Known Data Problems

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Overview

EPA manages many national information systems with data flowing from EPA and state/tribal/local agencies. These data streams arrive into national systems in many ways. For example, some jurisdictions maintain their own databases and upload their datasets into EPA's systems, while others directly enter information into EPA systems. Given the complexity of transactions, occasional problems occur with the migration of data into national systems. This page lists known data quality problems with larger sets of data. Concerns have been identified by EPA or state/local environmental agency staff.

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 complexities described above.

Additional data quality information may be available:

Submit a Known Data Problems update:

To correct, update, or clarify an existing known data problem or submit a new issue, EPA and state/local agencies can send information and language to Scott Fontenot (fontenot.scott@epa.gov) or by using the Contact Us form.

For other issues:

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Data Alerts

Known data problems are described in program-specific sections below. EPA and/or the state/local agencies that report data to EPA also have identified some data problems that have a broad impact on the completeness, timeliness, and/or accuracy of data shown in ECHO. These issues are noted as Primary Data Alerts within the program-specific sections.

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Clean Air Act (CAA) Alerts

LouisianaIn 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 February 2018)
New YorkECHO 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 March 2020)

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Clean Water Act (CWA) Alerts

General

Penalty Data - Prior the 2015 NPDES Electronic Reporting Rule (40 CFR 127), it was not a requirement that penalty data be reported to the national system. The rule requires authorized states and EPA Regions to share basic information regarding enforcement actions. This includes the type of enforcement action, information specific to final orders (administrative or judicial), penalty information, information regarding permit schedules or compliance schedules, and information regarding milestones or sub-activities identified in permit schedules or compliance schedules. States are now working to improve this data sharing with EPA. (Updated February 2018)

Single-Event Violations - Single-Event Violations (SEVs) include one-time events as well as violations with longer durations. These are violations that are generally not automatically flagged by the data system (e.g., inspection identified violations, sewer overflow, spill of industrial waste, discharges without a NPDES permit). These violation determinations are often manually generated by the authorized NPDES program, as opposed to violations that can be system created or generated (e.g., effluent exceedances of permit limits are automatically flagged by ICIS-NPDES). The 2015 NPDES Electronic Reporting Rule (40 CFR 127) requires authorized states and EPA Regions to share SEV data on all facilities (major and non-major). However, this requirement does not include SEV data generated from construction stormwater inspections where the regulatory authority did not take a formal enforcement action. As noted in preamble to the final rule, EPA made this distinction based on the large number of facilities in this segment of the NPDES universe (approximately 200,000 new construction sites each year). See 22 October 2015; 80 FR 64079. Prior to the NPDES eRule, states only had to share data on SEVs from majors. Historically, SEV data sharing varies widely by state. States are now working to improve this data sharing with EPA. (Updated February 2018)

Effluent Exceedance Violation - For effluent violations on Discharge Monitoring Reports (DMRs), the National Pollution Discharge Elimination System Integrated Compliance and Information System (ICIS-NPDES) determines effluent exceedance violations and calculates the percent the DMR reported value exceeded the permit limit. At times, the percent exceedance calculated is 2,147,483,650 or 99,999 percent but the Detailed Facility Report will display "LIMIT VIOLATION" because these values are not representative of the actual measured percent exceedance and should not be interpreted this way. These data no longer appear on ECHO reports; users of the full downloadable datasets should be aware of this issue. (Updated December 2018)

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. (Updated February 2018)

Universe Data - The 2015 NPDES Electronic Reporting Rule (40 CFR 127) requires authorized states and EPA Regions to share basic facility information on all NPDES-permitted facilities. This data sharing is being phased in over time. In particular, states have until December 2020 to start collecting and sharing data on general permit covered facilities with EPA. During this implementation period, EPA’s national NPDES data system (ICIS-NPDES) will not have data on the entire universe of NPDES regulated facilities. (Updated February 2018)
Arizona

Primary Data Alert: Due to data migration issues between Arizona’s water quality compliance tracking database and EPA’s program data system (ICIS-NPDES), there may be data quality errors between November 2012 and July 2015. If you feel the compliance data is in error, please contact ADEQ at 602-771-4623. (Updated January 2017)

During federal FY08, ADEQ did not populate EPA's Permit Compliance System (PCS) database with enforcement information. This means that fiscal year 2008 information about compliance and enforcement in Arizona is not available in national databases or the ECHO website. These data no longer appear on ECHO reports; users of the full downloadable datasets should be aware of this issue. (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 stormwater violations under the CWA. (Arizona reported July 2009)
Delaware

Delaware has two facilities that still have the issue outlined below (parameter code 82581 and 82582). Delaware is working to resolve the issue but has not indicated a timetable.

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. ​These data no longer appear on ECHO reports; users of the full downloadable datasets should be aware of this issue. (Updated March 2020)
IndianaThe 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 exceedance violations to appear when they may not be entirely accurate. (Updated October 2017)
IowaThe Iowa Department of Natural Resources continues to work with EPA to address issues with the transfer of data from the state system to ICIS-NPDES. Due to these data transfer issues, the facility compliance status in ECHO may not be accurate. Specifically, facilities may erroneously appear to be in significant noncompliance for failure to submit DMRs or failure to meet compliance schedule milestones. ECHO users are encouraged to contact the Iowa Department of Natural Resources to verify the compliance status of a facility prior to taking action based upon the data obtained from ECHO. (Updated September 2020)
KansasPrimary Data Alert: 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 reporting, quarterly reporting, etc.) for some permits may make permittees appear out of compliance after the data transfer from their state system to ICIS-NPDES. ECHO Users should verify all data with Kansas Department of Health and Environment (KDHE) Exitprior to using it for any intended purpose. KDHE and EPA are working to resolve the issue. (Updated October 2017)
MichiganThe State of Michigan is experiencing issues affecting the transfer of data from the state database (MiWaters) to the federal database (ICIS-NPDES). Facility compliance status and discharge monitoring report and data displayed on ECHO may not be accurate especially for those permits issued prior August 2015. Specifically, facilities may appear to be in noncompliance for failing to submit required discharge monitoring reports and/or results for specific parameters, which may or may not be the case. The State of Michigan is actively working to resolve the issues. (Updated March 2018)
MissouriPrimary Data Alert: Facilities appear in ECHO to be in noncompliance for failing to submit expected Discharge Monitoring Reports (DMRs) and/or Programmatic Reports, which may or may not be accurate. Users should verify this data for accuracy with Missouri Department of Natural Resources (DNR) before using it for any intended purpose. Missouri DNR and EPA are continuing to work to resolve all data integrity issue. (Updated September 2020)
NebraskaNebraska's CWA data problem is related to facilities appearing in ECHO as noncompliant for failing to submit expected DMRs, which may or may not be the case. The state agency is working with EPA to resolve this issue. (Posted March 2019)
New Jersey

New Jersey has been reporting data into the national system of record (ICIS-NPDES) since March 2018. Please be advised that, for major facilities, the database only contains State-populated NPDES information (e.g. permit, DMR, State-issued formal enforcement action and inspections, etc…) dating back to January 1, 2011. Further, for minor facilities and general permits, the database contains the following State-populated data:

  • NPDES permit information dating back to the permits that were in effect as of February 20, 2018,
  • NPDES DMR data dating back to January 1, 2017 for the permits that were in effect as of February 20, 2018,
  • State-issued formal enforcements actions, associated with the permits that were in effect as of February 20, 2018, that only impacted effluent limitations,
  • State-issued formal and informal enforcement action and inspection data, as well as compliance schedule data, subsequent to March 2018.
The limitations identified above will impact a user’s ability to download historical information. (Updated September 2020)
North CarolinaPrimary Data Alert: North Carolina is experiencing issues affecting the upload of data to the national program system ICIS that may cause NPDES-permitted facilities to erroneously be displayed in ECHO as being noncompliant for incomplete or deficient parameter reporting, or for failing to report data for entire outfalls. North Carolina is actively pursuing technical and programmatic solutions to resolve these problems. In the meantime, users are encouraged to contact the North Carolina Division of Water Resources Exitto verify the compliance status of the state’s permitted facilities prior to taking any action based upon their depiction in ECHO. Please see North Carolina Data Alert Text (PDF) (2 pp, 1088K, About PDF) for more detailed information. (Posted August 2017)
OhioPrimary Data Alert: The Ohio Environmental Protection Agency (OEPA) continues to work with EPA to address issues with the transfer of data from the state system to ICIS-NPDES. Due to these data transfer issues, the facility compliance status in ECHO may not be accurate. Specifically, facilities may erroneously appear to be in significant noncompliance for failure to submit DMRs or failure to meet compliance schedule milestones. ECHO users are encouraged to contact the OEPA to verify the compliance status of a facility prior to taking action based upon the data obtained from ECHO. (Updated November 2020)
OregonICIS-NPDES (national program system) data for Oregon is accurate according to state databases, with the exception of actual inspection dates for stormwater permits. (Updated September 2020)
PennsylvaniaPrimary Data Alert: Please note that some of Pennsylvania’s current discharge monitoring and compliance data is not correctly transferring into EPA’s ICIS-NPDES system. Therefore, some facilities may be incorrectly flagged as non-compliant in ECHO reports. Pennsylvania and EPA are working together on a resolution to the data transfer issue. The Pennsylvania Department of Environmental Protection (PADEP) may have additional information on activities and compliance determinations on its website - see links to PADEP wastewater reports.EXIT(Updated September 2020)
Vermont

Primary Data Alert: Vermont began flowing data to the national program system ICIS-NPDES in September 2012; however, the discharge monitoring reports from Vermont facilities prior to September 2012 are not available in ICIS-NPDES. The monitoring data was not entered into the legacy data system as expected prior to the migration of the VT data to ICIS-NPDES. Due to this incomplete data at the time of migration, some Vermont facilities appear to be in noncompliance for failing to submit discharge monitoring reports when in fact they are in compliance. 02/03/2017 addition: Some errors may be seen due to communication problems between the state data system and ICIS-NPDES. Vermont is working on upgrading its system to meet NPDES eReporting Rule requirements. If you have questions, please contact Mari Cato (Mari.Cato@vermont.gov). (Updated February 2017)

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. PCS contained a significant number of Discharge Monitoring Report non-receipt violations for Vermont. State records confirmed 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 were often listed erroneously because of the lag time between receipt and data entry. These data no longer appear on ECHO reports; users of the full downloadable datasets should be aware of this issue. (Updated October 2011)
Virginia

The following caveat is noted for permits with pH limitation using three different pH parameters:

  1. parameter code 00400 - pH with a limit of 6.0 to 9.0 standard units;
  2. parameter code 72107 – length of longest pH excursion (limited with a maximum of 60 minutes);
  3. parameter code 82582 - pH range excursions, monthly total accumulation (limited with a maximum of 446 minutes)

These three parameters are used when continuous pH monitoring is required in a permit and are allowed as per 40 CFR § 401.17, which states that 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 72107).
The pH limit of 6.0 to 9.0 can be exceeded (or in certain permit cases, not exceeding 4.0 -11.0) in an effluent without violating the permit if it is not outside the range for more than 60 minutes at any one time or for more than seven hours and 26 minutes (446 minutes) for the monthly total. (Updated September 2020)
WashingtonPrimary Data Alert: A large 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. Washington State is not currently transferring permitting data into the EPA program system due to technical system issues. Washington’s Department of Ecology is actively working to resolve the issue. Users should verify these data with Washington Ecology via the PARIS permit database Exit prior to using it for any intended purpose. (Updated May 2021)
West VirginiaPrimary Data Alert: The West Virginia Department of Environmental Protection (WVDEP) has been working toward full implementation of the Clean Water Act NPDES Electronic Reporting Rule. Although WVDEP is making progress and set up new data flows, WVDEP’s data flow to the national program system, ICIS-NPDES, is still undergoing development and testing. Until this is complete, there may be errors causing facilities to be flagged as Significant/Reportable Noncompliers in EPA’s public system. WVDEP and EPA are working together on a regular basis to correct these issues to fully meet the requirements of EPA’s electronic reporting rule and ensure the accuracy of facility noncompliance reporting in the public systems. Until this work is complete, West Virginia’s state database includes the most accurate information. If you would like more information, please contact Peggy Kozak (Peggy.J.Kozak@wv.gov) for routing to the appropriate WVDEP staff member. (Updated October 2020)
WisconsinPrimary Data Alert: Wisconsin is experiencing issues affecting the upload of data to the national program system ICIS-NPDES. Discharge Monitoring Report and facility compliance status data displayed on ECHO may not be accurate. Specifically, facilities may appear to be in noncompliance for failing to submit required discharge monitoring reports, which may or may not be the case. Wisconsin is actively working to resolve the issue. ECHO users are encouraged to contact the Wisconsin Department of Natural Resources to verify the compliance status of a facility prior to taking action based upon the data obtained from ECHO. (Updated March 2020)
WyomingPrimary Data Alert: Wyoming is experiencing issues affecting the upload of data to the national program system ICIS. Discharge Monitoring Report and facility compliance status data displayed on ECHO may not be accurate. Specifically, facilities may appear to be in noncompliance for failing to submit required discharge monitoring reports, which may or may not be the case. Wyoming is actively working to resolve the issue. (Updated October 2017)

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Resource Conservation and Recovery Act (RCRA) Alerts

GeneralClosed/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.
CaliforniaRegulation of hazardous waste in California is a partnership between federal, state, and local agencies. TSDFs are regulated by the California Department of Toxic Substances Control (the state). If a TSDF is also an LQG, the LQG portion is regulated by the state and the local agency.  LQGs and SQGs are regulated by 81 local agencies, doing thousands of inspections per year. Data for RCRA inspections, violation, and enforcement actions conducted by USEPA Region 9 and the California Department of Toxic Substances Control are fully loaded to RCRAInfo (and so displayed in ECHO). Data from the local agencies is not fully loaded. For the full story, please review both ECHO and the CalEPA Regulated Site portal. For information about manifests in California, please see the Hazardous Waste Tracking System. For businesses wishing to correct their data in ECHO, please use the “report an error” button from the page depicting the data in question. (Updated February 2021)

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Safe Drinking Water Act (SDWA) Alerts

GeneralPrimary Data Alert: 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.
WashingtonA small number of water systems appear in ECHO to be in noncompliance for failing to monitor or report, which may or may not be the case. Users should verify these data with Washington State Department of Health prior to using it for any intended purpose. The Department is actively working to resolve the issue. (Posted January 2018)

 

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