Reporting
Go through the sections below.
NPDES Record Keeping and Reporting
It is a Municipal NPDES Permit requirement to keep record of NPDES complaints, investigations, and enforcement activities. It is also a Permit requirement to report on these activities annually, as part of the Municipal NPDES Annual Report. In addition to Annual Reporting, you may be required to pull NPDES-related Code Enforcement records for public records requests, State or Federal EPA NPDES Compliance Audits, or as a result of third party environmental litigation. Needless to say, it is critical to keep quality records of your NPDES activities.
Records to Retain
Following your Agency's record retention policies, you should retain records of inspection and investigation reports, follow-up activities, warning letters, violation notices and other enforcement records.
Information to Record for NPDES Investigations
NPDES investigations must include the following information. (Note sewer spills have specific reporting requirements beyond that listed below.)
When the complaint was received by your Agency.
Complainant contact information, and any information on the compliant that is provided by the complainant.
When your Agency responded, and contact info of the responding staff.
The contact information of the Responsible Party (RP), if one is identified.
A description of the violation, if one is detected.
If a spill, to the best of your estimation:
the date/time the spill started and stopped
the approximate size of the spill
whether the spill entered the storm drains or reached surface waters
whether the spill impacted surface waters
How the spill was cleaned-up
When spill notifications were made, if applicable
If applicable, information on agencies that were notified or participated in the response
Corrective actions required, and the date to comply.
The status of corrective actions made.
Whether the case is open or closed.
Also include pictures that verify, at the least, that the violation did occur, and that the violation was corrected. (A reminder that if you are on private property, you must request authorization to take pictures.)
Note the level of detail you provide should scale with the nature of the violation. A singular case of non-residential car washing to the street can be quite brief: A few sentences of information could capture all that is needed. A large volume spill demands more detail. Also, cases that may require continued or significant enforcement actions demand more detail. In these cases, you may need assistance from--or defer to--your Agency's NPDES Inspector or Program Manager in completing the report.
Annual Reporting
Your municipality is required to report annually on NPDES violations that occurred within the reporting year. The reporting year is July 1 to June 30. To complete the Annual Report, you will need to supply basic information on NPDES violation cases that occurred in this time period. Your Agency's NPDES Stormwater Program Manager will let you know the specific data request. But it may include:
Whether the violation was an illicit discharge or a stormwater BMP deficiency (or both)
If applicable, the type of illicit discharge
Whether the violation is closed or open
What type of enforcement actions were used
If Code Enforcement cases are logged in an electronic database, it would be good to label NPDES violations as such. That is, if possible, use labels or keywords like "NPDES" or "Illicit Discharge", so that it is easier to recall these cases when your Agency's NPDES Stormwater Program Manager requests the data.
Program Effectiveness Assessment
Annual Reporting is a time to assess program effectiveness, and to identify and respond to trends. If you are in a position to do so, discuss lessons learned with your Division supervisor or your Agency's NPDES Program Manager, so that your Agency's NPDES Program may be improved as the years progress.
