado Colorado reports enforcement and penalty data for NPDES-regulated entities and facilities to ICIS-NPDES. Based on a July 2009 review of the State Review Framework CWA Multi-State Report made available on ECHO, the state is aware that penalty data are not appearing in the report. (Updated July 2009)
Delaware In some EPA region 3 states (Delaware, Virginia, West Virginia), some pH violations are in error. In certain permits, there are three different pH parameters used to express the pH limitation:
  1. parameter code 00400- pH with a limit of 6.0 to 9.0 standard units;
  2. parameter code 82581- number of excursions greater than 60 minutes at any time;
  3. parameter code 82582 - total minutes that exceed 446 minutes for a month.
These three pH parameters are used when continuous pH monitoring is required in a permit and are allowed as per 40 CFR 401.17, which states:
"...excursions from the range (6.0 - 9.0) are permitted subject to the following limitations: 1) the total time during which the pH values are outside the required range of pH values shall not exceed 7 hours and 26 minutes (446 minutes) in any calendar month (parameter code 82582); 2) no individual excursion from the range of pH values shall exceed 60 minutes (parameter code 82581)."
The pH limit of 6.0 to 9.0 can be exceeded in an effluent without violating the permit if it is not outside the range for more than 60 minutes at any one time or if the total minutes it is outside the range does not exceed seven hours and 26 minutes for the month. When the pH data from a facility's discharge monitoring report is entered in EPA's Permit Compliance System (PCS), the actual pH value is entered, which may be outside the permitted range. As stated above, however, it may not be a permit violation, and PCS does not take this into account. ECHO displays PCS data and may indicate pH violations that were not violations. (Updated October 2011)
Indiana The Indiana Department of Environmental Management (IDEM) strives to ensure the NPDES monitoring results posted to ECHO are accurate, and IDEM works diligently to verify the results, but reporting irregularities and identified non-receipt violations often take additional time to research. IDEM continuously reviews these types of data irregularities to verify their accuracy and when appropriate contacts the NPDES permit holders to obtain revised results. The delay in getting these results posted to ECHO may at times cause non-receipt, compliance schedule milestone, and to a lesser extent, effluent exceedence violations to appear when they may not be entirely accurate. (Posted October 2011)
Michigan In Michigan, PCS contains a significant number of Discharge Monitoring Report non-receipt violations. In most cases, the reports were actually submitted on time but were either not received by data entry staff or were not codable. EPA is working with the state to correct this situation.
Vermont
  • Many Vermont facilities are erroneously shown as having DMR non-receipt violations in the period April through June 2003. Reports were received in a timely manner, and DMR data was entered by the state. However, the data was rejected by EPA's Permit Compliance System (PCS) due to computer communication problems. These data no longer appear on ECHO reports; users of the full downloadable datasets should be aware of this issue. (Updated October 2011)

  • PCS contains a significant number of Discharge Monitoring Report non-receipt violations for Vermont. State records confirm high compliance rates for facility DMR submittals but delays in data entry and data transmittal to PCS cause them to be flagged for non-receipt. Similarly, compliance schedule reporting violations are often listed erroneously because of the lag time between receipt and data entry. For questions about CWA data in VT, please contact Ginny.Little@state.vt.us.
Virginia In some EPA region 3 states (Delaware, Virginia, West Virginia), some pH violations are in error. In certain permits, there are three different pH parameters used to express the pH limitation:
  1. parameter code 00400- pH with a limit of 6.0 to 9.0 standard units;
  2. parameter code 82581- number of excursions greater than 60 minutes at any time;
  3. parameter code 82582 - total minutes that exceed 446 minutes for a month.
These three pH parameters are used when continuous pH monitoring is required in a permit and are allowed as per 40 CFR 401.17, which states:
"...excursions from the range (6.0 - 9.0) are permitted subject to the following limitations: 1) the total time during which the pH values are outside the required range of pH values shall not exceed 7 hours and 26 minutes (446 minutes) in any calendar month (parameter code 82582); 2) no individual excursion from the range of pH values shall exceed 60 minutes (parameter code 82581)."
The pH limit of 6.0 to 9.0 can be exceeded in an effluent without violating the permit if it is not outside the range for more than 60 minutes at any one time or if the total minutes it is outside the range does not exceed seven hours and 26 minutes for the month. When the pH data from a facility's discharge monitoring report is entered in EPA's Permit Compliance System (PCS), the actual pH value is entered, which may be outside the permitted range. As stated above, however, it may not be a permit violation, and PCS does not take this into account. ECHO displays PCS data and may indicate pH violations that were not violations. (Updated October 2011)
Washington A number of EPA-authorized CWA NPDES facilities in Region 10 do not have up-to-date permit limits entered in PCS. In April 2010 Washington launched its new data system Permit and Reporting Information System (PARIS). PARIS is unable to communicate with PCS or ICIS-NPDES; however, it is anticipated that by November 2012, PARIS will be flowing data to ICIS-NPDES. The public can access and search PARIS. Questions regarding the status of Region 10's data management plan should be directed to Kimberly Ogle at 206-553-0955. Questions regarding the status of the state data management plan should be directed to Sharon O'Connor at 360-407-6073. (Updated November 2011)
West Virginia In some EPA region 3 states (Delaware, Virginia, West Virginia), some pH violations are in error. In certain permits, there are three different pH parameters used to express the pH limitation:
  1. parameter code 00400- pH with a limit of 6.0 to 9.0 standard units;
  2. parameter code 82581- number of excursions greater than 60 minutes at any time;
  3. parameter code 82582 - total minutes that exceed 446 minutes for a month.
These three pH parameters are used when continuous pH monitoring is required in a permit and are allowed as per 40 CFR 401.17, which states:
"...excursions from the range (6.0 - 9.0) are permitted subject to the following limitations: 1) the total time during which the pH values are outside the required range of pH values shall not exceed 7 hours and 26 minutes (446 minutes) in any calendar month (parameter code 82582); 2) no individual excursion from the range of pH values shall exceed 60 minutes (parameter code 82581)."
The pH limit of 6.0 to 9.0 can be exceeded in an effluent without violating the permit if it is not outside the range for more than 60 minutes at any one time or if the total minutes it is outside the range does not exceed seven hours and 26 minutes for the month. When the pH data from a facility's discharge monitoring report is entered in EPA's Permit Compliance System (PCS), the actual pH value is entered, which may be outside the permitted range. As stated above, however, it may not be a permit violation, and PCS does not take this into account. ECHO displays PCS data and may indicate pH violations that were not violations. (Updated October 2011)
Wisconsin Wisconsin does not show enforcement action data. A data entry problem may exist. (Updated October 2011)

Hazardous Waste

General Closed/Inactive Facilities - Under the RCRA statute, no regulatory requirements mandate that sites that once handled hazardous waste notify that they have ceased waste management activities. As a result, the RCRAInfo database (which feeds ECHO) contains a listing of all regulated sites that at one point managed hazardous waste. The database includes both active sites and those that are no longer managing hazardous waste and/or are permanently closed. Including all sites assists EPA and the public in determining prior uses of land. EPA and the states developed a method for "inactivating" sites in RCRAInfo. The Facility Characteristics section of the Detailed Facility Report notes whether a RCRA site is considered active or inactive in RCRAInfo. This activity status is determined from the information most recently submitted by a site's representative or determined by EPA or state authority. Also, some states are still working to establish their inactive universes. Therefore, some sites shown to be "active" may not be actively managing waste. When interpreting the data, it is likely that a recent inspection, violation, or enforcement action is a good indicator that the site is actively managing waste.
California As of May 2006, the majority of data for RCRA inspections, violations, and enforcement actions conducted by local California jurisdictions is currently available in RCRAInfo, EPA's national hazardous waste data system. ECHO, which retrieves enforcement data from RCRAInfo, reflects most of the enforcement activities conducted by these local agencies. California is working with EPA to develop and build a new data system that will regularly store and transfer RCRA inspection, violation, and enforcement action data from local jurisdictions to RCRAInfo. This new system, once in place, will help ensure that ECHO is populated with accurate and complete data on a regular basis. (Updated May 2006)
Texas Some Texas compliance information is inaccurate - a large number of violation end dates (more than 500) for violations older than ten years have not been entered into the national system, therefore creating the appearance that some facilities' violations continue for a longer period of time than they actually do. This situation is due to problems in converting some codes from the Texas Commission on Environmental Quality system to the national system, RCRAInfo. The state and EPA are working on a resolution. (Updated October 2011)

Drinking Water

General Drinking water data shown in ECHO are based on violations reported by states to EPA's Safe Drinking Water Information System. EPA is aware of inaccuracies and underreporting of some data in this system. We are working with the states to improve the quality of the data. For more information, see the SDWIS home page.
California Violations may be incorrectly reported as unaddressed. A data processing error in SDWIS resulted in the deletion of state enforcement actions that occurred within the last three years. Therefore, the violations associated with those enforcement actions may incorrectly appear to be unaddressed. EPA is working with California to correct their data in SDWIS, and the corrections will appear in the April 2012 update of ECHO. (Posted Feb 2012)
Colorado An automated data processing error may have caused some resolving actions to not be correctly associated with the violations they address. Therefore, the affected violations may incorrectly appear to be unresolved. Colorado is further investigating this issue. (Posted May 2011)
Mississippi Under the Safe Drinking Water Act Radionuclides Rule, all community water systems are responsible for monitoring for the presence of radioactive substances in their drinking water and reporting the results to the state. The State of Mississippi provides water testing services to all of its public water systems. Because Mississippi has to date supplied EPA with valid initial monitoring results for only a small number of its community water systems, almost all of the CWSs in the state have been in violation of the monitoring requirements of the Radionuclides Rule since early 2008. (Updated October 2011)
North Carolina A data processing error in SDWIS has caused some enforcement actions to not be correctly associated with the violations they address. Therefore, the affected violations may incorrectly appear to be unaddressed. EPA has corrected the error in SDWIS, but the North Carolina database needs to be corrected. EPA will help North Carolina to correct their data, which will appear in future updates of SDWIS in ECHO. (Posted May 2011)

Abbreviations

Abbreviations used:

AFS Air Facility System - Clean Air Act Stationary Source data
CAA Clean Air Act
CWA Clean Water Act
DMR Discharge Monitoring Report (CWA program)
FY Federal Fiscal Year
HPV High Priority Violator (CAA program)
ICIS-NPDES Integrated Compliance Information System for NPDES data - Clean Water Act direct discharge data (modernized system)
NPDES National Pollutant Discharge Elimination System (under CWA)
PCS Permit Compliance System - Clean Water Act direct discharge data
RCRA Resource Conservation and Recovery Act
RCRAInfo RCRA - hazardous waste data
SDWA Safe Drinking Water Act
SDWIS Safe Drinking Water Information System - SDWA water system, violation, and enforcement action data
SNC Significant Noncompliance (CWA/RCRA programs)

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