Report Examines EPA Enforcement Actions

Evidence suggests that EPA has shifted NPDES compliance and enforcement staff from traditional NPDES program activities to work on wet weather issues...

Evidence suggests that EPA has shifted NPDES compliance and enforcement staff from traditional NPDES program activities to work on wet weather issues, according to a recent report from the EPA Office of Inspector General.

Five of the EPA regions that provided information from Fiscal Year 1999 through 2003 indicated that they have shifted resources to address wet weather violations of the Clean Water Act.

The report came in response to concerns about a decline in the number of NPDES enforcement actions. A 2003 internal report noted that "formal" NPDES actions against major facilities had declined over the previous three years. EPA had explained the decline by declaring that an increasing share of EPA's clean water enforcement efforts are directed toward correcting more complex wet weather violations of the Clean Water Act.

During its investigation, Inspector General found that the annual number of EPA formal NPDES enforcement actions slightly increased rather than decreased between FY 1999 to FY 2003. However, the IG's office did not find evidence of an increase in wet weather enforcement actions.

"A continuous, significant shift of resources toward addressing wet weather cases over the last five years has not been matched by a corresponding increase in the share of wet weather enforcement actions, which we would have expected to see if EPA's assertion were true," the report said.

According to respondents from the 10 EPA regions, wet weather enforcement cases require more resources to complete than traditional NPDES enforcement actions. Further, eight of the 10 regions said that conducting enforcement actions against combined sewer overflows/sanitary sewer overflows requires more resources than other types of wet weather actions.

A copy of the report is available at

EPA Publishes Water Reuse guidelines

EPA, in partnership with the U.S. Agency for International Development (U.S. AID), has developed new guideless for water reuse. The 2004 Guidelines for Water Reuse Manual (EPA625-R-04/018) includes recommendations and supporting information.

"This updated toolkit will help water managers advance water conservation and sustainability efforts at home and abroad," said Benjamin Grumbles, Acting Assistant Administrator for Water.

The document updates a 1992 Guidelines document published by EPA. The new manual includes expanded coverage of water reuse issues and practices in other countries. It was developed via an EPA Cooperative Research and Development Agreement (CRADA) with Camp Dresser McKee and an Interagency Agreement with U.S. AID, along with extensive contributions by volunteers.

The manual features new and updated case studies, expanded coverage of indirect potable reuse and industrial reuse issues, new information on treatment and disinfection technologies, emerging chemicals and pathogens of concern, economics, user rates and funding alternatives, public involvement and acceptance (both successes and failures), research activities and results, and sources of further information.

It also includes as an updated matrix of state regulations and guidelines, and a list of state contacts. This information should be useful planners, consulting engineers and others actively involved in the evaluation, planning, design, operation or maintenance of water reclamation and reuse facilities.

The updated Guidelines document is being distributed (in both printed and CD formats) by EPA's Office of Research and Development/Technology Transfer Program as one of their Manuals of Practice. Copies of the updated manual can be ordered via the website and has been posted in pdf form at

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