IV.2 Report Preparation

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IV.2 Report Preparation
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EPA NPDES Report Guidelines

• Section 2.G Inspection Report of the NPDES
  Compliance Inspections Manual

http//www.epa.gov/compliance/resources/publicatio
ns/monitoring/cwa/inspections/npdesinspect/npdesma
nual.html
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What Should Be Included

• Consider Activity Purpose
• Screening-level inspection
• Compliance audit or inspection
• Permit re-issuance audit
• Consider Presence/Absence Of Enforceable Language
• Recommendations vs. deficiencies (potential
  violations)
• Inclusion/exclusion of particular observations
• Use of guidance and compliance assistance
• Consider the Anticipated Audience
• MS4 program staff
• High-level managers and officials
• Regulatory enforcement staff

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What Should Be Included

• In all cases the objective is to organize and
  coordinate all audit and inspection information
  and evidence into a comprehensive, usable
  document.
• Include only accurate information
• Information should be relevant to the subject of
  the report
• The more comprehensive the evidence is, the
  better and easier to determine compliance status

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What Should Be Included

• Per the NPDES Compliance Inspection Manual
• NPDES Compliance Inspection Report Form 3560
  (applies to audits as well)
• Supplementary narrative information
• Copies of completed checklists
• Documentary support
• Inspection Conclusion Data Sheet

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How Should Reports Be Written

• In all cases, each potential violation should be
  made obvious to the reader
• State the requirement (statute, permit,
  regulation SWMP)
• Describe and present how the MS4 failed to meet
  the requirement
• Present and describe all photographs, documents,
  statements, and other evidence

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How Should Reports Be Written

• When is Additional Narrative Appropriate?
• Providing recommendations, suggestions, and/or
  guidance via compliance assistance?
• Conveying areas to address in upcoming permit
  re-issuance?
• Communicating strengths and weaknesses of the MS4
  program and assessing program effectiveness?
• Evaluating and determining how to address
  non-enforceable elements of the permit and
  program?

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How Should Reports Be Written

• Plan For Success
• Prepare the report as soon as possible following
  the activity
• Group findings by program area
• Write the report in the first person and
  reflective of a point in time
• Use simple, direct language, and short sentences
• Include only known facts and cite source
• The facility representative stated the MS4 has
  80 outfalls.