State Comments on Frozen Data |
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EPA captures (or "freezes") aggregated state data yearly. These frozen data sets are used in several places on EPA's website, including portions of the Enforcement and Compliance History Online (ECHO) website. Frozen data is used in the Annual Reports, State Review Framework Multi-State Report, and the State Review Framework data downloads which are available for CAA, CWA, and RCRA.
Several states have indicated that at the time the data were frozen, that errors existed. States that identified problems with the data were asked to send either a data file with corrected information, or a link to a state website that explained data errors or corrections. States that submitted information appear in the below table.
Comments on Frozen Data | ||
Other Data Quality Resources | ||
The purpose of this page is to display state comments on frozen data, but additional data quality information which is not specific to the frozen data is available through the known data problems and State Review Framework Recommendations Tracker. In the table below, the "Other Resources" column provides links to the data quality information available through these sources. Data quality issues displayed on these sites may be relevant to the frozen data sets.
2011 Comments on Frozen Data | 2010 Comments on Frozen Data | 2009 Comments on Frozen Data | 2008 Comments on Frozen Data
2011 Comments on Frozen Data 1 |
Other Resources |
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State | Media | Comments | Data Links | |
Alabama | CAA | Metric 1A1 for the CAA data erroneously assumes that any source classified as a major source at the plant level should have a Title V air program code and should be identified as a major source subject to the CMS policy. However, due to the State of Alabama's continued regulation of total suspended particulates (TSP), the State has numerous sources that are major sources under the PSD air program due to their potential to emit TSP. In AFS, Alabama has correctly entered these sources without a Title V air program code and as not being subject to the CMS policy. Metric 1A2 for the CAA data erroneously assumes that any source classified as a synthetic minor source at the plant level should have a FESOP air program code and should be identified as a synthetic minor source subject to the CMS policy. However, due to the State of Alabama's continued regulation of total suspended particulates (TSP), the State has numerous sources that are synthetic minor sources under the PSD air program due to their potential to emit TSP. In AFS, Alabama has correctly entered these sources without a FESOP air program code and as not being subject to the CMS policy. |
CAA Data Alert SRF Data Quality Recommendations |
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CWA |
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SRF Data Quality Recommendations | ||
Alaska | CAA | A problem with the translation of data between EPA and the State exists for facility classification data and the FCE data, so the Data Metrics do not reflect the State's activities or facility classification. |
CAA Data Alert SRF Data Quality Recommendations |
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Colorado | CWA |
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CWA Known Data Problems SRF Data Quality Recommendations |
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Connecticut | CWA |
Data for non-municipal permits was reviewed and CT DEP offers the following caveats:
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SRF Data Quality Recommendations | |
Delaware | CWA |
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CWA Known Data Problems SRF Data Quality Recommendations |
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Florida | CWA |
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SRF Data Quality Recommendations | |
RCRA | Metric 1b1 and 1b2 (facilities inspected and number of inspections): The inspection total numbers for 2011 include 2,256 "site visits" that were conducted for the sole purpose of determining whether businesses were still operating as previously notified, and not to determine compliance status. Inspection total numbers for the other years do not include "site visits" due to differences in data translation, so the inspection trend numbers should be viewed with this understanding. | SRF Data Quality Recommendations | ||
Indiana | CAA | Regarding Metrics 1a3, 1a4, 1b1, 1b2, and 1b3, Indiana recognizes that these counts are not accurate and both Indiana and the EPA are working together to improve NSPS and NESHAP data in AFS. Regarding Metrics 1a5, 1a6, 1d1, and 1d2, based on historical database inaccuracies made by EPA and/or the state, the sources listed may not have had violations or compliance status issues within the federal Fiscal Year 2011 period in question. IDEM continues to work with EPA to improve current data quality and accuracy regarding compliance status on these facilities. |
CAA Data Alert SRF Data Quality Recommendations |
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Kansas | CWA | Most of the data that involves enforcement and compliance schedules is incorrect because KDHE has its own database system to track these data. These data are not loaded to PCS unless EPA Region 7 chooses to load the data. The high number of facilities in SNC is the result of the failure of KDHE to load DMR data to PCS in a timely manner. The data were provided to KDHE in a timely manner from the permittees, are in the KDHE database system and have been reviewed. | SRF Data Quality Recommendations | |
Kentucky | CAA | In general, the frozen data in the EPA's FY 2011 report and the current data in the Kentucky Division for Air Quality's (DAQ) database are reasonably consistent with the following exceptions:
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CAA Data Alert SRF Data Quality Recommendations |
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CWA |
The Kentucky Dept. for Environmental Protection has verified the FFY2011 data for the CWA. The following caveats apply:
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SRF Data Quality Recommendations | ||
Louisiana | CWA |
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SRF Data Quality Recommendations | |
Maine | CWA |
The State of Maine DEP has reviewed the FY 2011 CWA Data and has added appropriate flags. The State of Maine DEP would like to have the following caveats posted on the EPA website;
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SRF Data Quality Recommendations | |
Michigan | CAA | The EPA Class of SM or synthetic minor is incorrect for many facilities. Most of the facilities are B or minor sources. About 700 facilities' EPA classes will be manually corrected by Michigan in AFS during calendar year 2012. |
CAA Data Alert SRF Data Quality Recommendations |
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CWA |
Michigan continues to have data problems with getting some data into ICIS. We have reviewed the summary data available through the website, and noted problems with the number of non-major individual permits and general permits (the number of non-majors with individual permits should be 416, the number of non-majors with general permits (non-storm water) is 844, 296 for MS4 general permits, and 2862 for industrial storm water general permits), the lack of enforcement data, the lack of SEV, the number of facilities with permit schedule violations and compliance schedule violations, and the non-major facilities in Category 1 and 2 noncompliance (for CY2010 we reported 213 facilities in those categories combined). We are not able to correct the data at this time due to staff resource constraints. The problems in EPA's database (ICIS) revolve around moving data to ICIS, not in capturing data. We believe our database holds most, if not all, of the required data. A historical perspective might help others to understand some of our problems. A few years ago we were using PCS. At EPA's request we moved to ICIS in August, 2010. When we did that, our electronic data transfer for DMR data failed. We've been working on resolving the problem since that time. A solution is close at hand. During that time period (since August 2010), we have been manually entering DMR data for majors in ICIS even though all the data comes to us electronically. We require all DMR data (for both majors and minors) to be submitted to us electronically. Manually entering this data uses staff time that can be better utilized elsewhere, but we understand the need for moving this data to ICIS. With the move to ICIS, we also lost our ability to batch load inspection data to EPA's database. PCS accepted batch load inspection data, but ICIS does not. Fortunately we have been getting assistance from EPA Region 5 staff in our effort to load inspection data. Several years ago we were in a position to move much of the required data elements to EPA's database through the data exchange, but the schemas were not finalized. The effort to finalize the schemas has been slow, but we understand that many of the schemas are now finalized (only the enforcement schemas remain to be done). We intend to make substantial progress this year in moving data from our database to ICIS. We have an EPA grant to aid us in the effort. We expect to have the DMR data flow working shortly. We expect to have facility and permit data flow working early this spring, with follow-up testing to be completed by mid-summer. Once these systems are in place and operational, we'll be able to devote staff resources to addressing other issues with our data. We continue to work with the EPA Region 5 staff to resolve ICIS data issues. We are currently in the process of developing a new database. The requirements for our new database will include full upload of data to ICIS. We also expect to be fully compliant with the soon to be proposed e-reporting rule. |
CWA Data Alert CWA Known Data Problems SRF Data Quality Recommendations |
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Minnesota | CAA | The Minnesota Pollution Control Agency has made all reasonable effort to verify and correct the data presented in the OTIS/ECHO State Review Framework (SRF) environment. This has been done by ensuring that the data contained in the respective EPA program systems, ICIS-NPDES, RCRAInfo and AFS are in agreement with the Delta data system maintained by the MPCA as implementer of these programs for the State of Minnesota. Where discrepancies still exist, they are often beyond the control of the MPCA because they are related to the procedures by which the EPA IDEA/OTIS/ECHO database aggregates and assesses the data stored in the stand-alone program systems. The MPCA is unable to correct or influence any errors that arise in this process, which is wholly within the control of the EPA. For complete and current information on regulated parties in Minnesota, the MPCA suggests that the data be accessed through our What's in my Neighborhood website. The SRF Metrics may not accurately reflect Minnesota's performance on enforcement due to a conflict between federal standards for data transparency and State of Minnesota data practices laws. Under Minnesota law, the outcome of a compliance evaluation or enforcement action is not public until it is final, nominally defined as the later of the final execution of a compliance or enforcement instrument or the exhaustion of all available appeals. As a result of Minnesota law and the mechanisms by which the federal program systems publish data to public systems, Minnesota cannot share information on certain in-process compliance evaluations and responses. Here is a caveat relating to the Title V Compliance Certification review result code of "MV". This code has been used by our state to signify that deviations were reported, however it does NOT imply that noncompliance was found. The RDE8 result code of "Y" also signifies that deviations were reported, so the "MV" result code is actually redundant in the way we have used it. One solution that I propose is to change the "MV" status codes to "MC" if no follow-up enforcement action was initiated (or the review was not part of a case pathway) That procedure should largely eliminate unnecessary calls from Regulated Parties concerned about the often false "Violations" triggered by these reviews (even they doesn't change the facility compliance status) |
CAA Data Alert SRF Data Quality Recommendations |
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CWA |
The Minnesota Pollution Control Agency has made all reasonable effort to verify and correct the data presented in the OTIS/ECHO State Review Framework (SRF) environment. This has been done by ensuring that the data contained in the respective EPA program systems, ICIS-NPDES, RCRAInfo and AFS are in agreement with the Delta data system maintained by the MPCA as implementer of these programs for the State of Minnesota. Where discrepancies still exist, they are often beyond the control of the MPCA because they are related to the procedures by which the EPA IDEA/OTIS/ECHO database aggregates and assesses the data stored in the stand-alone program systems. The MPCA is unable to correct or influence any errors that arise in this process, which is wholly within the control of the EPA. For complete and current information on regulated parties in Minnesota, the MPCA suggests that the data be accessed through our �What's in my Neighborhood' website. The SRF Metrics may not accurately reflect Minnesota's performance on enforcement due to a conflict between federal standards for data transparency and State of Minnesota data practices laws. Under Minnesota law, the outcome of a compliance evaluation or enforcement action is not public until it is final, nominally defined as the later of the final execution of a compliance or enforcement instrument or the exhaustion of all available appeals. As a result of Minnesota law and the mechanisms by which the federal program systems publish data to public systems, Minnesota cannot share information on certain in-process compliance evaluations and responses. Minnesota data was migrated from the EPA's PCS data system to the new system, ICIS-NPDES, February-March 2011. Due to the magnitude of the changes in the data structure, a number of errors were generated in historic data. Minnesota is not required to supply detailed information on non-major facilities to ICIS-NPDES. For information on non-major facilities the MPCA suggests that the data be accessed through our What's in my Neighborhood website. |
SRF Data Quality Recommendations | ||
RCRA | Most of Minnesota data are correct in the national program system RCRAInfo. But due to Minnesota's data privacy rules some data are not displayed in ECHO. | SRF Data Quality Recommendations | ||
Mississippi | CWA | Metric 1f2: Logic used by EPA to retrieve data counted formal actions more than once. Only 38 formal actions at CWA NPDES facilities in FY11 | SRF Data Quality Recommendations | |
Nebraska | RCRA | NDEQ records indicate that it appears there is a discrepancy in the total number of active LQGs, SQGs, and other active sites. Also, the number in data metric 1c2 is unverifiable based on the parameters. Metric 1e2 number of sites in SNC - ID number NED000610550 should not be listed as a current SNC. An SNN record dated 5-25-2007, Consent Order signed, should have removed this facility ID from being a SNC. | SRF Data Quality Recommendations | |
New York | CAA | NY DEC found many cases of old data (orphaned) that is not currently being uploaded from our database extract into EPA AFS. Most of the errors we found were in the 1a3 and 1b2 drill downs. However, we expect similar problems may exist with the 1b3 drill down but did not have the resources to investigate the hundreds of facilities at this time. In many of the bad data instances the facilities never held air pollution program permits and/or do not have any 40 CFR Part 61 NESHAP applicable requirements. We suspect many were erroneously given a NESHAP program and/or pollutant by someone other than NY staff. As noted we did not have time to verify every single piece of the thousands of pieces of data but we believe in most cases, other than those outlined above, that the data batch uploaded from the NY DEC system to EPA AFS is accurately portraying our universe of facilities, applicable programs and recorded violations. Not all inspections were entered in RCRAInfo before EPA's deadline of 2/22/2012. |
CAA Data Alert Known Data Problems SRF Data Quality Recommendations |
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RCRA | NY does not use the federal generator status field in RCRAInfo to track a site's RCRA hazardous waste generation status (i.e. LQG, SQG) and this field is inaccurate for NY sites. We use an internal database of manifest and Hazardous Waste Report data of shipments and generation instead. NY also does not use the active site field in RCRAInfo. This results in the calculation of certain RCRA State Review Framework Metrics being inaccurate, especially # 5 b, c, and d, about inspection coverage, and any other calculations using these numbers would also be inaccurate. The percent of NY LQGs and SQGs inspected, or inspection coverage, is greater than calculated. These numbers are based on current universe counts for LQGs and SQGs, but since these universe change on a daily basis, some of the LQG/SQG inspections conducted are not credited in EPA's SRF reports because the site moved out of the universe. EPA R2 and NY have agreed to target inspections at long-term LQGs, since a very large percent of our LQGs are an LQG for a year or less. Inspecting sites that don't generate hazardous waste on an ongoing basis is difficult. 5-10 inspections (violations, and enforcements) have not been entered because no RCRA EPA ID # has been issued to the site by EPA R2. NY conducts inspections at facilities that do not have EPA ID#s and are not required to notify EPA or NY of their hazardous waste activities (i.e. federal CESQGs, and non-regulated facilities) and get an EPA ID#. The inspection activities, enforcement actions, and resulting monetary penalties assessed or collected as a result of such enforcement activities by NY are not captured or reflected in the EPA metrics. As a result, EPA's metrics understate NY's full range of hazardous waste compliance, inspection, and enforcement efforts. Not all inspections were entered in RCRAInfo before EPA's deadline of 2/22/2012. |
SRF Data Quality Recommendations | ||
North Carolina | CAA | OTIS Data Verification Caveats for FY2011 Metrics:
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CAA Data Alert SRF Data Quality Recommendations |
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CWA | Problems with the translation and timing of the data between EPA and the State exist for the number of active major permits and non-major general permits, informal and formal actions, total penalties assessed, unresolved compliance schedule violations, and non-majors facilities with Single-Event Violations reported, so the data metrics do not reflect the complete number of activities the State performed. | SRF Data Quality Recommendations | ||
RCRA | North Carolina added two RCRA Enforcement Action codes to its state's program, codes 214 and 215. Code 214 is utilized for a legislative change that allows for the assessment of the reasonable costs of any investigation, inspection, or monitoring associated with the assessment of a civil penalty against any person who is assessed a civil penalty. Code 215 is utilized for a facility that fails to pay NC hazardous waste fees when due. | SRF Data Quality Recommendations | ||
North Dakota | CWA | North Dakota has determined that all facilities listed in Category 1 noncompliance have terminated permits and are not under an administrative extension. Any compliance related issues with these facilities under a terminated permit are in error. North Dakota has determined that the facilities listed in Category 2 noncompliance are either under a terminated permit that is not under an administrative extension and in error, or facilities that were entered into PCS by EPA Region 8 for inspections in which EPA was the lead. |
SRF Data Quality Recommendations | |
Oklahoma | RCRA | SRF report shows no penalties collected during Fed FY11. Below is a summary of actual penalties collected between 10/1/10 & 9/30/11.
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SRF Data Quality Recommendations | |
Pennsylvania | RCRA | Any potential and/or actual data discrepancies that might exist will be investigated and resolved in accordance with the PADEP QA/QC Data Management Plan. | SRF Data Quality Recommendations | |
Puerto Rico | CAA | Some data still under review or is not shown. We are reviewing AFS to determine the problems. |
CAA Data Alert SRF Data Quality Recommendations |
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Rhode Island | RCRA | RIDEM was not able to verify State Review Framework data metrics 1a2, 1a3, 1a4 and 1c1 due to the fact that the State's database does not collect this information. | SRF Data Quality Recommendations | |
South Dakota | CWA |
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SRF Data Quality Recommendations | |
Texas | CAA |
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CAA Data Alert Known Data Problems SRF Data Quality Recommendations |
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RCRA | The Texas Commission on Environmental Quality (TCEQ) Field Operations Support Division (FOSD) has completed the data verification process for the FY2011 RCRA Data Metrics. Based on the review, the TCEQ reports the following data caveats:
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Known Data Problems SRF Data Quality Recommendations |
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Virginia | CWA |
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CWA Known Data Problems SRF Data Quality Recommendations |
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RCRA | Two invalid ID's were identified in metrics 1a2 (count should be 259; there were two invalid ID's: VAR000513538, VAD018753881) and 1a5 (count should be 232; there were two invalid ID's: VAR000513538, VAD018753881). | SRF Data Quality Recommendations | ||
Washington | CAA | Washington Southwest Clean Air Agency - SWCAA will work with the EPA Data Steward regarding the metrics under review and to correct any remaining deficiencies. |
CAA Data Alert SRF Data Quality Recommendations |
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RCRA | The handler translation problem between RCRAInfo and the state system noted in previous years has been resolved. RCRAInfo now reflects the correct number of active sites in Washington. Burlington Environmental Kent, LLC, WAD991281767, continues to show as a state unaddressed SNC. This is likely due to multiple inspections resulting in formal and informal actions linked to violations. The site has received multiple penalties from Ecology since entering SNC status and is definitely not unaddressed. Ecology's regional offices have reviewed the inspection data captured in metrics 1B1 and 1B2 and made any corrections found. However, resource limits prevent individual verification of each datum in metrics 1B1, 1B2, 1C1, 1C2 and 1D1. We are confident that the nearly 1,900 entries are very close to correct. |
SRF Data Quality Recommendations | ||
West Virginia | CWA | The State of West Virginia has completed its review of CWA data. One data issue is that it appears outfall and effluent data appears missing when the fact is that these are collection systems and outfall and effluent data doesn't apply. These are designated in the rdf10 field as 4952C facilities (collection systems). |
CWA Known Data Problems SRF Data Quality Recommendations |
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Wisconsin | CAA | We have updated/corrected the AFS data on the basis of the data that we have in our state system (WARP, Wisconsin Air Resources Program). We are unable to verify or challenge some of the metrics because we have just begun to track those data (Air Program subparts in particular) and our data are incomplete. We maintain very little data in AFS for Tier II facilities and the metrics for those data are of limited value. |
CAA Data Alert SRF Data Quality Recommendations |
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Wyoming | CAA | This data reflects all available information entered into AFS by the State of Wyoming at this time. The number of NOVs does NOT include any Asbestos NOV or 4 additional NOVs that were issued to facilities that do not exist within our database or AFS. the Penalties collected does not reflect that amount collect for Asbestos NOVs. |
CAA Data Alert SRF Data Quality Recommendations |
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CWA | 8a1: Active Major Facilities in SNC during the Reporting Year (10/1/10-9/30/11) During the year EPA reported of 5 Major Facilities that were in SNC as a result of various QNCR runs. Apparently there are multiple parameter codes in PCS for various parameters. Of the five listed Major Facilities 4 of them are the results of PCS set up with the wrong codes. Once these codes were corrected in the PCS set up these facilities were reported as back in compliance. Only one Major Facility (City of Casper) had a true effluent exceedance resulting in SNC. Therefore, Wyoming only had one Major Facility in "true" SNC. |
CWA Data Alert SRF Data Quality Recommendations |
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RCRA | On the State Comparative Maps and Dashboards, the Final Formal Enforcement Actions with Penalties view and chart incorrectly show zero for fiscal year 2011. Wyoming had one final formal enforcement action with penalty in fiscal year 2011. | SRF Data Quality Recommendations |