By Jeryl L. Olson and Craig B. Simonsen
The Illinois Environmental Protection Agency (Illinois EPA) had first introduced the “eDMR” (electronic Discharge Monitoring Report) system in April 2004.
The eDMR system was developed so that National Pollutant Discharge Elimination System (NPDES) permittees with a computer and an Internet connection could complete, sign, submit, edit, and re-submit eDMR forms online. When the eDMR system was introduced it was completely voluntary, but the Illinois EPA was “strongly encouraging” NPDES permittees to use the eDMR reporting method.
In December 2013 Illinois EPA notified the regulated community that it had begun transitioning facilities to another DMR reporting program – NetDMR. The NetDMR system, like the eDMR system, is a Web-based tool that allows NPDES permittees to electronically sign and submit their DMRs. Illinois EPA claims that “NetDMR is a substantial improvement over eDMR.”
NetDMR is a Web-based tool that allows NPDES permittees to electronically sign and submit their discharge monitoring reports (DMRs) to the U.S. Environmnetal Protection Agency’s Integrated Compliance Information System (ICIS-NPDES) through its Central Data Exchange (CDX) node on the Environmental Information Exchange Network. The Illinois EPA has chosen NetDMR over the current electronic reporting tool, eDMR, due to the direct link to the U.S. EPA’s ICIS-NPDES, and “because it is more user friendly.”
Illinois EPA “strongly encourages you to transition to NetDMR as soon as possible, however due to the eDMR systems unreliable status you must transition to NetDMR no later than March 31, 2014.” In addition, if you are unable to immediately begin reporting utilizing NetDMR, “a three month supply of hardcopy paper preprinted DMRs will be provided for your convenience.”
For Illinois NPDES facilities, the NetDMR system appears to be a useful tool for maintaining compliance with facility NPDES permits. Keep in mind though, that like other e-filed reports, it will be promptly and publically available online for competitors and environmental groups to access and analyze, and reports noting exceedances may result in rapid enforcement. If a facility is regularly reporting exceedances of permit limits you should consult with your environmental counsel. Make sure that the plant is in compliance with its permit, or make a good paper trail as to why it is not.
Source: Seyfarth, Shaw Law Firm