The following is a list of deliverables from this project:
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Automatic assignment of SEV codes to DWE’s NJPDES NOVs within the NJEMS Database to be submitted to EPA.
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Data query/flow for Linkages between Compliance Evaluations, Enforcement Actions, and SEVs to be submitted to EPA.
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Automatically generated XML spreadsheets for the submission of SEV and Linkage Data to EPA’s Exchange Network Services Center. This includes generating data for the Reportable Noncompliance (RNC) fields for SEVs triggering SNC status. The RNC fields will be used for EPA’s NPDES Noncompliance Reports (NNCRs).
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Addition of Deficiency Codes to the compliance monitoring data currently being submitted to EPA for Pretreatment, Urban Stormwater (MS4), and CAFOs. (As there are only 2 CAFO facilities, a determination may be made during this project that data entry for CAFOs will be handled manually).
Listed below is how DWE expects the sequence of events and the data to be shared with EPA:
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A DWE inspector completes a compliance monitoring activity (e.g., on-site inspection, off-site desk audit) of the NPDES regulated entity.
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Next the DWE inspector completes the inspection report that documents the findings in NJEMS/PEGA. DWE reviews relevant records to assess compliance with Clean Water Act and applicable NPDES permits, compliance orders, and other regulations and laws. The inspection report is reviewed by the inspector’s supervisor and then locked.
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DWE shares key inspection report data (e.g., compliance monitoring activity end date) and deficiencies with EPA's national NPDES data system (ICIS-NPDES). Timely data entry is within 40 days of the date of the completed inspection report or record. The next steps may happen prior to submission of this data; however, this is where EPA puts this step in their Data Sharing Guidance.
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Next the DWE inspector determines that the NPDES-regulated entity has one or more events of noncompliance and issues an enforcement action such as an NOV (Notice of Violation). The SEV code is automatically applied based on which permit condition is out of compliance either instantaneously or by nightly cycle.
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Next DWE shares this via an electronic data transfer of this Single Event Violation and related linkage data with EPA’s national NPDES data system (ICIS NPDES). Timely data entry is within 40 days of the determination date.
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RNC fields will be updated with resolution data as violations are handled by DWE and submitted to EPA.