Office of Enforcement and Compliance Assurance

NPDES Electronic Reporting Rule

Analysis A: Discharge Monitoring Reports

23 September 2010
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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
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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
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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
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1. 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 paperbased DMR submission process.
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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 ICISNPDES 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.

1.1 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
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• 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.

1.2 ASSUMPTIONS AND CONSTRAINTS

The following assumptions and constraints apply to this document:
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• 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.

1.3 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.
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2. 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.

2.1 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 ICISNPDES 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.

2.1.1 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).
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2.1.2 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 Regulated  View DMRs associated with assigned Permit(s).
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User Role User 

Organization

User Privileges

Data Provider –

View Only

Community

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).

2.1.3 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.
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Email Event Email Description

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

2.2 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 
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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 2-2 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 
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3. PROPOSED SOLUTION

NetDMR is an ideal system for expansion, as it provides the regulated community with an easyto-use tool that quickly and efficiently reports DMR data directly from permittees to ICISNPDES. 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

3.1 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 3.2.3.1 

and 3.2.4 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
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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 

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
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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 ICISNPDES, 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. 

3.2 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:
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• 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 ICISNPDES

• Customization for state-specific requirements.

The following sections discuss each of the major enhancements in more detail.

3.2.1 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:

3.2.1.1 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 
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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 ICISNPDES. 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.

3.2.1.2 Parameter and Value-Level Data which are not expected by ICISNPDES

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 3.2.3.1 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. 

3.2.1.3 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 
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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.

3.2.1.4 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.

3.2.2 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. 
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3.2.2.1 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.

3.2.2.2 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 ICISNPDES. 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.

3.2.3 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.

3.2.3.1 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.

3.2.3.2 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 
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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.

3.2.3.3 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.

3.2.3.4 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
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• 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. 

3.2.4 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.

3.2.4.1 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.
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4. 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.

4.1 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.

4.1.1 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 preprint 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. 

4.1.2 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 
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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.

4.1.3 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.

4.1.4 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.

4.1.5 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.

4.1.6 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.

4.1.7 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.

4.1.8 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.

4.1.9 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.
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4.1.10 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.

4.1.11 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.

4.1.12 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.

4.1.13 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.

4.1.14 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.

4.2 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 
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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

4.3 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.
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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
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State

Number of Regulated 

Universe Currently in 

ICIS-NPDES and PCS

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
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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. 

4.4 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).
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5. 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

5.1 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 4.1 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 4.2 .

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.
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5.2 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
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Benefit Description Benefactor CWA Plan 

Goal Met

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
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Challenge Description Affected Party

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 ICISNPDES. 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
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Challenge Description Affected Party

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
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6. 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.

6.1 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.
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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.

6.2 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. 
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6.3 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.

6.4 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 
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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.

6.5 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.

6.6 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.

6.7 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.
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7. 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.

7.1 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. 
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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. 

7.2 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.

7.3 ICIS-NPDES DATA PUBLISHING 

ICIS-NPDES staff is in the process of investigating CDX tools for publishing data out of ICISNPDES 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.