Mark Stanifer, IDEM, The Most Commonly Reported NPDES Violations in Indiana, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

1. Midwest Environmental
Compliance Conference
Chicago Mariott O’Hare
October 29, 2015
Mark Stanifer, Chief
Compliance Branch
Office of Water Quality
Indiana Department of Environmental Management

2. The Most Commonly Reported
NPDES Violations in Indiana
• Most frequent reported
• Findings/violations identified by inspectors
• Compliance rates identified by inspectors
• Enforcement cases by sector
• Other happenings at IDEM

3. Five most frequent self-reported
numeric effluent violations overall:
January through June 2015 (from ICIS)
– Ammonia 641
– Total Suspended Solids 460
– E. coli 221
– CBOD 196
– Residual Chlorine 177
• All of these are typical of sewage

4. Five most frequent self-reported
numeric effluent violations:
Nonconventional pollutants
January through June 2015 (from ICIS)
• Iron 32
• Zinc 24
• Copper 22
• Molybdenum 17
• Cyanide 14

5. Most frequent violations identified by OWQ
staff at NPDES facilities OVERALL
2014 and 2015
– Numeric effluent violations
– SSO, overflow, bypass events
– Poor operation and maintenance
– Self-monitoring, records, reports—late and missing
– Lab issues (techniques, documentation)
– Inadequate flow meters

6. Most frequent single event violations (SEVs)
identified by inspectors at major NPDES
facilities during 2014 and 2015
– SSO, Overflow, Bypass
– Operations
– Self-Monitoring, Records, Reports
– Maintenance
– Lab issues

7. Inspections Conducted during 2014 and 2015
Recon CEI Complaints
Violations to enforcement 6 12 1
Violation letters 248 546 14
Minor issues identified 101 391 11
No violations identified 329 681 24
Total: 2364

8. Compliance ratings determined by inspectors
at NPDES facilities during 2014 and 2015.
MAJOR dischargers: By sector
Number
Inspected % Compliance
Industrial 67 98.64%
Mixed Ownership 13 89.58%
Municipality 237 93.56%
State/Federal 1 71.43%
Total/overall: 318 94.39%

9. Compliance findings identified by inspectors at
NPDES facilities during 2014 and 2015
MINOR dischargers: By sector
Number Percent
Inspected Compliance
General 255 97.99%
Industrial 466 96.39%
Mixed Ownership 484 88.84%
Municipality 637 90.30%
Pretreatment 224 95.96%
State/Federal 67 94.06%
Total/overall: 2133 92.57%

10. NPDES Enforcement Cases Initiated (NOVs)
by Sector
1-1-14 to present
Major Minor
Semi-public 1 7
Municipal 8 14
Industrial 1 5
Unpermitted NA 3

11. NPDES Enforcement Cases Resolved With
Final Order, by Sector
1-1-14 to present
Major Minor
Semi-public 2 9
Municipal 6 20
Industrial 3 5
Operator NA 5
Unpermitted NA 4

12. Staff Changes
• Chief of Staff Carol Comer became Commissioner
• OWQ Assistant Commissioner Bruno Pigott
became Chief of Staff
• OWQ Deputy Assistant Commissioner Martha
Clark Mettler became Assistant Commissioner
• OWQ Permits Branch Chief Paul Higginbotham
became Deputy AC

13. Electronic Reporting

14. NPDES Electronic Reporting Rule
• EPA proposed rule July 2013, supplemental notice
December 2014.
• OMB review completed & signed by Administrator
McCarthy 9-24-15.
• Published in Federal Register October 22.
• Effective date December 21, 2015.
• Deadline for electronic submission of DMRs end of 2016.
• Other reports end of 2017 (maybe).
• Indiana using NetDMR application for DMRs.
• 50% of Indiana NPDES facilities now enrolled in/using
NetDMR.

15. WW Operator Certification Exams
Up an running!
• New System
– Offer exam through Ivy Tech Community
College and IDEM.
– 26 IVY Tech testing centers
– Exam scheduled by appointment
throughout the week
– Results available immediately
• Old and New System
– IDEM continues to offer the exam once
annually
– 12 people sat for paper exam Oct. 8

16. Questions?
Mark Stanifer
Branch Chief
Compliance Branch
Office of Water Quality
Indiana Dept. of Environmental Mgmt.
317-232-8431
mstanife@idem.IN.gov