Oregon Department of Environmental Quality Announces Coding for NPDES Noncompliance Reports

Legal Alert

The Oregon Department of Environmental Quality (DEQ) updated its COVID-19 Response page to provide guidance to entities with National Pollutant Discharge Elimination System (NPDES) permits who may experience monitoring, sampling, and reporting disruptions during the COVID-19 pandemic. DEQ announced that it “expects NPDES permittees to make good faith efforts to comply with all permit requirements” and “take all possible steps to return to compliance” if reporting obligations cannot be met.

DEQ advises NPDES permit holders to document and report noncompliance with NPDES permit requirements. Reports of noncompliance should include:

  • the nature and dates of noncompliance;
  • how noncompliance was caused by COVID-19; and
  • the actions and decisions taken in response to the noncompliance.

In certain scenarios, DEQ recommends special reporting to the agency:

  • Missing Data: If disruptions related to the pandemic lead to missing monitoring and sampling data, DEQ recommends reporting the error in NetDMR using NODI Code Z – COVID-19, and adding “COVID-19” to the comment field with a narrative description of the disruption that impacted sampling, monitoring, or reporting.
  • Electronic Reporting: If unable to report electronically, DEQ recommends contacting a compliance officer to discuss options for a temporary waiver.
  • Reporting Interruption: If unable to report at all, DEQ recommends contacting a compliance officer to discuss a timeline for resuming reporting, including late submission of missing reports.

DEQ’s update follows the U.S. Environmental Protection Agency’s Temporary Advisory for NPDES Reporting, which provided guidance and new NODI coding for NPDES program operators.

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