Limit Sets Welcome to the Limit Set on-line training module. Prior to reviewing this module, you should have completed the Permitted Feature module first. Remember there is a specific order when entering the permit limit data into ICIS. First step is the permitted feature, second is the limit sets and third is to add the parameter limits.

Limit Sets Defined Limit Sets - groups monitoring & reporting requirements for each Permitted Feature Limit Sets typically apply during particular operating conditions such as: Summer vs Winter High production volume vs low production volume Frequency of reporting (monthly, quarterly, yearly, etc) Limit Sets define Discharge Monitoring Reports (DMRs) What date range will be covered on the DMR form When the first DMR will begin when the DMRs are due to the Agency The purpose of the Limit Sets is to group the monitoring and reporting requirements for each permitted feature based on the permit requirements. Limit Sets typically apply during particular operating conditions such as: summer versus winter months, and high production volume versus low production volume. In addition often times there are different frequencies of reporting, such as monthly, quarterly, semi-annual, yearly, A different limit set is created for each group. For instance canning vegetables – during the growing and canning season the limits would be different than low production time. A limit set will define the Discharge Monitoring Reports (DMRs). Data entered on the limit set determines what date range will be covered on the DMR form, when the first DMR will begin for that limit set, and when the DMRs are due to the Agency.

Limit Set Example 001 has monthly, quarterly, and yearly requirements Create 3 Limit Sets - For Expected DMRs and Generation of Violations Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec X X X X X X X X X X X X Monthly X X X X Quarterly X Yearly We will illustrate how the limit sets would be set up for Permitted feature 001 when the limits have requirements for monthly, quarterly, and yearly reporting. If you put all the parameters on one big limit set, you will get invalid non-reporting violations that will appear on the Internet and may be displayed on the Quarterly noncompliance report. When a facility has monthly reporting, a DMR must be submitted every month and if it is not submitted a non-receipt violation will be generated which is accurate. In the case of a quarterly DMR, generally they would have 4 DMR forms due in a year, and the DMR timeframe many times follow the calendar quarters. For instance, they would have a DMR from January 1st thru March 31st and another DMR from April 1st thru June 30th, etc. The facility would get valid non-reporting violations if any of the four quarterly DMRs were not submitted. However, if the quarterly requirements are combined with the monthly requirements on one limit set, all parameters would be expected monthly which is not accurate. The parameters that are required to be reported quarterly instead of monthly would get 8 months of invalid violations for failing to report the data every month. If you have a quarterly DMR from January 1 thru March 31st, the monitoring period end date is the date used for the DMR data entry, which in this case is March 31st. Invalid violations would appear for the months of January and February if you had put the requirements in one large monthly limit set. In the case of an annual requirement where they only have to submit one DMR from January 1st thru December 31st, if you group the limits in one monthly limit set, this facility would have invalid non-receipt violations for 11 months. The DMRs only need to be keyed for the end date of December 31st. For our example above, 3 limit sets should be created. One for monthly, one for quarterly and one for yearly requirements.

Actual Permit Language General Foods, Permitted Feature 001 Let’s review the permit requirements for Permitted Feature 001 in our General Foods permit. Are there any parameters that require samples taken monthly, weekly, or daily. If so, we will need to create a limit set for monthly reporting. Yes, Flow, Cbod, TSS, etc. Are there other requirements for bi-monthly, quarterly, semi-annual, or yearly? Yes, quarterly requirements for lead and copper. We will need to create a limit set for quarterly reporting also. You will need to be careful because there are parameter requirements in the sentences at the bottom of this page and there are also parameter requirements in the “Special Conditions” of this permit. We will set up our two limit sets a little later on. One for monthly reporting and the other for quarterly reporting. In addition, we will need to review our INFL permitted feature to see what limit sets need to be created.

Types of Limit Sets There are two types of Limit Sets Traditionally, Limit Sets are Scheduled DMRs are expected on a predictable basis Non-Receipt Violations are generated when 30 days late There are two types of Limit Sets available, scheduled and unscheduled. The traditional limit sets are the scheduled ones. This means the DMRs are expected on a predictable basis, every month, every quarter, etc. The permit requires the DMR by a specific date and non-receipt violations are generated when the DMRs are overdue. Almost all limits in the database are scheduled limit sets.

Unscheduled Limit Sets Special Regulatory Programs may need Unscheduled Limit Sets DMRs are entered on an as-received basis There is no DMR Due Date DMR Non-Receipt Violations are never generated Unschedule Limit Sets support the variable reporting needs of the Storm Water, Biosolids, and other programs Appropriate for event-based reporting, rather than a continuous discharge ICIS has the ability to track unscheduled DMRs. The Special Regulatory programs such as storm water may need unscheduled limit sets. DMRs may be due when certain conditions are met and a specific due date is not known. The DMRs are entered on as as-received basis, there is no DMR due date, and DMR non-receipt violations are never generated. Unscheduled limits sets can support the reporting needs of Storm Water, Biosolids, and other programs. The DMRs are event-based reporting rather than a continuous discharge.

Unscheduled Limit Sets Comparison Chart Scheduled Limit Sets Unscheduled Limit Sets Number of Report Units Number of Submission Units Modification Effective Date Initial Monitoring Date Modification Type Initial DMR Due Date You can see that there are more fields for scheduled limit sets than for unscheduled limit sets.

Expected DMRs Using Limit Set (and Limit) data, ICIS-NPDES creates an Expected DMR Schedule Allows users to see the expected discharge activity Aids in validation of submitted DMR data Scheduled Limit Sets get an Expected DMR Schedule when at least one Limit has been added to the Limit Set Expected DMRs are created one-at-a-time as they are received for Unscheduled Limit Sets The Expected DMR Schedule will be discussed more during the Limits and DMR units The Limit Set along with at least one parameter limit requirement are used to create Expected DMRs in ICIS. You will be able to view the expected DMRs and this will aid in the validation that DMR data was submitted. For unscheduled limit sets, the expected DMRs are created one at a time as the DMR data is received. We will be discussing expected DMR schedules later in other modules.

Limit Set Decision Making General Foods Permit Should we set up limit sets for “Scheduled” or “Unscheduled” Limit Sets? Do you know how often they should sample (monthly, quarterly? Both – monthly and quarterly are the DMRs due on a specific date? (check permit) Yes. “no later than the 15th of the following month” Scheduled or Unscheduled? Scheduled For our sample General Foods permit, should we create scheduled or unscheduled limit sets? Ask yourself these questions… Do you know how often they should sample, monthly, quarterly, yearly, etc. The answer is both monthly and quarterly for General Foods. Are the DMRs due on a specific date? Take a minute to review the Special Conditions in the permit to locate a DMR due date. After reviewing the General Foods permit we found that the DMRs are due “no later than the 15th of the following month”. So do we need scheduled or unscheduled limit sets? For General Foods we need scheduled limit sets.

Example of Report Units Example of an actual permit with different reporting frequencies This is an actual permit with different reporting frequencies. One for monthly, 3 for quarterly, 6 for semi-annual, and 12 for yearly DMRs.

Limit Set Data Entry Let’s get into the details of entering the limit set information.

Limit Set Screen The Limit Set Screen captures the following information Limit Set Information Limit Set Designator Default Months Limit Set Applies Status information Schedule information DMR Pre-print information User Defined Fields Default Statistical Base Codes The Limit Set Screen captures information which includes the permitted feature id, limit set designator and the default months that the limit set applies. In addition, the Status information, schedule information, DMR pre-print information, user defined fields, and the default Statistical Base Codes fields are also available.

Accessing Limit Sets from Permitted Feature From the Permitted Feature hyperlink Limit Sets To enter limit sets the permitted feature must exist in the database. The best way to enter the limit set is to be on the Permitted Feature hyperlink, and for the limit set that you are ready to enter limits for, click the limit sets icon on the right. If the permitted feature is not displayed, you will have to add the permitted feature first before moving forward.

Accessing from Limit Set Hyperlink From the Limit Set hyperlink Another way to enter the limit sets is from the Limit Sets hyperlink. Decide if you want to enter scheduled, unscheduled, or to copy a limit set. For General Foods, we will click on the Add scheduled limit set hyperlink.

Fields Required to be Entered Permitted Feature will have to be manually entered If you choose to enter your data this way, you will be required to type in the Permitted Feature. Remember the permitted feature must exist in the database before you can create the limit set and you must type it in exactly as it exists in ICIS. Note the required fields have a asterisk.

Limit Set Unique Data Elements Individual Limit Sets are unique according to the following data elements NPDES ID Permitted Feature Identifier Limit Set Designator (can be 1-2 characters, alphanumeric) Users are also able to name Limit Sets; the Limit Set Name is pre-printed on DMRs Individual limit sets are unique according to the following data elements. The 9 digit NPDES id. The permitted feature id is unique and you can now enter 3 or 4 characters. The Limit Set designator is now a two character field. In our legacy database, this was a one character field and many states and regions used the naming convention of “A” or “M” for monthly requirements, “Q” for quarterly requirements, “Y” for annual requirements. This field is now more flexible and you no longer need the designations as they have been used in the past although some states or regions are still using the same naming convention. It is important to know that you can change a limit set from monthly, to quarterly, and back to monthly during the lifetime of the permit. So the M and Q limit set designators wouldn’t be useful information. We recommend that you look to see how your limits are being coded at your agency to determine the limit set designator. This is a required field. The Name field is available so that you can name your limit sets and it will be displayed on the preprinted DMR form.

Default Months The default is “all months” checked The months checked on the Limit sets do not have to match the individual parameter limits Essentially the seasons on the parameter limits will override the ones on the limit set The default for the seasonal months is all months checked. The months checked on the Limit Set do not have to match the individual parameter limit seasons that are checked. Essentially the seasons on the parameter limits will override the ones on the limit set. There is one important detail we will mention where the seasons on the Limit Set may be impacting the way the DMR forms are being printed. Rather than displaying a full quarter on the DMRs from January 1 thru March 31 st, the quarter is showing as March 1 st thru March 31 st. It is important that January, February and March be checked on the Limit Sets in order for the full quarter to print correctly.

Default Months Seasonal Seasonal limits (i.e. Winter/Summer) As a data entry convenience, users may select default months that the Limit Set applies When coding the parameter limits the months selected below will be the default for each parameter limit Edits to Limit Set Months do not trickle down to already existing Limit Months You may have requirements in your permit for the winter months and another set of limits for the summer months. Suppose there are 25 parameters required for the winter months. It is inefficient for you to have to uncheck the months of March thru August for all 25 parameters so only the winter months are selected. As a data entry convenience, users may select the default months at the Limit Set level and in this case October thru February will be the default as you add the new parameter limits. This is the main benefit of the limit set to allow the user to set the default months for the parameter limits. If your limit set and parameter limits had all 12 months checked (which is the default) and the parameter limit record was saved, and then you realized that only the months of October or February should be checked, the parameter limit seasons must be modified. How do you handle this situation. You may decide to make the change to the limit sets in hopes that the months on the parameter limits would automatically trickle down. The system does NOT have this feature, it will be necessary for you to go into each parameter limit (25) to make the season changes. I would not bother changing the limit sets, go straight to the 25 parameters that need to be changed.

Limit Set and Compliance Tracking Status Limit Set Status gives users the ability to turn a Limit Set on or off for violation generation for a period of time Active (default) Inactive Like Compliance Tracking Status on the Permit, users can enter multiple Limit Set Statuses The limit set status enables the user the ability to turn on and off a specific limit set and violations will not be generated during that time. For instance in the case of a hurricane the wastewater treatment plant may be inoperable for a specific time frame. In other situations, the facility may be in operation, however this one particular discharge point was closed off and is no longer in operation. If the permit is terminated, some users have decided to change the limit sets to inactive for every limit set rather than terminate a permit especially if there is a chance the facility will come back into operation at a later date. Termination is final and once the permit is terminated, you will not be able to use the permit number again.

Schedule Data Fields Schedule Data include Number of Report Units Number of Submission Units Initial Monitoring Date Initial DMR Due Date Modification Effective Date Modification Type The schedule data includes the number of report units, number of submission units, initial monitoring date, initial DMR due date, modification effective date, and the modification type. Let’s look at the fields in the ICIS database.

Schedule Data Fields Schedule Data define the monitoring and reporting requirements for a Limit Set These fields are very important in ensuring that violations are generated accuracy and DMRs are for the correct timeframes Invalid non-receipt violations The schedule data defines the monitoring and reporting requirements for a limit set. These fields are very important in ensuring that violations are generated correctly, and that the DMRs empty slots are created for the correct timeframe. If invalid non-reporting violations are being generated, this is the first place I look to figure out what has happened. Notice the asterisks that identify the required fields.

General Foods Example Back to our General Foods example.

Actual Permit Example Let’s enter our Limit Sets for General Foods 001 A Monthly 001 Q Quarterly From our previous discussion we decided that we need 2 scheduled limit sets. We will use limit set 001 A for our monthly requirements and 001 Q for our Quarterly requirements. What other information do we need from the permit to get started. When do they start reporting their DMRs, when are the DMRs due and is the quarterly DMR on calendar quarters or do I just use the effective date of this permit? What happens if my permit is issued in the middle of a quarter? Do I back up the dates to get that DMR or do I wait until the first full quarter to require them to fill out a DMR?

Number of Report Units Number of Report Units The number of months covered by the DMR form (e.g., Number of Report Units = 3 reflects quarterly, 3-month long DMRs) Always measured in months General Foods Permit 001 A – what is the # of Report Units? The first required field in the schedule is the number of report units. Basically this means how many months will be covered on that DMR form. For instance the number of report units equal to 1 means a DMR will be for one month and a report unit equal to 3 means the DMR will cover 3 months, such as January, February and March. What is the number of report units for the monthly requirements for 001 A. That’s correct, 1. 1

Number of Submission Units The number of months DMR are submitted (e.g., Submission Units = 6 means submit DMR(s) every 6 months, = 3 means submit DMR(s) every 3 months Must be greater than or equal to Number of Report Units Must be evenly divisible by the Number of Report Units General Foods Permit – What is the submission units? We are still working on limit set 001 A. The number of submission units is the number of months submitted. Generally if a facility has a monthly requirement and they are required to mail each DMR monthly, then the answer is 1. If the facility has a monthly DMR, but the permit allows them to mail 3 DMRs on a quarterly basis, then the number of report units would be 1 for monthly DMRs and the number of submission units would be 3. Usually if it is semi-annual 6 months are on the DMR form and when they mail the DMR in it covers a 6 month period. What is the submission units for 001 A – General Foods? You are correct. The DMRs will be mailed monthly. 1 1

Initial Monitoring Date The date at which monitoring begins for the Limit Set Always begin on the 1° day of the month The initial monitoring date is the date on which monitoring begins for this specific limit set. The initial monitoring date must always be on the 1st day of the month. If you put the 15th of the month, you DMRs will say the 15th to the 14th of the next month and will cross over 2 months. Based on the permit for General Foods when would they start reporting the monthly requirements on a DMR form? Check your important permit dates that are displayed on this screen. When would the facility have to start reporting their monthly DMRs. July 1, 2012. 1 1 07/01/2012

Initial Monitoring Date Initial DMR Due Date The date that the first DMR for the Limit Set is due to the regulatory authority Must be greater than or equal to the Initial Monitoring Date + the Number of Submission Units For example, if a DMR starts monitoring on June 1st, and Number of Submission Units = 2, the Initial DMR Due Date must be greater than or equal to August 1st The initial DMR due date is the date the first DMR for that particular limit set is due to the regulatory authority. There is a business rule that says the initial DMR due date must be greater than or equal to the initial monitoring date and the number of submission units. For example, if a DMR starts monitoring their data on June 1st, and the number of submission units is equal to 2, the initial DMR due date must be greater than or equal to August 1. The DMR form will have June 1st thru July 31st and the DMR ending July 31st would not be due until the next month. 1 1 07/01/2012

Initial Monitoring Date General Foods Initial DMR Due Date? When is the July 2012 DMR due to your Agency? You can refer to the General Foods permit to figure out the initial DMR due date. If you take a look at Special Condition 9, you will see when the DMRs are due to the agency. In our example, General Foods will begin submitting DMRs with the July 2012 DMR and must mail the DMR in “no later than the 15th of the following month” , the DMR due date would be Aug. 15, 2012. 1 1 07/01/2012 08/15/2012

Initial Monitoring Date Initial Monitoring Date (IMD) can occur before the Permit Effective Date of the permit Business Rule - first DMR end date must be on or after the effective date of the permit Examples for Permit Effective Date of Sept 1, 2013 Monthly DMRs start 9/1/13 (IMD = 9/1/13) Quarterly DMRs for period July – Sept (IMD = 7/1/13 or 10/1/13) Semi-Annual DMRs for July – Dec (IMD = 7/1/13 or 01/01/14) Yearly DMR for Jan thru Dec (IMD = 1/1/2013 or 1/1/2014) We will spend a couple minutes discussing scenarios where the effective date of the permit is in the middle of a quarter, semi-annual or yearly reporting cycle. When the permit is effective in the middle of a cycle you have to decide when is that first DMR due. For the monthly DMRs it is very easy, effective September 1, 2013, first DMR is for September 2013. However let’s say your permit specially says that the DMRs must be submitted on calendar quarters, January thru March, April thru June, etc. The quarter the September DMR falls in is July thru September. We need to decide if the DMR data should come in for that one month or not. Let’s say the permit requirements are exactly the same and we do not want to miss the DMR for July thru September. In order for the DMRs and monitoring requirements to be set correctly, you will have to back up the monitoring period start date to July 1, 2013. On the preprinted DMR that is mailed, that one DMR will say Sept 1 st thru Sept 30 th and all future DMRs will be on the calendar quarters. If the permit does not mention calendar quarters, use the start date of Sept. 1 st and the first DMR will be for September thru November. However on the other hand if this limit set is new or has several different reporting requirements, it is not fair to require them to sample in the month of September when the permit allows them to take a quarterly sample. You will need to set the initial monitoring date to October 1, 2013 so the first full quarterly DMR will be for the October thru December timeframe. The same situations apply to bi-monthly, semi-annual, and yearly reporting. The initial monitoring dates in blue show the 2 choices you have to start the DMRs.

Modification Fields Original permit contains a change to the limits during the life of the permit Referred to as modified limits i.e. when construction is completed and plant expanded, limits will be modified to meet the new conditions Modified permit can be issued Original eff 7/1/2012 exp 6/30/2017 Modified eff 4/1/2014 exp 6/30/2017 The original permit may contain a change of limits during the life of the permit. These are referred to as modified limits. For instance when construction is completed and the plant has expanded, the limits will be modified to meet the new conditions. Another possibility is a modified permit can be issued at a later date. You can usually tell a permit is modified because the effective date will be different and less than 5 years, but the permit expiration date will be the same. You have to compare both permits to see what changes were made. The modification may not have any impact on the permit limits.

Agency Reviewer and Comment Fields Data entered in this section will be pre-printed on all the Limit Set’s DMRs Users can identify Agency Reviewer DMR Comments Some states had used the first three characters of the DMR comment field to put the initials of the person at their agency that would be reviewing the DMR. This helped with routing the DMRs more timely. The Agency reviewer and DMR comment fields are available and the information will be displayed on the DMR forms.

User Defined Fields User Defined Fields Optional fields that are available for states and regions to use at their own discretion User defined fields are available for your user. They are optional and can be used to track information that the state or EPA region would like to maintain.

Yes – Choose Save & Add Another Screen Options Screen Options Save and Exit Save & Add Another Cancel Do we have any other Limit Sets to enter for General Foods? Yes – Choose Save & Add Another The options at the bottom of the data entry screen are to Save and Exit, save and add another, or cancel. Since we have another limit set to add, we would choose Save and Add Another.

Review Permit for Limit Sets Let’s enter the remaining Limit Sets for General Foods We will walk thru the quarterly limit set 001 Q You can enter the limits set required for permitted feature INFL on your own Verify all limit sets have been completed We will enter the remaining limit sets for General foods. The next limit set is for our quarterly requirements on 001 which we are going to code as permitted feature 001 and a limit set designator of Q. You will need to create the limit set or sets for the INFL permitted feature by reviewing the permit. The answers will be displayed so you can verify your work before accessing our Limits module.

Schedule for Quarterly Requirements 001 Q – Quarterly Requirements Number of Report Units _ How many months on DMR form Number of Submission Units _ How many months submitted Initial Monitoring Date ___________ Initial DMR Due Date ___________ What is the answer to the number of report units. How many months will be included on that DMR form for quarterly requirements? Jot down your answer. Next what is the number of submission units. When they mail in their DMRs how many months will be included? What is the initial monitoring date (start date for the DMRs)? When is that first DMR due to your agency? Fill in the answers and remember to refer to the permit.

Schedule for Quarterly Requirements 001 Q – Quarterly Requirements Number of Report Units _ How many months on DMR form Number of Submission Units _ How many months submitted Initial Monitoring Date ___________ Initial DMR Due Date ___________ The answers are displayed. The quarterly DMR will have 3 months on the form, and the DMR will be submitted each quarter. The initial monitoring date is the effective date from the permit. When would the July-August-September DMR be due to your agency. October 24, 2012. 3 3 07/01/2012 10/15/2012

Schedule for Quarterly Requirements Add the Limit Set for the Quarterly Requirements Let’s add the Limit Set for our quarterly requirements.

Schedule for Quarterly Requirements Fields maintained when “Save and Add Another” What changes need to be made? Since we chose Save and Add Another, several fields were retained. It is important to check each field carefully so that invalid non-receipt violations are not generated. The limit set designator must be unique. We already used “A” for our monthly requirements and have decided to use “Q” for our quarterly requirements. The default months have an impact on the way your preprinted DMRs look. It is best to leave all months checked. If you have a DMR that is January thru March, some users have gone in and taken the check mark off of January and February. This causes your DMRs to print March 1st thru March 31st. This is incorrect as the facility can take a sample in January, February, or March. If all months are checked the DMR would print January 1st thru March 31st which is correct. The number of report units will change to 3 and the number of submission units will be changed to 3. Three months will be covered on each DMR and they will mail the DMR in every 3 months. The initial DMR date needs to be changed. The first DMR is for July 1st thru September 30th, so when would that first DMR be due. 10/15/2012.

Schedule for Quarterly Requirements The answer is…. Verify that your Limit Set for the quarterly requirements exactly matches this screen. You are ready to enter the limit set for the INFL permitted feature.

Permit Review for Limit Sets Enter the limits sets for the INFL permit requirements Monthly, quarterly, semi-annual, annual requirements? You can check your answers on the next slide Review the permit for the INFL requirements. Are there monthly, quarterly, semi-annual, or annual requirements. Create your limit set or sets and check your answers on the next slide. Check the frequency of analysis. If the frequency of analysis is once a month or more often, the data will be reported on the monthly DMR. Example a sample once or twice a week, or hourly.

Permit Review for Limit Sets When you complete the limit set for INFL, your screen should look like this….. When you finish entering the INFL limit set, you can check for accuracy on the ICIS screen. If your screen looks like this…it’s time for a well deserved break. If not, please go into the Limit Sets and “Edit” to make any necessary corrections.

Parameter Limits Now you are ready to move onward to the Parameter Limits module.

ICIS Customer Support at (202) 564-7756 or icis@epa.gov If further assistance is required please contact Your Assigned System Administrator or ICIS Customer Support at (202) 564-7756 or icis@epa.gov THANK YOU! This concludes the limit set module. There are some important tidbits about limit sets, statistical base codes, limit modifications and how to copy limits following this slide. If you want to find out more detailed information, we recommend that you continuing reviewing this module. Otherwise proceed to the Parameter Limits module. If you need further assistance please contact your System Administrator or the ICIS helpline at (202) 564-7756 or at icis@epa.gov.

Other Limit Set Tidbits There are other important tidbits you need to know about the Limit Set screens and modifications.

Expected DMRs and Violations These data drive the Expected DMR Schedule and calculations of DMR Non-Receipt Violations Updates to these data will have ripple effects in the system If an update will lead to the orphaning of received DMR data, the system will not allow the update For example, a monthly Limit Set cannot be changed to bimonthly if DMR data have been received for an off month Delete the “orphaned” DMR data first before making the Limit Set change The dates entered for the schedule drive the creation of the expected DMRs, and calculations for DMR non-receipt violations. Updates to those fields, may have a ripple effect in the database. If an update will lead to orphaning of received DMR data, the system will not allow the update. What is meant by orphaned is there is no expected DMR for that monitoring period end date any longer, and you cannot leave DMR data sitting out there with no limit requirements. For example, suppose the permit said if the facility has no effluent violations for one year, they could sample every 2 months instead of every month for a limit set. We would need to change the number of reporting units and submission units from 1 to 2. Instead of getting separate DMRs for January and February, the facility would now get one DMR for two months. Remember all DMR data is keyed on the the monitoring period end date. For the January February combined 2 month DMR, the data would be keyed on the last day of February. If there is any DMR data keyed for the month of January, the data would no longer be required, so you would have to remove the January DMR data before changing the limit set fields because it is considered orphaned. This only impacts the DMR data after the limit change happened.

Change in the Limit Sets Exercise Date Orphaned Yes/No Nov. 2013 Y / N Feb 2014 Y / N Mar 2014 Y / N Aug 2014 Y / N Sept 2014 Y / N This is a little exercise for you to figure out whether the DMR is ophaned or not. Answers will be on the next slide to give you time to figure out the answer. If there was DMR data keyed for the months on the left, based on the dates in the schedule above, would this DMR be orphaned or not. Hint - be sure to look at the initial monitoring date and the number of report units.

Change in the Limit Sets Exercise - Answers Date Orphaned Yes/No Nov. 2012 Y / N Feb 2013 Y / N Mar 2013 Y / N Aug 2014 Y / N Sept 2014 Y / N We will review Nov. 2012 first. Which set of limits above are in effect for Nov. 2012? The first set – monthly DMRs. Since the DMR is due every month, the DMR will not be orphaned. Which set applies for February 2013? The second set begins in Jan 2013. What is the submission units? 2 So the DMR will cover 2 months Jan 1 thru Feb 28 th. The expected DMR monitoring period end date is February 28 th. So this DMR would not be orphaned. Let’s look at March 2013. Which “initial monitoring date” would be in effect? The one beginning Jan 1, 2013. The number of report units is two, so a DMR will be generated from January 1, 2013 thru February 28, 2013, and the next DMR will be for March 1, 2013 thru April 30, 2013. The DMR for March / April will be keyed using the monitoring period end date of April 30, 2013. ICIS will not allow you to enter DMR data on March 31st and you would be leaving DMR data orphaned if you changed from monthly to bi-monthly reporting. You would have to delete the DMR data for March. Due to a change of limits on April 1 st, no DMR data would be keyed in for the month of April. For the semi-annual DMRs starting in April – the first DMR would be for April thru September and the 2 nd DMR would be for October thru March. What are the 2 monitoring period end dates? September and March. Any other month would be considered orphaned data.

Statistical Base Codes As a data entry convenience, users may select default Statistical Base Codes (stat base codes) that will be applied to all Parameter Limits Recommend that you only use this when you have a large number of parameters with the same stat base codes Limit Statistical Base Codes do not have to match the Limit Set defaults Edits to Limit Set Statistical Base Codes do not trickle down to already added Limits The default statistical base code feature is available for data entry convenience. Usually if you have several parameters with the exact same statistical base code – referred to as the stat base code, you may want to use this feature as it will save you alot of time when coding your parameter limits. The stat base code on the limit set does not have to match the stat base code on the parameter limits. The parameter limits will override the ones in this section. If you finished coding your limits and found that you had made a mistake, making a change to this screen will not work. When the value is changed, it will not trickle down to limits that are in the database already. You will have to go into each parameter limit and make the change one at a time.

Statistical Base Codes Using the default Stat Base code may cause data invalid non-receipt violations if you don’t check your permit requirements carefully If you use this feature to save time, you have to be very careful because you may accidentially forget to blank out the stat base code or change the stat base code for parameters that don’t require these specific stat base codes. Invalid non-receipt violations could be generated. We will give you an example of how this works. Lets say we have 40 parameters with the stat base code of 30 day limit in the concentration 2 field and 7 day average in the concentration 3 field. To save a lot of time, we decide to use the default stat base code feature and enter the common stat base codes that are required. In the Concentration 2 field we put 30 day average and in the Concentration 3 field we put 7 day maximum. This means that every parameter limit we create will be automatically populated with this information. Maybe 80% of our parameters have this…. We have to change 20% of the other parameters to the correct stat base codes when the parameter limits are entered.

Statistical Base Codes Maximum Minimum We will enter the limit for pH. Most permits require a pH minimum and maximum. The minimums have been entered in the Concentration 1 field and the maximum has been entered in the concentration 3 field for many years. Although with ICIS, it is flexible about which of the 3 fields you use. As you can see the Concentration 2 and concentration 3 fields are auto populated with the stat base codes that we entered on the limit set. We need to check carefully what the requirements should be in ICIS. The concentration 1 stat base code is blank, so we need to choose minimum. The concentration 3 field needs to be changed from 7 day average to maximum. Check the Concentration 2 field. Since a stat base code is coded in, ICIS thinks that the concentration 2 field must be reported. If they do not report that value (and they will not be entering that field on a DMR form), the facility will get invalid non-receipt violations that will most likely appear on the Internet. It is very important to blank out the Stat base code in Concentration 2. The first item on the pull down menu is a blank.

Default Statistical Base Code Word to the wise. Use the default statistical base code feature carefully.

Statistical Base Codes Limit Sets and Limits Default Months do not match Parameter limits months – ALL Expected DMRs generated correctly DMR will show January 1, 2013 to March 31, 2013 Limit Set Limits Quarterly Just a reminder that basically the default months on the limit sets are for data entry convenience and the months checked will trickle down to the parameter limits. If the months on the limit set and the parameter limits do not match, the months on the parameter limits will override the limit set values. In this case all months are selected in the limits, so the expected DMRs are generated correctly and since this is a quarterly DMR, the DMRs will show January 1, 2013 thru March 31, 2013. As long as all months are displayed on the limits, the quarterly DMRs will print correctly.

Statistical Base Codes Limit Sets and Limits Default Months match Expected DMRs are not generated correctly DMR will show March 1, 2013 to March 31, 2013 Limit Set Limits Quarterly If the months on the limit set and the parameter limits match, the months on the parameter limits are the ones evaluated. In this case only the monitoring period end date for the quarter is checked. Expected DMRs are generated with a correct monitoring period end date, however the DMR period will be displayed for one month instead of 3 months. The DMR will show March 1 st thru March 31 st 2013. This is misleading to the permittees filling out the form. They can take their sample in January, February or March. By showing March only on the DMR, it appears that they must sample in March. You would need to change the months to ALL for each parameter limit in order for the forms to print correctly.

Modifications The original permit may have modifications included or a modified permit could be issued at a later date.

Permit Modifications Limit Set modifications are used to apply a change from a point in time forward Limits start as quarterly, then semi-annual, then bi-monthly Limit set modifications are used to apply a change from a point in time forward. For instance in our example, the facility starts with monthly reporting until the semi-annual requirements begin on October 1, 2012. Monthly DMRs would have been submitted for July, August and September. The semi-annual DMR would be for a 6 month period October 1st thru March 31 st. Then beginning April 2013, the facility would begin reporting bi-monthly with the first DMR being for the time period April 1 st thru May 31 st. The facility would continue to report bi-monthly until a change is made in the manage schedule area.

Changes Made to Limit Schedules Effect on reporting frequency Increasing or decreasing number of Report Units/Submission Units impacts DMR reporting frequency DMR submission frequency Initial DMR Due Dates When a modification is saved, ICIS–NPDES Recalculates the expected DMR schedule Reevaluates existing DMR Non-Receipt Violations Validates that previously received DMR data will not be orphaned Effect on length of submission period Changing the Initial Monitoring Date and Initial DMR Due Date impacts The amount of time after monitoring period to submit the DMR Validates previously received DMR data is not orphaned When changes are made to the Report units, submission units, modification or the dates, several processes are run. Review this slide in detail for recalculations, reevaluations and validations that will take place.

Permit Modifications Modification Effective Date and Modification Type Must be entered in the Limit Set Manage Schedule Mod Effective Date and Modification Type are required In this example, Permittee changed from quarterly to monthly reporting Let’s say in our example that the facility had conditions in their permit stating they would report quarterly for one year and then they had to change to monthly reporting. From the Limit Set schedule screen, you will click on “manage schedule”. Enter the information to change to monthly reporting along with the modification effective date and modification type.

Permit Modifications Modification effective date does not impact the modified limit start date First modification effective date is 1/18/2013, however the limit start date is 10/1/2012. There is no business rule to check that limit starts before effective date Second modification effective date 6/4/2013, however the limit start date is 7/1/2013 This slide is added because of calls to ICIS Customer Support. It is important to know that the modification date does not impact the modified limit start dates. The first modification effective date is 1/18/2013, however the limit start date is 10/1/2012. There is no business rule to check that the limit start date is prior to the modification effective date. The second modification effective date is 6/4/2013; however the limit start date is 7/1/2013.

Permit Modifications If you have 2 modifications starting the exact same day, ICIS will randomly choose one of them to be in effect You can code in a modification with no base limit Another question that has come up is when using 2 modifications with the exact same date. If you use the same modification start date, ICIS will randomly choose one of them to be in effect. Also you can code in a modification with no base limit.

New Feature Copying Limit Sets and Limits Saves time and resources There is a new feature to save time and resources to copy limit sets and limits. This is especially helpful for copy limits from a Master General Permit to General Permit covered facilities although it can be used for all permits. You may have 10 groups of limits that are very similar and it would save time to copy one set and make a few minor changes to the others. You can view these slides now or come back to them when you are ready to copy limit sets and limits.

Copying Limit Sets From the permit where the limits are being entered, you can copy limits from the same permit or from other permit numbers such as the master general permit number. Click on the copy limit sets hyperlink.

Copying Limit Sets Copy several Limit Sets 001-C, 001-D, 001-E from NM0022250 to NM0022292 Notice we are in NPDES id NM0022292. We want to copy 3 limit sets from NM0022250 to this permit number. 001 C, 001 D and 001 E.

Copying Limit Sets Enter Source ID – NM0022250 You will be required to enter the Source NPDES id. This is the id that you want to copy the limit sets from in the database. Continue

Copying Limit Sets Discuss options on screen There are several options on this page. You can use the Filter by in the Header area. A list of all the current limits are displayed, but we only wanted to copy 001. We could easily filter by Permittee Feature 001. You can also enter a default limit start date and end date which will trickle down. Even though the dates may be populated for all the limit sets, only the ones that you put a check mark in the left hand column will be copied. The others will be ignored. As you can see only 001 C, 001 D and 001 E have check marks on the left. Under the target Permitted feature, you will need to enter the permitted feature that you want to use for the new set of limits. The designator is also a required field. The number of report units, submission units and the dates must be filled in. Since the dates are entered above as soon as we click “prepopulate” the dates will be displayed in the fields below. You can change the limit set name. Notice all these are “scheduled” limit sets and it is hard coded which means you cannot switch to unscheduled limit sets.

Copying Limit Sets Click Prepopulate – Notice all Limit Sets were filled in (even ones you don’t want to copy) Only Selected Limit Sets will be copied Notice that after we click the prepopulate buttons, the dates are entered for all the fields below. Only selected 3 limit sets are checked to be copied, so the other dates were ignored and only the 3 sets were copied successfully (no error message for dates entered with missing fields)

Copying Limit Sets Success, now you can verify the limit sets were copied over with the correct information.