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Michigan RCRA Data
Data from the Michigan Department of Environmental Quality (MDEQ) to EPA for the Resource Conservation and Recovery Act (RCRA), Subtitle C program, specifically hazardous waste and used oil, is not current for compliance and enforcement data. Due to changes by EPA in the data translation procedures, MDEQ has not translated the compliance and enforcement data since May 5, 2006, while the translation program is re-written. Consequently, evaluations, violation, and compliance action data that can be viewed on the MDEQ web page (http://www.deq.state.mi.us/WDSPI/) will not be available on ECHO until fiscal year 2009. Also, any corrections made to the MDEQ database will not be displayed on ECHO before that time. However, handler (site) data is translated monthly from MDEQ into the EPA national program database, RCRAInfo, which then populates ECHO.

Clean Air Act Compliance Status and Violations
ECHO provides a High Priority Violator flag that signals when more serious compliance problems have been identified. This on/off flag does not provide details about alleged violations. However, ECHO also provides violation/compliance status data, which provides some detail about the nature of alleged violations. Violation status data should always be reported when a High Priority Violator determination is made, and should also be reported for many violations that do not rise to the level of High Priority Violations. It is possible for specific violations to be resolved (ended) while the High Priority Flag remains on. EPA's review of the data in ECHO indicates that the High Priority Violator flag is normally reported by states. EPA's review of the violation status data, namely the CAA subprogram violated and the pollutant in violation, indicates that errors of omission exist in many states. These errors of omission could leave the ECHO user with the impression that a facility has no violations, when in fact, violations have been determined. The information below is provided to inform ECHO data users about whether to expect to see violation status data in ECHO reports. Violation data appear to be missing or incomplete in AK, AZ, CA, FL, HI, LA, ME, MI, MT, NE, NJ, NM, NV, TX, WA, WY. The following states/territories report a limited amount of violation data: AL, CO, CT, ID, IL, IN, MA, MN, MO, NH, OR, RI, TN, UT, VA. The following states/territories report some violation data: AR, DE, GA, KY, MD, NC, OH, SD, WV. The following states/territories frequently report violations: IA, MS, NY, OK, PA, PR, SC, WI. Due to a small number of regulated sources, EPA's analysis for DC, KS, ND, VI, VT was inconclusive in regard to violation reporting. EPA is working with the states to improve the consistency of reporting CAA violations. ECHO users interested in CAA violation data within a state that infrequently reports CAA violation status to EPA's national database may consider researching other available information (for example, state Web sites or state-published information). (Based on FY2007 data.)

Vermont CWA Data
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

Oregon CWA Data
U.S. EPA provided compliance updates to the Permit Compliance System (PCS) until August 2004. The Oregon Department of Environmental Quality (DEQ) resumed compliance data entry for PCS in March 2009. This note describes possible idiosyncrasies of the ECHO PCS facility reports for certain Oregon major facilities as a result of this transition for over four years.

While Oregon DEQ was updating PCS from August 2004 to March 2009, EPA placed the "U(Undtrm)" code on the "SNC/RNC Status" line for each of the affected quarters. This undetermined status coding will remain unchanged for PCS data before the first quarter of the federal fiscal year 2008 (October-December 2007 or "QTR1 Oct-Dec07"). The U(Undtrm) code is locked (cannot be changed) in PCS for quarters prior to the first quarter of 2008.

The Significant Non-Compliance (SNC)/Reportable Non-Compliance (RNC) status for this facility is displayed as undetermined for the ECHO Detailed Facility Report only. In other words, it may appear in the facility report that the facility had undetermined compliance prior to first quarter of 2008. However, Oregon DEQ was performing compliance and enforcement for this facility before/during/after this period although this report may indicate undetermined SNC/RNC status prior to the first quarter of 2008. Also, the Envirofacts Detailed Report in the Measurements and Violations section shows accurate compliance and enforcement details for all PCS data despite the ECHO SNC/RNC Status line indicating undetermined compliance.

Please check the Envirofacts Detailed Report in the Measurements and Violations section. The links to the Detailed Reports for all affected facilities are listed here (pdf, 69KB, 2pp). If you have additional questions about the Oregon PCS facility reports or facility compliance and enforcement, please contact the Oregon Data Steward, Jim Billings, at 503-229-5073 or Billings.Jim@DEQ.state.or.us.

Michigan CWA Data
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 were not codable. EPA is working with the state to correct this situation.

This page is intended to provide information on broad-scale data issues that may impact the completeness, timeliness, or accuracy of data shown in ECHO. For other data quality issues, please see the Known Data Problems section.

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