



Office of Enforcement and Compliance Assurance







NPDES Electronic Reporting Rule
Analysis A: Discharge Monitoring Reports





23 September 2010

Table of Contents

1. Introduction	1
1.1 Purpose	2
1.2 Assumptions and Constraints	3
1.3 Document Overview	4
2. Overview of NetDMR	5
2.1 Current Implementation	5
2.1.1 User Administration, System Administration, CROMMER Compliance	5
2.1.2 User Functionality	6
2.1.3 NetDMR Email Notifications	7
2.2 State Data Submissions	8
3. Proposed Solution	11
3.1 Architecture and Data Flows	11
3.2 Modifications to Existing Capabilities	13
3.2.1 DMR-Related Data Not Currently Stored in ICIS-NPDES	14
3.2.2 Increase the Volume of Data Submitted in a Single Transaction	16
3.2.3 Increased NetDMR Functionality and Interactions with ICIS-NPDES	17
3.2.4 Customization for State-Specific Requirements	19
4. Technical Considerations for an Enhanced NetDMR	20
4.1 Existing eDMR Systems	20
4.1.1 National Installation of NetDMR	20
4.1.2 Enfotech E2 Software	20
4.1.3 California ESMR	21
4.1.4 Illinois eDMR	21
4.1.5 Indiana eDMR	21
4.1.6 Maine EFIS	21
4.1.7 Mississippi eDMR	21
4.1.8 North Carolina eDMR	21
4.1.9 South Carolina EFIS	21
4.1.10 Texas NetDMR	22
4.1.11 Washington WebDMR	22
4.1.12 West Virginia eDMR	22
4.1.13 Wisconsin eDMR	22
4.1.14 Wyoming eDMR	22
4.2 Mapping of RIDE Data Elements into eDMR Systems	22
4.3 Reporting Universe	23
4.4 Reporting Frequency	26
5. Technical Feasibility of an Enhanced NetDMR	27
5.1 Data Analysis	27
5.2 Benefits and Challenges	28
6. Legal Considerations for an Enhanced NetDMR	32
6.1 Regulation Cites	32
6.2 Statutory Determination	33
6.3 Information Collection Request Issues	34
6.4 Data Stewardship Issues	34
6.5 CROMERR Compliance Issues	35
6.6 Exemptions and Waivers	35
6.7 System of Record	35
7. Specific Considerations for an Enhanced NetDMR	36
7.1 Key Steps for Adoption	36
7.2 State System Compatibility	37
7.3 ICIS-NPDES Data Publishing	37

List of Tables
TABLE 2-1: NetDMR User Roles and Privileges Overview	6
Table 2-2: NetDMR Email Summary	7
Table 4-1: RIDE DMR Data Elements	23
Table 4-2: Regulated Entities in ICIS-NPDES and PCS	24
Table 4-3: Regulated Entities Not in ICIS-NPDES and PCS	26
Table 5-1: NPDES DMR Frequency	27
Table 5-2: NetDMR Enhancements Potential Benefits	28
Table 5-3: NetDMR Enhancements Potential Challenges	29

                                List of Figures
Figure 2-1: Example of State Data Transfer to ICIS-NPDES	8
Figure 2-2: CDX Web Services Used by NetDMR	9
Figure 3-1: eNPDES DMR System and Data Integration Framework	12


Introduction
The Environmental Protection Agency (EPA) Office of Enforcement and Compliance Assurance (OECA) released the Clean Water Act Action Plan (CWAAP) in October 2009. This plan contains ambitious short- and long-term goals for revamping the approach to enforcement of clean water laws. One major goal of the CWAAP is to improve transparency and accountability in enforcement activities. The plan identified increased electronic reporting of data by regulated entities as one of the keys to achieving that goal.
Taking the results of the CWAAP, the eReporting Workgroup identified electronic reporting projects that could potentially assist in meeting the goals of the CWAAP. The projects generally fall into two categories:
Application Data: allows the regulated entity to submit Permit and Master General Permit coverage applications and Notices of Intent (NOI) electronically to the regulatory authority. This could also include application fee collection and tracking. 
Compliance Data: allows the regulated entity to submit compliance data such as Discharge Monitoring Reports (DMRs), Program Reports, and Schedule Event achievement and reporting dates directly to the regulatory authority. 
The following projects were evaluated under this effort:
eNPDES Program Reports (Compliance Data)
eNOI Expansion (Application Data)
eCertification (Compliance Data)
NetDMR Enhancement (Compliance Data)
ePermitting (Application and Permit Data).
There are many worthy projects, however, resources are limited. As such, each proposed eReporting project has received a preliminary evaluation to assist in determining whether the project should be funded and implemented. This proposed project aims to expand the reach of the existing EPA electronic DMR (eDMR) tool to include more of the reporting required but not currently being captured by regulated facilities under the National Pollutant Discharge Elimination System (NPDES) Program.  The project identifies potential implementation of future enhancements, while allowing states to continue using their eDMR systems to ensure their data gets reported to EPA's Integrated Compliance Information System for NPDES (ICIS-NPDES).
The National Installation of NetDMR (NetDMR) is EPA's current eDMR tool that was released in June of 2009 and allows NPDES regulated entities to enter and electronically submit DMR data through the Central Data Exchange (CDX) to ICIS-NPDES, as an alternative to the paper-based DMR submission process.
All states are required to report federally required DMR data to ICIS-NPDES or EPA's legacy Permit Compliance System (PCS). States currently report DMR data to ICIS-NPDES using the following methods:
Collect paper-based DMR forms, manually enter the information into the state database, and enter the required federal data into ICIS-NPDES either on the web or through Batch eXtensible Markup Language (XML) files.
Develop a customized state eDMR tool that allows regulated entities to enter and electronically submit DMR data into a web-based application. The DMR data is then sent to the state database and the state is responsible for entering the required federal data into ICIS-NPDES either on the web or through Batch XML files.
Create a customized installation of NetDMR, which sends data directly from the regulated entity to ICIS-NPDES via CDX. Texas is currently the only state with its own installation of NetDMR.
Allow regulated entities to enter data into the National Installation of NetDMR, which is provided and hosted by EPA. These DMRs are sent directly to ICIS-NPDES via CDX.
Purpose
This document provides an overview of the proposed eDMR project and its technical and cost considerations. As part of the analysis, information were gathered and analyzed to inform the following subject areas:
Identifying NetDMR and existing state eDMR tools and experience
Mapping of data collected by the eDMR tools into the proposed Requisite ICIS-NPDES Data Elements (RIDE) data element list to determine which data elements are being captured
Size of the reporting universe that are currently using NetDMR, and potential reporting universe candidates
Frequency of DMR reporting based on existing regulations
Total volume of data that may be reported to NetDMR
ICIS-NPDES data required by NetDMR and state eDMR systems to perform properly
Key considerations regarding existing state eDMR tools (e.g., can tool be used by states with additional information needs than EPA)
Key complications for expansion to national use (e.g., can tool be used to standardize processes and data collection)
Technical feasibility of enhancing NetDMR to accommodate the potential reporting universe candidates
CDX data flow options that are available between regulated facilities, NetDMR and state eDMR tools
Compatibility of NetDMR and state eDMR tools with EPA's ICIS-NPDES system
Flexibility of the NetDMR tool for use with state data systems
Estimated cost to enhance NetDMR
Estimated O&M costs for an enhanced NetDMR
Non-EPA support for NetDMR and state eDMR tools
Regulation cites to be modified or added to impose the requirement for using NetDMR
Statutory determination on EPA's ability to collect the data and implement the various aspects of the rule
Gist of the modified or added regulations
Associated Information Collection Request (ICR) issues
Data stewardship issues
Cross-Media Electronic Reporting Regulation (CROMERR) compliance issues
Triggers for electronically reporting information
Phasing of the reporting universe candidates
Exemptions or waivers to allow paper reporting for facilities demonstrating hardship
Identifying the system of record 
Changes in state costs
Benefits to states
Changes in EPA Regional costs
Benefits to EPA Regions
Changes in reporting universe costs
Benefits to the reporting universe
Needs to be met through eDMR reporting
Reporting of data contained within an eDMR tool
Key steps to be taken to facilitate adoption of an eDMR tool
Specific modifications needed to NetDMR to support the candidate reporting universe
Modifications needed to state eDMR systems to support reporting data to ICIS-NPDES
Process for reporting of NetDMR data to states
Modifications needed to support special regulatory programs
Phasing of special regulatory program data collection
New rules from EPA's Office of Water (OW) regarding self-monitoring
Each chapter of the document follows a common format to provide this information. Common concepts are repeated in the chapters so that each chapter stands alone as its own comprehensive document for effective use by EPA workgroups with a focus on each of the solutions.
Assumptions and Constraints
The following assumptions and constraints apply to this document:
State eDMR systems were identified through a combination of calls between OECA and states, information on the Exchange Network, or results of Google searches.
State eDMR systems were evaluated based upon available online documentation of these systems.
For each state eDMR tool, at least two sample state systems were evaluated against a national set of data requirements.
The existing NetDMR/CDX/ICIS-NPDES architecture will be leveraged and enhanced for each system.
Cost considerations do not include impacts to state or regulated community costs including reductions in burden, state system development costs, and state system maintenance costs.
State permit and limit data must exist in ICIS-NPDES, rather than in PCS, in order to participate in the use of the tools.
NetDMR will be the mandatory eDMR solution for all EPA Regions and the optional eDMR solution for states not able to host their own eDMR tool. A state with an existing eDMR tool may be required to modify their tool to report all required data to ICIS-NPDES.
Document Overview
The following sections comprise this document: 
Section 2: Overview of NetDMR  -  This section describes NetDMR and how it reports data to ICIS-NPDES.
Section 3: Technical Considerations for an Enhanced NetDMR  -  This section analyzes various aspects of existing eDMR tools such as data collected, and explores what is needed to enhance NetDMR to support the proposed NPDES reporting universe candidates.
Section 4: Technical Feasibility of an Enhanced NetDMR  -  This section explores the feasibility of expanding NetDMR.
Section 5: Legal Considerations for an Enhanced NetDMR  -  This section explores legal and regulatory issues that affect NetDMR.
Section 6: Specific Considerations for an Enhanced NetDMR  -  This section presents issues specific to an eDMR tool, such as steps toward implementation and data transfer from state systems.

Overview of NetDMR
This project aims to expand the reach of the NetDMR system to include additional functionality, streamline overlapping system functionality, and provide a more robust platform that EPA Regions, states, tribes and territories can use to manage and submit their DMR data across the entire reporting universe.
Current Implementation
NetDMR provides the regulated communities for participating regulatory authorities a tool to electronically enter, sign, and submit DMR data to ICIS-NPDES. To facilitate this process NetDMR exchanges DMR data through customized data flows. Several data flows have been developed to allow for the exchange of data between ICIS-NPDES and the NetDMR Tool.
The Basic Permit Data Flow (BPDF) allows NetDMR to retrieve all permit and facility data associated with a regulatory authority from ICIS-NPDES, while the Empty Slot Data Flow (ESDF) allows NetDMR to retrieve DMRs for anticipated measurements that are candidates for reporting, or "empty slot DMRs", from ICIS-NPDES. 
Once NetDMR is populated by the BPDF and ESDF, permittees can use it to enter their monitoring data for submission to ICIS-NPDES. NetDMR submits the DMR data to ICIS-NPDES using the ICIS-NPDES - NPDES Batch DMR Data Flow. Any error or warning messages that result from the processing of the DMR data by ICIS-NPDES are returned as an XML file to NetDMR via CDX through the Error Message Data Flow (EMDF).
Transactions in the current implementation are asynchronous, and are queued up and processed by ICIS-NPDES during non-peak operating hours. Results are returned to NetDMR the morning following the submission.
User Administration, System Administration, CROMMER Compliance
NetDMR was designed with its own functionality for user administration, system administration, and CROMERR compliance. The system does not use existing CDX services for these functions. NetDMR was developed with custom functions to perform:
Initial User Registration
User Account Management
User Authentication and Authorization
User Activity Management specific to CDX Data Flow Transactions
CROMERR required secret questions
CROMERR required e-signature (hashing algorithm from CDX re-used).
User Functionality
Once registered as a user, NetDMR provides role/function-based privileges. NetDMR allows four types of users: 
System User 
Internal User
Permittee User
Data Provider User
Each user type can request a variety of roles specific to the user type. One must decide what roles and privileges they want to perform when choosing a user type during the initial NetDMR registration process because a user type cannot be changed once it has been created. Table 2-1 provides a summary of the functions available to each user type and the likely Organization to which the user belongs for the National Installation of NetDMR.
Table 2-1: NetDMR User Roles and Privileges Overview
User Role
User Organization
User Privileges


EPA HQ
   > Configures NetDMR Installation and manages installation level settings
   > Creates and manages all NetDMR instances and instance settings (e.g., system downtime, data flow settings, password change frequency)
   > Approve "View Only Internal User" to be an Internal Administrator
Internal User  -  View Only
Regulatory Authority
   > View DMR Copies of Records after signed and submitted by Permittee
   > Cannot view in-progress DMRs
   > Cannot modify in-progress DMRs
Internal User  -  Internal Administrator
Regulatory Authority
   > All User Activities for Internal User-View Only apply
   > Approve request for Internal User-View Only for other Regulatory Authority Users
   > Approves requests for Signatory Permittee access and manages subscriber agreements.
   > Modify a subset of the Instance Settings for the instance belonging to the user's regulatory authority
   > Request Basic Permit and Expected DMR (e.g., empty slots) data from ICIS-NPDES.
Permittee User or Data Provider  -  View Only
Regulated Community
   > View DMRs associated with assigned Permit(s).
Permittee User or Data Provider  -  Edit
Regulated Community
   > View and modify DMRs associated with assigned Permit(s).
Permittee User  -  Signatory

Regulated Community
   > View and modify DMRs associated with assigned Permit(s).
   > Sign and submit DMRs associated with assigned Permit(s).
   > Note: To become a Signatory, user must establish a Subscriber Agreement with the regulatory authority.
Permittee User  -  Permit Administrator
Regulated Community
   > Approves DMR View Only and Edit requests for users associated with assigned Permit(s).

NetDMR Email Notifications
NetDMR currently sends emails to users when internal and external events are triggered. Table 2-2 summarizes these emails.
Table 2-2: NetDMR Email Summary
Email Event
Email Description
Account Creation
NetDMR sends an e-mail to the user with a confirmation link to confirm the account. This requires answering one of the security questions when creating the account and creating a password to login
Account Created Confirmation
NetDMR sends an email to the user (except for System Administrators) confirming that an account has been successfully created for that user.
User Role Change Notification
NetDMR sends an email notification to the user (except for System Administrators) whenever that user's roles are changed (e.g., approved, denied, or revoked). 
Account Change Notification
NetDMR sends an email notification to the user (except for System Administrators) whenever that user's account information is changed.
Signatory Email Change Notification
NetDMR sends an email notification to the Internal Administrator and to the DMR submission notification email list when a Signatory's email address has changed.
DMR Submission Notification
NetDMR users with the Internal Administrator role are able to specify zero or more email addresses that will receive email notification for all DMR submissions for permits associated with that Instance.
DMR Submission Notification (Permit Specific)
NetDMR allows users with the Permit Administrator role to specify one or more email addresses that will receive email notification for all DMR submissions for a specific permit.
Account Lock Notification
NetDMR sends an email notification to the user and the Internal Administrator for that Instance when an account is locked.

Account Creation
NetDMR sends an e-mail to the user with a confirmation link to confirm the account. This requires answering one of the security questions when creating the account and creating a password to login

State Data Submissions 
ICIS-NPDES is designed to interact with CDX for processing electronic DMR data from both NetDMR and state agencies. The current data exchange model has states submitting or "pushing" data to CDX using the CDX standard web services of Authenticate, Submit, Notify and Download as shown in Figure 2-1.
Figure 2-1: Example of State Data Transfer to ICIS-NPDES 


Several states have expressed an interest in having EPA retrieve their DMR data ("pulling"). CDX has stated they have the capability to do this. Because CDX is the mechanism for transferring state data to ICIS-NPDES, each state will need to coordinate with CDX on setting up the process for retrieving data from the state's node.
ICIS-NPDES has an additional flow that provides DMR and limit data to NetDMR which is also available to states. In this particular data exchange model, NetDMR invokes one of three web services to request data from ICIS-NPDES called "getBasicPermitInfo", "getScheduledDMRsByDMR", and "getScheduledDMRsByDate". ICIS-NPDES receives these requests from CDX and returns the data to NetDMR through CDX. Figure 6-2 illustrates this process using the CDX standard web services of "Authenticate", "Solicit", "Validate", "GetStatus" and "Download" as shown in the diagram below.
Figure 2-2: CDX Web Services Used by NetDMR 




Proposed Solution
NetDMR is an ideal system for expansion, as it provides the regulated community with an easy-to-use tool that quickly and efficiently reports DMR data directly from permittees to ICIS-NPDES. Expanding NetDMR to further accommodate the needs of state regulatory authorities could significantly increase the amount of states and permittees that use NetDMR. State regulatory data entry time and costs would also be reduced by expanding the NetDMR system to report DMR data to state databases in addition to ICIS-NPDES, furthering the adoption of NetDMR by state and permittee users.
This section will discuss the proposed solution for NetDMR in the following areas:
Architecture and Data Flows Overview, which will explain how the proposed NetDMR system will relate to other systems
NetDMR Enhancements, which will explain the additional functionality for the proposed solution as well as current functionality that will be streamlined
Integration with CDX Technologies for System Administration and CROMERR, which will explain how NetDMR will re-use and integrate with existing CDX functionality
Supporting State Requirements, which will explain how state-specific eDMR functionality could be supported by NetDMR
Architecture and Data Flows
NetDMR currently has an integrated solution that shares data and transactions between NetDMR, ICIS-NPDES, and CDX. To meet the eNPDES needs of a NetDMR tool, the system should be expanded to have the capability to integrate with state eDMR tools as well (see Sections 6.2.3.1  and 6.2.4  for more details). The integrated framework must meet the following goals:
Allow data to be provided to NetDMR from ICIS-NPDES to set up use of the tool
Allow online permittee data entry for DMRs and other related form transactions containing federally required data and state specific data in NetDMR
Allow online regulatory authority viewing of DMRs within NetDMR and provide assistance to permittees in entering DMRs upon request
Allow submittal of DMR data to ICIS-NPDES and the return of the processing results to the tool as quickly as possible
Allow equivalent state NetDMR tools to submit approved DMR and related transactions containing the federally required subset of eNOI data to ICIS-NPDES for just in time processing and the return of processing results to the tool for real time user review
Allow states the ability to request federal and state-specific DMR data from NetDMR
To support these goals, the expanded eNPDES DMR System and Data Integration Framework will be built upon the use of Exchange Network technologies such as the Next Generation Node, submittal web services, and data publishing web services. Figure 3-1 provides a graphical description of the framework, followed by supporting text.
Figure 3-1: eNPDES DMR System and Data Integration Framework 
Publish Setup DataReceive Setup DataSubmit TransactionReceive SolicitationReceive TransactionSubmit ResultsReceive ResultsPublish ResultsReceive State QueryCDXState Node/NetDMRDMRSystems:-Can elect to solicit setup data from ICIS-Can submit transactions for Just In Time or Batch Processing to ICIS-Can receive DMR and COR documents from CDX-Can query the Federal Tool to receive comprehensive data.Receive Setup DataSubmit TransactionReceive ResultsReceive ResultsSubmit Data QuerySolicit Setup DataNetDMRToolContains federally required and additional data for electronic DMR transactionsContains state-specific data for state DMRs and related dataSolicit Setup DataICIS:-Contains Setup Data-Processes NetDMRTransactions-Provides Just In Time Error Messages or Confirmation for DMR and related transactionsSubmit DMR/COR  to StateReceive DMR/COR from Tool

The depicted integrated framework will provide the necessary components to meet the above stated goals as follows:
State Instance Setup (Figure 3-1=Blue)  -  For NetDMR, when a regulatory authority elects to use NetDMR and the NetDMR System Administrator sets up that regulatory authority's instance, the Basic Permit Data Flow is triggered to solicit basic permit data for the regulatory authority. Currently, NetDMR is configured to gather the results of the basic permit data solicitation each night, but is configurable to do gather this data on a more frequent basis. NetDMR data flow configuration changes can be made to update the Permits in NetDMR multiple times per day. System testing should be conducted to ensure that more frequent, daytime updates will not impact the online user experience. Once a Permit's administrator assigns a Signatory to the permit, NetDMR requests expected DMR form data from ICIS-NPDES. The data will not be available to the user until the following day. In addition, if changes are made to the underlying data in ICIS-NPDES, manual user intervention is required by the regulatory authority to request an update from ICIS-NPDES. To eliminate this manual intervention and improve the timeliness and accuracy of expected DMR form data in NetDMR, the data flow will be enhanced to push more timely updates from ICIS-NPDES to NetDMR.
Submit DMRs to ICIS-NPDES (Figure 3-1=Green)  -  Upon certification and regulatory authority approval of DMR forms, the regulatory authority user will submit the transaction for ICIS-NPDES Processing, via CDX. CDX will virus scan, archive, validate the transaction against the NetDMR XML schema, perform any CROMERR required functions, and then pass the transaction to ICIS-NPDES for immediate processing. Upon receipt, ICIS-NPDES will immediately process the transaction using established NPDES DMR business logic to populate the DMR forms for the permit. If successful, the transaction will be saved to ICIS-NPDES, and a confirmation of processing will be submitted back to the tool, via CDX. If the transaction fails the business logic, detailed error messages will be generated and sent back to the tool, via CDX, for review by the user. The user will wait for the confirmation and error messages in real time, and will be able to respond immediately to any error messages and resubmit. In addition, any state that has a NetDMR Report Tool and an Exchange Network Node can perform the same transaction submission to ICIS-NPDES, assuming the use of the same XML schemas and CDX web services.
Submit DMR, Copy of Record, and Documents to State (Figure 3-1=Yellow)  -  Upon receipt of successful DMR processing from ICIS-NPDES, the tool can trigger a submission of the DMR Copy of Record (i.e., an XML file including the federal and state specific data) and any corresponding documents that have been attached along with the DMR to the state node, via CDX. Upon receipt the state could file the Copy of Record (COR), DMR data, and corresponding documents into their state systems as desired.
Publish DMR and Related Forms with Federal and State Data to States (Figure 3-1=Orange)  -  A data publishing framework will be set up to serve DMR data to any state that has an Exchange Network Node. A series of canned data publishing/querying web services can be set up with standard query parameters to be provided by the state. Queries such as DMRs for a specific permit with a specific Monitoring Period End Date will be set up. The state will be able to initiate a query from their node to collect the data from the tool's database. 
Modifications to Existing Capabilities
The proposed NetDMR solution contains all the same functions as the current system, with select enhancements to existing functions and additional new functionality to support the needs of regulatory authorities and their regulated communities.
These enhancements come in the following categories:
Changes to receive DMR-related data that are not currently stored in ICIS-NPDES
Changes to increase the volume of data that can be submitted in a single transaction
Increased access to NetDMR functionality and more automated interactions with ICIS-NPDES
Customization for state-specific requirements.
The following sections discuss each of the major enhancements in more detail.
DMR-Related Data Not Currently Stored in ICIS-NPDES
NetDMR was originally designed and built with the intention of being the mandatory eDMR solution for EPA regions and an optional solution for states having their regulated universe send DMR data to ICIS-NPDES. In order for NetDMR to be a full eDMR solution that will enable the states to offer their regulated universe a single tool for data submittal, there are several categories of DMR data that are not needed for the federal ICIS-NPDES system that NetDMR should receive and store. These data would not be sent to ICIS-NPDES, but would be submitted and stored in NetDMR. These categories of data include:
Sub-Monthly Monitoring Data
Federal regulations allow monthly, quarterly, semi-annual, and annual reporting of wastewater discharges. States may also allow daily (Oregon) and weekly (Missouri). Neither ICIS-NPDES nor NetDMR currently support the entry of daily or weekly monitoring data. 
Since EPA does not need sub-monthly DMR data, ICIS-NPDES will not be updated to include this data. NetDMR will need to be enhanced to allow the entry of these data and to calculate the monthly values that are required for ICIS-NPDES. 
This will entail the design of new screens and database tables that allow for entry of daily or weekly monitoring data that will be able to be rolled up to the current DMR form. There will need to be a way for the user to indicate the nature of the data entered (e.g., daily or weekly data, averages or maximums), and it will need to validate against the same parameter and unit code lists used by ICIS-NPDES (NetDMR already has this capability, but new values may need to be added). Business logic will need to be added to ensure that these data are valid (e.g., the system should prevent entry of 10 weekly sets of monitoring data for a single month). 
If the system is to be enhanced such that NetDMR is expected to roll up the daily and weekly data into a monthly DMR to be submitted to ICIS-NPDES, a considerably robust set of business logic will need to be added to the system. 
First, the system will need to validate the daily/monthly data against the anticipated measurements that are candidates for reporting, or "empty slots", expected for the monitoring period being reported. The system will need to ensure that only the daily/monthly data that are mapped to expected slot data are rolled up. A background process will need to be designed to perform the calculations to roll up the daily or weekly data into a single monthly DMR that is adherent to the federal standards. This process will then generate an XML transaction to submit the monthly data to ICIS-NPDES as part of the usual NetDMR-ICIS-NPDES data exchange. 
Depending on the nature of the daily/monthly data, some data may not be able to be rolled into a single DMR form. Significant analysis will need to be performed to ensure the algorithms for performing these calculations are complete. If states have different methodologies for performing the roll ups, the process will be even more complex. A function may need to be added to allow or require the regulated entity user to review the rolled up DMR prior to its being submitted to ICIS-NPDES. A significant legal question may also exist about compliance liability if the regulated entity user submits certified daily/weekly data that NetDMR rolls into a monthly form.
Parameter and Value-Level Data which are not expected by ICIS-NPDES
The NetDMR tool and ICIS-NPDES require that a permit limit parameter and permit limit value exist for the entry of DMR parameters and values based on the expected schedule generated in ICIS-NPDES. For example, if there is no limit for arsenic for a limit set, no DMR data for arsenic can be entered on that limit set's DMR forms. In addition, if there is a limit for arsenic, but there is no limit value for quantity, no quantity values for arsenic can be entered on the DMR form.
However, some states allow their regulated community to submit values that are not included in the limits and even parameters that are not included in the limits and will wish to have the ability to continue to do so in their eDMR solution. 
NetDMR will need to be updated to allow users to submit additional parameter and value data that are not expected by ICIS-NPDES for existing limit sets. For the new values, the system will need to require the user to enter a statistical base code so that the end recipient of the data knows what it reflects, and for new parameters, the system will need to require the user to enter the full parameter code, monitoring location code, and season ID. The system will then need to distinguish between received data that are expected by ICIS-NPDES and received data that are not expected so that when NetDMR generates the XML transaction for submittal to ICIS-NPDES, only the expected data are sent. Additionally, if simultaneous submission to state systems as described in Section 6.2.3.1   is implemented, NetDMR will need to send all the received data to the state so there will be different XML transactions for ICIS-NPDES and the state system. 
Unscheduled DMRs
ICIS-NPDES has the ability to generate an expected DMR schedule for scheduled limit sets and also to have "unscheduled" DMRs that have forms entered only if and when the user submits them. Examples of unscheduled DMRs include storm water event reports that need only be reported if an event occurs. NetDMR currently does not support unscheduled limit sets.
In order to support unscheduled DMRs, NetDMR would need to be modified to have a data flow in which the user selected a limit set from a permit, supplied a Monitoring Period End Date (MPED), and requested a DMR form. NetDMR would create an Add DMR transaction request that would be issued to ICIS-NPDES. ICIS-NPDES would receive the request, validate that a form could indeed be created for that MPED, generate the empty slots for that form, and run a mini-ESDF transformation to send the data (or an error message) back to NetDMR. These requests would need to be fulfilled on an immediate basis. The NetDMR screen functionality would also need to be updated to accommodate the concept of a DMR with no DMR Due Date, as that data element is not populated for unscheduled DMRs.
Municipal DMR Data from Industrial User Permits not Entered into ICIS-NPDES
Municipalities run their own NPDES Programs, which receive discharges from their regulated Industrial Users (IUs). These IUs are subject to discharge and monitoring requirements that are structurally very similar to NPDES individual permits. However, a municipality that is a control authority is not considered to be a regulatory authority for the NPDES Program and cannot be assigned its own instance in NetDMR, nor is its IUs entered into ICIS-NPDES.
To gather these important municipal DMR data, NetDMR would need to be updated to:
Create a new regulatory authority access level for municipalities
Create functionality to allow municipalities to enter Permit IDs for their industrial users
Create functionality to receive DMR data for a limit set when no empty slot data exist; this would include requiring the regulated entity user to define the statistical base codes for the values reported on the parameters and designate the monitoring period end date. Likely there would need to be some cut and paste functionality that would allow the user to copy a previous DMR and update it for the current monitoring period. These DMRs would not have a DMR due date, since without limit sets and limits in the system there is no way for NetDMR to anticipate when data will be received.
Modify NetDMR to send the XML files for these DMRs to the municipal system rather than to ICIS-NPDES.
Increase the Volume of Data Submitted in a Single Transaction
When designing functionality for mass submittal of data, a balance generally needs to be made between user experience and system performance. That balance is constantly adjusted as users use the system and learn where efficiencies can be gained. The following enhancements would allow the NetDMR users to more efficiently submit data. 
Ability to Sign and Submit More DMRs at One Time
NetDMR currently allows ten DMRs at a time to be signed and submitted. A permittee with 500 DMRs to submit is thus required to repeat 50 steps of selecting ten DMRs at a time and submitting them. To reduce submission time, NetDMR will need to be modified to allow 100 DMRs at a time to be signed and submitted.
Ability to Enter No Discharge Indicators on the DMR Level During the Import DMR Process
Regulated entity users are allowed to import spreadsheets into NetDMR containing multiple DMRs for one permit. There are times when multiple DMRs have the same no discharge indicator (NODI) to be reported but the NetDMR upload routine requires each quantity or concentration to have the no discharge code present. A permittee with 100 DMRs to submit with a total of 200 quantities or concentrations having the same no discharge indicator will need to copy the same no discharge code into 199 cells in the spreadsheet before uploading it into ICIS-NPDES. To lessen the burden, NetDMR must be modified to allow the upload file to contain one no discharge indicator for each DMR form. This will entail the creation of an upload file that contains only the DMR key identifying data and a NODI code. NetDMR will then need to add a process that creates the entire DMR form with NODI at each value for submittal to ICIS-NPDES.
Increased NetDMR Functionality and Interactions with ICIS-NPDES
Several changes to the NetDMR tool's architecture and administrative functions have been suggested in order to facilitate state acceptance of the tool and enhance the user experience.
Simultaneous Submission of DMRs to State Databases (in Addition to ICIS-NPDES)
NetDMR is designed to submit DMRs without attachments to ICIS-NPDES, but several states have expressed an interest in receiving this data directly from NetDMR rather than having to enter it into their databases manually. In addition, NetDMR allows a regulatory authority or permittee to select up to ten DMR copies of record (COR) with their attachments and download them manually. States such as Louisiana have a document management system and want NetDMR to send them the CORs as they are submitted to ICIS-NPDES. NetDMR needs to be modified to submit DMRs with their attachments to states while keeping the functionality of sending DMRs without attachments to ICIS-NPDES. Section 5.2.2.2 describes this process.
More Frequent Receipt of Data Updates from ICIS-NPDES
For NetDMR, when a regulatory authority elects to use NetDMR and the NetDMR System Administrator sets up that regulatory authority's instance, the Basic Permit Data Flow is triggered to solicit basic permit data for the regulatory authority. Currently, NetDMR is configured to gather the results of the basic permit data solicitation each night, but is configurable to do gather this data more frequently. NetDMR data flow configuration changes can be made to update the Permits in NetDMR multiple times per day. System testing should be conducted to ensure that more frequent daytime updates will not impact the online user experience. 
Once the administrator assigns a Signatory to a Permit, NetDMR requests expected DMR form data from ICIS-NPDES. The data will not be available to the user until the following day. In addition, if changes are made to the underlying data in ICIS-NPDES, manual user intervention is required by the regulatory authority to request an update from ICIS-NPDES. To eliminate this manual intervention and improve the timeliness and accuracy of expected DMR form data in NetDMR, the data flow will be enhanced to provide real-time updates from ICIS-NPDES to NetDMR.
Automated Login 
To log into NetDMR, a user must first click on an icon representing the state the permitted facility resides in and then select a list of regulatory authorities from a pick list before being presented with a screen to enter a login ID and password. Several NetDMR users have requested the ability to log into NetDMR in one easy step. 
Currently a user may have the same login ID for more than one regulatory authority such as Tetratech performing data entry for EPA Regions 9 and 10, or the state a permitted facility resides in may have more than one regulatory authority instance in NetDMR such as Utah DWQ or EPA Region 8.
To resolve this issue, NetDMR will be modified to ensure that a user ID is unique across NetDMR and can be associated with one, and only one, instance. The NetDMR front end can then be modified so that there is a single log in page in which the user enters the login ID and password and NetDMR will then know automatically to which instance to route the user. To support this change, existing login IDs that are shared across multiple instances will need to be split into separate login IDs and those changes shared with the users associated with the ID, who will need to get used to logging in with different IDs based on the data they wish to enter. The business rule will need to be added to ensure ID uniqueness, and the login screens changed to accommodate the instant log in.
Integration with CDX Technologies for System Administration and CROMERR
As stated in the Current Implementation section above, NetDMR was designed with its own functionality for user administration, system administration, and compliance with CROMERR. The system does not use existing CDX technologies for these functions. NetDMR was developed with custom functions to perform:
Initial User Registration
User Account Management
User Authentication and Authorization
User Activity Management specific to CDX Data Flow Transactions
CROMERR required secret questions
CROMERR required e-signature (hashing algorithm from CDX re-used)
While NetDMR has in-system functions to perform these activities, it is planned that new OECA eReporting systems will re-use and integrate with existing CDX functionalities to perform the activities. This integration will reduce the level of effort associated with development and facilitate efficient Network Operations Board CROMERR approval of new systems. Given this departure in using a common framework for user and system administration, some level of integration between NetDMR and the other eReporting systems, such as Single Sign-On, will be necessary to provide the appearance of a seamless, one stop shop solution for the users. 
Customization for State-Specific Requirements
NetDMR was created with the intent to simply gather data for EPA regions and states and transfer the data to ICIS. In this aspect, it has proven to be effective but as new states start using NetDMR they are identifying new aspects of the tool that need to be addressed.
Customized Subscriber Agreements
Under the CROMERR rule, a wet ink signature can be captured under a Subscriber Agreement on behalf of a digital signature. NetDMR stores data for subscriber agreements such as regulatory authority contact name and address but generates subscriber agreements from a generic template used by all regulatory authorities and does not store the end result. Regulatory authorities are able to add information to the end of the generic subscriber agreement but cannot modify the body of the text within the resulting subscriber agreement. Some of the states are required by their own CROMERR regulations to have customized text within the body of a subscriber agreement. NetDMR needs to have the ability to store and generate one generic template per regulatory authority and also store the subscriber agreements generated for each permitted signatory.

Technical Considerations for an Enhanced NetDMR
There are several considerations to be made when determining how to expand NetDMR to reach its full potential. This section begins with an inventory of electronic DMR systems and ends with anticipated volumes and costs for expanding EPA's existing NetDMR tool to accommodate the needs of an overarching electronic reporting system.
Existing eDMR Systems
Along with NetDMR, some regulated entities may elect to use an electronic DMR reporting tool hosted by the state, local or tribal regulatory authority administering their permit. Most of these tools submit data to the state system which in turns sends the data to either EPA's legacy Permit Compliance System (PCS) or ICIS-NPDES. Texas has a copy of NetDMR hosted on their servers that submits data to ICIS-NPDES directly. This section provides summary data on all known eDMR tools.
Due to the large amount of eDMR systems, the bulk of this report focuses on systems able to send data to ICIS-NPDES such as the National Installation of NetDMR, Enfotech's E2 system being used by multiple states, and Illinois' eDMR system.
National Installation of NetDMR
NetDMR has been in production since June 2009 and is the mandatory eDMR tool for EPA regions but is an optional eDMR tool for states. It is currently being used by Arkansas, Connecticut, Hawaii, Louisiana, Tennessee, Utah and all EPA Regions except Region 4 and Region 5. Colorado, Georgia, Indiana and Kentucky are in the process of evaluating it use. 
EPA regions are covered by an approved EPA CROMERR application but each state must submit their own CROMERR application and have it approved before using NetDMR in production. All of these states are CROMERR approved except Arkansas and Hawaii; they are both awaiting CROMERR approval. 
The NetDMR tool is hosted at CDX and uses standard CDX web services to extract DMR pre-print data for scheduled limits from ICIS-NPDES and send reported DMR data to ICIS-NPDES on a daily basis. Each Regulatory Authority has data for its own permittees filtered out from the other Regulatory Authorities. 
Enfotech E2 Software
Enfotech developed an eDMR tool called E2 currently used by Alabama, Florida, Michigan, Ohio, Oklahoma, Pennsylvania and Virginia. It is hosted at the state and extracts DMR pre-print data for all limits from the state's database, and sends report DMR data on a daily basis to either PCS or ICIS-NPDES via a state node on the Exchange Network. Oklahoma has received CROMERR approval, and Florida, Michigan and Ohio are awaiting CROMERR approval. Alabama, Pennsylvania and Virginia have not applied for CROMERR. The Michigan eDMR system has been tested with ICIS-NPDES Batch and went into production in August 2010.
California ESMR
California's ESMR tool has been in production since 2004. It was originally developed by a contractor for the Army Corps of Engineers and has been modified for California's needs. State daily monitoring reports are stored in the state system and are not electronically transferred to ICIS-NPDES. It is not CROMERR compliant.
Illinois eDMR
Illinois' IT staff created an eDMR tool that is hosted at the state and extracts DMR pre-print data for all limits from the state's database, and sends report DMR data to ICIS-NPDES via the state node on the Exchange Network on a daily basis. Their eDMR system has been in production since May 2009 and is awaiting CROMERR approval.
Indiana eDMR
The Indiana eDMR tool pre-populates limit data from Indiana databases. In production since September 2009, the DMRs are stored in the state system and not electronically transferred to ICIS-NPDES. It is CROMERR compliant.
Maine EFIS
The eDMR tool that is part of EFIS was jointly developed system with South Carolina. It allows facilities to submit DMRs electronically but Maine has not placed it into production yet. It is not CROMERR compliant.
Mississippi eDMR
In production since 2003, the eDMR tool Mississippi uses stores DMRs in the state system but does not electronically transfer them to PCS. It is not CROMERR compliant.
North Carolina eDMR
The North Carolina eDMR tool went into production in September 2009. DMRs are stored in the state system but not electronically transferred to PCS. It is not CROMERR compliant.
South Carolina EFIS
The eDMR tool that is part of EFIS was jointly developed system with South Carolina. It allows facilities to submit DMRs electronically. South Carolina placed it into production but Maine has not marketed it yet. It is not CROMERR compliant.
Texas NetDMR
Texas NetDMR is a CROMERR compliant tool for allowing permittees to report NPDES DMR data to ICIS-NPDES electronically. It is hosted at Texas and uses standard CDX web services to extract DMR pre-print data for scheduled limits from ICIS-NPDES and send reported DMR data to ICIS-NPDES on a daily basis. Each Regulatory Authority has data for its own permittees filtered out from the other Regulatory Authorities. Texas NetDMR has been in production since June 2009.
Washington WebDMR
Washington state's WebDMR went into production in April 2010. DMRs are stored in the state system and electronically transferred to PCS. It is CROMERR compliant.
West Virginia eDMR
In production since January 2009, West Viriginia's eDMR tool stores DMRs in the state system and electronically transfers DMRs to PCS. It is not CROMERR compliant.
Wisconsin eDMR
Wisconsin placed their eDMR system into production in 2005. It stores DMRs in the state system but does not electronically transfer them to ICIS-NPDES. It is not CROMERR compliant.
Wyoming eDMR
IntelliSys developed the eDMR tool used by Wyoming that went into production in early 2006. DMRs are stored in the state system but are not electronically transferred to PCS. It is awaiting CROMERR approval.
Mapping of RIDE Data Elements into eDMR Systems
As shown in Table 4-1, all state electronic DMR systems capture most of the DMR data as required in the Requisite ICIS-NPDES Data Elements (RIDE) data element list contained within the proposed ICIS-NPDES Policy Statement dated April 30, 2007 with the exception of Mississippi. Mississippi does not track the Limit Set ID or the monitoring location code.
There are no known eDMR systems capturing biosolids beryllium indicator, mercury indicator, pollutant table(s) met, pathogen reduction, vector attraction data in the format specified in the RIDE list. Instead, EPA regions and states that have gathered biosolids land application, surface disposal, incinerator and co-disposal data are passing the information to PCS and ICIS-NPDES as parameter limit measurements instead of as discrete Yes/No indicators or vector codes and descriptions. 
NetDMR does not capture this data and there is no official form for reporting the data in this format for regulatory authorities to use. Thus, either these fields must be added to an official form and NetDMR and state eDMR systems will need to be modified to accommodate this data as specified in the RIDE list, or EPA will need to change the RIDE list to remove these fields and allow the reporting of this data as parameters instead of discrete elements. 
Table 4-1: RIDE DMR Data Elements
RIDE Data Element
Captured in NetDMR
State eDMR System(s) Capturing the Data Element
NPDES DMR


Permitted Feature ID
Yes
All
Limit Set ID
Yes
All except Mississippi
Parameter Code 
Yes
All 
Monitoring Location 
Yes
All except Mississippi
Monitoring Period End Date 
Yes
All 
NODI 
Yes
All 
DMR Quantity or Concentration Value
Yes
All 
Concentration/Quantity Units
Yes
All 
DMR Value Received Date
Yes
All 
Value Type (Q1, Q2, etc)
Yes
All 
Value Qualifier (= < > T E)
Yes
All 
Biosolids DMR


Beryllium Indicator
No
No States
Mercury Indicator
No
No States
Pollutant Table(s) Met
No
No States
Pathogen Reduction for Land Application
No
No States
Vector Attraction Reduction for Land Application
No
No States
Pathogen Reduction for Surface Disposal
No
No States
Vector Attraction Reduction for Surface Disposal
No
No States

Reporting Universe
The reporting universe for an eDMR reporting tool consists of regulated facilities that exist in ICIS-NPDES and PCS now plus the candidate regulated facilities under the NPDES reporting rules that exist but are not in ICIS-NPDES or PCS.
ICIS-NPDES and PCS combined currently contain 63,125 regulated entities with active limits that are candidates for reporting DMRs electronically. Table 4-2 provides a count for each state and selected territories. The acronyms "GE" and "GM" in this table represent the "Gulf of Mexico", where "GE" denotes EPA Region 4 oil platform locations and "GM" denotes EPA Region 6 oil platform locations, the acronym "NN" represents the Navajo Nation, and the acronym "SR" represents the St. Regis Nation.
Table 4-2: Regulated Entities in ICIS-NPDES and PCS
State
Number of Regulated Universe Currently in ICIS-NPDES and PCS
AK
312
AL
4,620
AR
1,462
AS
7
AZ
194
CA
471
CO
2,536
CT
424
DC
26
DE
59
FL
623
GA
893
GE
270
GM
268
GU
15
HI
62
IA
1,398
ID
351
IL
2,374
IN
3,240
KS
222
KY
3,661
LA
859
MA
439
MD
3,143
ME
601
MI
990
MN
1,011
MO
4,607
MP
3
MS
3,734
MT
679
MW
1
NC
1,309
ND
115
NE
718
NH
149
NJ
1,175
NM
146
NN
31
NV
13
NY
3,344
OH
3,481
OK
741
OR
122
PA
788
PR
266
RI
346
SC
1,004
SD
536
SR
2
TN
1,301
TX
4,609
UT
451
VA
762
VI
92
VT
48
WA
38
WI
148
WV
952
WY
883

According to the Office of Water and EPA's ECHO website, there are approximately 403,336 other NPDES regulated universes not currently in ICIS that are candidates for eDMR reporting, such as vessels, SIUs, and biosolids. Table 4-3 lists the estimated number of regulated entities within these universes.
Table 4-3: Regulated Entities Not in ICIS-NPDES and PCS
Regulated NPDES Universe Not Currently Required to be Input into ICIS-NPDES and PCS
Count of Facilities 
Vessels 
50
New Vessels
3,000
SIUs in non-pretreatment cities
1,384
All SIUs (includes non-pt cities)
23,094
Biosolids Monitoring
3,208
CAFOs (75% are likely to need permits)
19,000
General Permits (Not Elsewhere Classified)
20,000
Combined Sewer Systems
800
Separate Sewer Systems (including satellite systems)
20,000
Construction Storm Water (yearly new constructions sites > 1 acre)
200,000
Industrial Storm Water
89,000
Municipal Separate Storm Water Sewer systems
7,300
Biosolids Generator
16,500

This brings the total number of regulated entities that are within the eDMR regulated universe as candidates for future eDMR reporting to 466,461. 
Reporting Frequency
According to 40 CFR Part 122.41(i), the NPDES regulated community (with certain specific exceptions) must report their waste water discharges to a regulatory authority at least once per year. ICIS-NPDES stores DMRs for NPDES permits for a reporting period of at least one month and at most 60 months. States may also allow daily (Alabama, California, Connecticut, Indiana, Kansas, Massachusetts, North Carolina, Oregon and Washington), weekly (Connecticut) or once during the permit cycle (Virginia) reporting of waste water discharges. See 40 CFR Parts 122.41(j) and 122.41(l).
Technical Feasibility of an Enhanced NetDMR
This section of the paper is focused on evaluating the current NetDMR solution and proposing an enhanced version of NetDMR to meet EPA's expanded eReporting requirements for an eDMR system. In addition, this section details some of the high-level steps required for the proposed solution, evaluates potential benefits and challenges of the solution, and provides a high-level Rough Order of Magnitude (ROM) estimate of the cost to implement the solution.
To evaluate the impact of such a solution, it is important to understand the magnitude and frequency of such reports to be provided to the regulatory authority and the EPA from the regulated community. Table 5-1 details the latest estimates.
Table 5-1: NPDES DMR Frequency
Report Type
Estimated Reporting Universe
Estimated Reporting Frequency
Estimated Reports Per Year
Reporting Size
Peak Reporting Time
DMR
63,125 in ICIS or PCS + 403,336 not in ICIS or PCS
Mostly monthly; some daily, weekly, quarterly or annual
12 x (63,125 in ICIS or PCS + 403,336 not in ICIS or PCS)

5,597,532
Large amount of data
None

Data Analysis
The data analysis for eDMR systems was completed using information from the National Installation of NetDMR tool, Michigan's eDMR tool, and Wyoming's eDMR tool. Refer to Section 3.1 for details on these tools.
In order to determine the required RIDE data elements for an expanded National Installation of NetDMR, a detailed data analysis of the current national NetDMR system and two state eDMR systems was performed. Although several states have eDMR systems, Wyoming and Michigan were analyzed due to the quality and availability of online documentation.
The state systems contain all the RIDE data elements for the basic DMR forms. They do not contain the special regulatory program data elements, but those need not be a hindrance to feeding a national system according to the discussion in Section 3.2  .
The proposed NetDMR system includes expanding upon additional RIDE data elements to include Biosolids DMR data. NetDMR would then capture all 18 RIDE data elements, which would allow states to store and report Biosolids DMR data in addition to basic DMR data.
Benefits and Challenges
There are a number of potential benefits to the permittees, regulatory authorities, and the federal government as described in Table 5-2, NetDMR Enhancements Potential Benefits. The benefits for each category of enhancement are listed individually in the table.
Table 5-2: NetDMR Enhancements Potential Benefits
Benefit
Description
Benefactor
CWA Plan Goal Met
Receive DMR Data Not Currently Stored in ICIS-NPDES
Reduced burden on state and permittee for submitting and maintaining sub-monthly DMR data
By adding the capability to enter daily and weekly discharge reports to NetDMR, it will reduce the need for permittees to submit data to both NetDMR for monthly, quarterly, semi-annual, and annual reporting and to the State for daily or weekly reporting.
States would not have to maintain a separate DMR system that allows for daily and weekly submissions
Permittee,
Regulatory Authority
Yes
Increased accuracy of data collection and improved transparency for unexpected parameter and value data
By allowing permittees to submit values and parameters that are not expected, it expands the amount of information available on the site. This shows the public and regulators a better picture of the site and allows the permittee to fully disclose all activities on the site.
All Stakeholders
Yes
Reduced burden on permittees to submit Municipal data to multiple sources
Gathering municipal DMR data and allowing Municipalities access to the data will reduce the need for permittees to submit data to NetDMR and the municipality.
Permittee
Yes
Increase Volume of Data in Single Transaction
Reduced Submission Time by allowing more DMRs to be signed and submitted
By increasing the amount of DMRs that can be signed and submitted at one time, it reduces the amount of time a permittee is submitting data through NetDMR
Permittee
Yes
Reduced burden on Permittee to enter no discharge indicators for multiple DMRs
By modifying NetDMR to allow an upload file to have only one NODI for each DMR form, it reduces the need for permittees to copy and paste multiple values over and over again
Permittee
Yes
Increase Access and Automation with ICIS-NPDES
Reduced burden for states to manually enter DMR data by using simultaneous submission
Simultaneous submission of DMRs without attachments to ICIS-NPDES and state systems would reduce the manual data entry of DMR data into state systems.
Simultaneous submission of DMR copies of record to ICIS-NPDES and state systems would reduce the need for states to manually download these attachments
Regulatory Authority
Yes
Reduced wait time for changes to ICIS-NPDES data
By allowing for real-time updates to NetDMR from ICIS-NPDES, data will stay in synch and manual requests from regulatory authorities to update NetDMR will be reduced.
Permittee,
Regulatory Authority
Yes
Reduced burden to log in to NetDMR
By allowing NetDMR users the ability to log in automatically to all of their facilities for each of the regulatory authorities they support, it decreases the log in time for permittees and increases the amount of time available to enter data.
Permittees
Yes
Customize for State-Specific Requirements
Flexibility in subscriber agreements
By storing and generating one customized subscriber agreement for each regulatory authority, NetDMR will meet the needs of states to have customized text in the body of a subscriber agreement
Regulatory Authority


Standard technology project challenges and risks will apply to the NetDMR expansion effort, and in addition, Table 5-3 lists the specific challenges that must be taken into consideration for this effort. The challenges for each category of enhancement are listed individually in the table.
Table 5-3: NetDMR Enhancements Potential Challenges
Challenge
Description
Affected Party
Receive DMR Data Not Currently Stored in ICIS-NPDES
Complicated business logic for rolling up daily/weekly DMR data
Validating daily/weekly DMR data against expected empty slots will involve intricate coding and testing. Depending on the daily/weekly DMR data, some may not be able to be rolled up into a single DMR form. Significant analysis of algorithms is required to ensure calculations are correct. States may have different methodologies for rolling up this data, which could mean multiple processes for calculating data would need to be developed.
Regulatory Authority,
Federal Government
Legality or discourse of rolling up daily/weekly DMR data
There may be a significant compliance liability question for permittees that rely on system calculations to establish a monthly DMR from user-entered daily or weekly data. In addition, the process of rolling up data may vary between states.
All Stakeholders
Discerning Expected and Unexpected Data in NetDMR
A complex Background process would need to be implemented in the NetDMR application so only expected Parameter and Value level data are submitted to ICIS-NPDES. If simultaneous submission is also selected, then 2 separate XML files (1 for the state system and 1 for ICIS-NPDES) would need to be created by NetDMR
Federal Government
Municipalities receiving DMR data
Municipalities would need Exchange Network Nodes to receive XML files from NetDMR through CDX
Municipality
Increase Volume of Data in Single Transaction
Scrolling through DMRs to sign and submit
Due to screen sizes, permittees would need to scroll through 100 DMRs at a time if they wanted to review before signing and submitting to ICIS-NPDES.
Permittee
Increase Access and Automation with ICIS-NPDES
Tracking which system is associated with which regulatory authority
In order to enable simultaneous submission of DMRs to ICIS-NPDES and specific state systems, NetDMR would need to associate DMR data with each state or municipal system to ensure the data was submitted to the correct system
Regulatory Authority,
Federal Government
Network Nodes for receiving data
Regulatory Authorities would need to obtain and maintain a network node if one does not already exist for them in order to receive new or updated DMR data.
Distinct data flows would need to be developed for each regulatory authority to route the submission to the appropriate node
Regulatory Authority,
Federal Government
Development of real-time batch data flows
Currently, there are no federal EPA NPDES systems that have a real-time batch data flow from application to CDX to ICIS-NPDES and back. Given the level of integration and requirement for all systems to be available 24 hours a day and 7 days a week, additional complexity is introduced.
Federal Government
Consolidating and retaining Login ID uniqueness across multiple NetDMR instances
Initially, existing login IDs that are shared across multiple instances would need to be reassigned to avoid users sharing the same login ID. Users will need to adjust to using a different login ID to access all facilities for all regulatory authorities. Business rules will need to be added to NetDMR to ensure login ID uniqueness and login screens would need to be changed to accommodate automated log in.
All Stakeholders
Customize for State-Specific Requirements
Variability in state requirements
The states may have requirements that could be constantly evolving. Managing these changes among multiple generic templates could be difficult. If state changes exceed the number of user defined fields, additional problems would arise. In addition, training for individual states could be demanding if training materials are not updated with each change.
Regulatory Authority,
Federal Government


Legal Considerations for an Enhanced NetDMR
Various EPA regulations and statutes support the reporting of DMRs for NPDES individual permits, general permits and regulatory programs as well as electronic reporting. This section explores applicable regulations, statutes and CROMERR compliance and discusses changes that need to be considered to these regulations and statutes in order to allow NetDMR to collect electronic information from all members of the future regulated universe members.
Regulation Cites
Two regulations direct the mechanism for reporting monitoring results and the length of time the results must be kept by the regulated universe and regulatory authorities, one regulation directs the activities of electronic reporting, and one proposed policy statement lists the specific data to be reported to EPA by a regulatory authority.
According to Title 40 of the Code of Federal Regulations (CFR), Part 122.41(l)(4), "(i) Monitoring results must be reported on a Discharge Monitoring Report (DMR) or forms provided or specified by the Director for reporting results of monitoring of sludge use or disposal practices.  (ii) If the permittee monitors any pollutant more frequently than required by the permit using test procedures approved under 40 CFR part 136 or, in the case of sludge use or disposal, approved under 40 CFR part 136 unless otherwise specified in 40 CFR part 503, or as specified in the permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted in the DMR or sludge reporting form specified by the Director." 
According to 40 CFR 122.41( j)(2), "Except for records of monitoring information required by this permit related to the permittee's sewage sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR part 503), the permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least 3 years from the date of the sample, measurement, report or application. This period may be extended by request of the Director at any time."
In addition, EPA's Cross-Media Electronic Reporting Regulation (CROMERR) provides the legal framework for electronic reporting to the Agency as well as states, tribes, and local governments that are authorized to administer EPA programs including NPDES. EPA published a final regulation on October 13, 2005, establishing a framework by which it will accept electronic reports from regulated entities. CROMERR could apply to any document submissions required by or permitted under any EPA or authorized program governed by EPA's regulations in 40 CFR if it is submitted electronically.
Under CROMERR, both new and existing electronic reporting systems require EPA approval, and owners of existing electronic reporting systems must have submitted their CROMERR application to EPA by January 13, 2010. Authorized programs that are currently or plan to receive electronic reports may apply for approval of electronic reporting for one or multiple programs through one application process. The performance-based criteria used by EPA to evaluate electronic reporting systems address a number of topics, including, among other things:
Criteria for establishing a copy of record 
Integrity of electronic document 
Opportunity to review and repudiate copy of record 
Validity of electronic signature 
Determination of the identity of the individual uniquely entitled to use a signature device
Applications for approval of electronic reporting systems must contain:
A certification, signed by the State Attorney General (or the chief administrative official in the case of tribes and local governments), that existing laws or regulations provide the legal authority to implement and enforce electronic reporting; 
A listing of the electronic document receiving systems for which approval is being requested and a description of how the system will satisfy the requirements of CROMERR; and 
A schedule of upgrades that may affect CROMERR compliance.
The CROMERR rule does not apply to documents submitted by fax, on magnetic media such as floppy disks, or on optical media such as compact disks (CDs); submissions that are not covered under 40 CFR; or electronic reporting systems that are not designed to replace reports submitted on paper.
The proposed ICIS-NPDES Policy Statement drafted on April 30, 2007 introduces Requisite ICIS-NPDES Data Elements (RIDE) in Appendix 2s as a comprehensive list of data fields to be submitted to EPA by NPDES authorized regulatory authorities. This list includes 12 data fields pertaining to DMRs. 
Statutory Determination
Under Section 308(b) of the Clean Water Act and Title 33 of the United States Code § 1318(b), the owner or operator of any point source must establish, report and maintain records of violations to an effluent limitation, effluent standard or pretreatment standard. There are no federal statutes that address electronic reporting requirements, and no changes are recommended to support the mandatory reporting of DMR for the proposed regulated universe. 
Information Collection Request Issues
EPA has issued 16 NPDES-related Information Collection Requests (ICRs) consisting of program-based (i.e., Pretreatment Program), activity-based (i.e., Applications, Discharge Monitoring Reports [DMRs]), and rule-based (i.e., Cooling Water Intake-Phase II, Storm Water Program Phase II) ICRs.
Historically, EPA identified the five activity-based ICRs as representing the base NPDES program.  Those ICRs include:
Applications ICR (OMB Control No. 2040-0086)
DMR ICR (OMB Control No. 2040-0004)
Modification/Variance ICR (OMB Control No. 2040-0068)
Compliance Assessment/Certification ICR (OMB Control No. 2040-0110)
State Program ICR (OMB Control No. 2040-0057)
Several additional ICRs include activities that contain similar activities to those identified in the five base NPDES program ICRs and as such, are being consolidated into this ICR.  Those four ICRs include:
Storm Water Program Phase II (OMB Control No. 2040-0211)
Storm Water discharges associated with construction activities (OMB Control No. 2040-0188)
CSO Control Policy (OMB Control No. 2040-0170)
NPDES Great Lakes Water Quality Guidance (OMB Control No. 2040-0180
In addition,  the ICRs account for the burden related to EPA's upcoming Eligible Commercial and Other Non-recreational Vessels General Permit, and a new ICR has been proposed for CAFOs in 2010 (Animal Sectors; EPA ICR No. 1989.07; OMB Control No. 2040-0250).
Each individual ICR provides the Agency's estimate of the annual costs of DMR submittals and  should be evaluated for possible adjustments to match the volumes of newly identified NPDES reporting requirements which will expand the existing regulated community as contained within this report.
Data Stewardship Issues
The National Installation of NetDMR is designed to allow regulated entities to input their DMRs and submit them to ICIS using their regulatory authority's workspace or "Instance" separate from the workspaces of other regulatory authorities. Each regulatory authority is responsible for viewing the DMRs submitted within their workspace to ensure they are accurate and complete. As errors or discrepancies for a DMR are found within ICIS, the regulatory authorities are expected to work with their regulated entity in getting the data corrected. This process has worked well and should be continued under mandatory electronic reporting to avoid data stewardship issues.
CROMERR Compliance Issues
The biggest issue states appear to face with CROMERR is the inability to get approval from their Attorneys General (AGs) for utilizing digital signatures in place of wet ink signatures. Several NetDMR states lost several months in their CROMERR application process waiting for their AGs to review and sign the package before submitting it to EPA, and South Dakota has placed their plans to use NetDMR on hold until a regulation is passed for their state to allow digital signatures. 
The biggest issue EPA will face regarding CROMERR compliance is the attitude of some states they should be able to continue to use a non-compliance CROMERR electronic reporting tool because they require their regulated entities to submit a paper copy of the DMR to match the electronic version. 
Exemptions and Waivers
Special situations exist that may keep a regulated entity from participating in the mandatory reporting of electronic DMR data, such as:
Financial hardship for an individual or small regulated entity
Additional time needed for setting up a computer or unavailability of electronic connections in a remote area for a regulated entity.
Complying with the requirement conflicts with the regulated entity's procedures
A regulated entity that is required to submit small DMRs sporadically 
For these situations, a time sensitive exemption or waiver should be made available to the regulated entity by providing a form to fill out and submit to their regulatory authority for approval. Each exemption or waiver should have an expiration date of no greater than one year with an option to extend it for a limited period of time.
System of Record
According to CROMERR, Section 3.2000(b)'s leading clause and Section 3.2000(b)(4) require all approved electronic reporting systems to be able to generate a copy of record (COR) that is made available to the submitters and/or signatories for review and repudiation. NetDMR adheres to this rule by storing DMR CORs and allowing users to repudiate or correct a COR.


Specific Considerations for an Enhanced NetDMR
In order for the National Installation of NetDMR to be a successful tool for the proposed regulated universe, regulatory authorities must understand the expectations for their roles in regard to implementing and supporting NetDMR. In addition, NetDMR is designed for the average user but enhancements will be necessary in order for it to adequately accommodate the proposed regulated universe. This section explores these two concepts in depth.
Key Steps for Adoption
States typically experience a low percentage of usage by the regulated community in the early years of an eDMR release. For example, Alabama's eDMR system has been in production for less than a year with 10-15% of their regulated entities using it, while Ohio has offered an eDMR system since 2005 and has all but 23 regulated entities using it.
A more important factor in successful usage of an eDMR tool appears to be the effectiveness of a marketing campaign targeted toward the regulated community. Over 40% of Michigan's regulated entities were using their eDMR system within 22 months after a strong marketing effort, yet California's eSMR system has been in production since 2004 and only 25% of their major regulated entities are reporting their data electronically.
The National Installation of NetDMR was placed into production June 23, 2009. Two regulated entities were using it within the first month and the total number of regulated entities using NetDMR increased to 38 as of August 31, 2010.
Regulated Authorities (State or EPA) must perform a wide range of outreach activities to inform their regulated community of their intention to accept electronic reports through the National Installation of NetDMR or their own electronic DMR system. 
For NetDMR, OECA assists regulatory authorities by hosting a NetDMR website with reusable CROMERR application templates, providing training through Webinars and recorded demos, and offering a test database for staff at regulated entities to practice entering or uploading DMR data electronically to ensure a smooth transition when moving to the production environment. A consortium of States and EPA Regions developed a NetDMR brochure specifically for regulated entity staff to use. It includes some basic information about NetDMR, notice of upcoming NetDMR training, contact information, and how to access the NetDMR website where they may obtain a copy of User Guides containing step-by-step instructions developed specifically for regulatory authority and their regulated community. Technical assistance is provided by OECA to the Regulated Authority users who in turn provide technical support to the regulated entity staff using the NetDMR tool. 
Ohio used a phased approach to rolling out their new eDMR system one district at a time using various methods to communicate the benefits to their regulated community of submitting DMRs electronically via flyers, brochures, phone calls, e-mails and trade associations. They established a robust training program for regulated entity staff that included instructions posted in the Internet, classroom training and hands-on workshops. 
State System Compatibility
The most important requirement is to ensure the system is in compliance with CROMERR. Out of 19 existing state eDMR systems, 10 are not CROMERR compliant. All of these states except Mississippi are able to report their DMR data to ICIS-NPDES or PCS in the correct format. Mississippi will need to provide a limit set designator and monitoring location code to the parameters they report, and all states reporting data to PCS will need to add the limit season number to the limit related data elements being reported to ICIS-NPDES.
ICIS-NPDES Data Publishing 
ICIS-NPDES staff is in the process of investigating CDX tools for publishing data out of ICIS-NPDES and back to the states. The CDX data publishing tools are SOAP web services, RSS or Atom news feeds, and REST web hotlinks. News feeds and web hotlinks are designed for small, recurring data transfers and with DMR data being reported in large volumes in the middle to end of each month the SOAP web services look to be the most promising tool for ICIS-NPDES data publishing use. The process would be similar to the data exchange model NetDMR uses with ICIS-NPDES as described previously with the data requests coming from and returned to a state's node.
       
 
