The Wise Report
On Sept. 24, 2015, the EPA signed the final rule which requires NPDES regulated entities to electronically submit specific permit and compliance monitoring information instead of filing paper reports. This rule will be implemented in two phases. Phase I becomes effective on Dec. 21, 2016, and Phase II becomes effective on Dec. 21, 2020. The following is a brief summary of the Phase I and Phase II requirements as they apply to NPDES regulated entities.
Phase I Requirements – effective Dec. 21, 2016
- All NPDES regulated entities that are required to submit discharge monitoring reports (DMRs) must do so electronically using NetDMR.
- NPDES regulated entities include facilities that discharge wastewater (for example, facilities classified as major or minor dischargers, individually permitted facilities, and facilities covered by general permits).
- The TCEQ may grant Temporary Waivers to the electronic reporting rule in limited cases where adequate broadband access is not available or other situations as approved by the EPA.
Phase II Requirements – effective Dec. 21, 2020
- All NPDES regulated entities that are required to submit a notice of intent (NOI), a notice of termination (NOT), a no exposure certification (NEC), or a low erosivity waiver (LEW) must do so electronically using STEERS (for example, Industrial Multi-Sector General Permits and Construction Stormwater General Permits).
- NPDES regulated entities that are required to submit the following periodic reports must do so electronically: Sewage Sludge/Biosolids Annual Program Reports, Concentrated Animal Feeding Operation (CAFO) Annual Program Reports, Municipal Separate Storm Sewer System (MS4) Program Reports, Pretreatment Program Reports, Significant Industrial User Compliance Reports (in municipalities without approved pretreatment programs), Sewer Overflow/Bypass Event Reports, and CWA Section 316(b) Annual Reports.
- The TCEQ may grant Temporary Waivers to the electronic reporting rule in limited cases where adequate broadband access is not available or other situations as approved by the EPA.
If you have any questions concerning the NPDES Electronic Reporting Rule, please contact Small Business and Local Government Assistance at 800-477-2827.
As has been discussed previously, the TCEQ will require all soil confirmation samples for volatiles and TPH be collected using EPA Method 5035, beginning January 1, 2016. I asked Anne Strahl, with the TCEQ about the need to use EPA method 5035 for TPH being collected in conjunction with UST sites, since TPH is only used as a screening tool to determine which soil sample(s) will be analyzed for PAH. She said that EPA Method 5035 would not be required in this case. However, it would be required if the site were subject to TRRP, since TPH can be used to help close a site. You will still need to use EPA Method 5035 for volatiles under both the UST and TRRP rules.
Henry M. Wise, P.G.
The Wise Report