Discharge Monitoring Reports: No Discharge vs No Sample Taken
Stormwater monitoring requirements vary with each permit; therefore, monitoring may or may not be required for your facility. If stormwater samples are required, samples must be collected at each outfall representing the facility's discharge. The stormwater permit will indicate what type of monitoring is required, along with the frequency and submission of any monitoring data.
A Discharge Monitoring Report (DMR) contains the results of stormwater monitoring. The stormwater permit will outline how monitoring data needs to be submitted and the due dates for DMRs. Permittees are encouraged to sample early in the monitoring period in case the opportunity is not available later. Permittees can collect a stormwater sample and submit DMRs prior to the due date; however, extension and/or late reports are typically not allowed past the end of the monitoring period.
What happens if you don’t collect a stormwater sample during the monitoring period? You must still submit a DMR and mark the report as either “No Discharge” or “No Sample Taken.” What’s the difference? One is a legitimate reason the sample was not taken, and the other is not following the stormwater regulations.
Maybe it didn’t rain that much during the monitoring period, or your site is designed to hold water and there was no discharge at your outfall. In that case, you can submit the DMR as “No Discharge,” indicating there are no discharges that occurred during the monitoring period. Additional documentation will need to be submitted with the DMR and can include inspections, photographs, and precipitation information (e.g., rain logs) indicating there was no opportunity to collect the sample at any time during the entire monitoring period in which a sample could be taken (i.e., no measurable storm events occurred during the monitoring period or if there was a measurable storm event no discharge occurred).
What if you just forgot to take the sample, or there was no one qualified/trained to take the sample? If you cannot collect and report the stormwater sample, you must submit the DMR as "No Sample Taken.” You must also add comments to the DMR to explain the missing data. It is the permittee’s responsibility to ensure that there is a trained/qualified person to oversee the stormwater requirements. Permittees must emphasize to employees the importance of stormwater sampling and ensure the stormwater training program is up to date, conducted annually, and repeated more often if there are new employees.
The only time you can report “No Discharge” is when there has actually not been any discharge. A “No Discharge” report cannot be used if your facility was discharging stormwater but you were sick, out on vacation, busy, or just simply forgot to collect the sample. It’s not technically correct to report “No Discharge” if there, in fact, was a discharge. In many instances, severe enforcement actions occur because of incorrect reporting.
Stormwater permits require self-monitoring, and the regulatory authorities place the responsibility on you as the permittee to follow the regulations and take the stormwater samples within each monitoring period. If the facility fails to take a stormwater sample within the set monitoring period and therefore reports a DMR as “No Sample Taken,” this indicates a failure to comply with the permit conditions and, therefore, will likely result in a permit violation. The violation created for submitting as “No Sample Taken” is less significant than not submitting a DMR at all. Failure to submit a DMR creates a significant violation, which puts the facility on certain lists that can lead to enforcement.
DMRs will require the responsible official to “acknowledge” reported violations and missing fields prior to being signed and submitted. Therefore, it is important that the signatory authority review the DMR to verify that all required information has been successfully entered and submitted.
Need help with your stormwater permit program? Cornerstone EHS has been involved in helping facilities get and stay in compliance with stormwater permits across the United States since our founding in 1995. Our qualified professionals know the ins and outs of stormwater regulations and can help you. Contact us today.
Industrial Stormwater Best Management Practices
Stormwater is the water that originates from precipitation such as heavy rain or meltwater from hail or snow. Many industrial facilities introduce materials to stormwater through the outdoor storage, handling, and transfer of product materials, by-products, and waste products. These industrial products often contain pollutants such as metals, oil, and grease which negatively impact stormwater runoff. Additionally, industrial activities can cause erosion and sediment problems that also impact stormwater runoff.
Best Management Practices (BMPs) are pollution control measures designed to prevent or reduce the effects of pollutants in stormwater runoff from industrial stormwater discharges. Some BMPs are specific and well-defined, while others are general in nature. Facilities determine which BMPs to use based on permit requirements, the facility’s specific industrial materials, and the facility’s specific activities.
BMPs should be considered as a system or series of activities that may include non-structural and structural BMPs.
Non-structural BMPs are management techniques implemented through simple daily duties. The facility identifies and implements site-specific BMPs which have a direct impact on the day-to-day operations. Some of the more common non-structural BMPs include good housekeeping, eliminating and reducing exposure, management of salt and/or industrial storage piles, management of runoff including soil and erosion prevention, and dust control.
Structural BMP options vary depending on the pollutants each can treat, efficiency, maintenance issues and limitations of controls. Structural BMPs are more technical in nature and advanced technical expertise is required to make informed decisions about implementing structural stormwater BMPs. It
is suggested to consult with a licensed professional engineer early in the decision process. Common structural BMPs include sedimentation systems (e.g. retention ponds), infiltration systems (e.g. stormwater trenches), filtration systems (e.g. vegetative filters), and proprietary systems (e.g. vortex separators).
Federal regulations require stormwater discharges associated with specific categories of industrial activity to be covered under a National Pollutant Discharge Elimination System (NPDES) permit. EPA has developed a fact sheet for each of the 29 industrial sectors regulated by the NPDES permits. Each fact sheet describes the types of facilities included in the sector, typical pollutants associated with the sector, and types of stormwater control measures used to minimize the discharge of the pollutants. These BMP fact sheets are a great starting point for determining the various pollutants which cause stormwater pollution at a facility and provide BMPs that are applicable to a specific industrial facility operation.
Regular inspections of a facility’s BMPs are required by the NPDES permits. These inspections are integral in determining if structural and nonstructural BMPs are properly functioning, require maintenance, or need to be changed. Inspections also determine the accuracy of the facility’s written stormwater plan, as all observations and any changes made as a result of the inspections must be documented in the written plan.
For more information on BMPs for stormwater, check out EPA.gov or reach out to your Cornerstone Team directly.
