Indiana Launches Electronic NPDES Discharge Monitoring Reports
By Jennifer Thompson, Attorney, Bingham Greenebaum Doll LLP
Any Indiana facility with an individual or general National Pollutant Discharge Elimination System permit that is required to submit a paper discharge monitoring report (DMR) to the Indiana Department of Environmental Management (IDEM) can now submit an electronic DMR via a secure internet connection entitled “NetDMR.” The NetDMR service has been provided free of charge to IDEM by EPA. The data submitted to IDEM and EPA via NetDMR will be downloaded into EPA’s Integrated Compliance Information System (ICIS) network automatically. Currently, IDEM has to manually input data from the written DMRs it receives every month into the ICIS database. At the present IDEM is not able to convert the data submitted via NetDMR into a format resembling the current written DMR document for inclusion in IDEM’s Virtual File Cabinet, but IDEM is reviewing its options.
IDEM recommends that permittees attend a free internet-based seminar provided by either EPA or IDEM before using NetDMR. IDEM also recommends that sources utilize the NetDMR website to become familiar with registration, data entry, and the submittal process. Before using NetDMR, permittees will have to request signatory authority and submit a subscriber agreement to IDEM. The applicant will have to agree to the terms and conditions of the agreement and then print, sign, and mail the form to IDEM before the NetDMR service can be fully accessed online.
Unfortunately, NetDMR does not allow the electronic input of Monthly Monitoring Reports/Monthly Report of Operations (MMR/MRO); however, MMRs/MROs are still required to be submitted. MMRs/MROs can be printed, signed and scanned as pdf files and submitted as an attachment to the corresponding NetDMR submittal. Permittees can include up to 20 MB of attachments per submittal. Explanations of permit noncompliance (including permit limit exceedances, missed samples or reduced frequency of analysis) and previously faxed Noncompliance Reports should also be attached as pdf documents to the NetDMR submittal. Permittees are still required to keep a record of the DMR they submit via NetDMR, so permittees must remember to print a copy of their NetDMR submission along with any attachments every month.
NetDMR is currently an optional program for Indiana permittees; however, EPA is in the process of promulgating regulations which would require electronic reporting for some facilities as early as January 2014. Only a handful of Indiana permittees are participating in the program so far, but the number of participants is expected to grow as IDEM becomes more familiar with the process and provides outreach to permittees. IDEM staff are encouraging permittees to consider NetDMR because it reduces paperwork, and improves timeliness and accessibility of DMR data.
To view a complete PDF of the March/April 2012 issue of the Environmental Letter, click HERE.