# NPDES Electronic Reporting Rule **Analysis E: A nnual Compliance**  **Certifications**

13 September 2010 DCN 00212 **TABLE OF CONTENTS Page**  1.0 O VERVIEW
................................ ................................ ................................ .............................. 3 2.0 INDUSTRIAL S TORMWATER A NNUAL C OMPLIANCE C ERTIFICATIONS
................................ ... 10 3.0 A CTIVE C ONSTRUCTION S ITES A NNUA L C OMPLIANCE C ERTIFICATIONS
.............................. 16 4.0 C ONCENTRATED A NIMAL F EEDING OPERATIONS (CAFO S ) C OMPLIANCE C ERTIFICATIONS
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**1.0 O**  **VERVIEW** 1.1 Background On 15 October 2009, the Agency issued the Clean Water Act Action Plan which sets forth a series of commitments by the Agency

to revamp its NPDES enforcement program. 1 A major commitment from the Action Plan is to improve management and performance of the NPDES program b y requiring electronic reporting of NPDES information from regulated facilities. EPA is developing a rulemaking, NPDES Electronic Reporting Rule (RIN: 2 020

- AA47), to solicit input and formalize the requirements for electronic reporting. Electronic reporting will likely

reduce the burden for facilities to report to regulatory agencies and for states to report to EPA. Expected benefits include lower process ing costs for facilities and states, improved data quality and accuracy, greater data accessibility and transparency for the public, and an increased ability

to target and address noncompliance that will improve and protect water quality

. Compliance for most NPDES program components is not solely based on the submission of discharge monitoring reports (DMRs). NPDES program compliance is also assessed b y inspections and the state or EPA Region’s review of periodic or incident based reports f rom permittees. These non

- DMR reports (also known as “program reports”) are required under EPA’s regulations and they provide an update to program implementation items beyond what is included in the permit application or permit issuance process

. Separate r ulemaking anal ys es focus on converting DMR and program reports from paper

- based to electronic reporting ( see “Anal ys is A” and “Anal ysis F,” respectivel y). This document focuses on potential new annual compliance certifications to supplement DMRs and program reports. When entities recognize that: (1) neither EPA nor the states will likely conduct inspections at their facilities; (2) no requirements exist for the facilities to monitor and report their compliance status to regulatory agencies; and (3) neithe r EPA nor the states will likely initiate enforcement actions against their facilities, deterrence theory and empirical evidence suggests a low potential for compliance

- enhancing deterrent impacts. 2 Inorder to enhance CWA compliance and direct government inspection and enforcement resources towards the facilities and sectors experiencing the most severe CWA noncompliance, EPA examined whether it should creat e new electronic

- based annual compliance certifications to supplement DMRs and program reports. For the proposed NPDES Electronic Reporting Rule EPA opted to not create an y new reporting requirements. T he first step is to identify where EPA might want to create new or improved electronic compliance certifications. This document identifies the following list of potential new electronic

based annual compliance certifications:

1 These commitments are documented in the 8 November 2009, “Implementation Approach for the CWA Enforcement Action Plan”. This document and other key CWA Enforcement Action Plan documents are available at EPA ’s Online Tracking Information System (OTIS) . [Available at: http://www.epa

- otis.gov/ ]. 2 U.S. EPA, 2010. “Proposal For Expanding NPDES Self

- Monitoring, Certification And Electronic Reporting Requirements ” September 3rd.4

 Section 2.0: Facilities regulated by master general permits (sector based general permits and industrial stormwater monitoring) that do not require DMRs or other compliance certifications. Initial estimates are that this might be 10% of the facilities regulated by master general permits.
 Section 3.0: Active c onstruction s ites that are regulated by the recentl y promulgated effluent limitations guidelines.
 Section 4.0: Concentrated Anim al Feeding Operations (CAFOs) that are not required to submit DMRs or other compliance certifications. This analy sis builds off of existing certification

- like requirements (e.g., biosolids certifications regarding vector attraction reduction, annual nonc ompliance report required from vessels) as these existing requirements provide model language and for the above three new annual compliance certifications. This analy sis also builds off of the work done in support of the Clean Water Action Plan. 1.2 Pote ntial Design Principles for Successful Annual Compliance Certifications T he following ten design principles that will likely lead to successful application of new annual compliance certifications. 3 These principles should guide the identification regulate d sectors and facilities that are good candidates for new electronic

- based annual compliance certifications. These principles can also guide the development of the tools for electronic reporting (e.g., user interface requirements, frequency of reporting, t ypes of data that aid in compliance determinations). These principles also identify that public reporting of this annual compliance data enhances deterrence and accountability among regulated entities. 1. Establish clear and objective criteria : In certification programs, the substantive requirements against which regulators or organizations determine compliance must be sufficiently

clear and objective to allow regulated entities and certifiers to consistently and accuratel y apply

the criteria and as certain compliance. 2. Require specific, fact

- based certifications : Regulated entities should certify that the meet specific conditions, as opposed to merel y signing general compliance statements. 3. Provide technical assistance to regulated entities : Re gulated entities must know and understand the applicable regulations and standards, including when and how these criteria apply

to their particular operations. 4. Use uniform monitoring and certification forms and test standards : Forms containing consistent, objective assessment criteria advance industry compliance with certification programs and promote effective compliance evaluations by regulators across facilities. 5. Ensure competent and responsible certifiers : Certifiers must maintain speci fied credentials, meet particularized competence criteria, and operate independently from their clients.

3 U.S. EPA, 2010. “Proposal For Expanding NPDES Self

- Monitoring, Certification And Electronic Reporting Requirements ” September 3rd.5

6. Employ

effective and efficient electronic reporting s ys tems : Reporting sy stems should be inexpensive and user friendly for regulated entities. El ectronic reporting encourages programmatic compliance and timely submission of reports, while also improving data quality

. 7. Maintain a formal inspection and enforcement presence : Regulatory programs that provide for random agency inspections, in addit ion to certification requirements, promote increased compliance incentives among regulated entities since the agencies may verify the entities’ reported information. 8. Promote accurate reporting through personal liability requirements : Certification pro grams that include provisions for civil and/or criminal liability for inaccurate or falsified reporting creates increased compliance incentives for regulated entities. 9. Enhance deterrence and accountability through public reporting : Evidence suggests that publicly reporting information submitted pursuant to certification programs, through avenues such as website posting, enhances deterrence and accountability among regulated entities. 10. Structure programs to promote effective measurement and evaluati on : Regulators employing certification programs must consider, when initiating the program, how to effectivel y define, ascertain, and measure program success through their receipt of the requested data and certifications. 1.3 Proposed Tools for Electron ic Data Collection This paper identified two business models for developing new annual compliance certifications: (1) Closed Platform Model (EPA Built Tool; and (2) Open Platform Model (Third Party Commercial Software Vendors). These represent the user interface for inputting data and digitally signing the new annual compliance certifications. These two business models are not mutually exclusive and both can be developed to accommodate the different NPDES program sectors and the different needs of regulate d entities. Additionally , both models will need to conduct similar tasks in defining how the data from the annual compliance certifications will be migrated from the regulated entity into ICI S

NPDES. The following tasks can be used to support both business models. Both models will need to e stablish the procedures consistent with the Exchange Network that will enable permittees to submit the ir annual compliance certification data with an option to allow state addendums. The two models will also need to creat e an Extensible Markup L anguage (XML) schema for each annual compliance certification that feeds data into IC IS

- NPDES . T he data element crosswalk for each program report should be harmonized with the EPA's Environmental Data Standard (EDSC) and Exchange Ne twork. Development of this crosswalk might include the following tasks:

 Link data element names with the EDSC to ensure that the data element naming and definition are consistent with the EDSC standards.6

 Link the data elements with the EPA's Shared Schema Components (SCC) to select/reuse current SCC to form the building blocks for the XML schema. In some cases, there might be a need to extend the current SCCs to accommodate new data elements based on the Exchange Network XMLschema design guidelines.

 Create a XML schema with schema documentation. Create a schema conformance report and submit it to the Exchange Network Network Technical Group (NTG) to get approval and be adopted as the standard for future data flow schema. Th ese steps will help support both b usiness models and will help prepare EPA Regions and states to share annual compliance certification data with EPA via the Centralized Data Exchange (CDX). EPA will also need to develop the Flow Configuration Document s (FCD) for defining how EPA Regions, states, and facilities will share annual compliance certification data via the Exchange Network node protocols and the CDX. A FCD is intended to define the supported data services and processes that are used to exchange information. This document will also identify entity responsible for reporting each data element and how this data will be transmitted to EPA (e.g., web

- based submission, networ k submission, web services) and whether the submissions will be from an EPA bu ilt electronic collection tool or an open platform (third party commercial software vendor tool). This document will also describe an y software or information technology needed to complete these annual compliance certification

. T his document will also show how the standardized program report data compl y with CROMERR. 1.3.1 Closed Platform Model (EPA Built Tool) This model relies on EPA to build and maintain an electronic reporting tool. This model has the benefits of EPA controlli ng all aspects of electronic data collection and offering this tool to regulated entities at no cost. The challenges for this tool would be the costs for EPA to build and maintain this tool, market the tool, and provide customer support. EPA’s netDMR is an example of this ty

pe of tool for electronic data collection. 4 1.3.2 Open Platform Model (Third Party Commercial Software Vendors) This model involves partnering with commercial software vendors in order to lower the burden for facilities to report annual compliance certification data. The open platform model is based on the IRS model for collection and transmission of tax data. See Figure 1

- 1.

4 See http://www. epa.gov/netdmr/7 **Figure 1**
**- 1:**  Schematic of IRS Open Platform Model for Collecting Tax Data Similar to the IRS sy stem EPA’s open platform ‘e

- File’ sy stem would rely on third

- part y commercial software vendors to provide the user interface with the regulated community . EPA’s open platform model would also specify how these third

- part y commercial software vendors would share annual compliance certification data with EPA and the states through the Central Data Exchange and the Environmental Information Exchange Network. 1.3.3 CROMERR Compliance EPA will need to ensure that both the closed model (EPA built tools) and open model (third p art y commercial software) includes the appropriate identity - proofing, authentication, and encry ption standards for demonstrating compliance with Cross

- Media Electronic Reporting Regulation (CROMERR). EPA will need to show how the annual compliance certific ation data from the user front end tool will identify the name of the responsible official attesting to the accuracy of the submission and how this official is subject to criminal sanctions for misreporting or other fraud. 1.4 Federal and State Examples of Compliance Certifications There are a variety

of ongoing programs that rel y on self

- monitoring, reporting, and/or certification (self and third

- part y) to assure regulatory compliance and/or participant performance. 5 The selected programs represent a variet y of regulatory and voluntary approaches to self

- monitoring, reporting, and certification. This section focuses on the CWA compliance certifications (“program reports”) required b y N ew York State (NYS) Department of Environmental Conservation (DEC)

. T hese compliance certifications are not new nor are they submitted electronicall y . However, the NYSDEC paper

- based program reports, required under existing Federal and state regulations, do demonstrate the effectiveness of compliance certifications and some of the ten design principles described above. NYSDEC requires five types of permittee compliance self

- certifications or “program reports” ( see related discussions in Analy sis F)

. NYSDEC believes its certification requirements have increased permittee and industry awareness of their compliance obligations. Because the

5 U.S. EPA, 2010. “Proposal For Expanding NPDES Self

- Monitoring, Certification And Electronic Reporting Requirements ” September 3 rd . Much of this section is taken from this reference.8

permittees know that NYS DEC is enforcing the reporting requirements , they generall y provide the required information to NYS DEC in a timely and correct manner. The following list include s each t yp e of self

- certification and its corresponding approximate volume of transactions/year: 1. CAFO General Permit

- Annual Compliance Report 6

- 600/ year 2. POTW Annual Flow Management Certification*

- 620/year 3. MS4 General Permit Annual Municipal Compliance Certification (MCC)

- 500/year 4. CAFO General Permit CNMP Certification**

- 600 total 5. CAFO General Permit Annual NMP certification

- 600/year * required by NYS SPDES regulations for POTWs subject to individual permits ** o ne - time initial plan certification The NYSDEC considers annual reports for MS4s and CAFOs to be analogous to traditional DMRs and treat s them similarly from a timeliness standpoint. While some of the c ertifications are one

- time requirement s (e.g., CAFO has completed its Comprehensive Nutrient Management Plan or CNMP) and others are annual (e.g., POTW flow certification), the compliance response is the same. Facilities that fail to submit the required certification within 30 day s after the permit due date receive a Notice of Violation (NOV) , with an additional 30 day s to submit the certification or face formal enforcement. Failure to comply with the NOV results in the issuance of a Short Form Consent Order (SFCO) with penalty. Failure to sign the SFCO leads to the filing of a Notice of Hearing/Complaint (NOHC) with an increased penalty. The NYSDEC CAFO program has contained self

- certification requirements since the inaugural 1999 permit. Th e certification requirement applies to both the CAFO permittee and the certified CNMP planner to co

- certify that the CNMP is in place and being full y implemented. NYS DEC used to send letters to CAFOs to remind them to send in annual reports , but it discontinued this process once it felt comfortable that th e facilities understood this requirement

. Approximately 600 CAFOs operate in New York, but onl y about 35 certified CNMP planners work in the state

. In 1996, NYS DEC established a CAFO work group with NYSDAM, NRCS, the Cornell School of Agriculture, environmental groups, agribusiness and county soil and water districts to address related implementation issues. According to NYSDEC, this communication has helped make the program successful and allows NYSDEC to monitor CNMP and CNMP planner quality

. NYSD EC added the POTW flow certification requirement to the NYS SPDES regulations in 2003 , but the agency did not implement it until 2007. The POTW flow certification requires the annual reporting of influent flow and loads against the DEC

- approved POTW design capacity. If the POTW reaches threshold levels (e.g. annual flow over 95 percent of design capacity) , it must comply with specific compliance schedule items. According to NYSDEC, i n practice, it has already issued enforcement orders to the majority of the POTWs that trigger the threshold levels to address an y existing violations.

6 Federal and state

- issued NPDES CAFO permits require annual reporting, pursuant to 40 CFR §122.42(e)(4). NYS DEC’s systematic approach to the revie w and evaluation of its Annual Com plian ce Reports may comprise a b est p ractice that EPA could encourage and build on nationally

.9

The MS4 annual report/MCC allows co

- reporting b y cooperating MS4s. NYSDEC achieved e fficiencies b y changing from a traditional report to a compliance checklist form. NYS DEC reports that c oordination with , and funding of , regional planning councils to work with the MS4s in preparing their reports has promoted a high compliance rate. NYS DEC is assessing MS4 on

- the

- ground performance b y inspecting the MS4s over the last few ye ars (NYSDEC must conduct several additional ye ars of inspections to cover all of the MS4s )

. Generall y, MS4 performance has been uneven , but improving. The self

- monitoring, reporting, and certification approaches employed by NYSDEC to regulate CAFOs, POTWs, and MS4s parallel, in certain respects, how DMR requirements operate. In 2008, NYSDEC averaged about 90 late DMRs per month (5 percent SNC for DMR no nsubmittal). NYSDEC’s noncompliance rate for DMR submissions and response to noncompliance highlight the value, when employing self

- certification s ys tems, of responding promptly to non
- reporting and monitoring the content of submitted reports. Accordingl y, in 2008 , NYS DEC broke the annual report review process into two steps. First, DEC began ensuring that permittees submit the report s and started respond ing to an y non - submissions in a streamlined fashion with the issuance of NOVs. Second, DEC began per form ing detailed reviews of the content in the submitted reports. NYSDEC now receives about 50 late DMRs per month (2.7 percent SNC for DMR non

- submittal). The residual noncompliance occurs for a my riad of reasons, such as factors related to improper per mit transfers, failure to submit DMRs for no

- discharge limits , and failure to contact NYS DEC to suspend DMRs for non

- operating facilities. In comparison to the DMR program, the compliance rate for the annual submittals under the NYSDEC programs remains in the high 90

- percentage range
. The 90 plus percent compliance rate encompasses the submission of the report s, without account ing for issues related to the quality

of the program s on which the permittees are reporting. During the first several ye ars of DEC’s implementation of the certification requirements, it did not perform compliance follow up for non

- submissions until it received and reviewed the annual reports

. 1.5 If such a requirement were included in the regulation, would it be feasible to impose a single nationwide submission date The due date for each new electronic

- based annual compliance certification should be evaluated separately . To assess compliance across the state, Regional or national scale it may not be necessary

for compliance certifications to be sent on one date. It may help with implementation to stagger submissions as the Agency ’s resources can be measured out incrementall y. EPA can also stagger the requirements of new electronic

- based compliance certifications so as iterati vely improve the process. Additionally , EPA’s NPDES Electronic Reporting Rule may

require NPDES permit writers to implement requirements for electronic reporting through the renewal of permits, which are not sy nchronized. This would be an appropriate quest ion to solicit input during the public comment period.10

**2.0 I**  **NDUSTRIAL S**  **TORMWATER A** **NNUAL C**  **OMPLIANCE C**  **ERTIFICATIONS 2.1**  **Overview** Section 402(p) of the Clean Water Act provides that stormwater discharges associated with industrial activity , including those related to construction activity , entering waters of the United States must receive authorization under a NPDES permit. There are ten categories of industrial activity

incorporating 29 industrial sectors requiring NPDES permits fo r stormwater discharges. Since all but four states are authorized to implement the stormwater NPDES permitting program (NH, MA, NM, ID), the vast majority of industrial facilities get permit coverage through delegated state NPDES permit programs. Permit co verage for this universe includes individual permits and general permits. Stormwater runoff can have a significant impact on water quality. Several studies reveal that stormwater discharges from urban areas can include a variety of pollutants, such as tur bidity , pathogens, organic nutrients, hydrocarbons, metals, oil and grease, and debris. Stormwater can pick up a variet y of pollutants such as sediment, debris, pesticides, petroleum products, chemicals, solvents, asphalts and acids, and in extreme cases i t can alter the pH of the receiving stream or river. These pollutants can harm the environment and public health. According to EPA’s National W

ater Quality Inventory: 2002 Report , prepared under Section 305(b) of the Clean Water Act, 40% of surveyed rivers & 45% of surveyed lakes are not clean enough to meet basic uses ( e.g. fishable, swimmable and drinkable). The Report further showed that sediment contributes to the impairment of 31% of impaired rivers and streams (84,503 river miles) and 21% of impaired lake areas (1.5 million acres) and is the #2 cause of impairment for rivers and streams and the #3 cause for lakes. EPA estimates that there are over 100,000 industrial stormwater permittees nationwide, contained within 29 industrial sectors. According to the I CI S

-NPDES database, there are 9,683 permits with an industrial stormwater component. Due to sy stem limitations in PCS (currently 22 states), permits with an industrial stormwater compon ent are unable to be identified and evaluated for compliance and enforcement rates. The data entry requirements for industrial stormwater permits are based on the type of permit that is issued. Therefore, the data entry requirements for a permit with an in dustrial stormwater program component are based on whether the permit is a major, minor, or general permit. EPA manages the stormwater program for four states, District of Columbia, and federal facilities. EPA has a web

- based permit application sy stem (eNOI) to manage coverage for EPA

issued stormwater permits ( see “Anal ys is B”). Industries with stormwater control requirements can appl y for coverage under EPA’s the Multi

- Sector General Permit (MSGP) or submit a no exposure certification. EPA’s eNOI s ys tem also contains an electronic reporting s ys tem that enables industrial permittees to submit quarterl y DMRs, annual reports, and non

- compliance reports as required under EPA’s 2008 MSGP. Facilities are overwhelmingl y using the electronic submission feature ( 727 electronically submitted DMRs as opposed to 7 hardcopy DMRs). Industrial stormwater has been an EPA CWA compliance and enforcement priority since 2000 and continues to be a national priority.11

**2.2 Scope of New Electronic** 
**- based Annual Compliance C**  **ertification** This paper proposes to extend the annual reporting requirement in EPA’s MSGP to all facilities with industrial stormwater dischargers. Under this new compliance certification facilities must conduct annual comprehensive site inspections. Fac ilities may be waived from having to perform a comprehensive site inspection for an inspection period if they obtain authorization to discharge less than three months before the end of that inspection period. Should their coverage be administratively conti nued after the expiration date of their permit, the industrial facility

must continue to perform inspections annually until they are no longer covered. Qualified personnel must conduct comprehensive site inspections with at least one member of the industrial facility ’s stormwater pollution prevention team participating in the comprehensive site inspections. Each comprehensive site inspections must cover all areas of the facility affected by

the requirements in their permit, including the areas identified i n the facility ’s stormwater pollution prevention plan (SWPPP) as potential pollutant sources where industrial materials or activities are exposed to stormwater, any areas where control measures are used to comply with the effluent limits, and areas where s pills and leaks have occurred in the past 3 ye ars. The inspections must also include a review of any discharge monitoring data. Inspectors must consider the results of the past year’s visual and anal yt ical monitoring when planning and conducting inspection s. Inspectors must examine the following:

 Industrial materials, residue, or trash that may have or could come into contact with stormwater;  Leaks or spills from industrial equipment, drums, tanks, and other containers;
 Offsite tracking of industrial or w aste materials, or sediment where vehicles enter or exit the site;
 Tracking or blowing of raw, final, or waste materials from areas of no exposure to exposed areas; and
 Control measures needing replacement, maintenance, or repair. Stormwater control measures must be observed to ensure that they are functioning correctl y. If discharge locations are inaccessible, nearb y downstream locations must be inspected. **2.3 Example**  **Form for a Potential Electronically Reported Compliance Certification**  The following is an example form for a potential industrial stormwater annual compliance certification. For the proposed NPDES Electronic Reporting Rule EPA opted to not create an y new reporting requirements.12

**Industrial Stormwater Annual Compliance Certification Repor ting Form**  A. GENERAL INFORMATION 1. Facility Name: [Text Field] 2. NPDES Permit Tracking No.: [Text Field] 3. Facility Physical Address a. Street: [Text Field] b. City : [Text Field] c. State: [Text Field] d. Zip Code: [Text Field] 4. L ead Inspectors Name: [Text Field] Title: [Text Field] Additional Inspectors Name(s): [Text Field] Title: [Text Field] 5. Contact Person: [Text Field] Phone: [Text Field] E

- mail: [Text Field] 6. Inspection Date: [Text Field] B. GENERAL INSPECTION FINDINGS 1. As part of this comprehensive site inspection, did you inspect all potential pollutant sources, including areas where industrial activity may be exposed to stormwater?  YES  NO If NO, describe wh y not: [Text Field] NOTE: Complete Section C of this form for each industrial activity area inspected and included in your SWPPP or as newly identified in B.2 or B.3 below where pollutants may be exposed to stormwater. 2. Did this inspection identify an y stormwater or non
- stormwat er outfalls not previously identified in your SWPPP?  YES  NO If YES, for each location, describe the sources of those stormwater and non

- stormwater discharges and an y associated control measures in place. [Text Field] 3. Did this inspection identify any sources of stormwater or non

- stormwater discharges not previously

identified in your SWPPP?  YES  NO If YES, describe these sources of stormwater or non

- stormwater pollutants expected to be present in these discharges, and an y control measures in pla ce. [Text Field]1 3

4. Did you review stormwater monitoring data as part of this inspection to identify potential pollutant hot spots?  YES  NO  NA, no monitoring performed If YES, summarize the findings of that review and describe any additional inspect ion activities resulting from this review. [Text Field] 5. Describe an y evidence of pollutants entering the drainage s ys tem or discharging to surface waters, and the condition of and around outfalls, including flow dissipation measures to prevent scouring . [Text Field] 6. Have you taken or do you plan to take an y corrective actions since your last annual report submission (or since you received authorization to discharge under this permit if this is your first annual report), including any corrective acti ons identified as a result of this annual comprehensive site inspection?  YES  NO If YES, how man y conditions requiring review for correction action were addressed b y these corrective actions? [Text Field] NOTE: Complete the attached Corrective Action Form (Section D) for each condition identified, including an y conditions identified as a result of this comprehensive stormwater inspection. C. IN DUSTRIAL ACTIVITY AREA SPECIFIC FINDINGS Complete one block for each industrial activity area where pollutants may be exposed to stormwater. Cop y this section for additional industrial activity areas. In reviewing each area, you should consider:

 Industrial materials, residue, or trash that may have or could come into contact with stormwater;  Leaks or sp ills from industrial equipment, drums, tanks, and other containers;
 Offsite tracking of industrial or waste materials, or sediment where vehicles enter or exit the site;
 Tracking or blowing of raw, final, or waste materials from areas of no exposure to exposed areas; and
 Control measures needing replacement, maintenance, or repair. IN DUSTRIAL ACTIVITY AREA No: [Text Field] 1. Brief Description: [Text Field] 2. Are an y control measures in need of maintenance or repair?  YES  NO 3. Have an y control me asures failed and require replacement?  YES  NO 4. Are an y additional/revised control measures necessary in this area?  YES  NO If YES to an y of these three questions, provide a description of the problem: (Any necessary corrective actions should be described on the attached Corrective Action Form) [Text Field]14

D. CORRECTIVE ACTIONS Complete this section for each specific condition requiring a corrective action or a review determining that no corrective action is needed. Copy this section for additi onal corrective actions or reviews. Include both corrective actions that have been initiated or completed since the last annual report, and future corrective actions needed to address problems identified in this comprehensive stormwater inspection. Include an update on an y outstanding corrective actions that had not been completed at the time of your previous annual report. 1. Corrective Action No. [Text Field] of [Text Field] for this reporting period. 2. I s this corrective action:  An update on a corrective action from a previous annual report; or  A new corrective action? 3. I dentify

the condition(s) triggering the need for this review:  Unauthorized release or discharge  Numeric effluent limitation exceedance  Control measures inadequate to meet applicable water quality standards  Control measures inadequate to meet non

- numeric effluent limitations  Control measures not properly operated or maintained  Change in facility operations necessitated change in control measures  Av erage benchmark value exceedance  Other (describe): [Text Field] 4. Briefl y describe the nature of the problem identified: [Text Field] 5. Date problem identified: [Text Field] 6. How problem was identified:  Comprehensive site inspection  Quart erl y visual assessment  Routine facility

inspection  Benchmark monitoring  Notification by

EPA or State or local authorities  Other (describe): [Text Field] 7. Description of corrective action(s) taken or to be taken to eliminate or further investigate the problem (e.g., describe modifications or repairs to control measures, anal ys es to be conducted, etc.) or if no modifications are needed, basis for that determination: [Text Field] 8. Did/will this corrective action require modification of yo ur SWPPP?  YES  NO 9. Date corrective action initiated: [Text Field]15

10. Date correction action completed: [Text Field] or expected to be [Text Field] completed: 11.If corrective action not yet completed, provide the status of corrective action at the time of the comprehensive site inspection and describe an y remaining steps (including timeframes associated with each step) necessary to complete corrective action. [Text Field] E. ANNUAL REPORT CERTIFICATION 1. Compliance Certification Do you certify

that your annual inspection has met the requirements of this permit, and that, based upon the results of this inspection, to the best of your knowledge, you are in complian ce with the permit?  YES  NO If NO, summarize wh y you are not in compliance with the permit: [Text Field] 2. Annual Report Certification I certify under penalty

of law that this document and all attachments were prepared under m y direction or supervisi on in accordance with a s ys tem designed to assure that qualified personnel properl y gathered and evaluated the information submitted. Based on m y i nquiry of the person or persons who manage the sy stem, or those persons directly responsible for gathering th e information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility

of fine and imprisonment for know ing violations. Authorized Representative Printed Name: [Text Field] Title: [Text Field] The form will be digitally signed (in compliance with CROMERR) and dated by the user interface.16

**3.0 A**  **CTIVE C**  **ONSTRUCTION S**  **ITES A** **NNUAL C**  **OMPLIANCE C**  **ERTIFICATIONS 3.1**  **O verview**  Construction takes place on approximately 853,000 acres in the coterminous United States and results in the discharge of more than 5 billion pounds of sediment each ye ar. 7 All major surface water t ypes receive construction discharges, including streams, rivers, wetlands, lakes, estuaries, and other coastal waters. In an y given year, some level of construction activity occurs in the majority of U.S. watersheds. However, most construction acreage is concentrated in a relativel y limited number of watersheds. Between 1992 and 2001, more than half of all construction activity

took place in less than 5 percent of U.S. watersheds. A common development pattern is for new constructio n to concentrate in rural and suburban watersheds adjacent to more densel y developed urban areas. Because construction is a temporary activity , the locations of the most highl y impacted watersheds in the United States shift over time. Permit coverage unde r the construction stormwater program is primaril y through general permits, and construction sites regulated under the program are generall y required to submit a Notice of Intent (NOI) to the applicable permitting authority. Some authorized states may have a different permit application process. Because there is no central database for NOIs or other permit application information, information on the construction stormwater universe would have to be compiled from EPA and authorized states’ databases, and nationwide information is therefore not readily

available. An important feature of this sector is its transient nature (discharges from active construction sites are of a temporary nature). Currently , construction stormwater permits do not have “end

- of

- pipe” numeric effluent limits and do not require submittal of discharge monitoring reports (DMRs). This will change, however, beginning in August 2011 as the new Construction and Development Effluent Guidelines are implemented. Under the new rule, DMRs (or an e quivalent) are required to be submitted to the permitting authority on at least an annual basis. **3 .**  **2 Key Environmental Impacts/Footprint**  Stormwater runoff, including discharges from municipal storm sewers, industrial facilities and construction sites, can have a significant impact on water quality . Such discharges are responsible for beach closings, swimming and fishing advisories, and habitat degradation. Several studies reveal that stormwater discharges from urban areas can include a variety of pollut ants, such as turbidity , pathogens, organic nutrients, hydrocarbons, metals, oil and grease, and debris. As stormwater flows over a construction or industrial site or urbanized areas, it can pick up a variet y of pollutants such as sediment, debris, pestici des, petroleum products, chemicals, solvents, asphalts and acids, and in extreme cases it can alter the pH of the receiving stream or river. These pollutants can harm the environment and public health. According to EPA’s National W

ater Quality Inventory: 2 002 Report , prepared under Section 305(b) of the Clean Water Act, 40% of surveyed rivers & 45% of surveyed lakes are not clean enough to meet

7 U.S. EPA, 2009. “Environmental Impact and Benefits Assessment for Final Effluent Guidelines and Standards for the Construction and Development Category,” EPA

- 821

- R

- 09

- 012, November. [Available at: http://www.epa.gov/guide/construction/].17

basic uses ( e.g. fishable, swimmable and drinkable). The Report further showed the sediment contributes to the imp airment of 31% of impaired rivers and streams (84,503 river miles) and 21% of impaired lake areas (1.5 million acres) and is the #2 cause of impairment for rivers and streams and the #3 cause for lakes. **3.3 Number of Regulated Entities**  The constructi on universe is continually changing with new sites obtaining permit coverage in order to initiate construction activity and other sites terminating permit coverage once construction is complete and the site is stabilized. The construction industry is divid ed into three major subsectors: general building contractors, heavy construction contractors, and special trade contractors. General contractors build residential, industrial, commercial, and other buildings. Heav y construction contractors build sewers, ro ads, highway s, bridges, and tunnels. Special trade contractors ty picall y provide carpentry, painting, plumbing, and electrical services. EPA’s Office of Water estimates that nationwide the NPDES program regulates approximately 200,000 construction sites annually

. In the recent Construction and Development effluent guidelines rulemaking EPA estimates the annual amount of newl y developed land in the conterminous United States as being approximately

590,000 acres between 1992 and 2001. 8 By overlaying geograph ic information sy stem layers of states and watersheds, EPA was able to estimate the annual number of future acres of new development at both the state and watershed for that time period. EPA also used the eNOI data to estimate the number and type of constr uction sites. See the table below for this estimate of future construction acreage. **Estimated Number and Type of Future**  **Construction and Development Sites**

Source: Construction and Development Technical Development Document, Page 4

- 10.

8 See http://www.epa.gov/guide/construction/18

**3.4 Current Data**  **Entry Requirements** Most of the facilities in this sector are not “majors,” which means that states are not currentl y required to enter data on them in ICIS

-NPDES. As with any inspected facility , states and regions should enter facility (construction sit e) information and permit information resulting from the inspection. Violations found during inspections (single

- event violations) are required to be entered for EPA inspections, but not for state inspections. An additional problem with data collection on this sector is that many operators fail to file a ‘Notice to Terminate Coverage,” which affects EPA’s estimate of facilities regulated by the CGP. EPA manages the stormwater program for four states (NH, MA, NM, ID), the District of Columbia, and federal facilities. EPA has implemented a web

- based permit application sy stem (eNOI) to manage coverage for EPA

- issued stormwater permits. Alaska was partially delegated NPDES program authority and has adopted the use of eNOI. Construction site operators can apply for coverage under EPA’s Construction General Permit (CGP) or submit a low erosivity waiver, if applicable, for exclusion from the CGP. The objectives of the eNOI sy stem include: (1) more efficient NOI processing for EPA and operators; (2) reduce or elimi nate paper handling burdens; and (3) enable electronic data collection, management, anal ys is, and reporting. **3.5 Current Permitting Requirements**  The NPDES Phase I and Phase II stormwater permit programs are now fully implemented. 9 However, the new Construction and Development effluent guidelines (published 1 December 2009) add new regulatory requirements (40 CFR 450). These new requirements will require additional costs to state and regional NPDES programs. Specifically, these programs will incur costs for:

 Revising NPDES permits for incorporating the Construction and Development effluent guidelines (Part 450);
 Processing and analyzing discharge monitoring reports (DMRs) for construction sites regulated b y Part 450; and
 Reviewing the regulation, developing a plan for implementation, disseminating information to relevant parties, and potentiall y updating DMR data management systems. **3.6 New Electronically Reported Compliance Certification**  Section 402(p) of the Clean Water Act provides that stormwater discharges associated with industrial activity , including those related to construction activity , entering waters of the United States must receive authorization under a NPDES permit. Once oper ators of construction sites regulated b y the NPDES stormwater program obtain permit coverage, they must develop stormwater pollution prevention plans (SWPPPs), as well as implement sediment, erosion, and pollution prevention control measures in accordance with the SWPPPs, at their sites.

9 See http://cfpub.epa.gov/npdes/stormwater/const.cfm..19

The SWPPPs contain the parameters with which facilities must comply to meet the terms and conditions of the ir permit . Facilities must develop SWPPPs in accordance with sound engineering practices and based on site

- speci fic criteria. The SWPPPs focus on identifying sources of pollution in stormwater discharges on the sites, as well as developing and implementing appropriate measures to reduce pollutants in the stormwater discharges to ensure compliance with the ir permit

. This paper proposes to extend the annual reporting requirement in EPA’s Construction General Permit (CGP) to all facilities with industrial stormwater dischargers. This new annual compliance certification will require that permittees inspect designated areas on their sites at least once per week and within 24 hours after an y storm event of 0.5 inches or great er . Inspectors must visually

assess the disturbed areas and discharge points on the site, the condition and effectiveness of implemented sediment and erosion controls, and the quality of the receiving waters near the site , with regard to any evidence of pollutant introductions. The CGP specifies requirements for inclusion in inspection reports, such as the inspection date, pertinent weather information, and BMP descriptions. The CGP also provides standardized inspection forms, as attached below, as well as checklists, for potential utilization by the facilities, to be supplemented with any necessary

site

- specific information. The inspection reports must identify

any incidents of non

- compliance at the construction sites, as well as an y actions taken b y the facilities to return them to compliance with the CGP terms and conditions. If the permittees do not identify any incidents of non

- compliance, the inspection reports must contain a certification that the sites are operating in compliance with their SWPPPs and the CGP. The CGP requires that qualified personnel, either employed b y the construction site operators or hired as consultants, perform the site inspections. The inspectors must possess the necessary skills to assess conditions at construction sites pertaining to pollutant laden stormwater runoff, the effectiveness of implemented pollution control measures, and potential water quality impacts to nearb y water bodies. Following the inspections, a responsible officer, a general partner or proprietor of a partnership, or a principal executive officer for the construction site operators must sign and certify the inspection reports. The operators face EPA enforcement actions, including penalties, for knowingl y making false statements, representations, or certifications on their inspection reports. Construction site operators covered b y the CGP must retain inspection reports, with their SWPPPs, o n site for three years after the permit expires or terminates. Facilities must make copies of their SWPPPs readily available to authorized inspectors during any normal business hours. In addition, permittees must make SWPPPs available, upon request, to E PA and an y federal, state, or local agencies responsible for approving stormwater management plans, including sediment and erosion control plans, or evaluating water quality and habitat maintenance near the construction sites. Since the NPDES stormwater program requires construction site operators to develop and maintain SWPPPs, including updated inspection reports generated and retained on site in accordance with the SWPPPs, EPA could develop an electronic reporting sy stem through which site operators c ould scan, certify , and submit their inspection reports to EPA on an annual basis,20

without requiring an y substantial increased costs or resource demands on the facilities. While EPA would need to use resources to manage and systematically review this info rmation, having this information available for “desktop” types of compliance auditing could create efficiencies that would allow for fewer, resource intensive on

- site inspections. Another benefit of obtaining this information electronically is that EPA wo uld be able to improve targeting aimed at identifying serious noncompliance for those on

- site inspections that are conducted and would facilitate compliance reviews at a corporate and/or watershed level, as opposed to facility

- by

facility

. **3.7 Example**  **Form for Po**  **tential Electronically Reported Compliance Certification**  The following is an example form for construction stormwater annual compliance certification. For the proposed NPDES Electronic Reporting Rule EPA opted to not create any new reporting requirements. **Construction Stormwater Annual Compliance Certification Reporting Form**  **General Information Project Name**  **NPDES Tracking No. Location**  **Date of Inspection Start/End**  **Time Inspector’s Name(s)**  **Inspector’s Title(s) Inspector’s**  **Contact Information**  **I nspector’s Qualifications**  Insert qualifications or add reference to the SWPPP. (See Section 5 of the SWPPP Template) **Describe present phase of construction**  **Type of Inspection:**  Regular  Pre

- storm event  During storm event  Post

- storm event **Weather Information Has there been a storm event since the last inspection?**   Yes  No **If yes, provide:** Storm Start Date & Time: Storm Duration (hrs): Approximate Amount of Precipitation (in): **Weather at time of this inspection?**  Clear  Cloudy  Rain  Sleet  Fog  Snowing  High Winds  Other: Temperature: **Have any discharges occurred since the last inspection?**  Yes  No **If yes, describe:**21

**Are there any discharges at the time of inspection?**  Yes  No **If yes, desc ribe:**  **Site**
**- specific BMPs** 
 Number the structural and non

-structural BMPs identified in your SW PPP on your site map and list them below (add as many BMPs as necessary). Carry a copy of the numbered site map with you during your inspections. This list will ensure that you are inspecting all required BMPs at your site.
 Describe corrective actions initiated, date completed, and note the person that completed the work in the Corrective Action Log. **BMP BMP** 

**Installed? BMP** 

**Maintenanc e Required?**  **Corrective Action Needed and Notes** 

1  Yes  No  Yes  No 2  Yes  No  Yes  No 3  Yes  No  Yes  No 4  Yes  No  Yes  No 5  Yes  No  Yes  No 6  Yes  No  Yes  No 7  Yes  No  Yes  No 8  Yes  No  Yes  No 9  Yes  No  Yes  No 10  Yes  No  Yes  No 11  Yes  No  Yes  No **Overall Site Issues** Below are some general site issues that should be assessed during inspections. Customize this list as needed for conditions at your site. **BMP/activity Implement** 

**ed? Maintenan** 

**ce Required?**  **Corrective Action Needed and Notes**

1 Are all slopes and disturbed areas not activel y being worked properl y stabilized?  Yes  No  Yes  No

2 Are natural resource areas (e.g., streams, wetlands, mature trees, etc.) protected with barriers or similar BMPs?  Yes  No  Yes  No22

**BMP/activity Implement** 

**ed? Maintenan** 

**ce Required?**  **Corrective Action Needed and Notes**

3 Are perimeter controls and sediment barriers adequatel y installed (keyed into substrate) and maintained?  Yes  No  Yes  No

4 Are discharge points and receiving waters free of an y sediment deposits?  Yes  No  Yes  No

5 Are storm drain inlets properly protected?  Yes  No  Yes  No

6 Is the construction exit preventing sediment from being tracked into the street?  Yes  No  Yes  No

7 Is trash/litter from work areas collected and placed in covered dumpsters?  Yes  No  Yes  No

8 Are washout facilities (e.g., paint, stucco, concrete) available, clearl y marked, and maintained?  Yes  No  Yes  No

9 Are vehicle and equipment fueling, cleaning, and maintenance areas free of spills, leaks, or an y other deleterious material?  Yes  No  Yes  No

10 Are materials that are potential stormwater contaminants stored inside or under cover?  Yes  No  Yes  No

11 Are non

- stormwater  Yes  No  Yes  No23

**BMP/activity Implement** 

**ed? Maintenan** 

**ce Required?**  **Corrective Action Needed and Notes** discharges (e.g., wash water, dewatering) properl y controlled? 12 (Other)  Yes  No  Yes  No **Non -**  **Compliance** Describe an y incidents of non

- compliance not described above:

**CERTIFICATION STATEMENT** “I certify under penalt y of law that this document and all attachments were prepared under my direction or supervision in accordance with a s ys tem designed to assure that qualified personnel properl y gathered and evaluated the info rmation submitted. Based on m y i nquiry of the person or persons who manage the sy stem, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility

of fine and imprisonment for knowing violations.” **Print name and title:**

**___________________________________________________________________________** The form will be digitally signed (in compliance with CROMERR) and dated by the user interface.24

**4.0 C**  **ONCENTRATED A** **NIMAL F**  **EEDING OPERATIONS (**  **CAFO S**  **) C**  **OMPLIANCE**

**C ERTIFICATIONS**  **4.1 Overview**  The U.S. Department of Agriculture (USDA) estimates that operations that confine livestock and poultry

animals generate about 500 million tons of manure annually

– three times the amount of EPA’s estimate of 150 million tons of human sanitary waste produced annually in the U.S. Pollutants commonly associated with manure i nclude nutrients (mainly nitrogen and phosphorus), organic matter, solids, and pathogens. Under Section 305(b) of the Clean Water Act (CWA), states have consistently reported that agricultural activities

– including animal feeding operations

– are leading sources of pollutants such as nutrients, pathogens (bacteria), and organic enrichment (low dissolved oxygen) that are contributing to water quality impairment in U.S. surface waters. Adverse environmental and human health impacts associated with pollutants in animal manure include: eutrophication or nutrient over

- enrichment of surface waters, fish kills, reductions in dissolved ox ygen available for aquatic life, increase in suspended solids resulting in an increase in turbidity of surface waters and inhibit ion of the functioning of aquatic plants and animals, nitrate contamination of drinking water, and transmission of pathogens associated with food and waterborne diseases in humans. EPA and the states receive inconsistent information about the CAFO sector because most CAFOs do not have National Pollutant Discharge Elimination System (NPDES) permits, do not have traditional effluent discharge points and controls and, therefore, do not submit discharge monitoring reports (DMRs). Permit coverage for this universe includes individual permits and general permits. Man y states have their own permit programs for livestock operations, but because these operations do not meet EPA 's definition of NPDES "major," the states are not required to submit much data to EPA. EPA’s Office of Water estimates there are approximately 19,000 CAFOs. Under the terms of the NPDES CAFO regulations at 40 CFR §122.23, an animal feeding operation is defined as a larg e CAFO based on the number of animals raised in confinement, for example, 700 mature dairy

cows, 1,000 beef cattle, or 2,500 swine (each weighing 55 pounds or more). An animal feeding operation is defined as a medium CAFO based on both typ e and number of animals confined, for example 200 to 699 mature dairy cows or 300 to 999 beef cattle, 750 to 2,499 swine (each weighing 55 pounds or more) as well as certain other conditions at the facility , including pollutants discharged to jurisdictional waters via a ma n - made ditch or other man

- made device or pollutants are discharged directl y into waters of the United States which pass over/through the facility

or otherwise come into direct contact with the confined animals. Predominant animal agriculture sectors includ e dairy , beef cattle, poultry , egg laying operations, and swine. Every

EPA region has CAFOs. The states with the highest numbers of CAFOs include: Arkansas, Iowa, North Carolina, Minnesota, Texas, and California. Collectively , these states have more than a third of all CAFOs in the U.S, **4.2 Current Program Reporting**  Under the terms of EPA’s CAFO NPDES regulations as revised in 2008, only CAFOs that either discharge or propose to discharge must seek NPDES permit coverage. This aspect of25

the NPDES program requires NPDES permit authorities to obtain site

- specific information in order to require CAFOs to seek permit coverage if CAFOs do not seek coverage independentl y. Simple, easily

enforceable NPDES permit requirements for CAFOs are difficult to develop bec ause CAFOs do not have outfalls and effluent controls like other industrial point sources. Instead, CAFO permits require implementation of best management practices. A CAFO that believes it does not need to seek NPDES permit coverage can voluntarily certif y to the permitting authority that it does not discharge or propose to discharge. EPA does not receive copies of the CAFO certifications. The Office of Water estimates that approximately 15,000 large and medium CAFOs need permits and approximately 8,000 CAFOs currentl y have NPDES permit coverage. EPA regulations at 40 CFR 122.42(e)(4) require permitted CAFOs to submit an annual report to the NPDES Director. The annual report must include: (1) the number and type of animals, whether in open confinement or housed under roof; (2) estimated amount of total manure, litter and process wastewater generated by the CAFO in the previous 12 months (tons/gallons); (3) estimated amount of total manure, litter and process wastewater transferred to other person b y the CA FO in the previous 12 months (tons/gallons); (4) total number of acres for land application covered by the CAFO’s nutrient management plan; (5) total number of acres under control of the CAFO that were used for land application of manure, litter and proces s wastewater in the previous 12 months; (6) summary of all manure, litter and process wastewater discharges from the production area that have occurred in the previous 12 months, including date, time, and approximate volume; (7) a statement indicating whet her the current version of the CAFO's nutrient management plan was developed or approved b y a certified nutrient management planner; (8 ) actual crop(s) planted and actual yield(s) for each field; the actual nitrogen and phosphorus content of the manure, li tter, and process wastewater; calculations of maximum amounts of manure, litter, and process wastewater to be land applied at least once per ye ar; and the amount of manure, litter, and process wastewater applied to each field in the previous 12 months; re sults of any soil testing for nitrogen and phosphorus taken during the previous 12 months; and any supplemental fertilizer applied during the previous 12 months. **4 .3**  **Example Form for Potential Electronically Reported Compliance Certification**  The following is an example form that might assist EPA and the states in better identifying CAFOs that might require permitting

. For the proposed NPDES Electronic Reporting Rule EPA opted to not create an y new reporting requirements.

**CAFO Stormwater Annua**  **l Compliance Certification Reporting Form** A. GENERAL INFORMATION 1. CAFO Name: [Text Field] 2. Has this CAFO applied for a NPDES Permit?  YES  NO If YES, NPDES No.: [Text Field]26

3. CAFO Phy sical Address a. Street: [Text Field] b. City : [Text Field] c. State: [Text Field] d. Zip Code: [Text Field] e. L ocation (longitude and latitude) of the CAFO 4. CAFO Owner Name: [Text Field] a. Title: [Text Field] b. Street: [Text Field] c. City : [Text Field] d. State: [Text Field] e. Zip Code: [Text Fiel d] f. Phone: [Text Field] g. E

- mail: [Text Field] 5. I s the CAFO Operator is different than the CAFO Owner?  YES  NO If YES, a. CAFO Owner Name: [Text Field] b. Title: [Text Field] c. Street: [Text Field] d. City : [Text Field] e. State: [Text Field] f. Zip Code: [Text Field] g. Phone: [Text Field] h. E

- mail: [Text Field] 6. I s the CAFO a contract operation?  YES  NO If YES, a. CAFO Integrator Name: [Text Field] b. Title: [Text Field] c. Street: [Text Field] d. City : [Text Field] e. State: [Text Field] f. Zip Code: [Text Field] g. Phone: [Text Field] h. E

- mail: [Text Field] 7. Ty pe of CAFO Facility : [Text Field] 8. Number [Text Field] and ty pe(s) of animals [Text Field] 9. Ty pe [Text Field]and capacity of manure storage: [Text F ield] 10. Quantity

of manure, process wastewater and litter generated annuall y by the CAFO [Text Field]27

11. Does the CAFO land

- apply manure?  YES  NO If No, a. What (if an y) are the alternative uses of manure, litter, and/or wastewater? [Text Box] b. Who if anyone receives your CAFO manure [Text Box] and how much do they receive in the last year [Text Box]. If YES, a. Does the CAFO implement a nutrient management plan for land application?  YES  NO b. Does the CAFO employ nutrient management practices and keeps records on site consistent with 40 C.F.R. § 122.23(e)?  YES  NO 12. What is the available acreage for land application: [Text Field] **CERTIFICATION STATEMENT** “I certify under penalt y of law that this document and all attachments were prepared under m y direction or supervision in accordance with a s ys tem designed to assure that qualified personnel properl y gathered and evaluated the information submitted. Based on m y i nquiry of the person or persons who manage the sy stem, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for sub mitting false information, including the possibility

of fine and imprisonment for knowing violations.” **Print name and title:**

**___________________________________________________________________________** The form will be digitally signed (in compliance with CROMERR) and dated by the user interface.