IDEM Bypass Reporting Form

On June 18, IDEM sent out notification that they are now requiring use of a newly designed Overflow/Bypass form. Check your spam folder if you haven't received it yet. It was sent by Deborah Brents. The IWEA Government Affairs Committee (GAC) has reached out to IDEM for clarification of the email and new form. I will update this post as IDEM addresses the concerns/questions that the GAC brought up.

There are a couple items that the Certified Operator and PrincipalExecutive Officer should be aware of, because IDEM is assserting that use of the new form is required immediately and that forms sent in without all data fields completed will be sent back as incomplete. Here are the things that the GAC has identified as items of concern:

  1. The new form REQUIRES reporting longitude & latitude of overflow locations. This means that before you can complete your form, you will need to somehow get these coordinates. You can use Google maps to narrow in on the location & then left click to "Drop a Marker". In the text box of the marker, longitude & latitude coordianates are given. For example, I am typing this from my office, lon/lat of 41.6277, -84.9836. IDEM has not identified the level of accuracy that we are required to report to (the number of decimal places). 
  2. In the Certification & Signature area, the form states "the person signing this document should be authorized to legally sign as a representative of the facility", but does not define "authorized to legally sign". Is this person the Certified Operator? The Principal Executive Officer? The is a problem for facilities that may currently allow an on call operator or shift supervisor to submit reports. 
  3. The new form will only permit you to report one (1) overflow incident per form. Previously, you could report two (2) incidents per form. 
  4. IDEM is requiring the new form to be used IMMEDIATELY! They have stated that any reports on previous version of the form will be returned. 
  5. Perhaps the most bizarre portion of the email was that IDEM cited Indiana Code that is completely out of context for municipal NPDES permittees. 

What about you? Do you have additional concerns about this new form or the way that IDEM is implementing this form? Talk about it here or shoot me an email. I will make sure that any additional concerns are forwarded to the Government Affairs Committee and will keep this posted updated!

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