This is to inform you of changes DEC is making to the requirement for publicly owned treatment works (POTW) to report annual average flow and influent mass loading (required by 6 NYCRR Part 750-2.9(c)).
Changes by DEC this year will allow POTWs to electronically submit the annual flow certification or to utilize the previous paper submission. DEC believes this new alternative will simplify the reporting process and provide permittees easy access to data they have already submitted to DEC. The effort is also consistent with requirements of the U.S. Environmental Protection Agency’s Electronic Reporting Rule, which moves toward electronic submission of State Pollutant Discharge Elimination System (SPDES) permit data and reports.
What changes will DEC make?
In the flow certification form mailing for this year, DEC will provide each permittee with a summary of their facility’s flow and loading data that was compiled using discharge monitoring reports (DMRs) submitted to DEC during calendar year 2016, which covers the period January 1, 2016 – December 31, 2016. DEC will also provide a simplified entry method for the form via the NY.gov site that will remove several of the steps in completing the form and utilizes an electronic submittal. The upcoming mailing will provide instructions for accessing an electronic annual flow certification form via the NY.gov site, giving permittees an opportunity to become familiar with electronic reporting. If a permittee wishes to use the traditional form, it can still be downloaded at: http://www.dec.ny.gov/chemical/8456.html and submitted to DEC as a paper copy or scanned and attached to the NetDMR submittal.
When will each POTW receive this information?
DEC intends to mail the data summaries with instructions for accessing NY.gov by March 21, 2017. While DEC normally mails the flow certification information in early February, to complete preparation of the electronic submittal and prepare the individual data summary, DEC has delayed our standard mailing. We hope that a simplified method and providing a data summary will ultimately present a time savings and easier format for permittees to certify.
When is this information due to the DEC offices?
6 NYCRR Part 750-2.9(c)(4) requires this information be received by March 28. Over the past 3 years, DEC has had 100 percent compliance in reporting of the required format and has not taken any formal enforcement action on the requirement. DEC expects to work closely with permittees to achieve this again and obtain a simplified process moving forward. The priority for DEC on this requirement is for the permittee to assess their condition and provide an accurate certification rather than strict compliance with the reporting deadline. Please contact the Bureau of Water Compliance at (518) 402-8177 if you have concerns about the March 28th deadline.
What if an Annual Flow Certification form has already been submitted?
Permittees that have already submitted a complete CY2016 certification form are not required to submit another form.