03/30/2007 05:42 PM
Regional Enforcement Water Branch Chiefs,
In June 2006, we sent you a Final Single Event Violation Data Entry Guide for the Permit Compliance System (PCS). Single event violations are one-time or long-term violations discovered by the permitting authority typically during inspections (and not through automated reviews of Discharge Monitoring Reports). The attached Regional Interim Data Entry Guide for ICIS-NPDES will serve as the key reference document for tracking EPA identified violations in ICIS-NPDES. Prior to finalizing this Guide and sending to any states, OECA is requesting that the Regions pilot using this Guide for the next four months.
This Interim Guide is purely intended for EPA Regional use to track single-event violations that are discovered by EPA. Please do not transmit this version to the states as we are still working with the states on the broader issues covered by the draft ICIS-NPDES Policy Statement, as well as the draft Wet Weather SNC Policy.
At the conclusion of this four month pilot, we would like feedback in two areas. First, we welcome comments on the content of the Guide. Second, we would like your assessment of the benefits and burdens associated with tracking this information at non-majors. We will hold a conference call this summer to gather your feedback, but also feel free to send written comments to Mike Barrette by August 1, 2007. Below is some additional contextual information about single-event violation tracking.
OECA believes that tracking inspection-related violations is of critical importance, and we ask that each Region carefully use ICIS-NPDES to register the start and end dates of violations that are discovered. Although the current draft of the ICIS-NPDES Policy Statement includes single event violations as a required (RIDE) data element for NPDES major and non-major facilities, we are still in the process of addressing state concerns with RIDE. As you know, these data were previously required for majors only; however, the data were of very poor quality - as you are discovering in your SRF reviews. Given the priority of our wet weather compliance monitoring and enforcement program, we believe that single-event violation tracking is critically important -- particularly at those facilities whose permits do not require DMRs. At these "non-standard" permittees, single-event violations are the ONLY electronic source of national data regarding violations that are discovered at these facilities. The pilot testing of this Data Entry Guide will allow us to better understand the implications of tracking such information, and can also ensure that EPA is well positioned to analyze and report the frequency of violation determinations in our wet weather universes. Tracking the violations arising from priority compliance monitoring activities will help us to demonstrate the importance of these activities. We realize that this will be somewhat of a “culture change” for the NPDES program in terms of data entry; however, we believe that any initial difficulties in adjusting to electronic tracking of these violations will be overcome to reveal the advantages of this approach.
The Regional Interim Single Event Violation Data Entry Guide for ICIS-NPDES includes the Single Event Violation codes table with definitions in Attachment 1. There are some technical differences in the handling of single event violations by PCS and ICIS-NPDES, which are described in Sections 3, 4, and 6 and Attachment 5.
In addition to the names on this email list, please forward this information to any other appropriate Regional managers and staff. Any questions may be directed to Amelie Van Den Bos at firstname.lastname@example.org.
And again, since this is only intended for EPA pilot use at this time, please do not distribute this version to the states.
David A. Hindin, Director
Enforcement Targeting and Data Division
Office of Compliance
U.S. Environmental Protection Agency