Data Entry Requirements

This table indicates where EPA requires data to be provided to national databases (which flow through to the ECHO website on a weekly basis, with the exception of drinking water data, which are updated quarterly). Data are provided by authorized state, tribal, and local governments, as well as EPA. This table is designed to help users understand where data are more complete. Many states voluntarily enter additional data that is not required; however, in boxes that indicated "Partial" or "N" for no, data completeness may vary widely from state to state. The ECHO website will show the information entered by states regardless of whether it is required. ECHO users may want to refer to state agency web sites for additional information.

  Clean Water Act - National Pollution Discharge Elimination System Clean Air Act - Stationary Sources Resource Conservation and Recovery Act - Hazardous Waste Safe Drinking Water Act
Facility/Source/ System Type Major (Individual Permit) Non-Major (Individual Permit)1 Non-Major (General Permit Covered Facilities)1 Major
(Large)
Synthetic Minor12
(Mid-Size)
Minors4,13
(Small)
TSDF and LQG5
(Large)
SQG6
(Small)
Public Water Systems
Estimated # of Active Regulated Entities 6,800 41,000 >300,000 15,000 24,000 >100,000 25,000 150,000 154,000
Data System ICIS-NPDES ICIS-Air RCRAInfo SDWIS-FED
Facility Universes Tracked Y Y Y Y Y Partial13 Y Y Y
Compliance Evaluation Performed
EPA Y Y Y Y Y Partial8 Y Y Y17
State Y Y Y Y7 Y7 Partial8 Y Y Y17
Compliance Evaluation Results (Violation/Compliance Status)
EPA Y Y Y Y9 Y9 Y9 Y11 Y11 Y
State Y Y2 Y2 Y9 Y10 Partial9 Y11 Y11 Y
Self-Reported Discharge/Violations
EPA Y Y Y Y10 Y10 Partial10 N/A N/A Y
State Y Y Y Y10 Y10 Partial10 N/A N/A Y
Severity of Violation (SNC/HPV)14
EPA Y Y Y Y Partial15 N16 Y Y N
State Y Y Y Y Partial15 N16 Y Y N
Notices of Violation (Informal Enforcement)
EPA Y Y Y Y Y Y Y Y N
State Y Y Y Y Y Partial8 Y Y N
Formal Enforcement Actions
EPA3 Y Y Y Y Y Y Y Y Y
State Y Y Y Y Y Partial8 Y Y Y
Amount of Assessed Penalties
EPA3 Y Y Y Y Y Y Y Y N
State Y Y Y Y Y Partial8 Y Y N

(1) The U.S. Environmental Protection Agency (EPA) recently promulgated the NPDES Electronic Reporting Rule (“final rule”) to modernize Clean Water Act reporting for municipalities, industries, and other facilities by converting to an electronic data reporting system. This final rule requires regulated entities and state and federal regulators to use existing, available information technology to electronically report data required by the National Pollutant Discharge Elimination System (NPDES) permit program instead of filing written paper reports. See National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule; Final Rule, October 22, 2015, 80 FR 64064. This regulation will help provide greater clarity on who is and who is not in compliance and enhances transparency by providing a timelier, complete, more accurate, and nationally-consistent set of data about the NPDES program. The final rule will implemented over the next few years (full implementation will be December 2020). During this transition period there will likely be more information available from ICIS-NPDES on major NPDES regulated entities. The list of data that must be electronically collected, managed, and shared with EPA’s ICIS-NPDES is listed in Appendix A to 40 CFR Part 127.

(2)  States must share Single Event Violation (SEV) data with EPA’s ICIS-NPDES except for construction stormwater inspections where the state does not take a formal enforcement action.

(3)  Federal enforcement actions and penalties are entered into the facility record in the ICIS-Air, ICIS-NPDES, and RCRAInfo. This information also is entered into the Integrated Compliance Information System for federal enforcement and compliance data (ICIS FE&C). Reports shown on this Web site display both pieces of information when available. In some instances, the same federal enforcement action will not appear in both systems, and in other cases, the same action will be in both systems. ICIS FE&C provides information on a wide range of statutes and programs, but is limited to EPA data only.

(4) Some states voluntarily report data on non-federally reportable CAA regulated sources in their state.

(5) TSDF - Treatment, Storage and Disposal Facility, and LQG - Large Quantity Generator.

(6) SQG - Small Quantity Generator. Data reporting requirements for the other facility types tracked in the Resource Conservation and Recovery Act Information system (RCRAInfo), such as Conditionally Exempt Small Quantity Generators and Transporters, are similar to the requirements for SQGs.

(7) Full Compliance Evaluations (FCEs) (which typically include an on-site inspection) are required to be reported, while Partial Compliance Evaluations (PCEs) are not, unless the PCE was conducted as part of a negotiated CAA Compliance Monitoring Strategy (CMS) plan.

(8) Full compliance evaluations conducted, notices of violation issued, formal enforcement actions issued, and penalties assessed at federally-reportable minor sources are required to be reported.

(9) States and EPA Regions are required to enter the compliance status per regulated pollutant(s) within an air program for each federally-reportable facility evaluated. EPA analysis shows that data quality problems exist regarding facility compliance status in specific states. EPA is working with the states on these issues. In addition, the results of stack tests and Annual Title V Compliance Certification reviews are required.

(10) The CAA requires that sources report activities, such as emission/stack tests, annual compliance certifications, periodic monitoring reports, etc. These reports may be used by the permitting authority to determine compliance, and their receipt and review are often used to determine compliance. Self-reported violations would also be required to be reported at federally-reportable minor sources. See March 22, 2010 EPA memo "Clarification Regarding Federally-Reportable Violations for Clean Air Act Stationary Sources" (PDF) (17 pp, 5.3M, About PDF).

(11) RCRAInfo contains violations of federal RCRA regulations and statutes as well as violations of states' hazardous waste management programs, which may be broader in scope or more stringent than the federal RCRA Subtitle C program.

(12) Synthetic Minors (SMs) are potentially major except limited by special state/federal permits called "synthetic" or Federally Enforceable State Operating Permits (FESOPs).

(13) This universe includes federally-reportable minor sources and other minor sources.

  • Minor sources subject to CAA Part 61-National Emissions Standards for Hazardous Air Pollutant Standards (NESHAPs); and,
  • Minor sources that are the subject of a formal enforcement action, part of a CMS plan, or have an active HPV.

See the March 22, 2010 EPA memo "Clarification Regarding Federally-Reportable Violations for Clean Air Act Stationary Sources" (PDF) (17 pp, 5.3M, About PDF). Minor sources with formal enforcement actions are tracked in ICIS-Air until the resolution of the violation.

(14) SNC stands for Significant Noncompliance and is used for CWA and RCRA. HPV stands for High Priority Violation and is used for CAA. Note that CWA minors that have SNC-level Violations are shown in ECHO as "Category I" violators. For SDWA, EPA determines serious violators based on a point system explained in the Enforcement Response Policy.

(15) If an emissions violation occurred for a pollutant, "synthetically limited" below a major source threshold by a federally enforceable permit then the HPV Policy would apply.

(16) The HPV policy normally does not apply to minor sources but may if added by an agency as a "Discretionary" HPV.

(17) The majority of compliance monitoring under SDWA for Public Water Systems consists of the primacy agency comparing a PWS's sample analysis with maximum contaminant levels established by the National Primary Drinking Water Regulations. In addition, primacy agencies are required to conduct and report sanitary surveys (on-site review) of PWS's water source, facilities, equipment, operation and maintenance.  Eight areas are evaluated for compliance: water sources; treatment; distribution systems; finished water storage; pumps, pump facilities and controls; monitoring, reporting and data verification; water system management and operations; and operator compliance with state requirements.

Other Notes
EPA maintains a list of known data quality problems. To check whether there are known issues within particular states in regard to populating this information, please refer to these links on the ECHO page. The State Review Framework program evaluation reports may also contain information about data quality within particular states. Typically, the authorized authority is either the state, EPA, tribal, or local government. In most cases, the state is the authorized authority. The authorized authority is primarily responsible for maintaining an inventory of regulated sources and doing core inspection, violation tracking and enforcement work. However, EPA may also conduct activities within states, so this table shows what data entry requirements EPA has for activities it performs in the states.
Acronyms - For a list of acronyms used on ECHO, see Acronyms.

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