NPDES Reporting Indiana Society of Mining and Reclamation Technology Transfer Seminar December 7, 2009 Indiana NPDES DMR Data: maintained for compliance tracking purposes for Indiana and EPA
IDEM Contact Information: • IDEM Toll Free Number: 800-451-6027 • Office of Water Quality, IDEM Ramona Malone, Receptionist: 317-232-8670 Office Fax Number: 317-232-8406 • Spill Hotline: 888-233-7745
IDEM Contact Information (cont): Data and Information Services Section: (for DMRs and MMRs) Jeff Ewick, Section Chief: 317-233-0676 email@example.com Rose McDaniel: 317-233-2653 firstname.lastname@example.org Helen Demmings: 317-232-8815 email@example.com
DMR Definition • DMR: Discharge Monitoring Report Form: a federal pre-printed Form (3320-1) • Source: IDEM prints DMRs using data from a federal database and mails them out annually. • The DMR is specific for that NPDES permitted facility. • There is one DMR per outfall: summary data from MMR will be used to complete the DMR. • The DMR must be submitted/postmarked by 28 days following its Monitoring Period end date.
MMR Definition • MMR: Monthly Monitoring Report: a state form required by Indiana • Source: http://www.in.gov/idem/5104.htm • For Coal Mines choose the “Industrial Type” MMR. • Can be used as an Excel Spreadsheet or printed as a copy that can be filled out by hand. • One MMR per outfall: data results for each day of sampling will be used to complete it. • MMR must be submitted w/corresponding DMR.
Goal: Report NPDES data Accurately, Completely, and on Time • To fulfill reporting requirements of NPDES permit. • To receive Compliant status (for DMR data) in EPA database. • To prevent false Missing violations from accruing. • To facilitate accurate data entry of NPDES sampling results. • To demonstrate good stewardship of the use of the waters of the State of Indiana.
DMR violations in the EPA database • There are 3 types of DMR data violations in the EPA database: MissingExceedenceLate • Missing DMR data is currently the most common violation for Indiana coal mine NPDES permittees, in the EPA database.
12/05/08: 1,915 Missing Coal Mine DMRs for Indiana from 01/07 to 09/08 Start of List End of List
12/04/09: 601 Missing Coal Mine DMRs for Indiana from 01/07 to 09/08 Start of List End of List
12/04/09: 629 Missing Coal Mine DMRs for Indiana from 01/08 to 09/09 Start of List End of List
DMR and MMR Forms are Provided by IDEM • IDEM prints and mails one years’ worth of DMRs per NPDES facility every July (using EPA database info). • DMR forms have exact codes, parameters, monitoring period dates, and IDs on them so that their data can be entered into the EPA database to receive compliant status each monitoring period. • MMRs can also be printed and mailed out, as requested, but are downloadable as Excel spreadsheets from the IDEM website.
Provide Correct Contact Address: To Receive DMR Forms • In order to receive annual paper DMRs, each facility must give IDEM has their correct mailing address. Please notify IDEM whenever there is a change. • Alternatively, facilities may receive their DMRs by email. Notify one of the Data Section Contacts with the email address of the appropriate contact person. • Another way a facility can receive their DMRs is to use electronic submittal via the new eDMR system.
Part I: How to complete the DMRand MMR forms correctly: In order to have compliant DMR data in the EPA database.
Check the DMR and MMR for completeness prior to submittal • For No Discharge monitoring periods - be sure the “No Discharge” box is marked. • For monitoring periods with discharge - be sure that each DMR blank is filled in with the required measurement and use correct abbreviations if parameters have no measured data results. • For all submitted DMRs: sign, date, and list the correct applicable telephone number.
Send the completed DMR/MMR to the correct IDEM address, on time • DMR/MMR submittal should be postmarked by the 28th of the month following the DMR Monitoring Period End Date to: • Indiana Dept. of Environmental Management • Office of Water Quality Mail code: 65-42 DISS • Data & Information Services Section • 100 N Senate Ave • Indianapolis, IN 46204
Supply both Average and Maximum Data, when required • Report both average and maximum data, even for once-per-month or quarterly sampling frequencies. • It is okay if the reported Average measurement is identical to the Maximum measurement. • If more sampling occurred than required, all data for that parameter must be on MMR. • And it should be reflected in the Average measurement on the DMR.
Report Flow in MGD • Report flow as million gallons per day (MGD), not gallons. For example: 10,000 gallons should be reported as 0.01 million gallons. • Do not report “0” flow on the DMR: either it is a “No Discharge” DMR or there was a flow measurement. • If the dry weather flow was “0”: “0” should be listed on the MMR for that day of discharge checking.
Calculate Average Flow Correctly • To average flow for dry and wet discharges: Use two flow samples representative for the month. Example 1: “0.000 MG” (dry) and 0.010 MG (wet) Monthly AverageDaily Maximum 0.005 MGD 0.010 MGD Example 2: “0.010 MG” (dry) and 0.050 MG (wet) Monthly AverageDaily Maximum 0.030 MGD 0.050 MGD
Calculate Averages correctly forOther Parameters on dry/wet months • Calculate averages (except pH) using measured data: Example 1: “No Discharge” (dry) and 40 mg/l (wet) TSS: Monthly AverageDaily Maximum 40 mg/l 40 mg/l Example 2: 3 mg/l (dry, but discharge) and 1 mg/l(wet) Iron: Monthly AverageDaily Maximum 2 mg/l 3 mg/l
Report Non-detect Data correctly • Report less than the Limit of Detection (i.e.,“<0.005”) when reporting non-detect DMR measurements. • The lab work (or testing equipment instructions) should indicate what the Detection Limit is. • Do not report “0” or “ND” or “BD” or “BDL”. • Be sure to use “<” symbol if “less than” is meant. • Less than (<) can only be used on the DMR in combination with the actual Detectionlimit.
Report Conditional Data Correctly • Use “Exempt” or “N/A” (“not applicable”) to report excused missing data, per parameter. • This should only be used for the exempt condition parameters when reporting alternative sampling. • Note: Exempt data that is truly exempt (as per the Rule) does not create missing data violations in the EPA database. Exempt data will be processed as compliant, as long as the reason for the missing data is clearly explained on the DMR.
Complete No. of Exceedences, Frequency, and Sample Type Correctly • Complete the remaining three columns on the DMR form. • When the reported measurement on the DMR exceeds the permit limit, report the number of times the limit was exceeded that reporting period in the “No. Ex.” column.
Report Other Missing Data Correctly • Use “*” (asterisk) on the DMR blank if sampling did not occur (but it should have) for a parameter. • Explain what the “*” (asterisk) means at the bottom of the DMR page. • Based on the explanation, IDEM Data Stewards can give the missing data a process code that will at least make the data appear more complete in the EPA database, although it may still generate some kind of missing data violation.
Report No Discharge correctly • Mark the No Discharge Box when submitting DMRs for outfalls that did not have a discharge for that monitoring period. • Do not ask IDEM (Permit Writers or Data Stewards) to temporarily “delete”, “inactivate”, or otherwise terminate an outfall as an alternative to reporting no discharge. Outfall inactivation should be permanent. • “Re-activating” an inactive outfall in the federal database can cause false violations to occur.
Report Alternative Parameters -1 • Under specific precipitation conditions, the permittee may adjust reporting as follows: • If precipitation <= 10 year, 24 hr storm event flow: • Report Flow, Settleable Solids, pH, Precipitation (inches/month) and Duration (days/month). • For all other parameters, report “N/A” or “Exempt”.
Report Alternative Parameters - 2 • If precipitation > 10 year, 24 hr storm event flow: • Report Flow and pH, Precipitation (inches per month) and Duration (days per month). • For all other parameters, report “N/A” or “Exempt”. • Precipitation and Duration shall be reported on both the DMR and MMR.
NPDES Permits w/no point discharge • NPDES permittees that have no designated outfall point but still have the possibility of discharging will receive a “000 A” outfall in the EPA database. • They will need to submit DMRs for this outfall, which should usually be “No Discharge”. • The parameters on the DMR will be the same as the Reclamation Outfall parameters (quarterly).
Part II. Permit Changes that require written notification to the Permit Section In order to have changes/corrections officially made to the permit and reflected in the EPA database.
Changes to Ownership, Facility Name, or Signatory Authority • Submit these changes to the Permit Section as soon as possible, using the correct notification form. • An ownership change requires a formal modification. • Be sure the notification form is filled out completely. • It may take 2-4 weeks for changes to be completed in EPA database. • New DMRs can be sent to the facility after that time.
Updating the Facility Location Address • Federal and State databases now require more complete locational information for facilities. • When applying for permit renewals (or even new permits) each facility needs to supply both: • a specific street address or the nearest crossroads to the NPDES permitted facility, and • latitude/longitude (“lat-long”) coordinates.
Changes to the Permit Coverage Area: Permitted area should be contiguous • The facility location lat-long should generally indicate the center of the facility. • Thus, each NPDES facility needs to be one contiguous site, not multiple noncontiguous mines. • During NPDES permit renewals, permits with noncontiguous pits/mines may be split such that each noncontiguous pit/mine will have its own NPDES permit (and improved locational information).
Changes to Outfall status • Activity statustypes: Active, Inactive, Proposed. • Drainage statustypes: Undetermined, Alkaline, Acid, Reclamation. • Changes to either status type should be sent to the Permit Writer on the notification form, in order to have the change made in the EPA database and on the corresponding DMR.
Report Influent for Undetermined Outfalls • Report the required pH and iron influent monitoring for Undetermined outfalls for at least 6 months. • After 6 months of data, permittee can apply to permit writer to remove the influent monitoring. • Permit writer will notify permittee and Data Steward if influent monitoring can be removed. • Permittee must continue to report influent monitoring until notified by permit writer, in order to prevent missing data violations in EPA database.
Report metals for Acid Outfalls • Report the required metal monitoring for Acid outfalls for at least 12 months. • After 12 months of metals data, permittee can apply to permit writer to remove the parameters. • Permit writer will notify permittee and Data Steward if metal monitoring can be removed. • Permittee must continue to report metal monitoring until permit writer notifies permittee otherwise, in order to prevent false missing data violations.
Adding an Outfall to Existing Permit • Notify the permit writer whenever a new discharge point is added to an NPDES permitted area. • Each new outfall, per permit, must have a new outfall ID that has never been used with that permit. • Each new outfall must also have a unique and permanent lat-long assigned, and a start date. • Do not re-use an outfall ID in a new location, per permit – it will compromise historical data.