How Should IT Departments Adapt to EPA eReporting?

Look out! It’s coming: EPA’s National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule (catchily referred to as the “NPDES eRule”) reaches full effect on December 21, 2025. And it’s up to water utilities’ IT teams to bring them into compliance.

The NPDES eRule requires water utilities to move all their reporting to a standardized, digital format, using online portals either provided by EPA or custom-created by individual states. That means no more submitting spreadsheets, docs, or PDFs by email, and certainly no more hard copy paper reporting by snail mail. 

December of 2025 may seem a long way off, but the NPDES eRule is broad, sweeping, and impacts every form of EPA reporting a water utility is responsible for. IT teams need to get moving now if they’re going to meet new compliance requirements on time. 

This article provides all the information you and the rest of your team needs to understand new electronic reporting regulations, and bring your water utility up to date ASAP.

What Is Electronic Reporting?

For the purposes of this article, “electronic reporting” (or “eReporting”) refers to using standardized online tools or web portals to submit reports to EPA. This is distinct from submitting reports by email, which many utilities did (and still do). 

The NPDES eRule was published on October 22, 2015, and came into effect December 21, 2015. It’s still in the process of being implemented. It will be fully implemented on October 22, 2025.

The eRule has two phases: Phase I and Phase II.

Phase I of the NPDES eRule is already in effect. It only requires utilities to eReport DMRs.

Phase II was slated to come into effect December 2020, but the deadline was extended. On September 23, 2020, EPA signed an extension into effect. The new effective date for Phase II is December 21, 2025.

The full list of reports affected by Phase II include (per EPA’s website): 

  • Notices of Intent to discharge (NOIs) under a general permit
  • Notices of Termination (NOTs) of coverage under a general permit
  • No Exposure Certifications (NOEs) under a stormwater general permit
  • Low Erosivity Waivers (LEWs) under a stormwater general permit
  • Concentrated Animal Feeding Operation (CAFO) Annual Program Reports
  • Municipal Separate Storm Sewer System (MS4) Program Reports
  • Pretreatment Program Annual Reports
  • Significant Industrial User (SIU) Bi-annual Compliance Reports in municipalities without approved pretreatment programs
  • Sewer Overflow/Bypass Event Reports
  • Clean Water Act (CWA) Section 316(b) Annual Reports

As you’ve probably already realized, preparing these reports is much more labor intensive than preparing DMRs. For every instance at your water utility where they exist in the form of spreadsheets or written documents, you will need to convert these documents to electronic formats compatible with new eReporting standards.

The most effective way to prepare for the full, Phase II rollout of the NPDES eRule is to transition now to a compliance and reporting system that is compatible with EPA’s new online reporting systems.

What Stage Are You at in Your Electronic Reporting Journey?

In order to get a clear idea of what steps your department must take to implement new, eRule-compliant reporting at your water utility, it’s essential to complete an audit of your current system.

Refer to the following categories to get an idea of where you stand, and plan the next steps you need to take to fully digitize your reporting and become compliant with eRule.

bundles bales of paper documents. stacks packs pile on the desk in the office

Stage 0: Cluttered Desk

Your reporting systems are tied up in a byzantine system of printouts, hard media (anything from floppy disks to USB sticks), and even the occasional quilt of Post-It notes. Completing a report means cracking open the filing cabinets of multiple stakeholders, and sometimes literally digging up old files.

If this sounds like your utility, you can take some comfort in the fact that you are not alone. A surprising number of water utilities across North America are still using analog—and often disorganized—systems to store and transmit data.

It comes with a lot of potential pitfalls, including:

  • Hard copy data lost in transit or misplaced
  • Files without backup copies being damaged or destroyed
  • Significant time costs associated with manual and analog processes
  • Loss of access to documents as older team members retire

If you’re at Stage 0, you’re most likely still filing reports by snail mail. You’ve got a long road ahead of you to come into compliance with the NPDES eRule. The good news is that, if you start now and get set up with a digital system that’s in full compliance with the new reporting standards coming into effect at the end of 2025, you should be able to meet the deadline. 


Stage 1: Basic Electronic Reporting

You create, share, and file your reports (and associated data) on the computer. When filing reports or sharing information with colleagues and across organizations, you save data in the form of Microsoft Office or Excel files, or PDFs, and send them as attachments to emails.

All of the digital data at your water utility is stored in-office, on employee computers, or on a shared local server accessible via intranet.

Common pitfalls at this stage include:

  • Lost data, as hardware is upgraded or experiences failures
  • Duplicate data, in the form of multiple files stored natively on different employees’ desktops (changes to files aren’t synced, so different copies may disagree with one another)
  • Vulnerability to viruses and ransomware
  • Danger of sabotage or information theft. Email is one of least secure means of transmitting data online, and leaves you open to interference from a variety of bad actors, from amateur hackers to hostile foreign governments
  • Information islands. An individual who relies on DIY Excel “cheat sheets” to access data or complete reports can become a weak link in an organization. When such an individual leaves on vacation or retires, even if their files are accessible, they aren’t necessarily usable by other people in the organization—leading to knowledge gaps and stalled workflows

If your water utility falls under this category, you’re one step closer than Stage 0 to meeting the requirements of the NPDES eRule. But, broadly speaking, you still have the following steps to complete:

  1. Assess the scope of migrating to a new compliance and reporting system compatible with the NPDES eRule
  2. Compile data from across disparate storage methods and file formats
  3. Input it into the new system
  4. Retrain personnel in the new system
  5. Adapt workflows so that all data entry and recall and report filing are completed exclusively within the new system

Completing Step 1 should help you understand the time cost of the transition. The sooner you get started, the better.

Avoid Spreadsheet Overload With SaaS

Think you can get by on spreadsheets? Think again. Using spreadsheets as databases often creates more problems than it solves. Download the guide and book a demo of Klir today.

Backflow-Cross-Connections_Report 3-2

Stage 2: Web-based

Your water utility is already using a reporting and compliance system that is fully compatible with the NPDES eRule. 

This system could be:

  • Fully customized. As a one-time purchase from a software company, your water utility management suite was custom-coded by their in-house engineers to meet the specific needs of your organization. Most likely, it’s locally hosted on your own servers. Changes to the software may require hiring engineers to modify the code.
  • Fully configurable. The software you use was created with as many configurable variables as possible, so it can be used by a large number of utilities across a wide range of use case scenarios. It’s hosted externally, in the cloud, using standard bank-grade encryption. The software automatically updates to ensure it’s always in compliance with changes to reporting standards.

You can learn more from our article, Configurable vs. Customizable Software: A Cost-Benefit Breakdown.

In either case, your system should be up to the task of completing, filing, and storing copies of reports in accordance with the NPDES eRule. If it isn’t, you should contact the manufacturer regarding updates—or else begin looking for a new software solution.

If you have a system like this in place, you’re head and shoulders above most water utilities in terms of coming into compliance with new reporting standards and improving the overall performance and data security of your organization.

If you don’t have a system like this in place, getting to Stage 2 should be your number one priority. It’s the surest way to help ensure you’re in compliance with the new rules.

On top of that, using a web-based compliance and reporting system means:

  • Data entry is easy. Predetermined forms and fields set specifically for your needs and standardized across the organization streamline the process of entering data and keeping it securely stored.
  • You spend less time searching for forms and information. A searchable database with organization-appropriate tagging makes it easy to look up info when you need it. No more long email threads as you try to track down misplaced files.
  • Everyone is on the same page. Whether data is hosted on a local server or in the cloud, team members are always referring and making changes to the same, authoritative file. No more out-of-sync duplicates.

To better understand the benefits of a web-based solution, check out our article, Why SaaS Makes Sense for Water Now More than Ever Before.


Stage 3: CROMERR and the Future

Even though Stage 2 should be your number one goal, there is an extra level of compliance that will soon become relevant to your water utility. 

The Cross-Media Electronic Reporting Rule (CROMERR) sets standards for NPDES-compliant electronic reporting systems. In particular, it ensures that all data entered is legally defensible, and includes a Copy of Record.

To be clear: It isn’t up to your water utility to apply for CROMERR. Rather, software manufacturers for water utilities must ensure their products are compliant and apply.

CROMERR is not fully in effect yet. However, if you are choosing an electronic reporting and compliance system for your water utility, before purchasing one, you should either make sure it is already CROMERR-compliant, or that the manufacturer has a clear timeline for bringing its software in line with CROMERR standards.

The Time for Action Is Now

EPA’s new eReporting rules may seem like a major obstacle. And there is no denying that, for many water utilities, becoming compliant will take a considerable amount of planning and effort.

But these new standards are simply an indicator of the direction water utility reporting is headed. Across a wide range of industries, fully digital and cloud-based reporting and data storage are becoming the norm. Utility reporting is no different.

There are many benefits that come with bringing your water utility in line with the new requirements, including increased efficiency and less risk of data damage, loss, or theft. Even if making the transition poses some difficulties, it will pay off in the long run.

If your water utility is at Stage 0 (“Cluttered Desk”), you can save yourself a significant amount of time and energy by skipping Stage 1 and going straight to Stage 2. Plugging data into spreadsheets is a stopgap solution, at best. 

Eventually, all utilities will need to become NPDES eReport compliant, and that means using a web-based solution like Klir.

Harness The Power of SaaS With Klir

We believe that utilities deserve world-class software custom-built for the water industry. Ready to see how scalable, flexible, continuously improving SaaS tools can help your utility overcome its biggest data challenges? Book a demo and get a tour of Klir today.

Water System Permitting and Compliance 101

Key takeaways:

  1. While managing the mountain of permitting and other compliance-related responsibilities involved in running a utility can feel daunting, surveying the compliance landscape and developing familiarity with major EPA programs is a great starting point.
  2. Becoming acquainted with the EPA’s new eReporting requirements and preparing for them is a great way to cut down on administrative work and signal that your utility is serious about streamlining reporting processes.
  3. Staying ahead of new regulations related to PFAS and Lead and Copper will be key to staying on top of compliance challenges and building robust permitting management programs.

Managing the storm of permits, rules and other regulations involved in running a water system can be a time-intensive, daunting, and even exasperating task. It isn’t unusual for larger utilities in the U.S. to juggle hundreds or even thousands of permits and regulatory responsibilities at any particular moment. 

The rules in these programs can change often, and the knowledge required to stay on top of them often lives inside the heads of a handful of veteran employees. If you’re just starting out, wrapping your head around everything you need to do to stay compliant can feel impossible.

One of the most effective ways to reduce the time you spend tracking and organizing mandated testing for these permits is to adopt an effective permit management system like Klir.

But it also helps to take a step back and to acquaint yourself with federal and state organizations that issue permits, reporting requirements, and recent changes.

To bring you up to speed, this guide reviews three important topics in water permitting:

  1. First, we’ll introduce some of the most important permit-issuing authorities in the United States at the federal and state level.
  2. Second, we’ll take a look at the reporting requirements for those programs, including important changes to those requirements, like the EPA’s eReporting initiatives.
  3. Finally, we’ll review some of the newest regulations in water and what you can do to prepare for them today.

EPA-Related Permits and Regulations

As a federal agency, the Environmental Protection Agency (EPA) is necessarily responsible for key permits relevant to water systems.

EPA permitting covers the mandates of the Safe Water Drinking Act (SWDA), hazardous waste permitting regulations, and the National Pollutant Discharge Elimination System (NPDES). It also covers the Clean Air Act (CAA), which is relevant to water facilities producing certain minimum amounts of air pollution.

SDWA Drinking Water Standards

Through the Public Water System Supervision (SWSS) program, the EPA protects 90 percent of the USA’s drinking water. In partnership with individual states, the EPA monitors the analytic testing results of samples taken by water systems, ensuring they stay within threshold amounts of chemical and microbial contaminants.

Consumer Confidence Reports (CCR)

The EPA also partners with states to make sure that local water systems follow the Consumer Confidence Report (CCR) rule.

This rule requires local water systems to prepare and distribute a brief annual report summarizing information about water sources, compliance, detected contaminants, and educational programs. 

The aim is to increase consumer awareness about how their water systems run, provide information on safe water use, and increase dialogue between consumers and their water utilities.

The water system must deliver a copy of this report to state authorities. Additionally, if it serves over 100,000 customers, it must post the report online using EPA’s CCR iWriter tool.

Hazardous Waste Permitting Regulations

The EPA also partners with states to administer hazardous waste permitting regulations. These regulations are intended as a “cradle to the grave” management system for hazardous wastes, controlling how they’re produced, transported, stored, and eventually disposed of.

That being said, hazardous waste permits aren’t only relevant to facilities that manage and dispose of waste. Gasoline, diesel, and batteries all qualify as hazardous wastes. And facilities running industrial boilers, furnaces, or generators may also need permits to operate.

Clean Air Act (CAA) Permits

When a water system produces enough air pollutants, it’s required to obtain a Clean Air Act (CAA) permit—typically, a Title V Permit. In some cases, this is provided by an EPA Regional Office. But typically CAA permits are handled by state, local, and tribal authorities.

Title V permits

Broadly, any source that has the potential to emit (PTE) 100 tons per year of air pollutants is classified under the CAA as a “major source,” and needs a Title V permit to operate. Pollutants fall into six categories:

    • Particulate matter
    • Carbon monoxide
    • Ozone
    • Lead
    • Sulfur dioxide
    • Nitrogen dioxide

A source also qualifies if it emits more than 100,000 carbon dioxide equivalent tons per year, uses a solid waste incinerator, or meets a few other specific thresholds. You can learn more about qualifying for a Title V permit here.

Title V permits last for five years after they’re issued. In order to keep their permit, a major source must monitor, record, and report their pollutant output. The specific methods for measuring and reporting vary according to each type of pollutant.

Other Permits at the Federal Level

Outside those permits directly administered by EPA, there are a number of federal-level permits that water systems may need to obtain.

Section 401 Water Quality Certifications

Under Section 401 of the Clean Water Act (CWA), before any federal agency issues a permit allowing discharge into US waters, the state or tribe responsible for the area where the discharge originates must issue a Section 401 permit

They can also waive certification—either expressly, or by failing to issue a 401 within a reasonable amount of time.

Even though they’re administered at the state and tribal level, 401s are federally mandated; there’s nowhere in the USA that a water system can get a federal permit to discharge into US waters without applying for a 401.

US Army Corps of Engineers Permits

In order for a water system to perform any construction or dredging in the USA’s navigable waters, it must apply for a permit from the US Army Corps of Engineers.

There are two types of permits:

  1. Individual or standard permits, issued when projects have “more than individual or cumulative impacts,” and must be evaluated based on environmental criteria, requiring a public interest review.
  2. General permits, issued for projects that will have minimal impact. They’re issued on the individual, nationwide, or category-specific level. 

Federal Energy Regulatory Commission (FERC) Preliminary Permits and Licenses

Any water utility involved in the construction of a hydroelectric project must be licensed by FERC. The licensing process typically begins with application for a preliminary permit, good for four years, that reserves the organization a spot in FERC’s queue of license applicants while the organization explores the potential location and other considerations prior to beginning construction. In order to start construction, the organization must obtain a hydropower license from FERC.

State and Local Level Permits

The permits covered above are all administered at the federal level, often in partnership with states and tribes. But, in order for any given water utility to carry out day-to-day activities, they must apply for and manage a swath of permits at the state and municipal level. 

While these permits are absolutely necessary and may in fact comprise the better part of a water system’s compliance and reporting tasks, they’re so specific to each particular utility and locale that it’s impossible to cover them in detail here.

If you’re unsure about permit requirements at the local level for water systems, get in touch with your municipal and state authorities.

Know You’re Compliant With Klir

Tracking permits is a massive task. Klir gives you an all-in-one solution that guarantees nothing slips through the cracks. Learn more about Klir’s powerful permit management solution and book a demo today.

What Is Electronic Reporting, and What Does It Mean for Utilities?

Rather than requiring you to stay compliant by submitting reports via physical mail or e-mail, the EPA is increasingly requiring utilities to do their reporting through online portals like NetDMR and the Central Data Exchange (CDX).

In most states the only report you’re currently required to e-report is the Discharge Monitoring Report (DMR), the form wastewater utilities use to self-report compliance with environmental law in the United States on a weekly or monthly basis.

But according to the EPA’s eReporting rule, utilities across the country will soon have to start using these portals to submit other reports like:

These reports are longer than DMRs and require a lot more manual work, which will make moving important reporting data out of paper and spreadsheets and into platforms like Klir all the more important.

An exhaustive list of all the reports that utilities will have to start reporting under the eReporting rule is available under the “Phase 2” heading of the EPA’s eReporting website.

CROMERR and What It Means for Electronic Reporting

The Cross-Media Electronic Reporting Regulation (CROMERR) establishes standards for the systems that receive reports and other documents that utilities submit to satisfy many of the programs mentioned above.

CROMERR-compliant systems ensure the integrity of electronic documents, that a Copy of Record is created, and that documents are signed with a proper Electronic Signature.

Why eReporting Is Important

Because many of the EPA’s eReporting requirements aren’t due to kick in for another few years, you might wonder whether preparing for it now is worth the time and money.

It absolutely is. Eliminating paper documents and manual data entry from your workflows can save you hours a week in administration work and free up your staff for more important tasks. 

Electronic reporting also cuts down on the risks of error, makes it easier to follow reporting requirements, and shows regulators that you’re serious about streamlining your reporting processes.

New Compliance Challenges and What They Mean for Utilities

In addition to changes around electronic reporting methods, regulators are also constantly changing and refining the contents of regulatory programs themselves.

Staying compliant means anticipating and preparing for new regulations, like the ones around effluents on the EPA’s UCMR lists. Here’s a brief rundown of the most important changes in the pipeline and what you can do now to prepare.


Per- and Polyfluoroalkyl Substances (PFAS — pronounced “PEE-Fass”) are a class of synthetic “forever chemicals” that have been linked to everything from cancer to high cholesterol.

We’re currently in the eye of storm when it comes new PFAS-related regulations. Maine has already banned the chemicals, 29 states have introduced numerical PFAS limits for water, and the White House is publicly detailing its anti-PFAS plan. Recently the EPA announced that 29 of the next 30 pollutants it would look at under its Unregulated Contaminant Monitoring Rule (UCMR) would be PFAS. Most experts agree that it’s only a matter of time before utilities will have to start sampling discharges and biosolids for many of the chemicals on this list.

The EPA has awarded millions in grants for PFAS research and mitigation. The agency said data gathered from the latest Unregulated Contaminant Monitoring Rule “will also serve as a potential source of information for systems with infrastructure funding needs for emerging contaminant remediation,” which makes compliance with UCMR 5 crucial.

Lead and Copper

Last year the EPA released the biggest overhaul to its Lead and Copper rule since 1991, and in November Congress included $15 billion for lead pipe replacement in its infrastructure plan, signaling that U.S. regulators were finally getting serious about lead in drinking water.

One of the biggest changes to the EPA’s Lead and Copper rule so far has to do with sampling—specifically the new rule that requires a fifth-liter (L5) sample at homes with lead service lines (LSLs) rather than the original first-liter (L1) sample to demonstrate compliance with water lead level (WLL) limits.

In preparation for the effort to replace all lead service lines with copper ones, utilities must also start building out lead service line inventories, which collect as much information as possible about which service lines in a distribution system are made of lead.

In most cases the EPA has delegated responsibility for inventory requirements to states, which means rules around how exhaustive these inventories must be will vary. Municipalities without access to complete historical records for lead line installations, for example, might be able to apply probabilistic approaches to determining how much lead is in their system.

How Klir Can Help

Klir is a single, unified operating system for water, pulling compliance, sampling, reporting and more into an easy to use dashboard. 

Learn more about how Klir can help your organization manage permits, cut down on administration and record-keeping work, and provide a level of organization-wide visibility unmatched by other systems.

Data Management for Backflow and Cross-Connection Control Programs

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Key takeaways:

  1. Backflow and cross-connection control programs generate a lot of data. Organizing and ensuring that data gets delivered to the right people—inspectors, customers, collaborators or regulators—on time is critical.
  2. As the amount of backflow data administrators are responsible for increases, storing and retrieving that data using paper and spreadsheet-based systems is becoming increasingly difficult.
  3. New data management technologies like Klir can help backflow prevention programs cut down on errors, automate away the most repetitive aspects of cross-connection control and help utilities achieve better and safer drinking water outcomes.

Residents in a Connecticut town knew there was something off about their washing machines, sinks and toilets: Hissing, bubbling noises were coming from the inside, while faucets sputtered out small streams of water mixed with a mysterious gas.

When they complained, city officials asked hundreds of residents to evacuate their homes and businesses. The gas was propane.

That same day, workers at a local propane storage facility had purged a tank in need of repair using water. That water came from a hose they attached to a city fire hydrant, and because the air pressure in the tank was higher than the one in the public water system, 2,000 cubic feet of propane gas backflowed into the city’s water supply over the course of 20 minutes. By the time city crews could respond, fires had broken out at two homes. At another home a washing machine exploded.

Backflow: An Enduring Challenge

Although no one ended up hurt, this is just one horror story out of many. Besides propane, substances reported in backflow incident reports have included pesticides, creosote, and even human blood. Backflow, if it isn’t controlled, can seriously harm or even kill the people relying on a utility’s potable water supply. And while the Safe Drinking Water Act and decades of new backflow and cross-connection control programming have helped to curb it, backflow is still an issue. One 2010 study found that backflow occurs in 5% of all homes with backflow-sensing meters.

Why Good Data Management Is Key to Backflow Prevention

As a water supplier, it’s your responsibility to maintain, monitor, and manage the systems that prevent backflow.

To achieve that goal, most cross-connection control programs must, at minimum:

  1. Install and maintain backflow prevention systems chosen according to level of hazard.
  2. Train and prepare water system personnel, including operators and inspectors.
  3. Periodically inspect and test backflow prevention systems.
  4. Maintain compliance with state and municipal plumbing and building codes.
  5. Educate customers and the general public about backflow risk.

Satisfying those goals involves collecting, managing and sharing backflow prevention data with numerous internal and external parties, including:

  • Customers
  • Plumbers
  • Local health agencies
  • Local building or plumbing departments
  • Other state and municipal authorities
  • Commercial stakeholders, including developers and contractors

One essential piece in your toolkit: An accurate, comprehensive record keeping and data management system that allows you to monitor and maintain the effectiveness of your program.

Your Cross-Connection Control Program, Streamlined

The sheer amount of data generated by backflow prevention programs might seem daunting and difficult to manage using paper and spreadsheets.

Thankfully, software-based platforms like Klir are making it easier than ever to retrieve and understand backflow data with powerful dashboards, asset mapping and project management automation capabilities. Learn more and request a demo today.

Data Management for Cross-Connection Control Programs: An Overview

According to the AWWA, most cross-connection control programs in the United States fall into one of four categories. 

Which one your organization implements will determine your responsibilities as a water supplier, your data management needs, as well as the outside parties you’ll need to report to and collaborate with.

1. System Protection

Also sometimes called Containment, Service Protection or Premise Isolation, under this kind of program each customer is evaluated (with a cross-connection risk assessment, covered below) on the level of hazard they present to the water system as a whole. 

Customers that present a significant hazard to the system have their connections contained from the rest of the system with a containment assembly installed at the meter or service connection to the water user.

What kind of protection does it provide? 

A system protection program only prevents on-site contamination from getting back into the water distribution system. The customers are ultimately responsible for what happens in their internal plumbing.

Whose responsibility is it? 

Usually it’s the local water suppliers, be they a public or private water department, and any system protection assemblies that are installed usually come under the control of the State Administrative Code.

2. Internal Protection

Under this kind of program, internal protection assemblies are installed to protect the quality of the drinking water within the water user’s building by protecting a specific piece of water-using equipment.

Property owners are responsible for implementing backflow protection according to guidelines set by the water supplier. That water supplier investigates to make sure effective prevention systems are in place, but does not inspect or test backflow preventers.

What kind of protection does it provide? 

An internal protection program protects the quality of the water within the facility.

Whose responsibility is it? 

In some cases it’s the local health agency, plumbing department or building department, and assemblies installed this way come under the control of the local Plumbing Code.

3. Comprehensive Programs

Popular with large city-run water utilities, these programs combine containment and isolation into one ‘comprehensive’ program. 

What kind of protection does it provide? 

These are considered to be the safest kind of program because there are two levels of protection: customer-side backflow preventers are the primary means of protection, and containment devices on the supplier side form a second line of defense. 

Whose responsibility is it? 

These are most common when the city or town is also the water supplier. Their jurisdiction and the fact that they control enforcement of the building code allows them to operate and enforce a comprehensive program.

4. Joint Programs

Private water suppliers without the jurisdiction that city-owned water suppliers enjoy might implement a joint program, which demands the cooperation of the water board, building inspection authorities, the fire department, and other responsible customers and users (such as secondary water suppliers.)

Such a program recognizes the standards and requirements of each authority involved, and aims to serve all their needs in order to deliver safe potable water.

Record Keeping For Cross-Connection Control: The Basics

Regardless of whether your program is focused on system protection, internal protection or both, it will likely generate a wide range of backflow-related reporting and correspondence, including:

  1. Cross-connection risk assessments
  2. An inventory of all backflow preventers
  3. Inspection and testing reports
  4. Backflow incident reports
  5. Correspondence with customers, utility personnel, and local authorities

Let’s take a closer look at each one, and also how and why you’ll want to organize and make those records available to internal and external users.

1. Cross-Connection Risk Assessments

A water supplier must complete a risk assessment for each customer in its water system. The assessment includes a water use questionnaire completed by the customer, as well as a cross-connection survey report.

The supplier should keep copies of both the initial assessment (completed when the cross-connection is initially established) and all subsequent reassessments (completed periodically according to the supplier’s cross-connection control program).

Water use questionnaire

A water use questionnaire collects information on how occupants of a premises use their water supply. That may include information about:

    • Any commercial activities in the building that could potentially impact the potable water supply during a backflow event (such as waste disposal or the use of industrial cleaning agents)
    • The presence of any storage tanks containing water that could make it into the water system during backflow
    • The presence (or absence) of backflow preventers, including their make, model, and service history

Cross-connection survey report

Completed by water supplier personnel, a cross-connection survey report includes information on:

    • Which cross-connections were surveyed
    • The hazard levels of the cross-connections surveyed
    • Any backflow preventers that were tested (and when, and by whom)
    • The testing kits used to test backflow preventers
    • Any violations detected during the survey

Cross-connection hazard levels

A cross-connection survey report includes information about the hazard level of each cross-connection surveyed, which will fall into one of three categories:

Low-Hazard (Pollution)

Potential backflow could pollute drinking water. The color, smell, and taste of the water could be affected, but there would be no adverse health effects to the people drinking it.

High-Hazard (Contamination)

Potential backflow could contaminate the drinking water. People drinking the water could become ill.

Lethal Hazard

This applies to radioactive material or raw sewage. A backflow event could result in death. In the case of lethal hazards, the only acceptable means of preventing backflow is an air gap. Mechanical backflow preventers should never be used for lethal hazards.

2. The Backflow Preventer Inventory

What are all of the assets that your backflow prevention program is responsible for? Your backflow preventer inventory should tell you.

It will include an entry for every customer in a water system, providing essential information on the backflow preventer installed at the cross-connection, including:

  • The location of the backflow preventer 
  • A description of the hazard being isolated, and its rating
  • The date the device was installed
  • The type of backflow preventer 
  • The make, model, capacity, and serial number of the preventer

Manage Assets and Plan Inspections With Klir’s Powerful Backflow Dashboard

Software systems like Klir can also display the status of your assets by location on a map, allowing personnel to plan routes and inspections visually and decreasing the chances that an asset will fall through the cracks. Book a demo to learn more today.

3. Backflow Inspection and Testing Reports

All backflow devices in a system must be inspected and tested on an annual basis. Each time, inspectors must file a report with the water supplier.

A water supplier’s collection of backflow inspection and testing reports helps to guarantee all devices are being monitored and maintained, minimizing the risk of failure and the likelihood of backflow events occurring.

The sample field test form from the Manual of Cross-Connection Control gives a good idea of what an inspection and testing report looks like before it is filled out. Generally, every report should include:

  • The name and phone number of the inspector/tester
  • The inspector/tester’s registration or license number
  • The date of inspection and the date of testing
  • Whether this was the first time the backflow device was tested, or whether it was an annual test
  • The results of the test
  • The device’s size, make, model number, and serial number
  • The device’s repair history
  • The device used for testing, including its make, model, serial number, and date of calibration
  • The name and phone number of the building contact

4. Tracking Backflow Incident Reports

In the event a backflow incident occurs, it’s essential to make sure it has been reported in as much detail as possible. You can get a sense of what is included in a backflow incident report from the reporting form used by the Pawtucket Water Supply Board.

Generally, an incident report should include:

  • Where the backflow originated from
  • The pollutants or contaminants (may include a chemical analysis)
  • Where pollutants or contaminants were distributed
  • The effects of pollution or contamination (including any adverse health effects)
  • The source of the pollution or contamination
  • The cause of the backflow
  • Corrective actions taken to restore water quality
  • Actions taken to prevent backflow from occurring again
  • The type of backflow preventer in place at the time

5. Correspondence 

Any time a water supplier communicates with external parties about cross-connections and backflow, it must keep copies of all correspondence. By doing so, it can track existing or recurring issues, or provide evidence in case of disputes. 

Additionally, any communications with personnel regarding the installation, inspection, or testing of backflow preventers should be saved.

When planning how to maintain records of correspondence, the following should be of highest priority:

  • Current service agreements with customers
  • Instructions for the installation of backflow preventers
  • Instructions for testing backflow preventers
  • Fines, warnings, and notices sent to customers
  • Communications with state and local administrative authorities

Why Good Data Management Makes Bulletproof Cross-Connection Control Programs

From the initial risk assessment to the moment a backflow incident report is filled out, good record keeping is crucial to almost every step of a healthy cross-connection control program. But why is managing and organizing that data in a centralized system so important? 

1. It’s the Law

As recommended by the AWWA, water suppliers must, at minimum, inform local regulators of:

  • The water supplier’s requirements, including the parameters for installing and maintaining backflow preventers in all premises
  • Results of the water supplier’s surveys of premises, including violations and any corrective actions taken
  • The receipt of any customer complaints that may indicate a backflow incident

In the event a state or local agency audits a water supplier, it may be legally necessary to present this information in order to avoid fines. Keeping those records in one place can save administrators a lot of time, stress and money.

2. It Makes Collaboration Easier

Any cross-connection control program initiated by a water supplier requires buy-in from a variety of outside parties, including customers, local authorities, plumbers and plumbing regulators, etc. 

When information needs to be exchanged, having it tied up in closed or outmoded systems—paper files, or local computer files that have to be sent as email attachments, for instance—naturally creates more work for everyone.

A comprehensive record keeping system makes it easy to securely store and share all records electronically, reducing hours of work and ensuring no important documents get lost in transit.

3. It Cuts Down on Risk, Paperwork and Administrative Overhead

Automatic alerts for scheduled events like inspection and testing or maintenance of backflow devices reduces the likelihood of errors.

Less Firefighting, More Peace of Mind

Integrated record keeping systems like Klir let you set up automatic alerts, so nothing ever slips between the cracks. Request a demo today to learn more.

4. Digital Records Are More Secure Than Paper

A digital record keeping system hosted on an external (ie. out of office) server is the most secure way to store, access, and share records for your organization. 

Water suppliers that rely on paper records for managing their cross-connection control program do so at their own risk. Paper records are more prone to damage, theft, and tampering than digital records. That puts the efficacy of your control program—and the safety of your customers—at risk.

5. It Makes Creating a Backflow Incident Response Plan Easier

A tidy digital record keeping system that lets you quickly and efficiently access your organization’s accumulated knowledge is a huge asset. The more information you have compiled about particular

  • Premises
  • Cross-connections
  • Contaminants and pollutants
  • Backflow preventers, and
  • Past backflow events,

the easier it is to create an effective backflow incident response plan. It also means less work for personnel—and fewer opportunities for errors—when determining the cause of a backflow incident and measuring its impact.

6. It Makes Dealing With System Growth Easier

As your water system grows, there are bound to be some bumps along the way. But a digitized record keeping system is able to meet the challenge, and scale with any growth on the horizon. 

Files stored locally on staff computers, or paper records that haven’t been digitized, all pose a risk to any water supplier aiming to smoothly scale. When you don’t have a central database to track your backflow preventer inventory, inspection and testing reports, and incident reports, it’s difficult to create standardized, repeatable processes and clearly defined workflows.

A digital records system fixes that by making sure you have all the information in one place, so your team can repeat what works, and improve on what doesn’t.


A cross-connection control program is essential for limiting the number of backflow incidents, conforming with federal, state and municipal monitoring requirements, and protecting the health of your customers. 

One of the most effective ways to manage your system and avoid errors is by using a centralized, digital records system that allows you to easily share information both within your organization and with outside parties.

Take Control of Your Cross-Connection Data

Klir’s cross-connection control module helps utilities schedule, organize, and run cross-connection control programs. Most importantly, it gives organizations the means to keep comprehensive digital records on all their cross-connection activities. Learn more and book a demo today.

How to Read and Manage NPDES Permits

Key takeaways:

  1. NPDES permits are long, complex and at times difficult to interpret for non-experts, and responsibility for them is often shared across teams that have an incomplete understanding of their contents.
  2. Reading your NPDES permit properly and making sure you’re reading the right version can help avoid confusion and mistakes when planning monitoring and compliance.
  3. Good recordkeeping and data management systems that centralize all permit-related reporting and correspondence can help everyone at your organization make sure they’re on the same page when it comes to your NPDES permit.

Few permits are as central to wastewater as National Pollutant Discharge Elimination System (NPDES) permits. But they’re also long, complicated and can be difficult to parse, which can lead to challenges around compliance

Large utilities might have several people responsible for different parts of an NPDES permit, which means information can sometimes get mistranslated or lost in the shuffle.

Worse, since permits must be re-issued every few years, facilities sometimes run the risk of employees reading from an old version with outdated information.

In this article, we’ll translate your NPDES permit into plain language. We’ll also go over some common mistakes people make when reading them, and discuss how good record keeping can help everyone at your organization make sure they’re on the same page when it comes to your NPDES permit.

What is an NPDES Permit?

Anyone who discharges pollutants from a point source into a water of the United States requires a National Pollutant Discharge Elimination System (NPDES) permit from their state or EPA Region.

Each of these terms is defined very broadly by the Clean Water Act, as decades of litigation have resulted in a cautious approach.

If you’re not sure whether something qualifies as a pollutant, point source, or water of the United States, assume it does until you can confirm it.


A pollutant is “any type of industrial, municipal, and agricultural waste discharged into water,” according to the EPA. Nearly anything you can think of can count as a pollutant — including some that aren’t obvious, such as soil, heat, and sand.

Point source

A point source is “any discernible, confined and discrete conveyance,” per the EPA, which is a fancy way of saying “the part where the waste comes out.” Pipes, ditches, channels, conduits, etc. count as point sources.

Water of the United States

A water of the United States, according to the EPA, is any “navigable waters, tributaries to navigable waters, interstate waters, the oceans out to 200 miles, and intrastate waters which are used: 

    • by interstate travelers for recreation or other purposes, as a source of fish or shellfish sold in interstate commerce
    • or for industrial purposes by industries engaged in interstate commerce.”

How Are Permits Issued?

Organizations apply for a permit through their state’s environmental regulatory agency or their regional EPA contact using the forms on the EPA’s NPDES portal

Who to apply to depends on the status of NPDES programs in your state or territory. If your state is partially authorized or unauthorized according to the map below, ask your regional EPA contact for guidance.

NPDES Program Authorizations as of July 2019

Permits are valid for five years. But that doesn’t mean you should file them away and forget about them. NPDES permits require regular upkeep to stay inside the bounds of the EPA’s guidelines. 

If your facility’s effluent output changes, for instance, you’ll need to update your permit.

What Does a Typical NPDES Permit Look Like?

NPDES permits can vary in appearance. State-issued permits might contain the logos of that state agency, for example. They might also use different terminology—for example, New York has its own version of NPDES called the State Pollutant Discharge Elimination System (SPDES). But each of these permits follow the same outline and use similar language. 

You can find digital copies of every federally-issued NPDES permit on the EPA website, and most state-issued permits are accessible through each state agency’s website. (California’s ​​State Water Resources Control Board makes all their permits available here, for example.)

The Main Parts of an NPDES Permit

All NPDES permits contain at least five sections:  

  1. A Cover Page including the name of the discharger, the permit number and the exact location of the discharge(s) and outfalls covered by the permit.
  2. Effluent Limitations laying out what pollutants the permit holder can discharge, how much and how often.
  3. Monitoring and Reporting Requirements that outline what the permit holder will do to stay compliant.
  4. Standard or General Conditions that apply to all NPDES permits and delineate the legal, administrative, and procedural requirements of the permit. 
  5. Special Conditions that might include additional monitoring activities, special studies, best management practices (BMPs), and compliance schedules.  

Here’s what you can expect to find in each one:

1. Cover Page

The permit cover page is a snapshot pf the most basic information about your NPDES permit, including:

  • the name of the discharger
  • the discharger’s address
  • a nine character NPDES permit number
  • the receiving waters
  • the exact location and coordinates of the discharge(s) and outfalls
  • when the permit comes into effect and expires

If you’re unsure whether the permit you’re looking at is up to date, the cover page should also have an Effective Date and an Expiration Date you can reference.

The cover page is usually followed by a schedule or list of submittals, which summarizes which reports you’ll have to submit to stay compliant, including Discharge Monitoring Reports (DMRs); applications for permit renewal; and noncompliance reports.

2. Effluent Limitations

Effluent refers to the pollutants that remain in wastewater after it’s discharged to surface waters. This is the most important part of your permit—it’s the reason it exists. 

There are two categories of limits to know about:

  • Technology-based effluent limits are minimum standards that broad categories of facilities must meet.
  • Water quality-based effluent limits (WQBELs) are in place to deal with pollutant concerns in a specific body of water due to the specific pollutant being discharged.

WQBELs are usually in place in small streams with little flow, waters that are very close to violating water quality standards, or waters with very few pollutants that regulators feel should be protected. 

Effluent limits themselves are defined using the following terms:

  • Load limits refer to the total amount of pollutant allowed per day, usually in lbs.
  • Concentration limits refer to the amount of a particular pollutant that is allowed in a volume of water discharged, usually in milligrams per liter (mg/l) or parts per million (ppm).
  • Monthly or 30-day average refers to the amount of pollutant you can release per day, over a monthly period.
  • Weekly average means the same thing — but weekly.
  • Daily maximum is the highest total amount of a pollutant you can release per day.

Allowable wastewater flow

The average (design average flow) and maximum (design maximum flow) number of millions of gallons per day (MGD) of wastewater that your facility can discharge may be listed on your permit in this section.

Effluent limits are usually recorded in table form, with effluents in the leftmost column and limits on the right.

The Effluent Limit table on Page 5 of the NPDES permit for the Brightwater Wastewater Treatment Plant in King County, Washington, for example, lists five parameters: Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS), Total Residual Chlorine, pH and Fecal Coliform Bacteria.

Effluent Limits in an NPDES permit for the Brightwater Treatment Plant in King County, Washington State

3. Monitoring and Reporting Requirements

This section lays out what kinds of samples must be taken and how often they must be reported. Some key terms to look out for here include:

Sample frequency

Your permit will let you know whether you must obtain samples daily, weekly, or monthly

Sample type

  • Continuous samples are taken constantly.
  • Grab samples are taken at a specific time not exceeding 15 minutes.
  • Composite samples are collected over time by continuous sampling or by mixing grab samples.

Whole Effluent Toxicity (WET) testing

Some permits will require WET testing, which measures the chronic and acute toxicity of the effluent as a whole—instead of just the concentration of each pollutant.

Instream monitoring

Some permits will require you to monitor not just the output of your effluent, but its impacts. This could include surveying sea life for health, sampling upstream and downstream, and more.

Stormwater contamination control

Municipal operators are often required to plan for stormwater runoff — including how effluent will change, where the stormwater will go, and a detailed sitemap.

Municipal pretreatment

Municipal sewage plants will often have to spell out their pretreatment program. If your facility discharges more than 5 million gallons per day, you probably have one such program.

4. General Conditions

This is an all-inclusive housekeeping-type section that includes when the permit holder must reapply for a new NPDES permit, when the facility can be inspected, and how to comply with state-specific laws.

It also deals with how the permit holder can navigate noncompliance, including their responsibilities and penalties for breaking rules. And it also lays out when, where, and how the permit holder must send notice to the authority for changes to their facility.

5. Special Conditions

This section outlines everything the permit holder needs to do to remain compliant outside of sticking to the effluent limitations outlined in the previous section. This might include:

Additional monitoring and special studies

This includes any sampling or testing that supplements or goes beyond regular monitoring. Treatability studies, toxicity identification evaluations, mixing or mixing zone studies, sediment monitoring, and bioaccumulation studies will all be referenced here.

Best management practices (BMPs)

These are any specific activities or prohibited practices your facility must adhere to, maintenance procedures it will have to follow, treatment requirements, and operating procedures to control things like spillage or leaks.

Compliance schedules

Some permits may include a schedule that provides the permit holder with more time to fix issues identified with their facility in the past. Examples include construction and inspection dates, pretreatment program development, and sludge disposal program implementation.

Common Mistakes People Make When Reading an NPDES Permit

These permits are often dozens of pages long and contain a lot of confusing jargon. There are any number of mistakes one can make while reading through it. But the most common ones tend to fall under the following categories:

1. Ignoring State-Specific Rules

Make sure you’re interpreting your permit based on the rules in your state, since they vary. These are usually outlined in the “General Conditions” section.

For instance, some states list a design maximum and design average flow of wastewater in MGD — though many don’t. Some states define the weekly average as going through Sunday to Saturday, while others define it as Monday through Sunday.

If you’re ever unsure about a part of your NPDES permit, seek out your state’s specific NPDES guidance documents or call your local authority for clarity.

2. Reading the Wrong Permit

Make sure you’re reading the most up-to-date permit available by checking the cover page for the Effective and Expiration dates of the permit.

Your organization may have altered its NPDES permit recently and it can do so at any time. 

Permits can be changed or updated when a wastewater treatment facility expands, changes ownership, updates its pollution control technology, or for many other reasons.

Permits will also be re-issued after they expire. But new permits are not always the same as the expired ones. 

You should receive a fact sheet along with your NPDES permit. That sheet should outline the changes. But don’t count on it — call your authority and ask to make sure.

3. Misinterpreting Sampling Requirements

The type and method of sampling will vary greatly from permit to permit. 

Know the difference between continuous, grab, and composite samples. Know what you’re sampling for. And know whether you’ll have to do WET testing, instream monitoring, or any of the other requirements listed above.

Remember, your permit will tell you whether you have to monitor your pollution output based on daily, weekly, or monthly averages.

4. Ignoring Additional Reporting Requirements

Every NPDES permit is different, and every wastewater facility is also different. Even if you’ve worked with other NPDES permits in the past, it pays to make sure you’re aware of all the rules and requirements that might be specific to your facility or organization.

How a Good Permit Management System Can Help

If navigating an NPDES permit itself wasn’t difficult enough, keeping track of all the additional paperwork involved in NPDES compliance—including Notices of Intent (NOIs), Municipal Separate Storm Sewer System (MS4) Program Reports, annual reports, and so on—can be downright frustrating. 

And it only gets worse when multiple staff members at your organization need access to that information. 

With all of that paperwork swirling around, the risk of making compliance decisions based on outdated permit information skyrockets.

That’s why in addition to making sure staff are able to read and understand them, it’s crucial that organizations store all of their permit documentation and related correspondence in a single, centralized permit management system that allows team members to:

  • Keep track of and set alerts for important permit-related deadlines
  • Generate permit reports automatically
  • Break down silos and make reliable permit information available across departments
  • Prevent lost, duplicate or outdated documentation

Eliminate Permit Confusion With Klir

Klir is a single, unified operating system for water, pulling every aspect of wastewater management—including compliance, sampling, reporting and more—into an easy to use dashboard. 

Learn more about how Klir can help your organization manage permits, cut down on administration and record-keeping work, and provide a level of organization-wide visibility unmatched by other systems.

How to Read and Fill Out Discharge Monitoring Reports (DMRs)

Key takeaways:
  1. One of the single biggest drivers of NPDES non-compliance is failure to properly submit a Discharge Monitoring Report (DMR).
  2. Staying compliant will mean cutting down on the major sources of DMR errors, including data management problems, calculation errors, confusion around state rules, and lack of clarity around permit rules in general.
  3. New data management technologies like Klir can help wastewater utilities cut down on errors, automate away the most repetitive aspects of DMR reporting and help utilities achieve their NPDES compliance goals.

Wastewater operators deal with a lot of paperwork in their day to day. But perhaps no single report is more central to wastewater than the Discharge Monitoring Report (DMR), the form wastewater utilities use to self-report compliance with environmental law in the United States.

If your facility is issued a National Pollutant Discharge Elimination System (NPDES) permit that requires sampling and monitoring, it must submit DMRs. The frequency with which you must submit DMRs is usually specified in the permit, and most reporting intervals are monthly, quarterly, semi-annually, or annually.

Although state and federal regulators will usually be the first to see them, DMRs aren’t just a tool for regulation. They’re also posted to the EPA’s Enforcement and Compliance History Online (ECHO) database, where they become an important resource for environmental groups, researchers and other members of the public.

DMRs and NPDES Non-Compliance

According to the EPA, more than half of all NPDES permit violations are reporting-related, most of which involve a permit holder failing to submit a completed DMR to the EPA or appropriate state agency.

As the EPA increases its efforts to crack down on significant non-compliance (SNC), eliminating reporting errors & delays will be more important than ever. Here we’ll review some of the most common submission errors that EPA officials encounter when reviewing DMRs and explore how better data management can help avoid them.

Submitting a DMR: the Basics

As of December 21, 2016, the EPA requires that DMRs be submitted electronically. Which tools you use to report electronically will depend on which state you’re in and which authority issued your permit. 

Most states either use NetDMR, a web-based tool provided by the EPA that allows you to electronically sign and submit DMRs, or a state-specific electronic discharge monitoring report system (eDMR).

As of January 2022, Nevada, Kansas, Oklahoma, Missouri, Ohio, West Virginia, Pennsylvania, Virgina, North Carolina, South Carolina, and New Jersey only use eDMRs, while all other states use both or just NetDMR.

How to Fill out an Electronic DMR

The NetDMR and eDMRs interfaces can vary, so we’ll refer to the sample physical DMR form provided by the EPA for simplicity’s sake here. 


The main purpose of a DMR is to report sampling data. Maximum, minimum and average sample measurement data are recorded in each row for each parameter, as well as:

A. The number of exceedances, which is the total number of sample measurements that exceed the daily maximum, daily minimum and weekly average permit limits.

B. The frequency of analysis, “01/07” for once a week, “01/30” for once a month, and so on.

C. The sample type, with “GRAB” indicating an individual sample, “24HC” a 24-hour composite sample, and “CONT” indicating continuous monitoring.

But that isn’t the only information you’ll need to fill out a DMR. You’ll also need:

  1. The permittee’s name and mailing address.
  2. A facility address (if different from above). 
  3. A nine character NPDES permit number.
  4. A four character discharge or outfall number.
  5. The monitoring period for this particular DMR, written out in Year, Month, Day format. For example, a January 1st to March 31st monitoring period would be written out as: “22 01 01 to 22 03 31.”
  6. The parameters specified in the NPDES permit. Each box must contain only one parameter name as well as the relevant STORET code, and parameters must be recorded in numeric order (by STORET code).
  7. See “A, B and C” above.
  8. The name or title of the Principal Executive Officer or Authorized Agent signing off on the DMR. (Who qualifies here should be spelled out in your permit.)
  9. The Original authorized signature of the Principal Executive Officer or Authorized Agent.
  10. The telephone number of the Principal Executive Officer or Authorized Agent.
  11. The date of the signature, in Year, Month, Day format.

Avoiding the Most Common DMR Errors

While everything from miscalibrated equipment to poor data management can contribute to reporting problems, according to the EPA and state administrators who read them, the most common DMR errors tend to fall into the following broad categories:

1. Not Reading or Understanding Your NPDES Permit

One of the most common mistakes operators will make is to gloss over important details of their permit, which should contain most of the information you’ll need to start filling out a DMR.

To avoid this, review an up to date version of your NPDES permit carefully and pay particularly close attention to:

  • Whether the permit has been re-issued recently, and whether any of the requirements have changed since the last version.
  • The load and concentration limits listed in the Effluent Limitations and Monitoring section of the permit, which may be measured over different periods of time and vary by parameter. 
  • If the permit is new, make sure the load and concentration limits agree with each other by converting concentration limits into load limits, or vice versa.
  • Any additional reporting you might be required to do for biosolids, biomonitoring, industrial pretreatment and so on.

If anything about your permit isn’t clear, contact your permitting authority for clarification.

2. Forgetting State-Specific Rules 

The language, definitions and requirements that permit writers use can vary quite a bit from state to state, and different state authorities also have different guidance documents that you need to follow when filling out a DMR. Some of these are available online (see the end of this guide for a full list) while others you might have to ask for.

But as the EPA’s Emilio Llamozas points out in a recently-published webinar, there are certain variations across state lines that routinely cause confusion. These include:

Definitions and Permit Language

Sometimes the way that your state understands or defines a word might not match up with your definition of that word. For example, although most NPDES permits make reference to monthly and weekly averages, not all states define those time periods the same way.

    • Some might define the “weekly average” as the week going through Sunday through Saturday.
    • Meanwhile a permit in another state might define it as going from Monday through Sunday

You might get different results with the two different definitions, so it pays to get clear on which one your permit is referring to.

Recording Non-Detects 

Some states might require you to record non-detects using the < symbol, accompanied by the method detection limit, while other states require that sample results below the practical limit of quantification be reported as zeroes

Other states might require you to use a no data indicator (NODI) code, specifically NODI code B, when the result is less than the method detection limit.

Practical Quantification Limits

Your permit might or might not also specify Practical Quantification Limits (PQLs), which indicates the minimum concentration of a substance that can be accurately measured in routine laboratory operating conditions. 

For example, your permit might provide a PQL of 5 μg/L for copper. If your current method of measuring copper has a PQL of 6 μg/L, you’re out of compliance with the permit’s PQL requirement and you’ll have to use a different method.

Additional Monitoring

If you monitor any pollutants more frequently than is required by your permit, your permit might require you to indicate and include those results in your DMR. Same goes for any erroneous or incomplete measurements, which you’ll need to make note of in the comments section of the DMR.

Rounding Numbers

Significant digits and rounding numbers can also be a source of confusion. The American Public Health Association’s rules for rounding, which most states use and can be tricky to follow, are a good example of this.

Numbers that end in 6, 7, 8 or 9 are rounded up, and numbers ending in 0, 1, 2, 3 or 4 are rounded down—so far so good. But if you’re dropping a 5 digit, the previous digit is rounded off to the nearest even digit

So for example: 

    • 1.05 would be rounded off to 1.0 (not 1.1), because 0 is the closest even digit. 
    • 1.15 would be rounded off to 1.2
    • 1.45 would be rounded off to 1.4 (again, because 4 is the closest even digit).

3. Data Mismanagement 

The movement of data from the lab where it is originally collected to the DMR can create lots of opportunities for error, which is one reason why so many utilities have pushed to adopt digital tools for data management and reporting in recent years. 

But as the EPA’s Juan Ibarra points out, whether you’re getting data from an external lab or an internal one, it’s ultimately your responsibility to check the data you’re plugging into the DMR to make sure it’s accurate.

He suggests that the best way to avoid this is to do what EPA inspectors do and “follow the data,” tracing it from the bench or worksheet, to the Monthly Summary, and finally to the DMR, taking particular care to:

  • Make sure the DMR mirrors the permit when it comes to parameters, frequency, sample type and location
  • Run the calculations for each parameter
  • Look at other review periods if you notice something wrong in the current one

4. Calculation Errors

It’s rarely the case that the units in your permit will line up exactly with the units in your raw sampling data. You’ll need to perform calculations to convert that data to the units required in the permit, but when those calculations are performed by hand, they can become a major source of errors, which might include:

  1. Calculating monthly average loading using average flow and average concentration of pollutant instead of dividing total loading calculated for each sample day by the total number of samples.
  2. Calculating maximum loading using maximum flow and highest concentration of pollutant (daily maximum loading does not necessarily occur on the same day as the daily maximum concentration).
  3. Trying to average a pH value (the pH scale is logarithmic). 
  4. Calculating Fecal Coliform as an arithmetic rather than a geometric mean.
  5. Calculating monthly average concentration without weighting it for flow
  6. Including data that falls outside of the month you’re calculating for in a monthly average calculation. (This usually happens when a week falls across two months and the 7-day average you calculated for that week finds itself into the monthly average.)

In addition to double checking your calculations for these specific figures yourself, it might also be worth running all of the calculations you perform for a DMR by a second person at your organization trained to perform those calculations.

How Digital Tools and Consolidation Can Help

Managing, storing and analyzing compliance data properly can be difficult—but it’s also crucial if operators want to avoid making errors in their reporting.

Filling out a DMR often involves wading through numerous different datasets, forms, spreadsheets, and other software tools. Constantly switching between data sources this way increases the chances of error and makes it difficult to check your work if you ever do decide to retrace your steps.

Consolidating all permit, monitoring, and sampling data and managing it using compliance software built specifically for wastewater utilities (such as Klir) can help operators:

  1. Automate simple repetitive tasks like copying and pasting, saving hours of busywork and cutting down on errors.
  2. Generate reports automatically and entrust math to software, cutting down on calculation errors.
  3. Eliminate application overlap and the need to context switch between paper-based and digital tools, eliminating the risk of creating overlapping data.
  4. Make sure that everyone who needs to access NPDES permits knows where they are, cutting down on risk of permit misinterpretation.

State-specific DMR guidance documents

In addition to the common mistakes reviewed above, you’ll need to review your own state’s guidance for DMRs in order to get the most accurate picture of what to avoid when completing one. 

Many states have published guides specifically for filling out DMRs, some of which are available on the internet and are listed below. At the same time, some of these guides may contain out of date information. The fact remains that the best way to get clear on DMRs is to talk to your state and use it as a resource.

State Agency

DMR Guidance Document

Arkansas Department of Environmental Quality

NPDES Reporting Requirements Handbook

Connecticut Department of Environmental Protection

Discharge Monitoring Report Instruction Manual

EPA Region 6 (New Mexico, Oklahoma, Louisiana, Arkansas, Texas)

NPDES Reporting Requirements Handbook

Federal EPA

NPDES Self-Monitoring System User Guide

Florida Department of Environmental Protection

Helpful Tips for Completing DMRs

Minnesota Pollution Control Agency

MPCA Wastewater Permit User’s Manual – NPDES and SDS permits

New York State Department of Environmental Conservation

DMR Manual For Completing the Discharge Monitoring Report for the State Pollutant Discharge Elimination System (SPDES)

New Jersey Department of Environmental Protection

NJPDES Monitoring Report Form Reference Manual

Oregon Department of Environmental Quality

Completing Discharge Monitoring Reports (DMRs)

Oklahoma Department of Environmental Quality

Guide to Preparing eDMRs

Pennsylvania Department of Environmental Protection

Discharge Monitoring Reports: A Guide to Electronic and Paper DMR Reporting 

Rhode Island Department of Environmental Management

Rhode Island Pollutant Discharge Elimination System (RIPDES) Discharge Monitoring Report (DMR) Instructions

Vermont Department of Environmental Conservation

eDMR tip sheet(NODI Codes) and Measurement Frequencies

Washington State Department of Ecology

Information Manual for Treatment Plant Operators 

West Virginia Department of Environmental Protection

NPDES Reporting Reference Manual

De-risk NPDES Data Management and Reporting With Klir

Klir is a single, unified operating system for water, pulling every aspect of wastewater management—including compliance, sampling, reporting and more—into an easy to use dashboard. Learn more about how Klir can cut down on administration and record-keeping work, create new opportunities for collaboration, and provide a level of system-wide visibility unmatched by other water data management systems.

On the Path to Full NPDES Compliance

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Key Takeaways

  1. Wastewater compliance professionals often manage critical data across a patchwork of paper-based, legacy, and modern data management systems. These fragmented systems introduce risk when managing NPDES compliance because there is no single source of truth.
  2. To make progress on significant non-compliance under NPDES, wastewater utilities will need to adopt better data management tools. These can help cut down on repetitive administrative work, make reporting easier and promote a proactive approach to tackling effluent and compliance schedule violations.
  3. These technologies also present wastewater utilities with the opportunity to move ‘beyond compliance’ by adopting practices that promote resiliency and prepare them for longer-term risks.

Compliance with the National Pollutant Discharge Elimination System (NPDES) permit program touches every aspect of what wastewater utilities do—from the sampling and monitoring regimes they implement, to the way IT departments manage their data, to the way operators calibrate and maintain their equipment.

At the same time, many utilities today continue to struggle to consistently meet the terms of their permits. Between a third and half of all major NPDES dischargers report some kind of violation every year, and in 2018 more than one in five found themselves in significant noncompliance (SNC) with NPDES, garnering hefty penalties and hours of headache-inducing paperwork.

Although the EPA’s National Compliance Initiative and programs like the Wastewater Expedited Settlement Agreement Pilot have made some inroads, noncompliance remains a problem for wastewater utilities and it pays to consider some of the steps operators, compliance managers and IT professionals can take to address it.

Getting to the Root of Significant Noncompliance 

Although effluent discharge and compliance schedule violations are a big problem, according to the EPA more than half of all cases of SNC under NPDES are reporting violations, and 7 out of 10 wastewater SNC violations between 2018-2020 were triggered specifically by a permit holder failing to submit a Discharge Monitoring Report (DMR), the primary method by which dischargers self-report compliance with the conditions of their permits.

National Quarterly DMR Non-Receipt Rate, 2018-2019

Source: EPA Region 1, 2020

What’s driving wastewater’s NPDES reporting problem? At a recent conference, EPA Office of Compliance head David Hindin suggested that everything from regulation complexity to workplace norms could be at play. 

“Common sense and our professional judgment may provide an effective basis upon which to implement environmental compliance programs—except when they don’t,” said Hindin. 

But while it may be easy to blame these failures on human error, the truth is that operators and compliance professionals at wastewater utilities often work in environments that are uniquely stacked against them from a data and reporting perspective.

  • Sampling data is often trapped in log sheets, spreadsheets and SCADA systems, creating data opacity and discouraging proactive data analysis practices.
  • The highly repetitive nature of reporting work itself—often involving the simple act of copying and pasting data from one source to another—creates a breeding ground for basic data entry mistakes.
  • Compliance and reporting processes remain poorly documented, trapped in the heads of one or a handful of individuals at the wastewater utility, or not documented at all. 

This guide lays out steps wastewater utilities can take to avoid these hurdles, do more with the data they already collect, use information technology to build resiliency and cultivate proactive practices, and ultimately set themselves on the path to full compliance under NPDES.

1. Fix the Gaps and Roadblocks in Your Compliance Data Workflows

Over the last two decades, a patchwork of paper-based recordkeeping, legacy software and more modern enterprise software has defined data management practices at wastewater utilities. 

Newer data management software is giving wastewater operators the ability to move beyond this status quo, however progress has been slow.

Although many already do an excellent job of sampling and monitoring, it’s too often the case that those efforts are hindered by workflows that are out of date, hard to work with, or simply nonexistent.

Completing a Discharge Monitoring Report (DMR) for a large wastewater utility often involves wading through a variety of different datasets and software tools, and every bit of friction in that process increases the risk of noncompliance. Specific pain points include:

Outdated Legacy Systems

Many facilities continue to manually enter their data into physical log sheets or SCADA systems, which can cause problems when it comes time to get that data back out and into the hands of a regulator. Additional data entry work, unfriendly user interfaces and slow software can turn tasks that should take minutes into ordeals that can take hours.

Error-Prone Reporting Tasks

Much of the work involved in NPDES compliance and reporting is highly repetitive, often involving copying and pasting data over and over again from spreadsheets and formulas into reports, and creating numerous opportunities for human error. Worse still, manually moving data across documents makes it difficult to identify those errors later, and also opens users to the risk of data duplication or deletion.

Too Many Tools

While paper-based record-keeping can pose problems, loading up on too many software tools can create a situation that is just as painful from a reporting perspective.

“One of the difficulties with diving into the digital world is that you end up having an app for this, and then an app for that, and then an app for that,” points out Adam McKnight, Data Analyst for Halifax Water’s Water Quality Programs. 

Digital transformation should be an important goal for every large wastewater utility, but spreading data across too many dedicated apps can make data management a time-consuming and frustrating experience.

Adopting Tools That Actually Work

While spreadsheets are currently the tool of choice at many wastewater utilities for managing, storing and analyzing compliance data, utilities will have to move past them if they’re to make any progress towards full compliance.

In a recent issue of AWWA Journal, Philadelphia Water Department environmental engineer Tyler C. Bradley points out how over-reliance on spreadsheets can contribute to “human error, lack of reproducibility, and lack of version control. While it is possible to overcome these by using a well-organized worksheet, the work is subject to these errors whenever a different user makes changes.”

The collaborative, cross-functional nature of work at wastewater utilities and the sheer volume of data they’re collecting means that we’ll need new tools that avoid these pitfalls and help users:

Automate Repetitive (and Easy-to-Automate) Tasks

The more repetitive the work, the more important it should be for a wastewater utility to automate it using procured or self-build data management software. Doing so can save administrators hours of busywork and cut down on the probability of human error.

Generate Reports

Compliance reporting and analysis often involves performing calculations on raw data, and doing so manually via spreadsheet can make it difficult for other users to review that work for errors. Entrusting this work to software that generates reports automatically can remove a significant amount of risk from this process.

Eliminate Application Overlap

When possible, utilities should prioritize software that integrates sampling, operations, research and other data and eliminates the need to context switch, learn new tools and create potentially overlapping datasets.

Outflows from LA Sanitation’s Hyperion Water Reclamation Plant 1-Mile Outfall (Photo credit: Google Earth)

2. Use Data to Move From Reactive to Proactive Problem Solving

While NPDES reporting violations are a problem, they’re not the only source of significant noncompliance at wastewater utilities. 

Even if better data management practices can make submitting DMRs a less painful process, effluent limit exceedances and compliance schedule violations will continue to be a serious problem, leading to operational headaches, EPA fines and poorer public and environmental health outcomes.

When implementing technologies that make it easier to report compliance and violations, it pays to consider how those same technologies can help wastewater utilities avoid violations in the first place—specifically by transforming wastewater problem-solving from a reactive process to a data-driven, proactive one. Specific ways that wastewater utilities can do this include:

Improving Remote Monitoring Capabilities

COVID-19 lockdowns across the country drove home the reality that the future of work is distributed and that the ability to access our work remotely is key to resilience. 

Thankfully the water industry is already ahead of the curve in this respect: many utilities already manage thousands of infrastructure assets remotely using sensors, controllers and transmitters. Building on that success and bringing remote monitoring data into a single, easily accessible system can help utilities:

    • Cut down on travel and site visits
    • Implement more accurate notification and alert systems
    • Shorten response times
    • Scale new operations quickly
    • Respond to unexpected staffing shortages 

Increasing Access to Real-Time Data

Being able to monitor water quality, energy consumption, pressure levels and myriad other data points in real time also gives operators, engineers and compliance workers the opportunity to spot and address new trends before they become problems. Making sure those real-time figures are accessible via user-friendly console or dashboard will be increasingly important as wastewater utilities consolidate and build out their data management systems.

Adopting Tools That Make It Easier to Share and Collaborate

Wastewater utilities don’t need algorithms and complex math to use data to tackle compliance challenges. In many cases, finding ways to make sure data is available to the right people at the right time can be just as important.

That’s why tools that create opportunities for communication and data sharing between compliance, operations, engineering and all other business units within a wastewater utility are also crucial. For larger organizations, that often means centralizing data in a universal, easy-to-access system that provides a single source of truth.

3. Aim Beyond Compliance

Wastewater treatment facilities aren’t always perfectly designed, and the world outside of them is subject to constant change. Trends that could impact the ability of wastewater facilities to stay compliant and successful include:

  • Urbanization and other fluctuations in population and flow
  • Shifts in the needs of local industry
  • The emergence of newly-regulated contaminants like PFAS
  • Changing regulations and permit requirements
  • Maintenance, design and equipment challenges
  • Increasing budgetary constraints 

Although it’s hard to beat compliance when it comes to north stars for wastewater utilities, if organizations are to truly succeed in an increasingly unpredictable future, they’ll have to build systems that account for the unexpected, build resilience and move beyond compliance as the sole goal.

Turn Data Graveyards Into Data Mines

The amount of data generated by wastewater treatment plants has increased exponentially over the last few decades. 

One 2014 study found that a single large wastewater treatment plant (0.8-3 million population served) can generate upwards of 30,000 data points, encompassing everything from sampling data to GPS coordinates, call logs, field notes and more. 

“Plant operators have an overwhelming stream of data at their hands, which is very difficult to process and analyze in a timely enough fashion to allow for better understanding or proper decision-making,” writes Lluís Corominas, a researcher at the Catalan Institute for Water Research. 

To better understand and predict noncompliance in our wastewater treatment systems, we’ll have to move from seeing these vast databases as a liability—or as Corominas puts it, “data graveyards”—to a valuable asset that can be mined for actionable knowledge. 

Leverage Machine Learning and Other Data Science Techniques

One benefit of adopting the data management practices and tools discussed earlier is that they open the door to more sophisticated forms of monitoring and analysis that ultimately allow utilities to do more with what data that they already have. 

Machine learning methods that determine patterns within large datasets are one such technique that is already showing promise in the urban water sector.

  • A recent pilot of machine learning tools for predictive control and advanced analytics at Singapore’s Ulu Pandan Water Reclamation Plant helped operators achieve a 15% reduction in aeration energy usage compared to conventional techniques. 
  • Similar techniques have recently been used to analyse wastewater data to determine the scale of local COVID-19 outbreaks in China and Canada
  • In 2018, researchers from Stanford also demonstrated how machine learning techniques could be used to double the number of Clean Water Act violations detected without increasing the number of inspections.

While many of these tools are still in their infancy, there’s no question that there are valuable insights to be gained from wastewater data, and that the sooner utilities can store, organize and centralize this data, the better.

How Klir Can Help

Klir is a single, unified operating system for water, pulling every aspect of wastewater management—including compliance, sampling and more—into an easy to use dashboard. Learn more about how Klir can cut down on administration and record-keeping work, create new opportunities for collaboration, and provide a level of system-wide visibility unmatched by other water data management systems.

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