ECHO Users Guide -- Understanding Federal and State Data Entry Requirements
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 is provided by authorized state, tribal, and local governments, 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)||Synthetic Minor2 (Mid-Size)||Minors3,4 (Small)||TSD and LQG5 (Large)||SQG6 (Small)|
|Estimated # of Active Facilities||6,700||39,000||>300,000||15,000||24,000||>100,000||25,000||150,000|
|Facility Universes Tracked||Y||Y||Partial||Y||Y||Partial3||Y||Y|
|Compliance Evaluation Performed|
|Compliance Evaluation Results (Violation/Compliance Status)|
|Severity of Violation (SNC/HPV)14|
|Notices of Violation (Informal Enforcement)|
|Formal Enforcement Actions|
|Amount of Assessed Penalties|
(2) Synthetic Minors (SMs) are potentially major except limited by special state/federal permits called "synthetic" or Federally Enforceable State Operating Permits (FESOPs).
(3) This universe includes federally-reportable minor sources and other minor sources. Federally-reportable minor sources include (1) minor sources subject to CAA Part 61-National Emissions Standards for Hazardous Air Pollutant Standards (NESHAPs), and (2) minor sources that are the subject of a formal enforcement action, part of a CMS plan, or have an active HPV. (See CAA MDR ICR (PDF, 33pp, 128KB), and the March 22, 2010 EPA memo "Clarification Regarding Federally-Reportable Violations for Clean Air Act Stationary Sources"). Minor sources with formal enforcement actions are tracked in AFS until the resolution of the violation.
(4) Some states voluntarily report data on non-federally reportable CAA regulated sources in their state.
(5) TSD - Treatment, Storage and Disposal facility, and LQG - Large Quantity Generator.
(6) SQG - Small Quantity Generator. Data reporting requirements for the other facility types tracked in the Resource Conservation and Recovery Act Information system (RCRAInfo), such as Conditionally Exempt Small Quantity Generators and Transporters, are similar to the requirements for SQGs.
(7) Full compliance evaluations (which typically include an on-site inspection) are required to be reported, and Partial Compliance Evaluations are not, unless the PCE was conducted as part of a negotiated CAA Compliance Monitoring Strategy (CMS) plan.
(8) Full compliance evaluations conducted, NOVs issued, formal enforcement actions issued, and penalties assessed at federally-reportable minor sources are required to be reported.
(9) States and EPA Regions are required to enter the compliance status per regulated pollutant(s) within an air program for each federally-reportable facility evaluated. EPA analysis shows that data quality problems exist regarding facility compliance status in specific states. EPA is working with the states on these issues. In addition, the results of stack tests and Annual Title V Compliance Certification reviews are required.
(10) The CAA requires that sources report activities, such as emission/stack tests, annual compliance certifications, periodic monitoring reports, etc. These reports may be used by the permitting authority to determine compliance, and their receipt and review are often used to determine compliance. Self-reported violations would also be required to be reported at federally-reportable minor sources. See March 22, 2010 EPA memo "Clarification Regarding Federally-Reportable Violations for Clean Air Act Stationary Sources."
(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 is a 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.
(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 an emissions violation occurred for a pollutant, "synthetically limited" below a major source threshold by a federally enforceable permit then the HPV Policy would apply.
(16) The HPV policy normally does not apply to minor sources but may if added by an agency as a "Discretionary" HPV.
(17) Federal enforcement actions and penalties are entered into the facility record in the Air Facility System (AFS), 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. 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.