A EPA COMPLIANCE ADVISORY --SKS5KK5S
National Compliance Initiative: Reducing Significant Noncompliance with National Pollutant Discharge
Elimination System Permits
EPA Document # 305F20006	December 2020
Federal Facility Compliance Under EPA's National
Compliance Initiative to Reduce Significant
Noncompliance with CWA NPDES Permits.
>	This advisory is intended to notify federal facilities with NPDES permits about an EPA-State enforcement and
compliance initiative focused on improving permit compliance and to help permittees with compliance problems
achieve or maintain compliance.
>	To improve surface water quality and reduce potential impacts on drinking water, EPA and states are focusing
increased attention on all individually permitted Clean Water Act National Pollutant Discharge Elimination System
(NPDES) permit holders in significant noncompliance (SNC) - including federal facility NPDES permit holders.
>	View EPA's NPDES SNC National Compliance Initiative (NCI): https://www.epa.gov/enforcement/national-compliance-
initiative-reducinq-siqnificant-non-compliance-national-pollutant
>	Significant noncompliance (SNC) is a designation given by U.S. EPA to NPDES facilities with violations of a more
serious nature and cause for concern. Pursuant to EPA enforcement policy, these violations will likely warrant an
enforcement response by EPA or the authorized state particularly if not promptly resolved by the permittee. For the
technical definition of CWA SNC, see https://echo.epa.gOv/help/reports/dfr-data-dictionarv#cwasnc.
Federal Facility Regulation Under the NPDES Permit Program.
The NPDES program, created in 1972 by the Clean Water Act (CWA), helps protect human health and the environment
by regulating water pollution from point sources that discharge pollutants into waters of the United States. Section 313 of
the CWA (33 U.S.C. § 1323) requires federal agencies to comply with federal, state, interstate, and local requirements to
control and abate water pollution, including, but not limited to, compliance with the NPDES permits.
A federal facility permitted under the NPDES program by EPA or an authorized state is required by Section 313 of the
CWA to comply with the effluent limits, reporting requirements, and other responsibilities specified in its permit.
Noncompliance with NPDES permits may subject federal facilities to enforcement by EPA or the authorized state.
If your department or agency owns or operates a facility with an EPA or state NPDES permit your facility has an obligation
to comply with the effluent limits, reporting requirements, and other requirements in the permit. Noncompliance may
subject the NPDES permittee to enforcement.
How Does This Initiative Affect Federal Facilities?
This NCI is intended to ensure that all NPDES permittees—including federal facilities—are complying with their permits.
NPDES permittees, regardless of facility size or type, will see an increase by EPA and its state partners in identifying and
addressing SNC violations at federal facilities using enforcement and other compliance tools. EPA is making federal
facilities aware of this initiative so they can take steps to address any significant noncompliance promptly.
EPA has engaged directly with the federal community on this NCI. When significant noncompliance is identified at specific
federal facilities, EPA's practice is to initiate a conversation with the respective federal department or agency
headquarters offices to better understand the noncompliance from a national perspective and to help these facilities return
to compliance. EPA has observed a very positive compliance response from federal agencies from this approach and
plans to continue this outreach into the future.
Furthermore, EPA's dialogues with federal agencies have contributed to improved data quality and completeness across
state and federal regulatory databases. Specifically, federal facilities have identified and reported data errors to EPA and
the states, resulting in correction of data contained within these data systems. This is vital to identify significant
noncompliance accurately, and federal facilities are playing an important leadership role in advancing the goals of this NCI
by helping to identify and provide more accurate and complete data.
Compliance Advisory
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How Do I Check the Status of NPDES Permitted Facilities?
NPDES permittees are encouraged to assess their compliance status in one or both of the following ways:
>	Ensure your discharge monitoring reports (DMRs) are accurate, complete, and timely submitted and received.
>	Use EPA's Enforcement & Compliance History Online (ECHO) tool to access your detailed facility report. EPA
recommends that federal facilities review their compliance statuses in EPA's Enforcement and Compliance History
Online (ECHO) database on a regular basis.
>	Use ECHO'S Early Warning Dashboard (EWD) tool to monitor real-time facility statuses to identify overdue DMRs and
underlying Technical Review Criteria (TRC) violations.
If your facility is identified in ECHO as being in significant noncompliance with its NPDES permit, EPA recommends that
you take prompt corrective actions to address this noncompliance. If you believe that the significant noncompliance
designation is the result of a data error, EPA recommends the permittee work with its permitting authority (either an
authorized state or EPA) to resolve the issue.
EPA strongly recommends that federal partners
register for an ECHOGov account to have access to
functions that are only available to ECHOGov users,
such as the Early Warning Dashboard. To register for
an ECHOGov account, you will need to validate your
government email by following these steps.
1)	From the ECHO main page click "Contact Us" in
the upper right-hand corner.
2)	Select the "Help" drop down menu.
3)	Select "Get Access"
4)	Click "Register and Log in to ECHO Gov"
5)	Follow Registration steps. The registration form
will ask users to provide an EPA point of contact.
(See contact information below.)
Helpful Resources
About: Early Warning Dashboard (EWD)
The EWD allows a user to view SNC statuses for last
official quarter, subsequent unofficial quarter, and current
quarter in progress ("real-time status"). Real-time statuses
indicate whether a facility would be in SNC if nothing
changed for the rest of the current quarter, or whether a
single additional effluent violation could cause SNC (this is
referred to as a "warning" status in the dashboard). The
dashboard also contains drill-down functionality for data
clean up that allow a user to understand the SNC causing
violation and identify erroneous or outdated violation data.
This tool is accessible to EPA, states, and other federal
users who register with ECHOGov at
https://echo.epa.gov/trends/data-viz
Fed Center
FedCenter.gov is the federal government's home for comprehensive environmental stewardship and compliance
assistance information for federal facility managers and their agencies. FedCenter can be found at: www.fedcenter.gov,
and is a collaboration of the U.S. EPA, Corps of Engineers, and numerous other federal agencies.
>	Compliance Assistance - NPDES SNC
>	Facility Regulatory Tour
>	Recorded Training Webinar: Intro to Early Warning Dashboard
To check your permit or contact your NPDES permitting authority (state or EPA):
>	For information on your state agency, use: https://www.epa.gov/npdes/contact-us-general-information-about-npdes
>	Learn more about EPA and the states' NPDES permitting authorizations for federal facilities.
If you have any questions please reach out to Nikki Freyre (Frevre.Dominigue@epa.gov, 202-564-0433) or Matthew Carr
(Carr.Matt@epa.gov, 202-564-7644), at the Federal Facilities Enforcement Office (FFEO).
Disclaimer
This Compliance Advisory addresses select provisions of EPA regulatory requirements using plain language.
Nothing in this Compliance Advisory is meant to replace or revise any NPDES permit, any EPA regulatory provision,
or any other part of the Code of Federal Regulations, the Federal Register, or the Clean Water Act.
Compliance Advisory
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