Known Data Problems

On this page:


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. Problems with the functioning of the website itself are listed on the Website Known Issues page.

Top of Page


Primary Data Alerts

EPA has identified some 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 program-specific sections.

Clean Air Act (CAA) Primary Data Alerts

Clean Air Act Data

ECHO is displaying Clean Air Act data from the modernized national data management system, ICIS-Air. Some states are still establishing complete data transfer connections to ICIS-Air. States in which some ICIS-Air data may be outdated or incomplete are Louisiana, Nebraska, North Dakota, and Texas. The ICIS-Air State summary (Excel, 16KB) lists the states and local agencies that send data by electronic transfer, along with a "Y" for each data family submitted. States/locals that enter data directly are not included on this list and may include some instances of outdated or incomplete data. EPA and state/local agencies are working toward transmission or entry of all data families.

Clean Water Act (CWA) Primary Data Alerts

EPA and states completed a significant data modernization project in late 2012. This allowed EPA to turn off the old data system, but some data flow issues prevent ECHO from showing a complete listing of violations and enforcement activity. These are described below.

Arizona CWA Data Arizona is not supplying EPA with data about its Clean Water Act NPDES Program due to issues with development of the data flows from the State database to ICIS-NPDES. EPA migrated Arizona's data from Legacy PCS to ICIS-NPDES on November 29, 2012. This allows users to see the list of regulated facilities and associated historical activities, however, subsequent DMR data and state inspection/enforcement activities are not being reported. Arizona began flowing data to ICIS-NPDES in September 2013. They were projected to complete their data flow to ICIS-NPDES by the end of December 2014.
Kansas CWA Data Kansas and EPA are reviewing minor facility Clean Water Act data for inaccuracies after implementation of the e-reporting rule and are currently working on a fix to resolve the issue.  A mix of multiple reporting frequencies (daily, quarterly, etc.) for some permits may make them appear out of compliance after the data transfer from their State system to ICIS-NPDES.
Missouri CWA Data Facilities appear in ECHO to be in noncompliance for failing to submit expected Discharge Monitoring Reports (DMRs), which may or may not be the case. Users should verify these data with Missouri Department of Natural Resources (DNR) prior to using it for any intended purpose. Missouri DNR and EPA are working to resolve the issue. 
New Jersey CWA Data New Jersey is not supplying EPA with required data about its Clean Water Act discharge program as it has not converted to the current program data system (ICIS-NPDES). EPA copied New Jersey's data from the old data system on 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.
Vermont CWA Data

Vermont began flowing data to ICIS-NPDES in September 2012; however, the monitoring reports from Vermont facilities prior to September 2012 are currently not available in ICIS-NPDES. The monitoring data was not entered into PCS as expected prior to the migration of the VT data to ICIS-NPDES. Due to this incomplete data in PCS at the time of migration, ECHO is reporting many Vermont facilities to be in non-compliance for failing to submit discharge monitoring reports when in fact they are in compliance.

Vermont DEC is working closely with the EPA to resolve the missing data issues regarding the older 2012 DMRs, but to date, this issue is not resolved. If you have questions, please contact Amber.vanZuilen@state.vt.us.
Washington CWA Data A small number of facilities appear in ECHO to be in noncompliance for failing to submit expected Discharge Monitoring Reports (DMRs), which may or may not be the case. Users should verify these data with Washington Ecology via the PARIS permit database prior to using it for any intended purpose. Washington Ecology is working to resolve the issue. 

Safe Drinking Water Act (SDWA) Primary Data Alerts

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.

Top of Page


Air

General
  • ECHO is displaying Clean Air Act data from the modernized national data management system, ICIS-Air. Some states are still establishing complete data transfer connections to ICIS-Air. States in which some ICIS-Air data may be outdated or incomplete are Louisiana, Nebraska, North Dakota, and Texas. The ICIS-Air State summary (Excel, 16KB) lists the states and local agencies that send data by electronic transfer, along with a "Y" for each data family submitted. States/locals that enter data directly are not included on this list and may include some instances of outdated or incomplete data. EPA and state/local agencies are working toward transmission or entry of all data families. (Updated August 2016)

  • 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.

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)

Top of Page


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)  (1 pp, 48K, About PDF) 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

Arizona is not supplying EPA with data about its Clean Water Act NPDES Program due to issues with development of the data flows from the State database to ICIS-NPDES. EPA migrated Arizona's data from Legacy PCS to ICIS-NPDES on November 29, 2012. This allows users to see the list of regulated facilities and associated historical activities, however, subsequent DMR data and state inspection/enforcement activities are not being reported. Arizona began flowing data to ICIS-NPDES in September 2013. They have projected to complete their data flow to ICIS-NPDES by the end of December 2014. (Updated November 2014)

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)
Kansas Kansas and EPA are reviewing minor facility Clean Water Act data for inaccuracies after implementation of the e-reporting rule and are currently working on a fix to resolve the issue.  A mix of multiple reporting frequencies (daily, quarterly, etc.) for some permits may make them appear out of compliance after the data transfer from their State system to ICIS-NPDES. (Posted January 2017)
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 not able to be coded. EPA is working with the state to correct this situation.
Missouri Facilities appear in ECHO to be in noncompliance for failing to submit expected Discharge Monitoring Reports (DMRs), which may or may not be the case. Users should verify these data with Missouri DNR prior to using it for any intended purpose. Missouri DNR and EPA are working to resolve the issue. (Updated July 2016)
New Jersey New Jersey is not supplying EPA with required data about its Clean Water Act discharge program as it has not converted to the current program data system (ICIS-NPDES). EPA copied New Jersey's data from the old data system on 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. (Posted December 2012)
Vermont

Vermont began flowing data to ICIS-NPDES in September 2012; however, the monitoring reports from Vermont facilities prior to September 2012 are currently not available in ICIS-NPDES. The monitoring data was not entered into PCS as expected prior to the migration of the VT data to ICIS-NPDES. Due to this incomplete data in PCS at the time of migration, ECHO is reporting many Vermont facilities to be in non-compliance for failing to submit discharge monitoring reports when in fact they are in compliance.

Vermont DEC is working closely with the EPA to resolve the missing data issues regarding the older 2012 DMRs, but to date, this issue is not resolved. If you have questions, please contact Amber.vanZuilen@state.vt.us. (Updated November 2014)

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 small number of facilities appear in ECHO to be in noncompliance for failing to submit expected Discharge Monitoring Reports (DMRs), which may or may not be the case. Users should verify these data with Washington Ecology via the PARIS permit database prior to using it for any intended purpose. Washington Ecology is working to resolve the issue. (Updated August 2016)
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)

Top of Page


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

Regulation of hazardous waste in California is a partnership between federal, state and local agencies. TSDFs and TSDFs that are also LQGs are regulated by the state; most LQGs and all SQGs are regulated by 83 local agencies. Data for RCRA inspections, violations, and enforcement actions conducted by the California Department of Toxic Substances Control is currently uploaded monthly from EnviroStor Data System to EPA's RCRAInfo. Data on inspections, violations and enforcement from California local agencies is uploaded weekly from CERS, which has been in transition to a full digital exchange and is approximately 50% loaded. 

LQG Specific: RCRAInfo includes a significant number of facilities self-identified as LQGs that have not been updated by business for decades. California does not use RCRAInfo as a management tool and does not routinely update it. The state has identified approximately 1,900 facilities as actual LQGs, while RCRAInfo identifies over 5,000 LQGs. Additionally, California has historically reported only the LQG inspections to RCRAInfo, not the SQG inspections. In fiscal years 2012 and 2013, the state’s automation project interfered with the complete reporting of LQG inspections and this resulted in the apparent decline in the number of inspections. California conducted well over 1,000 LQG inspections in both fiscal years 2012 and 2013. As California continues to fully automate reporting, all hazardous waste generator inspections, LQG and SQG, will be reported to RCRAInfo. In the last five fiscal years, California conducted over 30,000 hazardous waste generator inspections each year. (Updated April 2014)
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)

Top of Page


Drinking Water

General
  • Drinking Water system linkages to EPA's Facility Registry Service and any applicable Clean Air Act, Clean Water Act, or hazardous waste facilities are unavailable. This means Drinking Water systems appear as stand-alone facilities with no Facility Registry Service ID number. Additionally, some search options that rely on Facility Registry Service information, like the All Data County search, will not work for Drinking Water data. Linkages are expected to be restored by the end of November 2014. (Updated October 2014)
     
  • 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.
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)

Top of Page


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)

 

Top of Page