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APPENDIX O

Compliance Assessment Rules

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WMS Compliance Assessment Rules 1.0 INTRODUCTION Water Management System (WMS) will contain compliance assessment rules (stored procedures) that are similar to EPA’s rules contained in ICIS. In addition, DEP will also have some rules that go above and beyond EPA’s. For the sake of clarification, those rules that are unique to DEP will be highlighted. It is anticipated that the violations table in the database will have two indicator columns – one for “DEP Violation” and the other for “EPA Violation”. There may be “Y” indicators in one, both, or none of these columns as a result of compliance assessment. To the extent possible, the program will have access to tables that are called by the stored procedures to make adjustments to compliance assessment rules. The Non-Compliance Reporting Form (Non-Compliance Report) and a violations table in eFACTS will be populated as a result of the compliance assessment procedures. EPA has provided its compliance assessment procedures in ICIS for possible use in WMS. The intended, simplified sequence of DMR entry and calculation of violations for PA’s eDMR system is as follows: 1. The user enters (or uploads) data into the Daily DMR. 2. The user checks the “Complete” box for the Daily DMR. This action saves raw data and statistics to an

eFACTS table. (Recorded values are overwritten each time the user checks the box). 3. Statistical values are carried over to the Summary DMR Form. The user may override the auto-populated

values if desired. The user then checks the “Complete” box for the Summary DMR Form. 4. Compliance assessment procedures are run, and the number of violations per parameter are displayed in the

“No. Ex” field of the Summary DMR Form, as read-only. 5. Before the Master DMR can be submitted (i.e., the overall DMR including Daily DMR, Summary DMR Form,

Non-Compliance Report and required attachments), the Non-Compliance Report will need to be reviewed and checked “Complete”. The Non-Compliance Report is auto-populated with calculated violations after the Summary DMR “Complete” box is checked. These violations are shown as read-only to the user. The user may add additional information and report other violations pertaining to unpermitted discharges, etc. in other areas of the form before the Non-Compliance Report is marked as complete.

One objective of these rules is the creation of a “Quarterly Non-Compliance Report” (QNCR) from WMS that will match the QNCR in ICIS. (The QNCR is a compiled report of violations, different from Non-Compliance Reports submitted through eDMR that are facility-specific). 2.0 VIOLATION AND RNC OVERVIEW There are three basic stages in the compliance assessment procedures:

Violation generation: In this stage, all violations of permit conditions are noted, regardless of severity.

Violation RNC detection and resolution: In this stage, the system determines which violations warrant being labeled as reportable non-compliance (RNC). This includes detecting new RNC and determining that existing RNC violations have been suitably resolved and no longer qualify as RNC.

QNCR creation: In this stage, the overall compliance status of a permit is determined based on all the violations related to it.

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2.1 Violation Generation ICIS automatically generates three basic types of violations: schedule violations, effluent violations, and DMR non-receipt violations. For each of these three types of violations, there are one or two automatic processes that serve to generate the violations. For each type, there is a process that runs when certain data related to requirements or permittee performance are entered or edited. For schedule violations and DMR non-receipt violations, there are also processes that run nightly. In addition to these automatically generated violations, users can manually enter single event violations. Appendix A lists the specific types of violations that may be generated by ICIS or manually entered (this is a violations reference table that WMS will need to include). 2.2 RNC Detection and Resolution RNC detection serves to flag violations, or combinations of violations, that are considered severe enough that their resolution should be tracked. Each of the automatic processes that generate violations also has a component that serves to detect and resolve RNC related to the particular type of violation. In addition, there are two automatic processes that deal specifically with RNC, an enforcement action RNC process and an effluent RNC process. The enforcement action RNC process is triggered when violations are linked to final orders, when NPDES closed dates are entered, and by each of the data entry-triggered violation processes under certain circumstances. The effluent RNC process runs on a scheduled basis to detect and resolve effluent RNC. In addition to these automatic processes, users may also manually flag RNC. RNC may be resolved either automatically or manually. Examples of automatic resolution include receiving missing data, linking violations to final orders that meet criteria to resolve RNC, and sufficient clean data following effluent RNC. Appedix B and Appendix C, respectively, list the RNC detection and RNC resolution codes in ICIS that will need to be included in WMS. 2.3 The QNCR The QNCR is an automatically generated quarterly report that identifies an RNC status for each permit. The RNC status of a permit is based on its worst violation, as determined by a combination of resolution status and severity of the violation (i.e. whether it is considered significant non-compliance (SNC), a sub-set of RNC). Violations that are flagged as SNC are considered to be priorities. The automatically generated permit RNC status may be changed manually. If the manual change is made after the official QNCR is run for a quarter, it is marked as corrected manual. Corrected manual statuses have precedence over manual statuses entered before the official QNCR is run for a quarter, which in turn have precedence over automatic statuses. The table below lists the permit RNC status codes in ICIS in the hierarchy in which they are assigned. Statuses higher in the table take precedence over statuses lower in the table.

Order in Hierarchy Permit RNC Status Code RNC/SNC Code Description 1 S SNC SNC schedule violation

2 E SNC SNC effluent violation monthly average

3 X SNC SNC effluent violation non-monthly average

4 T SNC SNC schedule report violation

5 D SNC SNC DMR non-receipt violation

6 N RNC RNC violations only

7 P - Resolved pending

8 R - Resolved

9 C - Compliant (manual only)

10 Q - Resolved pending – compliance schedule (manual only)

The table below lists the quarter start and end dates and the approximate date on which the QNCR will be run for the quarter (as completed by EPA and should be completed by DEP).

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Quarter Start End QNCR Run 1 October 1 December 31 March 15

2 January 1 March 31 June 15

3 April 1 June 30 September 15

4 July 1 September 30 December 15

3.0 DMR PROCESSING RULES When the “Complete” box is checked on the DMR Form, WMS will compare the DMR and Daily DMR data to limits to determine whether any DMR value violates its limit value. As shown in Appendix A, there is one DMR Violation Code for Effluent Violations in ICIS – E90 – for “Reported DMR value exceeds maximum or average limit value or is below minimum limit value”. This Violation Code will also be used in WMS. The following describes stored procedures and specific actions that will be taken to calculate effluent violations. These are modeled after ICIS, but do not include many requirements that are specific to ICIS (e.g., “stay limits”, which are not planned for WMS). It incorporates processes to check compliance against revised data, which will need to be taken into account when the eDMR system is designed to address data revisions. 3.1 Effluent Violations Main Process The Effluent Violations Main Process involves the following steps: 1. If the limit value is “Report” and the parameter is not optional, initiate Administrative Discrepancy Process,

otherwise proceed to 2. 2. If adjusted DMR value is present (revision), use for compliance assessment. 3. If adjusted DMR value (revision) is NOT present, use DMR value (original) for compliance assessment. 4. If Violation Code E90 is NOT present:

A. Execute Exceeds Limits Process B. If exceeded flag is NOT Y, STOP C. Execute Percent Exceedence Process D. If percent exceedence exceeds range checking threshold, send warning message to user E. Generate violation E90 (Note – ICIS includes an additional step here – execute RNC When E90 Generated Process – but this appears to apply only where the limit is an enforcement action limit. Since DEP does not issue enforceable limits in enforcement action documents, this process will not be used).

5. If E90 is present:

A. Execute Exceeds Limits Process B. If exceeded flag is NOT Y:

(1) Delete E90 (2) Set percent exceedence to blank (3) STOP

C. Execute Percent Exceedence Process D. If percent exceedence exceeds range checking threshold, send warning message to user E. Execute RNC When E90 Present Process

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6. Initiate Administrative Discrepancy Process. 3.2 Exceeds Limits Process In ICIS, for each limit staff can designate whether the “limit compliance value indicator” is <, <=, >, or >=. This has an effect on how violations are computed. WMS is not currently planned to provide these indicators. Instead, a reference table will be created for statistical base codes (SBCs). This table will contain a column for “Statistical Base Code Type” (SBC Type), with possible values of Maximum, Average and Minimum. If an SBC has an SBC Type of Maximum or Average, then a violation will be assessed if the DMR value is greater than (>) the limit value. If an SBC has an SBC Type of Minimum, then a violation will be assessed if the DMR value is less than (<) the limit value. Therefore, all DMR values equal to the limit value will be considered in compliance in WMS. The Exceeds Limits Process involves three steps with additional rules and logic: 1. If SBC Type is Maximum, set exceeded flag to Y if DMR value (original or revision) > limit value. 2. If SBC Type is Minimum, set exceeded flag to Y if DMR value (original or revision) < limit value. 3. Return to Effluent Violations Main Process. The additional rules and logic for this process are as follows: A. Rules 1 and 2 above will be applied against both DMRs (statistical summary results) and certain SBCs on

the Daily DMR. The SBCs that will be assessed on the Daily DMR include: Maximum, Instantaneous Maximum, Daily Maximum, Minimum, Instantaneous Minimum, Average Weekly and Daily Minimum. The E90 Violation Code will not be applied against DMR values entered on the Daily DMR, although a “DEP Violation” indication will be made.

(Therefore, the Non-Compliance Report could display both “daily violations” and “monthly violations”). Example 1 – a facility is required to take weekly grab samples for pH. The minimum limit is 6.0 and the maximum limit is 9.0. The results for a month are as follows: 5.9, 7.0, 7.0 and 9.1. Two violations would be listed on the Non-Compliance Report – 5.9 (less than 6.0 limit) and 9.1 (greater than 9.0 limit). Example 2 – the same facility in Example 1 has the following results in a subsequent month: 5.7, 5.8, 5.9 and 6.0. Three violations would be listed on the Non-Compliance Report – 5.7, 5.8 and 5.9 (all less than 6.0 limit). B. If a limit is specified as “ND” in WMS and a value is reported on the Summary DMR that is not preceded with

a less than symbol, it should be counted as a violation. If the value is reported with a less than (<) symbol, compare the value to the “Quantitation Limit” value in WMS.

Example 1 – Total Priority Pollutants has an Average Monthly limit of “ND”. If the statistical value reported on the DMR is “0.1”, it is a violation. Example 2 – Total Priority Pollutants has a Daily Maximum limit of “ND”. There are three entered values on the Daily DMR - < 0.1, 0.1 and 0.2. The Quantitation Limit entered by staff in WMS is 0.1. There are two violations (0.1 and 0.2). Example 3 – Polyaromatic Hydrocarbons has an Average Monthly limit of “ND”. If the Quantitation Limit is 0.1, and the statistical value reported on the DMR is “< 0.11”, it is a violation. (Note – the Quantitation Limit value in WMS will be transmitted to ICIS anytime there is an “ND” (non-detect) limit, since ICIS does not accept “ND” limits). C. If the DMR value is preceded by a less than (<) symbol, ignore the symbol for the determination of violations,

except where the permit limit has an SBC Type of Minimum. In such cases, a value that is less than or equal to the limit is a violation. However, the E90 Violation Code will not be applied if the reported value = the limit value, since this would not be an EPA violation in ICIS (although a “DEP Violation” indication will be made).

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Example 1 – The average monthly limit is 0.1, and the reported average monthly value is < 0.1. This is not a violation. Example 2 – The average monthly limit is 0.1, and the reported average monthly value is < 0.11. This is a violation. Example 3 – The minimum limit is 5.0, and the reported minimum value is < 5.0. This is a violation. D. If the DMR value is preceded by a greater than (>) symbol (which will be possible only for bacterial

parameters), ignore the symbol for the determination of violations, except where the permit limit has an SBC Type of Maximum. In such cases, a value that is greater than or equal to the limit is a violation. However, the E90 Violation Code will not be applied if the reported value = the limit value, since this would not be an EPA violation in ICIS (although a “DEP Violation” indication will be made).

Example – The geometric mean limit is 200, and the reported geometric mean value is > 200. This is a “DEP violation” (but not an EPA violation). (Note – ICIS ignores all qualifiers such as < or > when entered into value fields). (Note – DEP allows entry of four NODI codes into eDMR currently, and this is anticipated to continue: A, E, FF and GG. In ICIS, E and FF produce effluent violations. The Exceeds Limits Process will also need to flag as EPA and DEP violations). 3.3 Percent Exceedence Process The Percent Exceedances Process is called as part of the Effluent Violations Main Process and involves the following steps: 1. If percent exceedence cannot be calculated for the parameter, STOP. (Note – in ICIS, a Percent Exceedence

Flag column is used to indicate “Y” or “N” for each parameter code within the parameter reference table). 2. Check DMR Value Qualifier (> or <). If DMR Value Qualifier is not > or <, go to Step 3. 3. If the limit parameter code is NOT a removal parameter (not in the list par_code = 81010, 81011, 80358,

81012, 50076, 80115, 81383, 81385, 00175, 81393, 81384, 82387, 80091, 81402, 00166, 00157, 82218, 81009) and SBC Type is Maximum or Average, set percent exceedence = [(DMR value / Limit value) – 1.0] x 100. If the SBC Type is Minimum, set percent exceedence = [1.0 - (DMR value / Limit value)] x 100. If SBC Type is not Maximum or Average or Minimum, set percent exceedence to blank.

4. If the limit parameter code IS a removal parameter (in the list par_code = 81010, 81011, 80358, 81012,

50076, 80115, 81383, 81385, 00175, 81393, 81384, 82387, 80091, 81402, 00166, 00157, 82218, 81009) and SBC Type = Maximum or Average, set percent exceedence = [(100 - DMR value / 100 - Limit value) – 1.0] x 100. If the limit parameter code IS a removal parameter and SBC Type = Minimum, set percent exceedence = [1.0 - (100 - DMR value / 100 - Limit value)] x 100. If SBC Type is not Maximum or Average or Minimum, set percent exceedence to blank.

5. If DMR Value Qualifier = >, and if SBC Type is Maximum or Average, set percent exceedence = 99,999. If

SBC Type = Minimum, set percent exceedence = [1.0 - (DMR value / Limit value)] x 100. 6. If DMR Value Qualifier = <, and if SBC Type = Minimum, set percent exceedance = 99,999. If SBC Type is

Maximum or Average, set percent exceedence = [(DMR value / Limit value) – 1.0] x 100. 7. Return to Effluent Violations Main Process. 3.4 RNC When E90 Present Process 1. If RNC tracking flag is OFF in WMS, initiate Administrative Discrepancy Process, otherwise proceed to 2. 2. If RNC detection code IS A OR P (Note – for enforcement action limits only, should not be used in WMS)

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A. Set RNC detection code, RNC detection date, RNC resolution code, and RNC resolution date to blank B. Return to Effluent Violations Main Process

3. If RNC detection code is NOT (A OR P):

A. Execute TRC Process B. Initiate Administrative Discrepancy Process

3.5 TRC Process 1. If new % exceedence (revision) = old % exceedence (original), STOP, otherwise proceed to 2. 2. If any of the following combinations of conditions are met, set RNC detection code, RNC detection date, RNC

resolution code, and RNC resolution date to blank:

A. (RNC detection code = T) AND (SBC NOT a monthly average), OR B. (RNC detection code = T) AND (SBC is a monthly average) AND (SNC parameter group = 1) AND (%

exceedence < 40%), OR C. (RNC detection code = T) AND (SBC is a monthly average) AND (SNC parameter group = 2) AND (%

exceedence < 20%), OR D. (RNC detection code = R) AND (SNC parameter group = 1) AND (% exceedence < 40%), OR E. (RNC detection code = R) AND (SNC parameter group = 2) AND (% exceedence < 20%)

3. Return to RNC When E90 Present Process (Note – SNC parameter groups are stored in the ICIS parameter reference table in an “SNC Flag” column, which will need to be included in WMS). 3.6 Administrative Discrepancy Process Administrative discrepancies are generated when DMR data does not match corresponding limit data for frequency of analysis or sample type. In ICIS, these discrepancies are not violations; however, DEP would like WMS to flag certain discrepancies as violations. These violations will not be given an EPA Violation Code, but will be stored with a code of S (Sample Type) and F (Frequency of Analysis) in the violations table, and have the “DEP Violation” indication made. The logic to be used is unique to DEP. Sample Type If the user overrides the pre-populated sample type on the DMR Form (i.e., the permit requirement), an analysis will be done to determine whether or not there is a violation. Below are all sample types anticipated for facilities to select in eDMR (Permit Sample Type) and sample types that are considered less stringent. If a facility selects a sample type that is less stringent than the permit-required sample type (as coded in WMS), it will be logged as an “S” violation.

Number Permit Sample Type Record “S” Violation If DMR Sample Type Is: (1) 1 Grab 10 - 14, 16 - 19

2 Grab-Composite 1, 10 - 14, 16 - 19

3 3 Grabs/24 Hours 1, 5 - 7, 10 - 14, 16 - 19

4 4 Grabs/24 Hours 1, 3, 5 - 7, 10 - 14, 16 -19

5 4-Hr Composite 1 - 4, 10 - 19

6 6-Hr Composite 1 - 5, 10 - 19

7 8-Hr Composite 1 - 6, 10 - 19

8 24-Hr Composite 1 - 7, 9 - 19

9 Composite 1 - 4, 10 - 19

10 Measured 1 - 9, 13, 14, 16 - 18

11 Recorded 1 - 9, 13, 14, 16 - 19

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Number Permit Sample Type Record “S” Violation If DMR Sample Type Is: (1) 12 Metered 1 - 9, 13 - 19

13 Calculation 1 - 9, 12, 14 - 19

14 Estimate 17, 18

15 I-S 1 - 14, 16 -19

16 In-Situ 1 - 15, 17 - 19

17 See Permit -

18 Visual -

19 Weir 1 - 9, 14 - 18

Note: (1) For Oil and Grease (parameter code 00556), Dissolved Oxygen (code 00300), pH (code 00400), Fecal (code

74055) and Total Coliform (code 74056), Temperature (code 00011), Total Residual Chlorine (code 50060) and Volatile Organic Compounds (e.g., BTEX) (code 49491), use of any “Composite” sample type should be deemed an “S” violation unless the permit is specifically coded this way in WMS.

Frequency of Analysis The DMR will calculate the actual sampling frequency based on entries in the Daily DMR and populate this value onto the DMR Form for each parameter. However, the user will be able to override the calculated value by selecting from a drop-down list. (The maximum sampling frequency that can be calculated and pre-populated onto the DMR Form is “1/day”. Since some parameters must be monitored more frequently, the user will need to select another frequency from a list. After a selection is made in which sampling frequency > 1/day for a parameter, subsequent DMRs will pre-populate the last frequency selected by the user for that parameter). Below are all sample frequencies that will be available for facilities to select in eDMR and sample frequencies that are considered less stringent. If a facility selects a sample frequency that is less stringent than the permit-required sample frequency (as coded in WMS), it will be logged as an “F” violation.

Number Permit Sample Frequency Record “F” Violation If DMR Sample Frequency Is: (1) 1 Continuous 3 – 36

2 4/hour 3 – 36

3 2/hour 4 – 36

4 1/hour 6 – 36

5 Hourly when Discharging 6 – 36

6 1/2 hours 7 – 36

7 4/day 8 – 36

8 1/shift 10 – 36

9 3/day 10 – 36

10 2/day 11 – 36

11 1/day 13 – 36

12 Daily when Discharging 13 – 36

13 5/week 15 – 36

14 1/weekday (1) 15 – 36

15 4/week 16 – 36

16 3/week 17 – 36

17 2/week 18 – 36

18 5/month 21 – 36

19 1/week 21 – 36

20 Weekly when Discharging 21 – 36

21 4/month 22 – 36

22 3/month 23 – 36

23 1/2 weeks 25 – 36

24 2/month 25 – 36

25 1/month 27 – 36

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Number Permit Sample Frequency Record “F” Violation If DMR Sample Frequency Is: (1) 26 Monthly when Discharging 27 – 36

27 3/quarter 28 – 36

28 2/quarter 29 – 36

29 1/60 days 31 – 36

30 Bi-Monthly 31 – 36

31 1/quarter 33 – 36

32 2/6 months 33 – 36

33 3/year 34 – 36

34 1/6 months 36

35 2/year 36

36 1/year -

37 2/discharge 38

38 1/discharge -

39 When Discharging -

40 Upon Request -

41 See Permit -

(1) Permit Sample Frequencies above are those frequencies commonly used in permits that will be available for

staff to select in WMS. A separate reference table will need to be created that includes not only the Permit Sample Frequencies, but all possible sample frequencies that could occur during the reporting period, so that the logic can compute violations.

Example 1 – a user enters six daily records for a parameter, each week. The logic will recognize this pattern as “6/week”. The reference table will need to include 6/week. If the permit requirement is 1/day, an “F” violation would be computed. Example 2 – a user enters 17 daily records for a parameter throughout a month (i.e., no specific pattern could be identified). When no pattern is identified, the logic will sum the number of entries and display it as “sum/reporting period (e.g., 17/month). The reference table will include 17/month and compare it to the permit requirement. 3.7 Rules for DMR Non-Receipt If a DMR value is missing (blank where a value was required), the system will generate DMR non-receipt violations for any values that were not received. (Note – this should not be possible because form-level validation in the DMR will prohibit the submission if there is not at least one value (i.e., numeric or NODI code) for each parameter, unless the No Discharge box is checked). In the event there is a missing DMR value, the Violation Code “D80” (for parameters with “Report” only limits) or the Violation Code “D90” (for parameters with numeric limits) will be written to the violations table in eFACTS. For Master DMRs that are not submitted by the due date, a stored procedure will automatically send facility users and staff a notification email that the DMR is late on the day after the due date. If the Master DMR has not been submitted within 15 days following the due date, then on the 15

th day the procedure will again distribute email

notification. Note – in addition to the procedures below, which are specific to EPA violations, if a Master DMR is not submitted by the due date it will be considered a “DEP violation”. The difference is that DEP considers it a violation when a Master DMR is submitted one or more days beyond the due date, and EPA only considers it a violation when the non-receipt is > 30 days. Note – EPA assesses non-compliance for DMR non-receipt at the parameter level, while DEP has traditionally assessed non-compliance at the DMR level. Both approaches will need to be incorporated into the procedures. 3.7.1 Scheduled DMR Non-Receipt Process The scheduled DMR non-receipt process will generate violations at the parameter level in cases where the date is now 31 or more days past the DMR due date. This procedure will run nightly. If Master DMRs have not been

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submitted within 30 days of the due date, on the 31st day, the Scheduled DMR Non-Receipt Process will record in

the violations table in eFACTS a “D80” violation for all parameters with “Report” only limits and a “D90” violation for all parameters with numeric limits (including “ND”), unless the Optional Monitoring flag for the parameter in WMS is ON or a NODI code has been submitted as the value. The procedure is as follows: 1. Flag all DMR values where the following conditions are met:

A. (Date of last successful run) < (DMR due date + 31) <= (Current date) AND B. DMR value received date is blank OR NODI is present

2. For each of the flagged DMR values, check that the limit is active. For the limit to be active, all of the following

conditions must be met. If any of the conditions is not met, STOP:

A. Permit type is NOT master general permit, AND B. Compliance tracking status is active as of the monitoring period end date (MPED), AND C. DMR non-receipt status is on, AND D. Subfacility status is active as of the MPED

3. Check the limit for any exceptions to DMR non-receipt. If any of the following conditions is met, STOP:

A. Limit value is optional monitoring, OR B. NODI is present

4. If monitoring only, generate D90 violation 5. If numerical limit, generate D80 violation 6. If the RNC flag is off, STOP 7. Check the statistical base code of the limit:

A. If statistical base code is a monthly average 1) Set RNC detection code = K 2) Set RNC detection date = DMR due date + 31 3) Set RNC resolution code = 1 (noncompliant) 4) Set RNC resolution date = RNC detection date 5) STOP

B. If statistical base code is a non-monthly average

1) Set RNC detection code = N 2) Set RNC detection date = DMR due date + 31 3) Set RNC resolution code = 1 (noncompliant) 4) Set RNC resolution date = RNC detection date 5) STOP

C. If statistical base code is NOT (a monthly average OR a non-monthly average), STOP

When the Master DMR is finally submitted, the late submission will be displayed on the Non-Compliance Report as a violation along with the number of days that it is late. 3.7.2 DMR Non-Receipt Update Process The DMR Non-Receipt Update Process will run whenever a user modifies (adds, deletes, or edits) data in the system that could affect DMR non-receipt violations. Depending on the change, DMR non-receipt violations may be generated or deleted. The number of days late indicator will also be updated. The DMR Non-Receipt Update Process is executed when any of the following data are modified:

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DMR value received date

DMR value, adjusted DMR value, value qualifier, reported unit code

NODI

Limit set and limit data

Frequency of analysis and reported sample type The process flow is as follows: 1. Check that the limit associated with the modified data is active. For the limit to be active, all of the following

conditions must be met. If any of the conditions is not met, STOP: A. Permit type is NOT master general permit, AND B. Compliance tracking status is active as of the MPED, AND C. DMR non-receipt status is on, AND D. Permitted feature (subfacility) status is active as of the MPED

2. If the limit value is monitoring only, STOP 3. If the DMR due date is blank, initiate Effluent Violations Main Process 1. If a DMR non-receipt violation (violation type = D80 OR D90) IS present, and the DMR submission received

date is NOT blank, and the DMR submission received date is <= due date + 31, then:

A. Delete D80 or D90 Violation Codes B. If DMR value received date > due date, calculate days late and record in table C. Initiate Effluent Violations Main Process

(Note 1 – this situation could only occur if the program is manually entering records into the eDMR database for a facility that submitted their report on time, and the program was not able to enter the data within 30 days of the DMR due date).

(Note 2 – ICIS has a “DMR value received date” field for each parameter, which defaults to the overall DMR submission date. There will not be a need to have this field in eDMR because validation procedures will prevent submission of blank results for parameters).

2. If a DMR non-receipt violation (violation type = D80 OR D90) IS present, and the DMR value received date is

NOT blank, and the DMR submission received date is > due date + 31, then:

A. Calculate days late and record in table B. If RNC resolution code is (6, 7, 8, 9, B, 3, OR 5), initiate Effluent Violations Main Process C. If DMR value received date is within the current or past QNCR quarter:

(1) Set RNC resolution code = 2 (back into compliance) (2) Set RNC resolution date = DMR value received date

D. If DMR value received date is NOT within the current or past QNCR quarter:

(1) Set RNC resolution code = W (waiting) (2) Set RNC resolution date = DMR value received date

E. Initiate Effluent Violations Main Process

(Note – this situation would occur if a facility submits their report more than 30 days late).

3. If a DMR non-receipt violation (violation type = D80 OR D90) IS present, and the DMR submission received

date IS blank (i.e., no report submitted), then:

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A. If E90 is present, delete E90 and set percent exceedence to blank B. If RNC resolution code for D80 or D90 is (I, A OR manual), STOP C. If RNC tracking flag is OFF in WMS, STOP D. Set RNC resolution code = 1 E. Set RNC resolution date = DMR due date + 31

(Note – this situation would occur if the procedure runs against a DMR that has not yet been submitted).

4. If DMR non-receipt violation (violation type = D80 OR D90) is NOT present, and the DMR submission

received date is <= due date + 31, then: A. If DMR value received date is > due date, calculate days late B. Initiate Effluent Violations Main Process (Note – this situation would apply to most DMRs, which are submitted within 30 days of the due date).

5. If DMR non-receipt violation (violation type = D80 OR D90) is NOT present, and the DMR submission received date is > due date + 31, then: A. Calculate days late and record to table B. If limit value is monitoring only, generate violation D80 C. If limit value is NOT monitoring only, generate violation D90 D. If RNC tracking flag is OFF in WMS, initiate Effluent Violations Main Process E. Check the statistical base code of the limit:

(1) If the statistical base code is neither a monthly average nor non-monthly average, initiate Effluent

Violations Main Process (2) If the statistical base code is a monthly average:

a. Set RNC detection code = K b. Set RNC detection date = DMR due date + 31

(3) If the statistical base code is a non-monthly average:

a. Set RNC detection code = N b. Set RNC detection date = DMR due date + 31

F. If the DMR value received date is within the current or past QNCR quarter:

A. Set RNC resolution code = W (waiting) B. Set RNC resolution date = DMR value received date C. Initiate Effluent Violations Main Process

G. If the DMR value received date is NOT within the current or past QNCR quarter:

A. Set RNC resolution code = 2 (back into compliance) B. Set RNC resolution date = DMR value received date C. Initiate Effluent Violations Main Process

(Note – the “Scheduled DMR Non-Receipt Process” should pick up non-receipt violations in these situations. This process may apply only where revisions are made to DMRs that are 30+ days late. System behavior for addressing revisions to DMRs will need to take this process into account).

3.8 Rules for Schedules WMS will generate violations against WMS schedules when schedule event dates are not met. Violation generation will be the same for permit schedules and compliance schedules, but RNC detection is different for some compliance schedules.

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There will be four types of schedule violations. In increasing order of severity, they are:

C10 – Schedule event reported late

C20 – Schedule event achieved late but reported

C30 – Schedule event unachieved but reported

C40 – Schedule event unachieved and not reported

The table below summarizes the circumstances with respect to schedule actual date, schedule report received date, and current date under which each type of violation will be generated.

Violation Code Schedule Actual Date Schedule Report Received Date Current Date

C10 <= Schedule Date > Schedule Date + 14

days N/A

C20 > Schedule Date Not blank N/A

C30 Blank Not blank > Schedule Date + 30

days

C40 Blank Blank > Schedule Date + 30

days

(Note – “DEP Violations” will be generated if schedule events are one day or more late). In ICIS, there are two processes that generate schedule violations: a process that runs nightly (Schedule Violations Nightly Process) and a process that runs when schedule data are modified (Schedule Data Modified Main Process). There is also a scheduled process that runs nightly to detect RNC for schedule violations (Schedule Violations RNC Detection Nightly Process). These processes will be put into place for WMS/eDMR. 3.8.1 Schedule Violations Nightly Process This nightly process will generate C30 and C40 violations for schedule events for which the reports have not been received or the event has not been completed. When the schedule violation nightly process runs, WMS will do the following: 1. Flag all schedule events where the following conditions are met:

A. Current date > schedule date + 30 AND B. Schedule actual date is blank AND C. (C30 OR C40) NOT present

2. If compliance tracking status is NOT active in WMS, STOP 3. If schedule report received date is blank, generate violation C40 4. If schedule report received date is NOT blank, generate violation C30 5. If the schedule event meets any of the following conditions, STOP

A. Schedule event type is NOT report, OR B. RNC category is NOT 1, OR C. RNC tracking flag is off

6. Set RNC data as follows:

A. RNC detection code = N B. RNC detection date = current date C. RNC resolution code = 1 (noncompliant)

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D. RNC resolution date = RNC detection date 7. STOP 3.8.2 Schedule Violations RNC Detection Nightly Process 1. Flag all schedule violations where the following conditions are met:

A. Current date > schedule date + 90 AND B. Schedule event type = S AND C. Schedule actual date is blank AND D. (RNC resolution code, RNC resolution date, RNC detection code, RNC detection date) are blank

2. If compliance tracking status is NOT active, STOP 3. If the violation meets any of the following conditions, STOP

A. Violation is NOT (C30 OR C40), OR B. RNC category is NOT 1, OR C. RNC tracking flag is off

4. Set RNC data as follows:

A. RNC detection code = S B. RNC detection date = current date C. RNC resolution code = 1 (noncompliant) D. RNC resolution date = RNC detection date

5. STOP 3.8.3 Schedule Data Modified Main Process This process runs when any of the dates (schedule date, actual date, report received date) related to a schedule are modified. It may generate, delete, and/or modify RNC detection for any of the four types of schedule violations. 1. If compliance tracking status is NOT active, STOP 2. If report received date is blank AND actual date is blank:

A. Execute C10 Process B. Execute C20 Process C. If schedule date + 30 < current date, execute C40 Process D. STOP

3. If report received date is NOT blank AND actual date is blank:

A. Execute C10 Process B. Execute C20 Process C. If schedule date + 30 < current date, execute C30 Process D. STOP

4. If report received date is NOT blank AND actual date is NOT blank:

A. If C30 is present OR C40 is present:

(1) Execute C10 Process (2) Execute C20 Process (3) If RNC tracking flag is off, STOP

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(4) If report received date <= schedule date + 30 , delete C40 violation and STOP (5) If actual date <= schedule date + 30, delete C30 violation (6) If RNC resolution code = (6, 7, 8, 9, OR B), STOP (7) Resolve C30 or C40 (8) Execute QNCR Process

B. If C30 NOT present AND C40 NOT present:

(1) Execute C10 Process (2) Execute C20 Process (3) If report received date > schedule date + 30:

a. Generate C40 violation b. Execute Detect C30/C40 Back in Compliance Process

(4) If report received date <= schedule date + 30:

a. If actual date <= schedule date + 30, STOP b. Generate C30 violation c. Execute Detect C30/C40 Back in Compliance Process

3.8.4 C10 Process 1. If report received date > schedule date + 14:

A. If C10 NOT present, generate C10 violation B. Return to Schedule Data Modified Main Process

2. If report received date <= schedule date + 14:

A. If C10 present, delete C10 violation B. STOP

3.8.5 C20 Process 1. If actual date > schedule date:

A. If C20 NOT present, generate C20 violation B. Return to Schedule Data Modified Main Process

2. If actual date <= schedule date:

A. If C20 present, delete C20 violation B. STOP

3.8.6 C30 Process 1. If C30 NOT present:

A. Generate C30 violation B. Execute Detect C30/C40 Noncompliant Process

2. If C40 NOT present:

A. If report received date <= schedule date + 30, STOP B. If report received date > schedule date + 30, execute C30/C40 Back in Compliance Process

3. If C40 present:

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A. If report received date <= schedule date + 30, delete C40 violation and STOP B. If report received date > schedule date + 30:

(1) If RNC tracking flag is off, STOP (2) If RNC resolution code = (6, 7, 8, 9, OR B), STOP (3) Resolve C40 (4) Execute QNCR Process

3.8.7 C40 Process 1. If C40 NOT present, generate C40 violation 2. Execute Detect C30/C40 Noncompliant Process 3. If C30 NOT present, STOP 4. Delete C30 violation 5. STOP 3.8.8 QNCR Process 1. If resolution date > quarter end date:

A. Set RNC resolution code = W (resolved pending) B. If C40 present, set RNC resolution date = report received date C. If C30 present, set RNC resolution date = actual date D. STOP

2. If resolution date <= quarter end date:

A. Set RNC resolution code = 2 B. If C40 present, set RNC resolution date = report received date C. If C30 present, set RNC resolution date = actual date D. STOP

3.8.9 Detect C30/C40 Noncompliant Process 1. If RNC tracking flag is off, STOP 2. If RNC tracking category NOT 1, STOP 3. If RNC resolution code = (6, 7, 8, 9, OR B), STOP 4. If event type is report, set RNC data as follows:

A. RNC detection code = N B. RNC detection date = current date C. RNC resolution code = 1 (noncompliant) D. RNC resolution date = RNC detection date

5. If event type is schedule AND < 90 days late, STOP 6. If event type is schedule AND >= 90 days late, set RNC data as follows:

A. RNC detection code = S B. RNC detection date = current date C. RNC resolution code = 1 (noncompliant) D. RNC resolution date = RNC detection date

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7. STOP 3.8.10 Detect C30/C40 Back in Compliance Process 1. If RNC tracking flag is off, STOP 2. If RNC category NOT 1, STOP 3. If RNC resolution code = (6, 7, 8, 9, OR B), STOP 4. If event type is report:

A. Set RNC data as follows:

(1) RNC detection code = N (2) RNC detection date = report received date

B. Execute QNCR Process

5. If event type is schedule AND < 90 days late, STOP 6. If event type is schedule AND >= 90 days late:

A. Set RNC data as follows:

(1) RNC detection code = S (2) RNC detection date = schedule report received date

B. Execute QNCR Process

4.0 RNC PROCESSING Certain violations are defined by regulations as being “reportable non-compliance” (RNC). The regulations at 40 CFR 123.45 define six categories of RNC:

Monthly average effluent limit violations: Monitoring data for a given parameter exceeding a limit by 40% (for group 1 pollutants) or 20% (for group 2 pollutants) twice during a six month period (These are referred to as “technical review criteria” (TRC) violations.), or by any amount 4 times during a six month period.

Non-monthly average effluent limit violations: Monitoring data for a given parameter exceeding a limit by 40% (for group 1 pollutants) or 20% (for group 2 pollutants) twice during a six month period, or by any amount 4 times during a six month period. Provided either no monthly average value exists for the parameter, or there is at least one violation of the monthly average limit for the parameter (but the monthly average violations do not meet the monthly average RNC definition).

Formal enforcement action limit violations: Any violation of limits set by an enforcement action. (Note – this should not apply to WMS, since limits are not placed in enforcement action documents in PA).

Schedule event violations: Missing a due date for a scheduled event by 90 days.

Schedule report violations: Missing a due date for a schedule report by 30 days.

Single Event: Violation of any type determined by the permitting authority to have an adverse effect on water quality or public health.

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The regulations require that RNC violations by major facilities be reported quarterly, which ICIS accomplishes by producing the QNCR. While only major facilities appear on the QNCR, ICIS detects RNC for violations for all facilities. WMS will have the same capabilities as ICIS. A subset of RNC violations are designated SNC. The definition of SNC is not regulatory, and may change. Violations designated as SNC are expected to receive priority attention for enforcement actions. RNC detection for DMR non-receipt and schedule violations will be handled by the non-receipt and schedule violation generation processes described above. RNC detection for effluent violations (except violations of enforcement action limits) is more complex and is processed separately, utilizing the percent exceedence calculated by the effluent violations generation process. 4.1 Effluent RNC Processing Effluent RNC is based on monitoring data over a six-month window that includes the quarter of the QNCR and the previous quarter. As noted, effluent violations are designated as RNC when monitoring data for a given parameter exceeds a limit by 40% (for group 1 pollutants) or 20% (for group 2 pollutants) twice during a six month period, or by any amount 4 times during a six month period. Effluent RNC for non-enforcement action limits may be resolved in three ways:

Monitoring data that has no effluent violations for three consecutive months

Violations no longer meet the RNC definition during the six month window being evaluated

A formal enforcement action final order with a compliance schedule is linked to the violation. The general steps in effluent violation RNC processing are: 1. Generate effluent violations, as described above 2. Perform enforcement action resolution for existing RNC 3. Perform effluent detection and resolution

A. Identify six-month window B. Identify eligible violations C. Detect monthly average TRC D. Detect monthly average chronic E. Detect non-monthly average TRC F. Detect non-monthly average chronic G. Resolve effluent RNC H. Resolve/resolve pending new RNC through enforcement action

4. Automatically update effluent RNC detection 5. Manually detect and resolve effluent RNC 4.2 Enforcement Action Resolution for Existing RNC A nightly process will run to update the RNC resolution code and RNC resolution date of existing effluent RNC. (Violations may be linked to enforcement action final orders before the violation is detected as RNC. This is why RNC resolution is performed as part of the RNC detection step.) If an enforcement action final order with a compliance schedule has been linked to a permit limit violation, OR a compliance schedule has been added to a final order linked to a violation, the RNC resolution data will be set as follows: RNC resolution code = 3 (resolved pending)

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RNC resolution date = issued/entered date of linked final order If a final order linked to a violation has been closed, the RNC resolution data will be set as follows: RNC resolution code = 5 (resolved) RNC resolution date = NPDES closure date of linked final order Resolved pending or resolved violations may be set back unresolved or resolved pending if the following have occurred:

Final order unlinked from violation

All compliance schedules removed from final order linked to violation

NPDES closure date of final order linked to violation is edited (Note – this functionality, which depends on linking enforcement actions to violations to resolve those violations, will be on hold until an Enforcement Action module is built within WMS). 4.3 Effluent Detection and Resolution Process The effluent detection and resolution process will run weekly during months before the QNCR runs (February, May, August, and November), and monthly in all other months. Step 1 - Identify six-month window Each time the effluent detection and resolution process is run, the administrator running the process will supply a window end date, which must be the last day of a month. WMS will then calculate: Quarter start date = first day of the month 3 months before the window end date Window start date = first day of the month 6 months before the window end date Step 2 - Identify eligible violations WMS will then collect the violations that meet ALL of the following criteria:

RNC tracking flag for the NPDES ID is on, AND

Compliance status for the NPDES ID is active, AND

Permitted feature (subfacility) type is (IMP or DP), AND

Parameter’s SNC group is (1 OR 2), AND

Limit value’s statistical base code type is (a monthly average OR a non-monthly average), AND

Violation code is E90, AND

Window start date <= monitoring period end date (MPED) for the violation’s DMR value <= window end date, AND

Violation RNC detection date is (blank OR <= window end date), AND

Violation RNC resolution code is NOT (3, 5, 6, 7, 8, 9, B OR T)

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The collected violations are then grouped into sets that have the same:

NPDES ID, AND

Permitted feature identifier, AND

Parameter code, AND

Monitoring location code Note that violations in a set may be from different limit sets. Step 3 - Detect monthly average TRC For each violation in a set, WMS will perform the following process to detect monthly average TRC: 1. If statistical base code type is NOT monthly average, skip to Step 5, detect non-monthly average TRC 2. If parameter SNC group = 1, count the MPED with monthly average violations with percent exceedence >=

40% 3. If parameter SNC group = 2, count the MPED with monthly average violations with percent exceedence >=

20% 4. If there are < 2 MPED with violations meeting TRC threshold, skip to Step 4, detect monthly average chronic 5. For each monthly average violation meeting the TRC threshold, set RNC data as follows:

A. RNC detection code = T B. RNC detection date = window end date C. RNC resolution code = 1 D. RNC resolution date = RNC detection date

6. If there are other monthly average violations that do not meet the TRC threshold, set RNC data for those

violations as follows:

A. RNC detection code = V B. RNC detection date = window end date C. RNC resolution code = 1 D. RNC resolution date = RNC detection date

7. If there are non-monthly average violations in the set:

A. If RNC resolution code is NOT (3, 5, 6, 7, 8, 9, B, OR T), set RNC data for those violations to blank 8. Continue to Step 7, resolve effluent RNC Tables 1 through 3 show example violation sets, including the % exceedence and RNC detection code. In these, and subsequent examples, the parameter/monitoring location code combination has Q1, Q2, C1, C2 and C3 limits, with Q1 and C1 being monthly averages and Q2, C2 and C3 being non-monthly averages. The parameter is in SNC group 1, so the TRC threshold is 40%. Boxes with RNC violations are bolded, boxes with TRC violations are also shaded. Boxes with double borders are of particular interest and are typically mentioned in the explanation of the table. Table 1 and Table 2 show examples of violation sets where RNC for monthly average TRC would be detected. Table 3 shows an example of a violation set where monthly average TRC would not be detected.

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Table 1: Example of monthly average TRC detection

In Table 1, months 1 and 3 are the two months that cause the parameter to be detected as TRC.


In Table 2, months 1 and 2 are the two months that cause the parameter to be detected as TRC. (Month 2 is counted only once, even though there are TRC violations of two limits for that month.)

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In Table 3, though there are two violations that exceed the TRC threshold, they are both in month 2. Therefore, the criterion that there be exceedences over the TRC threshold in two months during the six-month window is not met. Step 4 - Detect monthly average chronic If a set of violations does not meet the TRC criteria, WMS will next determine if there are chronic violations, by doing the following: 1. Count the MPED in the six-month window for which there is at least one violation of a monthly average limit 2. If the number of MPED is < 4, skip to Step 5, detect non-monthly average TRC 3. If parameter SNC group = 1:

A. For monthly average violations with percent exceedence >= 40%, set RNC data as follows:

(1) RNC detection code = T (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

B. For all other monthly average violations, set RNC data as follows:

(1) RNC detection code = C (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

4. If parameter SNC group = 2:

A. For monthly average violations with percent exceedence >= 20%, set RNC data as follows:

(1) RNC detection code = T (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

B. For all other monthly average violations, set RNC data as follows:

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(1) RNC detection code = C (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

5. If there are non-monthly average violations in the set:

A. If RNC resolution code NOT (3, 5, 6, 7, 8, 9, B, OR T), set RNC data to blank 6. Continue to Step 7, resolve effluent RNC Table 4 and Table 5 show examples of violation sets where monthly average chronic RNC would be detected. As above, Q1 and C1 are monthly averages and the parameter is in SNC group 1. Boxes with RNC violations, TRC and chronic, are bolded and shaded.

Table 4: Example of monthly average chronic RNC detection

In Table 4, five months (all but month 3) have monthly average violations, thus meeting the chronic RNC criterion.

Table 5: Example of monthly average chronic RNC detection

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In Table 5, months 1, 2, 5, and 6 have monthly average violations. Note that the violation of C1 in month 2 is assigned an RNC detection code of T because it exceeds the TRC threshold of 40% exceedence. Step 5 - Detect non-monthly average TRC If a set of violations does not meet the criteria for monthly average TRC or monthly average chronic RNC, WMS will determine if it meets the criteria for non-monthly average TRC. In order for a month to be counted toward the two months necessary for detecting non-monthly average TRC, there must be at least one non-monthly average limit that exceeds the TRC threshold AND, if there are any monthly average limits for the parameter, there must be at least one monthly average limit violation (of any magnitude) during the month. If there are at least two such months, violations of non-monthly averages exceeding the TRC threshold will receive an RNC detection code of R, while all other violations of the same limit will receive an RNC detection code of U. Violations of monthly average limits, while necessary to meet the criteria, will not be marked as RNC. The process is as follows: 1. If parameter SNC group = 1, count the MPED for which:

A. At least one non-monthly average limit has a violation with percent exceedence >= 40% AND B. There are no monthly average limits OR there is at least one monthly average limit effluent violation

2. If parameter SNC group = 2, count the MPED for which:

A. At least one non-monthly average limit has a violation with percent exceedence >= 20% AND B. There are no monthly average limits OR there is at least one monthly average limit effluent violation

3. If there are < 2 MPED meeting the criteria, skip to Step 6, detect non-monthly chronic 4. For MPED in which there are no monthly average limits OR there is at least one monthly average limit effluent

violation:

A. For non-monthly average violations exceeding the TRC threshold, set RNC data as follows:

(1) RNC detection code = R (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

B. For non-monthly average violations NOT exceeding the TRC threshold, set RNC data as follows:

(1) RNC detection code = U (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

5. Continue to Step 7, resolve effluent RNC Tables 6 through 8 show examples of violation sets evaluated for non-monthly average TRC. Q2, C2 and C3 are non-monthly averages, Q1 and C1 are monthly averages, and the parameter is in SNC group 1. Boxes with RNC detected are bolded, boxes with non-monthly average TRC are also shaded.

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Table 6: Example of non-monthly average TRC detection

In Table 6, month 1 meets the criteria due to violations of C1 and Q1, and month 3 meets the criteria due to violations of Q2 and C1. Since two months meet the criteria, the non-monthly average violations exceeding the TRC threshold are assigned RNC detection codes of R, and all other non-monthly average violations are assigned RNC detection codes of U.


In Table 7, months 1 and 3 again meet the criteria, as in Table 6. Despite the violation of C2 exceeding the TRC threshold, month 2 does not meet the criteria because there are monthly average limits and they do not have violations. Therefore, the non-monthly average violations for this month are not detected as RNC. The non-monthly average violations in month 4 are assigned RNC detection codes of U because there are monthly average violations in the month.

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In Table 8, month 1 does not meet the criteria because there are two monthly average limits, one with no data and one with no violation. Month 2 similarly does not meet the criteria, as described in Table 7. Since only month 3 meets the criteria, this set of violations does not qualify as having non-monthly average TRC. Step 6 - Detect non-monthly chronic If a set of violations does not meet the criteria for monthly average TRC, monthly average chronic, or non-monthly average TRC, it will be evaluated for non-monthly average chronic RNC. Similar to non-monthly average TRC, if a month includes monthly average limits, there must be at least one monthly average violation, in addition to a non-monthly average violation, in order for the month to count towards non-monthly average chronic. This means that parameters with monthly averages will never be detected for non-monthly average chronic RNC. To do so would require four months with monthly average violations, in which case the set would already have been detected as monthly average chronic and would not reach this stage of evaluation. For violation sets that include only non-monthly average limits, the process is as follows: 1. Count the MPED in the six-month window for which there is at least one violation of a nonmonthly average

limit 2. If the number of MPED is < 4, skip to Step 7, resolve effluent RNC 3. If parameter SNC group = 1:

A. For non-monthly average violations with percent exceedence >= 40%, set RNC data as follows:


B. For all other non-monthly average violations, set RNC data as follows:

(1) RNC detection code = H (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

4. If parameter SNC group = 2:

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A. For non-monthly average violations with percent exceedence >= 20%, set RNC data as follows:


B. For all other non-monthly average violations, set RNC data as follows:

(1) RNC detection code = H (2) RNC detection date = window end date (3) RNC resolution code = 1 (4) RNC resolution date = RNC detection date

5. Continue to Step 7, resolve effluent RNC Table 9 shows an example of a violation sets where non-monthly average chronic RNC would be detected. Q1, C1 and C2 are now all non-monthly averages, and the parameter is in SNC group 1. Boxes with RNC violations, TRC and chronic, are bolded and shaded.

Table 9: Example of non-monthly average chronic RNC detection

Months 1 through 4 have non-monthly average effluent violations. Since there are no monthly average limits, these months constitute the four required for the set to be detected as nonmonthly chronic RNC. Note that the violation of C1 in month 1 exceeds the TRC threshold and is therefore marked as non-monthly TRC (RNC detection code R). The remaining violations are assigned RNC detection code H for non-monthly chronic. Step 7 - Resolve effluent RNC After evaluating each set of violations for new RNC detection, ICIS-NPDES will automatically resolve RNC. There are two situations in which RNC will be automatically resolved:

No longer meeting criteria: The parameter was previously detected for RNC (using an earlier six-month window), but no longer meets RNC criteria in the current six-month window.

Three months clean data: The set of violations meets TRC criteria in the first three months of the six-month window, but is clean for the last 3 months.

The automatic resolution will include resolving remaining violations from before the window start date.

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The resolution step of the process will not change RNC resolution data for violations that were manually detected or that have already been set to resolved or resolved pending. No longer meeting criteria: This method of resolution applies only to permit limit violations (not violations of enforcement action limits). If a set of violations does not meet the criteria for any of the four types of effluent RNC (monthly average TRC or chronic or non-monthly average TRC or chronic), violations that were previously automatically detected for the same NPDES ID, permitted feature identifier, parameter code, and monitoring location code will be resolved. The RNC resolution data for the previous violations will be set as follows: RNC resolution code = 2 RNC resolution date = window end date Three months clean data:

This method of resolution may apply to either permit limit violations or enforcement action limit violations. Permit limit violations will be set to resolved, while enforcement action limit violations will be set to resolved pending. (Enforcement action limit violations can only be automatically resolved when the source final order is NPDES closed.) For permit limit violations with three months clean data, the RNC resolution data will be set as: RNC resolution code = 2 RNC resolution date = window end date Clean data are defined as DMR data having been received (i.e., not blank or NODI) and having no effluent violations. The clean data requirement is specific to the type of limit for which RNC was detected – if monthly average RNC was detected, all monthly averages in the set of violations must have clean data, if non-monthly average RNC was detected, all non-monthly averages in the set of violations must have clean data. There may be cases where there are multiple limit sets for a given parameter, monitoring location code, and month. In these cases, if one of the limit sets was not received or is all NODI, the month may still count as being clean, provided the other limit set was received. If there are any effluent violations for either limit set, however, the month will not be considered clean. Table 10 through Table 18 show examples of evaluation for three months clean data. As before, Q1 and C1 are monthly averages, Q2, C2 and C3 are non-monthly averages, and the parameter is in SNC group 1.

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Table 10: Example showing three months clean data

In Table 10, months 4, 5, and 6 are clean. All data have been received, and there are no violations.

Table 11: Example without three months clean data

In Table 11, month 5 is not clean due to the NODI for C1. Since this set of violations was detected as monthly average TRC and C1 is a monthly average, there are not three months of clean data, and the RNC resolution code will remain 1 (non-compliant).


In Table 12, month 5 is again not clean, in this case due to the effluent violation of C1.

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In Table 13 month 5 is not clean because DMR data was not received for C1.


In Table 14, month 5 is considered clean, despite the effluent violation of C2, because C2 is a non-monthly average and RNC was detected for monthly average TRC.

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In Table 15, month 5 is considered clean, despite NODI for Q2, C2 and C3 because these are non-monthly average limits and RNC was detected for monthly average TRC.


In Table 16, month 4 is clean because limit set A is clean, even though limit set B is NODI.

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In Table 17, month 4 is clean because limit set A is clean, even though limit set B has nonreceipt and NODI.


In Table 18, month 4 is not clean because of the violation of C1. When there are multiple limit sets, any effluent violation of either limit set prevents the month from being clean. Step 8 – Resolve/resolve pending new RNC through enforcement action

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The final step in the effluent RNC detection process is to resolve any newly detected effluent RNC that have already been linked to enforcement action final orders with compliance schedules. This may occur in cases where the linkage was made before the effluent RNC process was run. For permit limit violations: If an enforcement action final order with a compliance schedule has been linked to a violation AND the final order is NOT NPDES closed, the RNC resolution data will be set as follows: RNC resolution code = 3 (resolved pending) RNC resolution date = issued/entered date of linked final order If a final order linked to a violation has been NPDES closed, the RNC resolution data will be set as follows: RNC resolution code = 5 (resolved) RNC resolution date = NPDES closure date of linked final order For enforcement action limit violations (not applicable to PA): If the source final order of the enforcement action limit that was violated has been NPDES closed, the RNC resolution data will be set as follows: RNC resolution code = 5 (resolved) RNC resolution date = NPDES closed date of source enforcement action 4.4 Automatically Update Effluent RNC Detection Effluent RNC may be updated as part of the effluent violations process that runs when DMR data are modified. Specifically, if data are modified such that RNC criteria are no longer met for previously detected RNC, the RNC data will be set back to blank. For details, see the RNC When E90 Present Process and the TRC Process. 4.5 Manually Detect and Resolve Effluent RNC Users will be able to manually detect and resolve effluent RNC in WMS. WMS will not overwrite manual resolved or resolved pending RNC resolution codes, but it will overwrite manual detection with automatic detection. Manual detection will never be blanked out by WMS. 5.0 PERMIT RNC STATUS GENERATION When determining the compliance status to be listed on the QNCR for an NPDES ID (in the Violations Module of WMS), WMS will do the following: 1. If any violations are non-compliant (RNC resolution code = A OR 1):

A. If the following conditions are met, set Permit RNC status = SNC (S) and STOP:

(1) There are non-compliant violations with violation code = C30 OR C40, AND (2) The RNC detection code = S, AND (3) The event is category 1 OR is from a judicial final order

B. If there are non-compliant violations with violation code = E90 AND they are NOT percent removal

parameters:

(1) If the RNC detection code = (A, C, T, V, X, Y, OR Z), set Permit RNC status = SNC (E) and STOP (2) If the RNC detection code = (P, H, R, U, OR D), set Permit RNC status = SNC (X) and STOP

C. If there are non-compliant single event violations AND the RNC detection code = (G, I, J, OR B), set

Permit RNC status = SNC (E) and STOP

34

D. If the following conditions are met, set Permit RNC status = SNC (T) and STOP:

(1) There are non-compliant violations with violation code = C40, AND (2) The event type = R (report), AND (3) The event category = 1

E. If there are non-compliant whole permitted feature DMR non-receipt violations, set Permit RNC status =

SNC (D) and STOP F. Set Permit RNC status = RNC (N) and STOP

2. If NO violations are non-compliant (RNC resolution code = A, 1, OR W):

A. If any violations are resolved pending (RNC resolution code = 3, 4, 7, OR 8), set Permit RNC status = resolved pending (P) and STOP

B. If any violations are resolved (RNC resolution code = 2, 5, 6, 9, B, OR T) AND (quarter start date <= RNC resolution date <= window end date), set Permit RNC status = resolved (R) and STOP

C. Set Permit RNC status = blank and STOP Users will be able to enter a manual QNCR status for a permit. If a manual status is entered before the official QNCR has been run for a quarter, the manual status will override the automatic status for the quarter. After the official QNCR has been run for a quarter, users will only be able to update the corrected manual Permit RNC status. 6.0 SINGLE EVENT VIOLATIONS Single Event violations will be recorded on Non-Compliance Reporting Forms and submitted as part of DMR Submissions (or as standalone Non-Compliance submissions). Facilities will be required to select a Single Event Violation Code (derived from EPA) on the screen. When a code is selected, it is automatically deemed a “DEP Violation”. Users may, in the Violation Details screen of the WMS Violations Module, manually set the violation to RNC Status, which will also make the violation an “EPA Violation”, and will be picked up for upload to EPA.

Detailed Business Requirements for eDMR/WMS July 2011

Appendix A – Current List of ICIS Violation Codes

Status Flag

Violation Code Violation Desc

Violation Group Code

A D80 DMR, Monitor Only - Overdue DMR

A D90 DMR, Limited - Overdue DMR

A E90 DMR, Limited - Numeric Violation EFF

I M40 MANUAL NO RECEIVED VIOLATION MAN

A C10 Schedule Event reported late SCH

A C20 Schedule Event achieved late but reported SCH

A C30 Schedule Event unachieved but reported SCH

A C40 Schedule Event unachieved and not reported SCH

I M00 Manual Schedule Violation (Generic) SCH

I M10 Manual Reported Late Violation SCH

I M20 Manual Achieved Late Violation SCH

I M30 Manual Unachieved Violation) SCH

A A0011 Effluent Violations - Unapproved Bypass SEV

A A0012 Effluent Violations - Numeric effluent violation SEV

A A0013 Effluent Violations - Failed Toxicity Test SEV

A A0014 Pretreatment - IU Violation of Pretreatment Standards SEV

A A0015 Effluent Violations - Unauthorized Discharge SEV

A A0016 Effluent Violations - Reported Fish Kill SEV

A A0017 Effluent Violations - Inspection sample above historic DMR range SEV

A A0018 Effluent Violations - Approved Bypass SEV

A A0019 WW CAFO - Production Area Runoff SEV

A A0020 WW SSO - Discharge to Waters SEV

A A0021 WW CSO - Unauthorized CSO Discharge to Waters/Wet Weather SEV

A A0022 Effluent Violations - Narrative Effluent Violation SEV

A A0023 Effluent Violations - Industrial Spill SEV

A A0024 WW CSO - Dry weather overflow SEV

A A0025 WW CSO - Effluent Violations - O&M viol resulting in unauth spills/overflows to dry land/bldg backup SEV

A A0026 WW SSO - Overflow to Dry Land or Building Backup SEV

A A0A12 WW CAFO - Numeric effluent violation SEV

A A0A22 WW CAFO - Narrative effluent violation SEV

A A0C11 WW CSO - Related Unapproved Bypass SEV

A A0C12 WW CSO - Numeric effluent violation SEV

A A0C18 WW CSO - Approved Bypass SEV

A A0C22 WW CSO - Narrative effluent violation SEV

A A0M12 WW Storm Water MS4 - Numeric Effluent Violation SEV

A A0M22 WW Storm Water MS4 - Narrative effluent violation SEV

A A0N12 WW Storm Water Non-Construction - Numeric Effluent Violation SEV

A A0N22 WW Storm Water Non-Construction - Narrative effluent violation SEV

A A0R12 WW Storm Water Construction - Numeric Effluent Violation SEV

A A0R22 WW Storm Water Construction - Narrative effluent violation SEV

A A0S11 WW SSO - Related Unapproved Bypass SEV

A A0S12 WW SSO - Numeric effluent violation SEV

A A0S18 WW SSO - Approved Bypass SEV

A A0S22 WW SSO - Narrative effluent violation SEV

36

Status Flag



A B0011 Management Practice Violations - Failure to Develop/Enforce Standards SEV

A B0012 Management Practice Violations - Failure to Conduct Inspections SEV

A B0013 Pretreatment - Failure to Enforce Against I/U SEV

A B0014 Pretreatment - Failure to Issue SIU Permits SEV

A B0015 Pretreatment - Failure to Establish Local Limits SEV

A B0016 Pretreatment - Failure to Meet Inspection and Sampling Plan for SIUs SEV

I B0017 Management Practice Violations - Failure to develop any or adequate SWPPP/SWMP SEV

I B0018 Management Practice Violations - Failure to Implement SWPPP/SWMP SEV

A B0019 Management Practice Violations - Best Management Practice Deficiencies SEV

A B0020 Management Practice Violations - Improper Operation and Maintenance SEV

A B0021 Management Practice Violations - Laboratory Not Certified SEV

A B0022 Management Practice Violations - No Licensed/Certified Operator SEV

A B0023 Management Practice Violations - Improper Land Application (non-503 non-CAFO) SEV

A B0024 Management Practice Violations - Biosolids/Sewage Sludge Violation (Part 503 and State Regulations) SEV

A B0025 Management Practice Violations - Inflow/Infiltration (I/I) SEV

A B0026 Management Practice Violations - Failure to Allow Entry SEV

A B0027 Management Practice Violations - Failure to Develop Adequate SPCC Plan SEV

A B0028 Management Practice Violations - Failure to Implement SPCC Plan SEV

I B0029 WW CSO - Failure to Implement Nine Minimum Controls (NMCs) SEV

A B0030 WW CSO - Management Practice Violations - Failure to Develop or Submit Adequate LTCP SEV

A B0031 WW CSO - Failure to Implement LTCP SEV

A B0032 WW CAFO - Management Practice Violations - Failure to Develop or Update NMP SEV

A B0033 WW CAFO - Management Practice Violations - Deficiencies in Implementing the NMP/ permit SEV

A B0034 WW CAFO - Insufficient Buffers/Setbacks SEV

A B0035 WW CAFO - Insufficient Storage Capacity SEV

A B0036 WW CAFO - Management Practice Violations - Improper O&M SEV

A B0037 WW CAFO - Improper Mortality Management SEV

A B0038 WW CAFO - Direct Animal Contact with Waters of US SEV

A B0039 WW CAFO - Management Practice Violations - Improper Waste Management, excluding land

application SEV

A B0040 Management Practice Violations - Improper Chemical Handling SEV

A B0041 Management Practice Violations - Failure to Maintain Records SEV

A B0042 Management Practice Violations - Violation of a milestone in an order SEV

A B0043 WW CAFO - Management Practice Violations - Fail to inform permit authority of significnt NMP

changes SEV

A B0044 WW CSO - LTCP implementation schedule milestone missed SEV

A B0045 WW CSO - Violation of a milestone in a permit SEV

A B0046 WW SSO - Violation of sewer moratorium or restriction SEV

A B0A12 WW CAFO - Management Practice Violations - Failure to Conduct Self Inspections SEV

A B0A19 WW CAFO - Best Management Practice Deficiencies SEV

A B0A23 WW CAFO - Management Practice Violations - Fail to Implemnt Land App BMPs,excluding

buffers/setbacks SEV

A B0A40 WW CAFO - Improper Chemical Handling SEV

A B0A41 WW CAFO - Failure to Maintain Records or Meet Record Keeping Requirements SEV

A B0A42 WW CAFO - Management Practice Violations - Viol. of a milestone or final compliance date in an order SEV

A B0C17 WW Storm Water Construction - Failure to develop any or adequate SWPPP/SWMP SEV

A B0C18 WW Storm Water Construction - Failure to Implement SWPPP/SWMP SEV

A B0C41 WW CSO - Failure to Maintain Records or Meet Record Keeping Requirements SEV

A B0C42 WW CSO - Violation of a milestone in an order SEV

A B0M12 WW Storm Water MS4 - Failure to Conduct Inspections SEV

37

Status Flag



A B0M17 WW Storm Water MS4 - Failure to develop any or adequate SWPPP/SWMP SEV

A B0M18 WW Storm Water MS4 - Failure to Implement SWPPP/SWMP SEV

A B0M41 WW Storm Water MS4 - Failure to Maintain Records or Meet Record Keeping Requirements SEV

A B0M42 WW Storm Water MS4 - Violation of a milestone in an order SEV

A B0N12 WW Storm Water Non-Construction - Failure to Conduct Inspections SEV

A B0N17 WW Storm Water Non-Construction - Failure to develop any or adequate SWPPP/SWMP SEV

A B0N18 WW Storm Water Non-Construction - Failure to Implement SWPPP/SWMP SEV

A B0N41 WW Storm Water Non-Construction - Failure to Maintain Records SEV

A B0N42 WW Storm Water Non-Construction - Violation of a milestone in an order SEV

A B0P11 Pretreatment - Failure to Develop/Enforce Standards SEV

A B0P12 Pretreatment - Failure to Conduct Inspections SEV

A B0P40 Pretreatment - Improper Chemical Handling SEV

A B0R12 WW Storm Water Construction - Failure to Conduct Inspections SEV

A B0R41 WW Storm Water Construction - Failure to Maintain Records SEV

A B0R42 WW Storm Water Construction - Violation of a milestone in an order SEV

A B0S20 WW SSO - Improper Operation and Maintenance SEV

A B0S41 WW SSO - Failure to Maintain Records or Meet Record Keeping Requirements SEV

A BC291 WW CSO - Failure to implement required NMC #1(Proper operation and maintenance) SEV

A BC292 WW CSO - Failure to implement required NMC #2 (Maximum use of the collection system) SEV

A BC293 WW CSO - Failure to implement required NMC #3 (Review pretreatment requirements) SEV

A BC294 WW CSO - Failure to implement required NMC #4 (Maximization of flow) SEV

A BC295 WW CSO - Failure to implement required NMC #5 (Elimination of dry weather flow) SEV

A BC296 WW CSO - Failure to implement required NMC #6 (Control of solids) SEV

A BC297 WW CSO - Failure to implement required NMC #7 (Pollution prevention programs) SEV

A BC298 WW CSO - Failure to implement required NMC #8 (Public notification) SEV

A BC299 WW CSO - Failure to implement required NMC #9 (Monitoring) SEV

A BM19A WW Storm Water MS4 - Failure to properly install/implement BMPs SEV

A BM19B WW Storm Water MS4 - Failure to properly operate and maintain BMPs SEV

A BN19A WW Storm Water Non-Construction - Failure to properly install/implement BMPs SEV

A BN19B WW Storm Water Non-Construction - Failure to properly operate and maintain BMPs SEV

A BR19A WW Storm Water Construction - Failure to properly install/implement BMPs SEV

A BR19B WW Storm Water Construction - Failure to properly operate and maintain BMPs SEV

A BS42A WW SSO - Violation of milestone in an administrative order SEV

A BS42J WW SSO - Violation of milestone in judicial decree SEV

A C0011 Monitoring Violations - Failure to Monitor for Non-Toxicity Requirements SEV

A C0012 Pretreatment - Baseline Monitoring Report Violation SEV

A C0013 Pretreatment - Failure to Establish Self-Monitoring Requirements SEV

A C0014 Monitoring Violations - Invalid/Unrepresentative Sample SEV

A C0015 Monitoring Violations - Frequency of Sampling Violation SEV

A C0016 Monitoring Violations - No Flow Measurement Device SEV

A C0017 Monitoring Violations - Analysis not Conducted SEV

A C0018 Monitoring Violations - Improper Analysis or Lab Error SEV

A C0019 WW CAFO - Monitoring Violations - Failure to Test Manure or Soil, as Required SEV

A C0020 WW CAFO - Monitoring Violations - No Depth Marker in Storage Pond SEV

A C0021 Monitoring Violations - Failure to Monitor for Toxicity Requirements SEV

A C0A11 WW CAFO - Failure to Monitor SEV

A C0C11 WW CSO - Failure to monitor SEV

A C0M11 WW Storm Water MS4 - Failure to Monitor SEV

A C0N11 WW Storm Water Non-Construction - Failure to Monitor SEV

38

Status Flag



A C0R11 WW Storm Water Construction - Failure to Monitor SEV

A C0S11 WW SSO - Failure to monitor SEV

A D0011 Permit Violations - Discharge Without a Valid Permit SEV

A D0012 Permit Violations - CWA §308 Failure to submit required permit application information SEV

A D0013 Permit Violations - Unapproved Operation SEV

A D0014 Permit Violations - Application Incomplete SEV

A D0015 Permit Violations - Failure to Pay Fees SEV

A D0016 Permit Violations - Failure to Submit Timely Permit Renewal Application SEV

A D0017 Permit Violations - Violation Specified in Comment SEV

A D0A11 WW CAFO - Discharge without a permit SEV

A D0A12 WW CAFO - Permitting Violations - Failure to submit required permit application or identifying info SEV

A D0M11 WW Storm Water MS4 - Discharge without a permit SEV

A D0M12 WW Storm Water MS4 - CWA §308 Failure to submit required permit application information SEV

A D0N11 WW Storm Water Non-Construction - Discharge without a permit SEV

A D0N12 WW Storm Water Non-Construction - CWA §308 Failure to submit required permit application info SEV

A D0N18 WW Storm Water Non-Construction - Failure to apply for a notice of termination SEV

A D0R11 WW Storm Water Construction - Discharge without a permit SEV

A D0R12 WW Storm Water Construction - CWA §308 Failure to submit required permit application information SEV

A D0R18 WW Storm Water Construction - Failure to apply for a notice of termination SEV

A D0S11 WW SSO - Discharge without a valid permit (includes satellite systems) SEV

A D0S12 WW SSO - CWA §308 Failure to submit required permit application info (includes satellite systems) SEV

A E0011 Reporting Violations - Late Submittal of DMRs SEV

A E0012 Reporting Violations - Failure to Submit DMRs SEV

A E0013 Reporting Violations - Improper/ Incorrect Reporting SEV

A E0014 Reporting Violations - Noncompliance with Section 308 Information Request SEV

A E0015 Pretreatment - Failure to submit required report (non-DMR) SEV

A E0016 Reporting Violations - Failure to submit required report (non-DMR non-pretreatment) SEV

A E0017 Reporting Violations - Failure to Notify SEV

A E0018 WW SSO - Failure to report other violation SEV

A E0019 WW SSO - Failure to report violation that may endanger public health 122.41(l)(7) SEV

A E0A13 WW CAFO - Improper/Incorrect reporting SEV

A E0A14 WW CAFO - Noncompliance with section 308 Information Request SEV

A E0A16 WW CAFO - Reporting Violations - No Annual Report or Other Required Report Submitted SEV

A E0C13 WW CSO - Improper/Incorrect reporting SEV

A E0C14 WW CSO - Noncompliance with section 308 Information Request SEV

A E0C16 WW CSO - Failure to submit required report (non-DMR) SEV

A E0M14 WW Storm Water MS4 - Noncompliance with section 308 Information Request SEV

A E0M16 WW Storm Water MS4 - Failure to submit required report (non-DMR) SEV

A E0N14 WW Storm Water Non-Construction - Noncompliance with section 308 Information Request SEV

A E0N16 WW Storm Water Non-Construction - Failure to submit required report (non-DMR) SEV

A E0R14 WW Storm Water Construction - Noncompliance with section 308 Information Request SEV

A E0R16 WW Storm Water Construction - Failure to submit required report (non-DMR) SEV

A E0S14 WW SSO - Noncompliance with section 308 Information Request SEV


Appendix B – Current List of ICIS RNC Detection Codes

Detection Type Code

Rnc Detection

Code

Rnc Detection Code Entry

Flag Rnc Detection Desc Status Flag CHR C A Chronic Violation A

CHR H A Chronic Violation, Non-Monthly Average A

CHR Z M Manual Chronic A

DIS B M Manual 2A4 - Pass-Through A

DIS D M Manual Other A

DIS E M Manual 2F - Permit Narrative A

DIS F M Manual 2G - Violation of Concern A

DIS G M Manual 2A1 - Effluent Violation A

DIS I M Manual 2A2 - Unauthorized Bypass A

DIS J M Manual 2A3 - Unpermitted Discharge A

DIS Q M Manual 2B - Pretreatment A

DIS W M Manual 2E - Deficient Report A

EFF U A Other Violation with TRC Non-Monthly Average A

EFF V A Other Violation with TRC A

EFF X M Manual Other Violation with TRC A

ENF A A Enforcement Order A

ENF P A Enforcement Order, Non-Monthly Average A

RPT K A Non-receipt Violation, Non-Monthly Average A

RPT N A Non-Receipt of DMR/Schedule Report A

SCH S A Schedule Violation A

TRC R A TRC Limitations Exceeded, Non-Monthly Average A

TRC T A TRC Limitations Exceeded A

TRC Y M Manual TRC A


Appendix C – Current List of ICIS RNC Resolution Codes

Rnc Resolution

Code Rnc Resolution

Code Entry Rnc Resolution Desc

Rnc Status Category

Code Status Flag

1 Auto NC - Unresolved RNC NC A

2 Auto RE - Back into Compliance RE A

3 Auto RP - Due to Formal Enforcement Action Final Order with Compliance

Schedule RP A

4 Auto RP - In Compliance with Formal Enforcement Action Final Order Requirement RP A

5 Auto RE - Resolved RP by NPDES Closure of Enforcement Action Final Order with

Compliance Schedule RE A

6 Manual RE - Manual Resolution by Enforcement Action RE A

7 Manual RP - Manual RP - In Compliance with Formal Enforcement Action Order

Requirement RP A

8 Manual RP - Manual Due to Formal Enforcement Action Formal Order RP A

9 Manual RE - Manual by Back into Compliance RE A

A Manual NC - Manual Unresolved RNC NC A

B Manual RE - Manual by EPA/State/Tribal Action RE A


Appendix D – Current List of ICIS RNC Status and Status Category Codes

Ref_RNC_Status

Rnc Snc Flag

Rnc Status Category Code

Rnc Status Code Rnc Status Desc Status Flag

R CO C Compliant (Manual Only) A

R NC N RNC Violations Only A

R RE R Resolved A

R RP P Resolved Pending A

R RP Q Resolved Pending - Compliance Schedule

(manual only) A

S NC D SNC DMR Non-Receipt Violation A

S NC E SNC Effluent Violation Monthly Average A

S NC S SNC Schedule Event Violation A

S NC T SNC Schedule Report Violation A

S NC X SNC Effluent Violation Non-Monthly Average A

Ref_RNC_Status_Category

Rnc Status Category Code

Rnc Status Category Desc

Status Flag

CO Compliant A

NC Noncompliant A

RE Resolved A

RP Resolved Pending A

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