Due to limited resources, agencies must frequently prioritize compliance efforts to target those facilities or sources that pose the greatest threat to human health and the environment. Avanti assists in focusing agency resources with strategies that identify meaningful targets in order to maximize environmental benefits.
Permit Management Oversight System
Avanti maintains the prototype version of the Permit Management Oversight System (PMOS), a web-based system that enables priority permit tracking and management and collection of priority permit inventories. Development of the PMOS prototype included development of the detailed requirements and design of the system in conjunction with EPA staff.
The systems tracks and displays basic permit information such as permit number; facility name; SIC code; major/minor permit status; priority and issuance year; previous issuance and expiration dates; whether the permit is EPA- or State-issued, Tribal or Non-Tribal; whether the permit discharges to a 303(d)-listed (i.e., impaired) waterbody or discharges an impairing pollutant; when the permit information was last updated and by whom; whether the EPA Region has concurred with the State’s prioritization; public notice, reissuance, and termination dates (and the reason for termination); and user comments.
NPDES Inspector Workshops
Avanti supports the Office of Compliance annual CWA/NPDES Technical Inspector Workshops to provide training to EPA inspectors on NPDES inspections. Topics covered include inspection preparation, report writing, flow measurement, and shipping samples for analyses. The workshops also have included field exercises in which participants chose one of four types of facilities to visit: a concentrated animal feeding operation (CAFO), a pretreatment facility, a wastewater treatment plant, or a storm water sewer overflow (SSO/CMOM) facility. Participants reviewed items to look for and key elements needed in an NPDES inspection for each of the facilities.
Biosolids Program Compliance
The Rural Branch of the EPA Water Permits Division operates under Section 405, Disposal of Sewage Sludge, of the Clean Water Act to oversee the implementation of Standards for the Use of Disposal of Sewage Sludge. Eight states have authorized NPDES biosolids programs and part of Avanti’s work was to evaluate the effectiveness of the programs in these states. Avanti collected environmental/engineering data for analyses, reviewed and assessed data quality, and conducted modeling and statistical analyses to determine compliance with biosolids disposal and reporting requirements. Analyses included current system evaluations, innovative treatment technology system costs, regulatory compliance cost estimation, and engineering performance and efficiency assessments.