Records, Reporting, and Compliance Documentation
Core Concepts
Accurate records and reporting are legal requirements. Key concepts include NPDES discharge monitoring reports (DMRs), pretreatment reports (e.g., periodic compliance reports), hazardous waste manifests (RCRA), biennial reports, SDS maintenance, training records, inspection logs, and chain of custody. Recordkeeping periods vary: NPDES requires 3 years (or longer for enforcement), RCRA hazardous waste manifests 3 years, training records 3 years. DMRs must be submitted monthly or as specified, signed by a legally authorized representative. Exceedances must be reported according to permit requirements (e.g., 24-hour oral, 5-day written). Spill reporting under CERCLA/EPCRA has reportable quantities (RQs). Traps include confusing reporting deadlines (e.g., 24-hour vs. 5-day), misapplying signatory requirements, and overlooking electronic reporting (e.g., NetDMR). Deviation reports for pretreatment. Manifest exceptions and rejection. Another trap: record retention periods differ by program; when in doubt, keep longer. Annual reports for stormwater. Compliance schedules in permits.
Worked Example
A facility exceeds its NPDES pH limit on a Sunday. The permit requires 24-hour oral notification and 5-day written follow-up. Rule of thumb: report exceedances within 24 hours orally, then in writing within 5 days. This shows the trap of waiting for the next business day or only submitting the DMR.