mark stanifer, idem, the most commonly reported npdes violations in indiana, midwest environmental...

Midwest Environmental Compliance Conference

Chicago Mariott O’Hare

October 29, 2015

Mark Stanifer, Chief

Compliance Branch

Office of Water Quality

Indiana Department of Environmental Management

The Most Commonly Reported NPDES Violations in Indiana

• Most frequent reported

• Findings/violations identified by inspectors

• Compliance rates identified by inspectors

• Enforcement cases by sector

• Other happenings at IDEM

Five most frequent self-reported numeric effluent violations overall:

January through June 2015 (from ICIS)

– Ammonia 641

– Total Suspended Solids 460

– E. coli 221

– CBOD 196

– Residual Chlorine 177

• All of these are typical of sewage

Five most frequent self-reported numeric effluent violations: Nonconventional pollutants

January through June 2015 (from ICIS)

• Iron 32

• Zinc 24

• Copper 22

• Molybdenum 17

• Cyanide 14

Most frequent violations identified by OWQ staff at NPDES facilities OVERALL

2014 and 2015

– Numeric effluent violations

– SSO, overflow, bypass events

– Poor operation and maintenance

– Self-monitoring, records, reports—late and missing

– Lab issues (techniques, documentation)

– Inadequate flow meters

Most frequent single event violations (SEVs) identified by inspectors at major NPDES

facilities during 2014 and 2015

– SSO, Overflow, Bypass

– Operations

– Self-Monitoring, Records, Reports

– Maintenance

– Lab issues

Inspections Conducted during 2014 and 2015

Recon CEI Complaints Violations to enforcement 6 12 1 Violation letters 248 546 14

Minor issues identified 101 391 11

No violations identified 329 681 24

Total: 2364

Compliance ratings determined by inspectors at NPDES facilities during 2014 and 2015.

MAJOR dischargers: By sector

Number Inspected % Compliance Industrial 67 98.64%

Mixed Ownership 13 89.58%

Municipality 237 93.56%

State/Federal 1 71.43%

Total/overall: 318 94.39%

Compliance findings identified by inspectors at

NPDES facilities during 2014 and 2015

MINOR dischargers: By sector

Number Percent

Inspected Compliance

General 255 97.99%

Industrial 466 96.39%

Mixed Ownership 484 88.84%

Municipality 637 90.30%

Pretreatment 224 95.96%

State/Federal 67 94.06%

Total/overall: 2133 92.57%

NPDES Enforcement Cases Initiated (NOVs) by Sector

1-1-14 to present

Major Minor

Semi-public 1 7

Municipal 8 14

Industrial 1 5

Unpermitted NA 3

NPDES Enforcement Cases Resolved With Final Order, by Sector

1-1-14 to present

Major Minor

Semi-public 2 9

Municipal 6 20

Industrial 3 5

Operator NA 5

Unpermitted NA 4

Staff Changes

• Chief of Staff Carol Comer became Commissioner

• OWQ Assistant Commissioner Bruno Pigott

became Chief of Staff

• OWQ Deputy Assistant Commissioner Martha

Clark Mettler became Assistant Commissioner

• OWQ Permits Branch Chief Paul Higginbotham

became Deputy AC

Electronic Reporting

NPDES Electronic Reporting Rule • EPA proposed rule July 2013, supplemental notice

December 2014.

• OMB review completed & signed by Administrator

McCarthy 9-24-15.

• Published in Federal Register October 22.

• Effective date December 21, 2015.

• Deadline for electronic submission of DMRs end of 2016.

• Other reports end of 2017 (maybe).

• Indiana using NetDMR application for DMRs.

• 50% of Indiana NPDES facilities now enrolled in/using

NetDMR.

WW Operator Certification Exams Up an running!

• New System – Offer exam through Ivy Tech Community

College and IDEM.

– 26 IVY Tech testing centers

– Exam scheduled by appointment

throughout the week

– Results available immediately

• Old and New System – IDEM continues to offer the exam once

annually

– 12 people sat for paper exam Oct. 8

Questions?

Mark Stanifer

Branch Chief

Compliance Branch

Office of Water Quality

Indiana Dept. of Environmental Mgmt.

317-232-8431

mstanife@idem.IN.gov