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
See the NPDES Violation Response section for information on NPDES investigation reporting.
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 Public Works responses are logged in an electronic database, it would be good to label NPDES violations. 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.
