Action Please By: August 15, 1997
To: Members & Subscribers From: National Office Date: August 1, 1997 Re: RA 97-16 Electronic Data Information For NPDES Permitting
AMSA is attempting to secure the use of electronic data submission (EDI) using PIN numbers in lieu of paper submittal for monthly NPDES reporting. The Department of Justice (DOJ) is reluctant to allow the use of PINs without an original signature with each DMR. This requirement would negate the efficiency of electronic data reporting. EPA's Office of Water has requested that AMSA survey its membership to assess its interest in using EDI for DMR submittal in lieu of paper submittal. EDI is part of the proposed pretreatment streamlining initiative scheduled for Federal Register notice in December 1997. AMSA proposes that an annual original signature certification is adequate to verify the appropriate use of the PIN number for the previous 12 months. Please respond to the following questions and FAX the completed page by August 15, 1997 to Sam Hadeed at 202-833-4657. Thank you.
1) Are you interested in using EDI to submit DMRs using a PIN number signature?
YES NO (If no, stop and fax response)
2) If YES, at what minimum interval would you be willing to provide a paper certification to verify that you sent the DMR under the approved PIN number?
A) Once a permit cycle (every 5 years)
B) Once a year (AMSA recommends annual certification)
C) Every 6 months
D) Every quarter
E) With each DMR (little benefit to EDI)
3) What type of information would you be willing to include on the certification?
- A) Signature with indication that DMRs were sent and are accurate. (AMSA recommended alternative)
- B) Information in (A) plus standard data elements, which could include certain data reported.
Name Phone Fax Agency Thanks for your participation. Please FAX response to Sam Hadeed at 202-833-4657 by August 15.