1. Does EPA’s March 31, 2020 “Temporary Advisory for National Pollutant Discharge Elimination System (NPDES) Reporting in Response to COVID-19 Pandemic” mean that EPA is no longer tracking discharge monitoring reports?
No. EPA is still tracking discharge monitoring reports in its data system for the NPDES program (the Integrated Compliance Information System (ICIS-NPDES)). Any reports of discharges in excess of NPDES permit requirements or missing reporting for non-excusable reasons will still register violations, and that information will continue be available to the public through EPA’s ECHO and Envirofacts websites. Even if some data are not available to report, the Temporary Advisory makes clear that all sampling or reporting that can occur should continue and may not be excused.
In situations where a required monitoring report cannot be submitted in whole or in part due to the COVID-19 public health emergency, EPA has created a new way to tag that missing data. When this tag is used, like the existing tags for excusable non-reporting, the ICIS-NPDES data system will not automatically register a violation for non-reporting. EPA and states will be able to identify the users of the new tag and follow up to determine whether there was non-compliance with permit requirements and can then adjust the data in the system to register violations.
2. In NetDMR, as a permittee, how do I add attachments to a DMR form?
- Attachment(s) can be added when completing a DMR form.
- The attachment functionality is only available in NetDMR. Attachment(s) will not go to EPA Integrate Compliance Information System (ICIS).
- NetDMR will not allow upload of files greater than 20 megabytes or files with the following file types: com, dll, exe, and vbs.
- Example: In this DMR, one attachment attached per a form. As a signatory, during the certifying step, check the option of receiving the attachment in the DMR submission email.
- The COR zip file contains the attachment(s).
3. Steps on adding an attachment in NetDMR?
- On the bottom of the DMR form, there will be a section to add comments and/or attachment(s).
- To add, click on “Add Attachment”
- Select file from computer.
- Click “Attach File” to upload attachment to DMR form.
- If done correctly, a message will appear stating your attachment was added
- All added attachment will be located on the bottom of the DMR form
4. How do I download an attachment?
- Click on the following hyperlink for a step-by-step on- How to Download CORs and Attachments
5. What NODI code should I use if data is not available to report?
- A new NODI Code, Code Z (COVID-19) to adjust to the evolving COVID-19 pandemic.
- If electing to use this code, you are indicating that the OECA Temporary Policy applies and you are taking the steps detailed in the policy.
- When using this code, please make available information documenting how Covid-19 was the cause of the missing data if EPA so requests. EPA encourages you to use the comment field and/or attachments in NetDMR to provide this information.
6. What additional information should be provided in an attachment to a DMR form in NetDMR?
- You should provide information on how COVID-19 was the cause of your inability to conduct required sampling, monitoring and/or reporting.