Known Data Problems

Known Data Problems

Overview | Air | Water | Hazardous Waste

Overview

EPA manages a series of national information systems that include data flowing from staff in both 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 to EPA that EPA then 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 by state. Where analysis indicates that the data was 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 that is included in the national enforcement and compliance databases. This effort includes close coordination with states on issues of data transfer, entry, and presentation. EPA and the states engaged in an intensive eight-month data quality review period prior to the release of the ECHO site. 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. ECHO documentation includes information on the quality of the data shown on ECHO, as well as information on random audit results.

Information regarding concerns identified below are based on a combination of sources:

Comprehensive EPA review of state (and in some cases, local) data done at least every three years on a rolling basis;

Annual analysis of data in national systems; and/or

Anecdotal information from state and EPA staff.

Acronyms used:


FY	Federal Fiscal Year

PCS	Permit Compliance System - Clean Water Act direct discharge data

ICIS-NPDES	Integrated Compliance Information System for NPDES data - Clean Water Act direct discharge data (modernized system)

AFS	Air Facility System - Clean Air Act Stationary Source data

RCRAInfo	RCRA - hazardous waste data

CAA	Clean Air Act

CWA	Clean Water Act

NPDES	National Pollutant Discharge Elimination System (under CWA)

RCRA	Resource Conservation and Recovery Act

HPV	High Priority Violator (CAA program)

SNC	Significant Noncompliance (CWA/RCRA programs)

DMR	Discharge Monitoring Report (CWA program)

To report large-scale problems with data, email donohue.allison@epa.gov. For errors on a particular facility report, please use the error correction process.

Please note that "real-time" data are not presented on this site. Although the information is updated every month, the lag time for data to become available on the Web site varies depending on the data system, activity, and negotiated reporting cycle. For example, an inherent lag time exists between the date an inspection is performed, the entry of the inspection into the state database, the uploading of data from the state to EPA, and the posting of data on the site. In some situations, data will enter the system quickly, in other circumstances the lag time may be 2-3 months.

Air

General	-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. -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.)

Alaska	An EPA comprehensive state review of FY03 and FY04 data occurred in April 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Alabama	Based on July 2007 annual analysis of FY04-06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Arizona	An EPA comprehensive state review of FY03 data occurred in February 2005. Based on August 2007 annual analysis of FY05-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Arkansas	An EPA comprehensive state review of FY05 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

California	EPA's comprehensive state and locality data review is expected to be completed by September 2007. Based on August 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Colorado	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Connecticut	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Delaware	An EPA comprehensive state review of FY05 data occurred in January 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

District of Columbia	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Florida	Based on July 2007 annual analysis of FY04-06 national system data, minor violations that occur at facilities are not reported to the national system. However, all High Priority Violations are reported to the system by the state. Based on the analysis, EPA believes this continues for FY07 data.

Georgia	An EPA comprehensive state review of FY04 data occurred in December 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Hawaii	EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Idaho	An EPA comprehensive state review of FY03 and FY04 data occurred in September 2006. Based on August 2007 annual analysis of FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Illinois	Based on July 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Indiana	-Based on September 2006 EPA comprehensive state data review of FY05 data, some violations that occur at facilities were not reported to the national system. Based on July 2007 annual analysis of FY04-FY06 national system data, EPA believes this also was true for FY04 and FY06 data. This means that some violations that occurred in FY04-06 will not appear on ECHO. -Based on September 2006 EPA comprehensive state data review of FY05 data, Indiana does not always report its High Priority Violation data within the time frame recommended by EPA policy. Based on July 2007 annual analysis of national system data, EPA believes this applies to FY06 data, as well. This means that the state may have identified HPVs that are not yet appearing on ECHO. -Based on September 2006 EPA comprehensive state data review of FY05 data, Indiana did not report all its enforcement actions in FY05. This means that the state may taken actions in FY05 that do not appear on ECHO. -Based on September 2006 EPA comprehensive state data review of FY05 data, Indiana did not accurately report penalty amounts in FY05. This means that the state may have assessed penalties in FY05 that do not appear on ECHO.

Iowa	An EPA comprehensive state review of FY05 data occurred in February 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Kansas	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Kentucky	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Louisiana	-EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data. -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.

Maine	EPA comprehensive state data review expected to be completed by September 2007. Based on March 2007 annual analysis of FY04-06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Maryland	An EPA comprehensive state review of FY04 data occurred in January 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Massachusetts	An EPA comprehensive state review of FY05 data occurred in October 2006. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Michigan	An EPA comprehensive state review of FY03 data occurred in February 2005. Based on July 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Minnesota	EPA comprehensive state data review expected to be completed by September 2007. Based on July 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

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.

Missouri	An EPA comprehensive state review of FY03 data occurred in January 2005. Based on August 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Montana	EPA comprehensive state data review expected to be completed by September 2007. Based on August 2007 annual analysis of FY04-06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Nebraska	EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Nevada	EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

New Hampshire	-Based on March 2007 annual analysis of FY04-06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data. -Based on September 2006 EPA comprehensive state data review of FY04 data, New Hampshire does not always report its High Priority Violation data within the time frame recommended by EPA policy. This means that the state may have identified HPVs that are not yet appearing on ECHO. Based on March 2007 annual analysis of national system data, EPA believes this continues for FY05-FY06 data. -Based on September 2006 EPA comprehensive state data review of FY04 data, most FY04 penalty data was not reported to the national system. The problem has been corrected in subsequent years.

New Jersey	Based on November 2004 EPA comprehensive state data review of FY03 data, some violations that occur at facilities are not reported to the national system. Based on March 2007 annual analysis of national system data, EPA believes this continues for FY05-FY07 data.

New Mexico	An EPA comprehensive state review of FY04 data occurred in September 2006. Based on August 2007 annual analysis of FY04-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

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. Based on September 2006 EPA comprehensive state data review of FY04 data, 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. -Based on September 2006 EPA comprehensive state data review of FY04 data, some New York compliance information is inaccurate – violation end dates may not be entered into the national system in a timely manner, therefore creating the appearance that some facilities’ violations continue for a longer period of time than they actually do. Based on March 2007 annual analysis of national system data, EPA believes this continues for FY05-FY07 data.

North Carolina	An EPA comprehensive state review of FY04 data occurred in December 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

North Dakota	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Ohio	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Oklahoma	An EPA comprehensive state review of FY03 data occurred in October 2004. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Oregon	EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of national system data, some violations that occurred at facilities were not reported to the national system in FY04 and FY06. This information is subject to change based on the comprehensive state data review.

Pennsylvania	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Puerto Rico	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Rhode Island	An EPA comprehensive state review of FY03 data occurred in March 2005. Based on March 2007 annual analysis of FY04-06 national system data, some violations that occurred at facilities were not reported to the national system. EPA does not know whether this continues in FY07.

South Carolina	An EPA comprehensive state review of FY03 data occurred in 2004. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

South Dakota	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Tennessee	Based on July 2007 annual analysis of FY04-06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Texas	-EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of FY05-FY06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data. -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.

Utah	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Vermont	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Virginia	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Virgin Islands	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Washington	EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of national system data, some violations that occurred at facilities were not reported to the national system in FY04 and FY06. Based on the analysis, EPA believes this continues for FY07 data. This information is subject to change based on the comprehensive state data review.

West Virginia	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Wisconsin	Based on September 2006 EPA comprehensive state data review of FY04, Wisconsin does not always report its High Priority Violation data within the time frame recommended by EPA policy. Based on July 2007 annual analysis of national system data, EPA believes this applies to FY06 data, as well. This means that the state may have identified HPVs that are not yet appearing on ECHO.

Wyoming	EPA comprehensive state data review expected to be completed by September 2007. Based on August 2007 annual analysis of FY04-06 national system data, some violations that occur at facilities are not reported to the national system. Based on the analysis, EPA believes this continues for FY07 data.

Water

General	Penalty Data - As of August 2007 annual analysis of FY04-FY07 national system data, most states do not report penalty data to the national system. It is not an EPA requirement that this 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. 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, 48KB) 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.

Alaska	An EPA comprehensive state review of FY03 data occurred in April 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Alabama	-An EPA comprehensive state review of FY05 data occurred in January 2007. -In Alabama, PCS contains a significant volume 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.

Arizona	-An EPA comprehensive state review of FY03 data occurred in February 2005. -Arizona does not show enforcement action data. EPA believes a data entry problem exists and is working on a resolution. -Arizona Reported on 7/2/09 - 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 on 7/2/09 - 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.

Arkansas	An EPA comprehensive state review of FY05 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

California	-EPA's comprehensive state data review is expected to be completed by September 2007. -For California, the PCS 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 PCS on a timely basis. Due to the reporting requirements in California, the report due dates exceed that of most states and result in the data system incorrectly identifying late-reporting violations.

Colorado	-EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems. -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.

Connecticut	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Delaware	-An EPA comprehensive state review of FY05 data occurred in January 2007. -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: parameter code 00400- pH with a limit of 6.0 to 9.0 standard units; parameter code 82581- number of excursions greater than 60 minutes at any time; 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.

District of Columbia	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Florida	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Georgia	An EPA comprehensive state review of FY04 data occurred in December 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Hawaii	-EPA's comprehensive state data review is expected to be completed by September 2007. -Hawaii does not show enforcement action data. EPA believes a data entry problem exists and is working on a resolution.

Idaho	An EPA comprehensive state review of FY04 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Illinois	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Indiana	-An EPA comprehensive state review of FY05 data occurred in September 2006. -In the state of Indiana, many non-receipt violations are erroneous and are currently being investigated, with resolution pending.

Iowa	An EPA comprehensive state review of FY05 data occurred in February 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Kansas	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Kentucky	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Louisiana	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Maine	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Maryland	Based on January 2005 EPA comprehensive state review of FY04 data, Maryland does not enter all informal enforcement action data into the national database. This means that many informal notices of violation or letters of violation (considered "informal actions" on ECHO) issued by the state will not be displayed on ECHO.

Massachusetts	Based on September 2006 EPA comprehensive review of FY05 data, due to resource constraints EPA Region 1 enters only higher-level enforcement actions that resolve SNC into the national database for Massachusetts. This means that many Notices of Noncompliance (considered "informal actions" on ECHO) issued in the state will not be displayed on ECHO.

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 were not codable. EPA is working with the state to correct this situation. -Based on February 2005 EPA comprehensive state data review of FY03 data, Michigan was not inputting all of its inspections into PCS. Michigan planned to correct this problem in FY05. This means that the actual number of inspections performed in FY03-05 may be greater than reported on ECHO.

Minnesota	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Mississippi	An EPA comprehensive state review of FY05 data occurred in July 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Missouri	An EPA comprehensive state review of FY03 data occurred in January 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Montana	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Nebraska	An EPA comprehensive state review of FY03 data occurred in January 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Nevada	-EPA's comprehensive state data review is expected to be completed by September 2007. -Nevada does not show informal enforcement action data. EPA believes a data entry problem exists and is working on a resolution.

New Hampshire	An EPA comprehensive state review of FY04 data occurred in September 2006. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

New Jersey	An EPA comprehensive state review of FY03 data occurred in November 2004. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

New Mexico	An EPA comprehensive state review of FY04 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

New York	An EPA comprehensive state review of FY04 data occurred in September 2006. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

North Carolina	An EPA comprehensive state review of FY04 data occurred in December 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

North Dakota	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Ohio	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Oklahoma	An EPA comprehensive state review of FY03 data occurred in October 2004. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Oregon	-EPA's comprehensive state data review is expected to be completed by September 2007. -A number of EPA-authorized CWA NPDES facilities in region 10 do not have up-to-date permit limits entered in PCS. An updated list of the specific facilities will be added at a later date. As a result, violations may be missing or erroneous in the PCS system for some facilities and, consequently, will not be correctly displayed in ECHO. region 10 has refocused PCS data entry for all region 10 states to only those permits where EPA is the permitting authority (Alaska, Idaho, federal and tribal facilities in Washington, and tribal facilities in Oregon). Questions regarding the status of region 10's data management plan should be directed to Kimberly Ogle at 206-553-0955. -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. -Oregon does not show enforcement action data for non-major facilities. EPA has determined that there may be a data entry problem and is working on a resolution.

Pennsylvania	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Puerto Rico	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Rhode Island	An EPA comprehensive state review of FY03 data occurred in March 2005. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

South Carolina	An EPA comprehensive state review of FY03 data occurred in 2004. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

South Dakota	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Tennessee	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Texas	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Utah	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Vermont	-EPA comprehensive state data review expected to be completed by September 2007. -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. Data quality flags are posted on the relevant ECHO Detailed Facility Reports. -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	-EPA's comprehensive state data review is expected to be completed by September 2007. -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: parameter code 00400- pH with a limit of 6.0 to 9.0 standard units; parameter code 82581- number of excursions greater than 60 minutes at any time; 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.

Virgin Islands	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Washington	-EPA's comprehensive state data review is expected to be completed by September 2007. -A number of EPA-authorized CWA NPDES facilities in region 10 do not have up-to-date permit limits entered in PCS. An updated list of the specific facilities will be added at a later date. As a result, violations may be missing or erroneous in the PCS system for some facilities and, consequently, will not be correctly displayed in ECHO. region 10 has refocused PCS data entry for all region 10 states to only those permits where EPA is the permitting authority (Alaska, Idaho, federal and tribal facilities in Washington, and tribal facilities in Oregon). Questions regarding the status of region 10's data management plan should be directed to Kimberly Ogle at 206-553-0955. -The Washington Dept. of Ecology has assumed PCS data management for CWA NPDES facilities where the state is the permitting authority. EPA's limited PCS data entry for these facilities ceased on September 30, 2004. Ecology is using a phased-approach to "translate" or upload state data to PCS. As a result, violations may be missing or erroneous in the PCS system for some facilities and, consequently, will not be correctly displayed in ECHO until the state system/PCS data interface is complete. Questions regarding the status of the state data management plan should be directed to Stephen Bernath at 360-407-6459. -Washington does not show enforcement action data for non-major facilities. EPA has determined that there may be a data entry problem and is working on a resolution.

West Virginia	-EPA's comprehensive state data review is expected to be completed by September 2007. -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: parameter code 00400- pH with a limit of 6.0 to 9.0 standard units; parameter code 82581- number of excursions greater than 60 minutes at any time; 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.

Wisconsin	-An EPA comprehensive state review of FY04 data occurred in September 2006. -Wisconsin does not show enforcement action data. EPA believes a data entry problem exists and is working on a resolution.

Wyoming	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

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 recently completed a workgroup process to develop 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.

Alaska	An EPA comprehensive state review of FY03 data occurred in April 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Alabama	An EPA comprehensive state review of FY05 data occurred in January 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Arizona	An EPA comprehensive state review of FY03 data occurred in February 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Arkansas	An EPA comprehensive state review of FY05 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

California	-EPA's comprehensive state data review is expected to be completed by September 2007. -As of May 2006, the majority of data for RCRA inspections, violations, and enforcement actions conducted by local California jurisdictions is currently available in RCRAInfo, EPA's national hazardous waste data system. ECHO, which retrieves enforcement data from RCRAInfo, reflects most of the enforcement activities conducted by these local agencies. California is working with EPA to develop and build a new data system that will regularly store and transfer RCRA inspection, violation, and enforcement action data from local jurisdictions to RCRAInfo. This new system, once in place, will help ensure that ECHO is populated with accurate and complete data on a regular basis.

Colorado	EPA comprehensive state data review expected to be completed by September 2007. Based on August 2007 annual analysis of national system data, some Colorado compliance information is inaccurate - a large number of violation end dates (more than 100) for violations older than three 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.

Connecticut	Based on March 2007 annual analysis of national system data, some Connecticut compliance information is inaccurate - a large number of violation end dates (more than 200) for violations older than three 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.

Delaware	An EPA comprehensive state review of FY05 data occurred in January 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

District of Columbia	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Florida	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Georgia	An EPA comprehensive state review of FY04 data occurred in December 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Hawaii	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Idaho	An EPA comprehensive state review of FY04 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Illinois	EPA comprehensive state data review expected to be completed by September 2007. Based on July 2007 annual analysis of national system data, some Illinois compliance information is inaccurate - a large number of violation end dates (more than 200) for violations older than three 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.

Indiana	An EPA comprehensive state review of FY05 data occurred in September 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Iowa	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Kansas	An EPA comprehensive state review of FY05 data occurred in June 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Kentucky	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Louisiana	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Maine	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Maryland	An EPA comprehensive state review of FY04 data occurred in January 2005. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Massachusetts	An EPA comprehensive state review of FY05 data occurred in October 2006. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Michigan	-An EPA comprehensive state review of FY03 data occurred in February 2005. -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.

Minnesota	EPA comprehensive state data review expected to be completed by September 2007. Based on July 2007 annual analysis of national system data, some Minnesota compliance information is inaccurate - a large number of violation end dates (more than 400) for violations older than three 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.

Mississippi	An EPA comprehensive state review of FY05 data occurred in July 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Missouri	An EPA comprehensive state review of FY03 data occurred in January 2005. Based on the comprehensive review and an August 2007 annual analysis of national system data, some Missouri compliance information is inaccurate - a large number of violation end dates (more than 50) for violations older than three 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.

Montana	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Nebraska	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Nevada	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

New Hampshire	An EPA comprehensive state review of FY04 data occurred in September 2006. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

New Jersey	An EPA comprehensive state review of FY03 data occurred in November 2004. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

New Mexico	An EPA comprehensive state review of FY04 data occurred in September 2006. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

New York	An EPA comprehensive state review of FY04 data occurred in September 2006. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

North Carolina	An EPA comprehensive state review of FY04 data occurred in December 2006. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

North Dakota	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Ohio	EPA comprehensive state data review expected to be completed by September 2007. Based on July 2007 annual analysis of national system data, some Ohio compliance information is inaccurate - a large number of violation end dates (more than 300) for violations older than three 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.

Oklahoma	An EPA comprehensive state review of FY03 data occurred in October 2004. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Oregon	-EPA's comprehensive state data review is expected to be completed by September 2007.

Pennsylvania	Based on August 2007 annual analysis of national system data, some Pennsylvania compliance information is inaccurate - a large number of violation end dates (more than 200) for violations older than three 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.

Puerto Rico	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Rhode Island	Based on March 2007 annual analysis of national system data, some Rhode Island compliance information is inaccurate - a large number of violation end dates (more than 50) for violations older than three 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.

South Carolina	An EPA comprehensive state review of FY03 data occurred in 2004. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

South Dakota	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Tennessee	EPA comprehensive state data review expected to be completed by September 2007. As of July 2007 annual analysis of national system data, EPA is not aware of data problems.

Texas	EPA's comprehensive state data review is expected to be completed by September 2007. Based on August 2007 annual analysis of national system data, some Texas compliance information is inaccurate - a large number of violation end dates (more than 500) for violations older than three 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.

Utah	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

Vermont	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Virginia	Based on August 2007 annual analysis of national system data, some Virginia compliance information is inaccurate - a large number of violation end dates (more than 50) for violations older than three 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.

Virgin Islands	EPA comprehensive state data review expected to be completed by September 2007. As of March 2007 annual analysis of national system data, EPA is not aware of data problems.

Washington	EPA's comprehensive state data review is expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

West Virginia	Based on August 2007 annual analysis of national system data, some West Virginia compliance information is inaccurate - a large number of violation end dates (more than 50) for violations older than three 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.

Wisconsin	Based on September 2006 EPA comprehensive state data review of FY04 data, Wisconsin does not always report its Significant Noncompliance data within the time frame recommended by EPA policy. Based on July 2007 annual analysis of national system data, EPA believes this applies to FY05-06 data, as well. This means that the state may have identified SNCs that are not yet appearing on ECHO.

Wyoming	EPA comprehensive state data review expected to be completed by September 2007. As of August 2007 annual analysis of national system data, EPA is not aware of data problems.

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