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ECHO Users Guide -- Understanding Federal and State Data Entry Requirements |
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This table indicates where EPA requires data to be provided to national databases (which flow through to the ECHO website on a monthly basis). Data flows from authorized state, tribal, and local gov'ts) and the EPA Regional offices. This table is designed to help users understand where data is more complete. Many states voluntarily enter additional data that is not required; however, in red and yellow boxes, data completeness may vary widely from state to state. The ECHO website will show the information entered by states regardless of whether it is required. ECHO users may want to refer to state web sites for additional information.
| Source Type | Clean Water Act - National Pollution Discharge Elimination System | Clean Air Act - Stationary Sources | RCRA (Hazardous Waste) | |||||
| Major/Large (individual permit) | Non-Major/Small - (individual permit)1 | Other Permits (wet weather, general, etc) | Major/Large | Medium Size2 | Other Minors/ Small3,4 | Large Facilities5 | Small Facilities6 | |
| Estimated # of Active Facilities | 6,700 | 39,000 | >300,000 | 15,000 | 27,000 | >100,000 | 25,000 | 150,000 |
| PCS/ICIS-NPDES | PCS/ICIS-NPDES | PCS/ICIS-NPDES | AFS | AFS | AFS | RCRAInfo | RCRAInfo | |
| Facility Universes Tracked | Y | Y | Partial | Y | Y | Partial3 | Y | Y |
| Inspection Performed | ||||||||
| EPA | Y | Y | Y | Y | Y8 | N3 | Y | Y |
| State | Y | Y | N | Y7 | Y8 | N3 | Y | Y |
| Inspection Results (Violation/Compliance Status) | ||||||||
| EPA | Y | Y | Y | Y9 | Y9 | Y10 | Y11 | Y11 |
| State | Y | N12 | N | Y9 | Y9 | Some10 | Y11 | Y11 |
| Data Entry of Self-Reported Discharge/Violations | ||||||||
| EPA | Y | N13 | N | 4 | 4 | N | N/A | N/A |
| State | Y | N13 | N | 4 | 4 | N | N/A | N/A |
| Severity of Violation (SNC/HPV)14 | ||||||||
| EPA | Y | Y | Y | Y | Some15 | N16 | Y | Y |
| State | Y | N | N | Y | Some15 | N16 | Y | Y |
| Notices of Violation (Informal Enforcement) | ||||||||
| EPA | Y | N | Y | Y | Y | Y | Y | Y |
| State | Y | N | N | Y | Y | N | Y | Y |
| Formal Enforcement Actions | ||||||||
| EPA17 | Y | Y | Y | Y | Y | Y | Y | Y |
| State | Y | N18 | N | Y | Y | N | Y | Y |
| Amount of Assessed Penalties | ||||||||
| EPA17 | Y | N | N | Y | Y | Y | Y | Y |
| State | N | N | N | Y | Y | N | Y | Y |
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(1) These facilities have specific permit limits and report discharges from pipes on a regular basis. (2) Includes two types of facilities: (1) Synthetic Minors (SMs) are potentially major except limited by special state/federal permits called "synthetic" or Federally Enforceable State Operating Permits (FESOPs) and (2) Minors subject to CAA Part 61-National Emissions Standards for Hazardous Air Pollutant Standards (NESHAPs). (See CAA ICR (PDF, 33pp, 128KB)) (3) "Other" minors become reportable if certain actions or violations occur, e.g., HPV, formal enforcement, voluntarily included in state CMS plan, etc. (4) The CAA has many requirements for self-reporting by facilities on both periodic or specific bases including: emission/stack tests, annual compliance certifications, periodic monitoring reports, etc. Normally provided in hard copy, these reports, once reviewed by the permit authority, may influence a violation determination and compliance status for the facility, and will often show up in ECHO. (5) Includes Treatment, Storage and Disposal (TSD) facility, and Large Quantity Generator (LQG). (6) Includes Small Quantity Generator (SQG). Data reporting requirements are similar for other facilities tracked in the Resource Conservation and Recovery Act Information system (RCRAInfo), such as Conditionally Exempt Small Quantity Generators and Transporters. (7) Full Compliance Evaluations (generally more thorough inspections) are required to be reported, and Partial Compliance Evaluations are not. (8) Universe and all enforcement data has required reporting, however, required inspections/compliance evaluations only the larger, synthetic minors (SM) permitted >= 80% of major threshold per CAA CMS Guidance. (9) States and Regions are required to enter violations found, however, EPA analysis shows that data quality problems exist in specific states. EPA is working with the states on these issues. (10) CAA violations at non-federally reportable sources are only required to be reported if the violation leads to an enforcement action. (11) RCRAInfo contains violations of federal RCRA regulations and statutes as well as violations of states’ hazardous waste management programs, which may be broader in scope or more stringent than the federal RCRA Subtitle C program. (12) There are a small subset of required violations that must be entered - namely violations at Publicly Owned Treatment Works with approved local pretreatment programs. These violations must be entered regardless of whether the facility is a major. (13) EPA has posted information about the data completeness by state for violation data at non-major facilities. (14) SNC stands for Significant Non-Compliance and is used for CWA and RCRA. HPV stands for High Priority Violation and is used for CAA. Note that CWA minors that have SNC-level Violations are shown in ECHO as "Category I" Violators. (15) If emissions violation(s) occurred for pollutant(s) "synthetically limited" below major threshold by FESOP permit then HPV would apply. (16) HPV Policy normally does not include "Other Minor" sources but may if added by an agency as "Discretionary" per HPV Policy. (17) Federal enforcement actions and penalties are entered into the facility record in the Air Facility System (AFS), PCS, ICIS-NPDES, and RCRAInfo. This information also is entered into the Integrated Compliance Information System for federal enforcement and compliance data (ICIS FE&C). Reports shown on this Web site display both pieces of information when available. In some instances, the same federal enforcement action will not appear in both systems, and in other cases, the same action will be in both systems. ICIS FE&C provides information on a wide range of statutes and programs, but is limited to EPA data only. (18) States are expected to enter formal enforcement action data for a small subset of these facilities -- particularly those which received federal grant money through the Public Law 92-500 funding mechanism to construct. Other Notes: EPA maintains a list of known data quality problems, and more serious data alerts. To check whether there are known issues within particular states in regard to populating this information, please refer to these links on the ECHO page. The State Review Framework program evaluation reports may also contain information about data quality within particular states. Typically, the authorized authority is either the state, EPA, tribal, or local government. In most cases, the state is the authorized authority. The authorized authority is primarily responsible for maintaining an inventory of regulated sources and doing core inspection, violation tracking and enforcement work. However, EPA may also conduct activities within states, so this table shows what data entry requirements EPA has for activities it performs in the states.
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