NPDES - Klir

How to Read and Manage NPDES Permits

Posted on March 10, 2022March 17, 2022 by Nick Zarzycki

Key takeaways:

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must be re-issued every few years, facilities sometimes run the risk of employees reading from an old version with outdated information.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

Pollutant

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:

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.
Effluent Limitations laying out what pollutants the permit holder can discharge, how much and how often.
Monitoring and Reporting Requirements that outline what the permit holder will do to stay compliant.
Standard or General Conditions that apply to all NPDES permits and delineate the legal, administrative, and procedural requirements of the permit.
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.

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)

Posted on February 23, 2022March 17, 2022 by Nick Zarzycki

Key takeaways:

One of the single biggest drivers of NPDES non-compliance is failure to properly submit a Discharge Monitoring Report (DMR).
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.
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:

The permittee’s name and mailing address.
A facility address (if different from above).
A nine character NPDES permit number.
A four character discharge or outfall number.
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.”
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).
See “A, B and C” above.
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.)
The Original authorized signature of the Principal Executive Officer or Authorized Agent.
The telephone number of the Principal Executive Officer or Authorized Agent.
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:

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.
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).
Trying to average a pH value (the pH scale is logarithmic).
Calculating Fecal Coliform as an arithmetic rather than a geometric mean.
Calculating monthly average concentration without weighting it for flow.
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:

Automate simple repetitive tasks like copying and pasting, saving hours of busywork and cutting down on errors.
Generate reports automatically and entrust math to software, cutting down on calculation errors.
Eliminate application overlap and the need to context switch between paper-based and digital tools, eliminating the risk of creating overlapping data.
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

Posted on February 7, 2022August 2, 2022 by Nick Zarzycki

Download the Guide

Join the club to get a PDF version you can share with the team or take on-the-go.

Key Takeaways

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.
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.
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

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.

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.