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ISGP: Reporting & Recordkeeping

Every permitted industrial site has a significant amount of paperwork to manage. Some of the paperwork is completed and remains on site as part of the internal recordkeeping procedure.

Other records must be completed and submitted to the Ecology SAW system and are available to the public on PARIS. The sections below outline the reporting and recordkeeping requirements for the ISGP. 

Quarterly DMR

The permit requires that once per quarter a site Discharge Monitoring Report (DMR) must be submitted via the online Secure Access Washington (SAW) site (due dates are Feb 15, May 15, Aug 15, and Nov 15, for the preceding quarter). If your facility did not have any discharge for that quarter, that does not absolve you of the requirement to create and submit a DMR; rather, you must report that you had no discharge. 

Ecology has also created these instructions on how to fill out a DMR.

Annual Report

The Annual Report is due annually on May 15 for the previous year. The report communicates two things:

  1. What happened the previous year?
    • Major changes – Staff, SWPPP, operations
    • Level II or III Corrective Actions implemented from benchmarks two years ago
    • Benchmark exceedances
  2. What will happen based on Level II or III benchmark exceedances from last year? (see our Corrective Action page for more information on benchmark exceedances)
    • What are you planning on implementing this year?
    • When do you plan to implement it in meeting the deadlines?

Each benchmark that was exceeded gets its own page in the Annual Report (duplicate pg 3 for each parameter exceeded). 

Recordkeeping

All site records shall be kept for a minimum of five years following the termination of permit coverage. This includes the SWPPP, a copy of the permit coverage letter, any transfer of coverage documents, the site log book, sampling results, inspection reports, calibration and maintenance records, and any other permit information.

Reporting Violations

Anytime sampling indicates an exceedance of a numerical effluent limit, or a permittee is unable to comply with any of the other terms and conditions of the permit, immediate action must be taken to minimize potential pollution and to correct the problem. Violation of the permit also requires immediate reporting to the local jurisdiction and the appropriate regional ecology office. Additionally, you will be required to submit a detailed written report to Ecology within 5 days of becoming aware of a violation.

What Must This Report Contain?

  • A description of the noncompliance, including exact dates and times
  • Whether the noncompliance has been corrected, and if not when the noncompliance will be corrected
  • The steps taken or planned to prevent the reoccurrence of noncompliance

Consistent Attainment

Facilities that show consistent attainment can reduce sampling from quarterly to once a year. Consistent attainment is achieved by having 8 consecutive quarterly samples that demonstrate reported values at or below the benchmark. Sites that don’t experience discharge during a quarter can’t count that quarter toward their 8. Sites that miss sampling for a quarter they should have sampled must start their count over. 

If a facility is in consistent attainment and exceeds a benchmark during its yearly sampling, it will no longer be considered in consistent attainment and must go back to quarterly samplings along with any corrective actions that may result.

Modification of Coverage

If a facility is anticipating a significant process change, or otherwise requesting a modification of permit coverage, they must submit a complete Modification of Coverage form to Ecology. This is due 60 days before implementing the process change, or by May 15th prior to a Corrective Action deadline if requesting a level 2 or 3 extension or waiver request.

What Does Significant Process Change Mean?
A significant process change means one of the following:

  • Add different pollutants in a significant amount to the discharge.
  • Increase the pollutants in the stormwater discharge by a significant amount.
  • Add a new industrial activity that was not previously covered.
  • Add additional impervious surface or acreage such that stormwater discharge would be increased by 25% or more.

Significant process change must still comply with the identified activities of the SEPA identified on the NOI. If they don’t, or a SEPA hasn’t been done on your facility, you may have to go through the SEPA process before obtaining a modification of coverage. For more information on the SEPA process see our SEPA page.

Modification of permit coverage also requires public notice in a local newspaper to run twice and also allows for a 30-day comment period for the public to present their views to the Department of Ecology.