Known Data Problems
On this page:
- Data Alerts
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:
- About the Data
- The State Review Framework Recommendations Report provides state-by-state findings based on regular, comprehensive state reviews. For the Recommendations Report, search for a state and statute to see all recommendations - data quality concerns tend to be addressed under element numbers 1-3.
- Comments provided by states during an annual data verification process are posted on the State Comments on Frozen Data page.
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 (email@example.com) or by using the Contact Us form.
For other issues:
- To report errors on a particular facility report, please use the error correction process.
- For problems with the functioning of the website itself, see the Website Known Issues page.
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.
|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 February 2018)|
|New Mexico||New Mexico is conducting ongoing review and research concerning resolution of errors resulting in incorrect FCE due dates. New Mexico will calculate FCE due dates and frequencies using the applicable CMS schedule based on the most recent FCE date and current facility classification until the problem is resolved. (Updated June 2022)|
|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 March 2020)|
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 2025 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 April 2022)
NPDES Noncompliance Report (NNCR)
DMR Reporting Violation (violation detection codes) - When toxicity parameters are reported to the data system under a different permitted feature than non-toxicity parameters (e.g., 001 and TX1), it is not possible to accurately detect DMR reporting violations. The evaluation for an entire DMR form missing is based on the permitted feature number and situations where all DMR values for a permitted feature are not reported under the same permitted feature, correct evaluation for an entire or partial DMR form missing must be confirmed manually. This affects the detection descriptions DMR Reporting (Entire) - No Data, DMR Report (Entire) - NODI, DMR Reporting (Partial) - No Data, and DMR Reporting (Partial) - NODI. (Updated February 2023)
For FY2021Q1, effluent violations can have a detection date after the resolution date. For example, an effluent exceedance violations with a monitoring period end date of October 2020 has a detection date of 12/31/20. If the violation is linked to a formal enforcement action with a compliance schedule that has a NPDES Closed Date in November 2020, the resolution date (November 2020) is before the resolution date (December 2020). (Updated February 2023)
|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)|
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:
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:
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)
|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 exceedance violations to appear when they may not be entirely accurate. Indiana issued a NPDES general permit that covers construction stormwater operators on December 18, 2021. Prior to this date, IDEM identified over 8,000 construction stormwater permits as individual NPDES permits in EPA's national NPDES data system, which supplies data to ECHO. IDEM is steadily terminating these individual NPDES permit records in EPA's national NPDES data system as they provide coverage under the December 2021 NPDES general permit. IDEM estimates that over the next five years all of the 8,000 individual NPDES permit records in EPA's national NPDES data system will be terminated with some records replaced by coverages under the December 2021 NPDES general permit. (Updated June 2022)|
The 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)
Iowa currently has missing data identified on the e-reporting dashboard. However, most of this data is not missing, rather it is the result of challenges with synchronizations of data between Iowa's NPDES permitting system and ICIS-NPDES. As Iowa works through the system changes necessary to accommodate the eReporting rule implementation, accurate reporting to eliminate the missing data is expected to be addressed. (Last updated: August 5, 2021)
Iowa currently has not identified most of the combined sewer overflow outfalls that they permit in EPA's ICIS-NPDES. This means that these outfalls are not included in the National Combined Sewer Overflow Inventory. EPA is actively working with Iowa DNR to resolve this data sharing issue. (Last updated: September 5, 2023)
|Kansas||Primary Data Alert: Kansas and EPA are reviewing non-major 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)|
|Michigan||Michigan's Department of Environment, Great Lakes, and Energy’s (EGLE) data discrepancies between ECHO and the State’s data system, MiEnviro, have several underlying causes as detailed below. Michigan considers the MiEnviro system the most accurate reflection of facility compliance status. Discrepancies can occur in data flow to ECHO when permits are superseded by different permit types, when violations are addressed through State compliance and enforcement actions, and with duplicate schedules of compliance. In addition, Combined Sewer Overflow features do not necessarily provide a complete or accurate representation for each outfall due to categorical differences. Some permits in the Michigan’s permit backlog have yet to be reissued in MiEnviro and data discrepancies will continue for those sites until the permit can be reissued in MiEnviro. Users should verify compliance status in MiEnviro at (https://mienviro.michigan.gov/ncore/external/home) prior to using it for any intended purpose. (updated October 2023)|
|Minnesota||Primary Data Alert: The Minnesota Pollution Control Agency (MPCA) has made all reasonable effort to verify and correct the data presented. This is done by ensuring that the data contained in the respective EPA program systems, ICIS-NPDES, RCRAInfo and AFS are in agreement with the Tempo data system maintained by the MPCA as an 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 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. The MPCA is in the process of implementing an ICIS-NPDES data flow to accurately represent the MPCA's collected eReporting rule required data into ICIS-NPDES. Until the MPCA's ICIS-NPDES data flow is fully implemented, the information presented through the dashboard will not be complete, current and/or accurate. For complete and current information on regulated parties in Minnesota, the MPCA suggests that data be accessed through our What’s in my Neighborhood website Exit and/or Wastewater Data Browser Exit. (Updated 5/3/2022)|
|Missouri||Primary Data Alert: 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. (Last updated: July 8, 2021)|
|Nebraska||Nebraska'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)|
EPA copied New Jersey's NPDES program data from EPA's previous NPDES data system (PCS) to EPA's current NPDES data system (ICIS-NPDES) on November 29, 2012. This allowed users to see the list of regulated facilities and associated historical activities; however, subsequent state activities were not updated in ICIS-NPDES until March 2018.
New Jersey has been reporting NPDES program data into EPA's current NPDES data system (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) dating back to January 1, 2011. Further, for non-major facilities and general permits, the database contains the following State-populated data:
The limitations identified above will impact a user’s ability to download historical information. (Updated June 2023)
|North Carolina||Primary 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)|
Primary 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)
Ohio has not identified some (approximately 10%) of the combined sewer overflow outfalls that they permit in EPA's ICIS-NPDES. This means that these outfalls are not included in the National Combined Sewer Overflow Inventory. EPA is actively working with Ohio EPA to resolve this data sharing issue. (Last updated: September 5, 2023)
ICIS-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)
The Oregon Department of Environmental Quality uses NetDMR to collect Discharge Monitoring Report data for >95% of their individually permitted facilities and has moved on to working on the General Permitted facilities. If ECHO users have questions or concerns, please contact Jim Billings, ICIS-NPDES Data Steward at Billings.Jim@deq.state.or.us. (Last updated: July 28, 2021)
|Pennsylvania||Primary Data Alert: Please note that the discharge monitoring and basic permit information for some of Pennsylvania’s general permits for industrial stormwater (PAG-03 permits) is not correctly transferring into EPA’s ICIS-NPDES system. Therefore, some facilities may be incorrectly flagged as unsubmitted/non-compliant in ECHO reports. Pennsylvania is working with EPA to correct the basic permit information in the ICIS-NPDES system. Once those corrections are made, the discharge monitoring information will be transferred to ICIS-NPDES and the facilities that submitted their reports to Pennsylvania on time will return to compliance. (Updated July 2023).|
|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)|
The following caveat is noted for permits with pH limitation using three different pH parameters:
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:
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)
|Washington||Primary 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 Virginia||Primary Data Alert: The West Virginia Department of Environmental Protection (WVDEP) has been working towards full implementation of the NPDES Electronic Reporting Rule. Although WVDEP is making progress and set up new data flows, WVDEP’s data flow to 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 E-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. (Last updated: July 28, 2021)|
|Wisconsin||Primary Data Alert: Wisconsin began requiring all NPDES individual permit holders to submit e-reporting of DMRs to the state’s NPDES permit compliance database prior to the implementation of the E-Reporting Rule. The percentage of “Unresolved DMRs” indicated on ECHO may be due more the challenges associated with uploading DMR data from the state database to ICIS-NPDES and the differences between the two systems and less with actual missing DMR data. Wisconsin continues to work through issues associated with the data transfer and intends to make necessary adjustments, especially as changes to ICIS-NPDES occur to fully implement the E-Reporting Rule. Until then, data discrepancies should be mostly resolved on a quarterly basis in line with the EPA permit non-compliance determination processing. (Last updated: July 28, 2021)|
|Wyoming||Primary 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)|
|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 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)|
|General||Primary 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.|
|Washington||A 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)|