One of EPA's strategic goals is to restore and maintain our oceans, watersheds and their aquatic ecosystems to protect human health, support economic and recreational activities, and provide healthy habitat for fish, plants and wildlife.
EPA measured the percent of major federal facilities with significant non-compliance (SNC) under the Clean Water Act (CWA) was higher than the percentage of SNCs under any other statute and has been higher for a number of years. These findings are outlined fully in the various State of Federal Facilties Reports. Federal agency compliance with requirements of permits issued under the CWA is lower than under any other environmental statute. In particular, Federal wastewater treatment facilities regulated under the National Pollutant Discharge Elimination System (NPDES) have poor reported compliance rates (see the Enforcement and Compliance History Online (ECHO) system, the Online Tracking System (OTIS), and the Permit Compliance System. If there is incorrect information in ECHO, there is an error correction process where Federal users can submit corrections.
In addition to the CWA, The Federal Facility Compliance Act (FFCA) dated 6 October 1992, amended the Solid Waste Disposal Act (SWDA) and addressed requirements for Federally owned treatment works (FOTW) under 42 USC 6939(e) (PL 102-386). The FFCA establishes a conditional domestic sewage exclusion for industrial discharges to an FOTW. This allows an FOTW to accept hazardous wastes, provided that certain conditions are met and the wastes are not acutely hazardous.
In general, facilities which discharge pollutants to water bodies are required by the CWA Title IV to obtain a permit (from an authorized state agency or EPA) for that discharge. The process for obtaining a permit and who is required to have a permit is codified in 40 CFR 166. The permit imposes restrictions and limitations on that discharge as well as including sampling and reporting requirements. EPA-identified Clean Water Act violations at federal facilities typically involve the facility discharging pollutants into rivers, streams, bays, oceans and other water bodies in excess of what their permit allows.
EPA is working directly with a number of noncompliant federal facilities to identify the root causes of their permit violations. In March 2006, EPA held a collaborative workshop with representatives of these facilities and wastewater treatment experts to identify practicable strategies to remedy their existing violations and prevent future violations. The meeting notes provide an overview of the NPES Integrated Strategy, NPDES reporting, and Agency-specific information from the Army.
After working with DoD components on improving compliance with the CWA, in January 2007 DoD issued a policy memorandum establishing a new goal of zero CWA significant non-compliance events. The memorandum also requires each DoD component with SNCs to identify the root causes of the non-compliance and to develop an action plan to remedy the non-compliance and prevent future non-compliance situations.
One of those strategies and solutions is to manage your wastewater facility through your environmental management system (EMS). The suggestions include recommendations for improving environmental management practices in response to specific examples of non-compliance at Federal facilities. It is based on information gathered from Federal agencies and facilities regarding non-compliance with NPDES requirements as well as information presented and discussed at an interagency Workshop held at EPA Headquarters in early 2006. For detailed regulatory information on who is required to obtain a NPDES point source discharge permit, how to go about obtaining that permit, and the responsiblities of the permitee see Home->Assistance->Facility Regulatory Tour->Wastewater Treatment Facilities.
For detailed regulatory information on who is required to obtain a NPDES point source discharge permit, how to go about obtaining that permit, and the responsiblities of the permitee see Home » Assistance » Facility Regulatory Tour » Wastewater Treatment Facilities.
In order to facilitate compliance with discharge reporting requirements, the Navy has issued guidance providing detailed information for submitting accurate discharge monitoring reports (DMRs) on time in order to reduce the occurrence of noncompliance findings due to incomplete or late DMR submittals