1. Single Event Violations
Welcome to the Single Event Violations module. Throughout this tutorial, we will discuss the specifics of Single Event Violations, referred to as SEVs. Included in the documentation available, various types of SEVs, data entry of SEVs, and detection/ resolution of these violations.

2. Violations Automatically Detected by ICIS
Effluent Violation
Delinquent
Schedule
Several types of violations are automatically detected by ICIS. Exceedances of a permit limit will generate an effluent violation, delinquent compliance schedule events from a permit or formal enforcement action and failure to submit Discharge Monitoring Events.
Failure to Submit
DMRs and Reports

3. Unexpected Violations Can Occur
Violations detected during an inspection
Unauthorized bypass
Discharging without a permit
Fish kill, etc.
In some cases, unexpected violations may occur that are not automatically generated by the database. Examples are violations detected during an inspection, unauthorized bypass, discharging without a permit or a fish kill. We refer to these type violations as Single Event violations.

4. SEVs SEVs required for Major permittees
States and EPA manually enter into ICIS
Unique violations that are not automatically detected
NPDES inspection or non-compliance report
Single event violations for all major permittees must be manually entered into ICIS by State and EPA personnel. In addition, EPA Regional offices are also required to enter Single Event violations for non-major permittees. We encourage states to enter the violations for non-majors, along with the ones detected for the special regulatory programs, such as Storm Water, CAFOs, pretreatment, etc. into ICIS. Many violations of the Clean Water Act are automatically detected by the database, such as effluent violations, non-reporting violations, and delinquent compliance schedules. SEVs are unique violations that are not automatically detected by ICIS and are often discovered during an inspection or submittal of a non-compliance report. We will discuss some of the most common SEVs that occur in the next few slides. You will be able to easily link the SEVs to any enforcement actions taken as a result of these violations.

5. SEV Guidance in ECHO
The single event guidance is available on the ECHO website. You will find several documents related to Single Events at this location.

6. Types of SEVs Bypass Fish Kills
There are several different types of Single Event Violations. For example, bypasses and fish kills are two of the most often noted types of Single Event Violations.

7. Violations Detected During an Inspection
Several different kinds of violations can be noted during an inspection. Here is a list of some of the violations that might be found during an inspection. If multiple violations were found during an inspection, then multiple Single Events would need to be created.

8. Failure to Apply for Permit
Here is a list of Single Event Violations that may occur from the permit application process.

9. Special Regulatory Programs
CAFOs
Pretreatment
There are several single event violations available for the special regulatory programs such as Storm Water, CAFO, Biosolids, Pretreatment, etc.

10. Special Regulatory Programs
Storm Water
Some of these may be required data entry for EPA Regions based on the “Interim WW SNC Policy”.

11. Data Entry SEVs
To begin the data entry process of Single Event Violations, select “Single Event Violation” on the left side of the global navigation menu.

12. Data Entry SEVs NM
This tutorial will discuss the various fields required and available for you to enter. As a reminder any fields with an asterisks (*) are required in order to save the record. The 4 required fields are the NPDES id, Violation Code, Single Event Violation Date, and Single Event Agency Type. Start by entering the 9 digit NPDES id.

13. Search for Violation Code
You will need to search for the Violation Code. When you select search a Pop Up box will appear with your choices. As you can see the list of codes available are extensive.

14. Violation Code Selections
There are so many codes that you may want to narrow down the list by performing a Search. For instance, if we are only interested in violations for Pretreatment, then the search criteria at the top of the screen will allow you to search for part of a name or the ICIS code. If the word “pretreat” is used, the list narrows to 11 choices where all of the violations begin with “Pretreat”.

15. Wildcard Feature
ICIS has a wildcard feature available. The percent sign (%) is entered before the name in the search criteria. This will result in any violations that have the word “pretreat” anywhere in the title. Two items were added and you will notice the last two do not begin with the word “pretreat”. Another thing you may notice is that you cannot see the entire description for the violations. To view the full description, select the violation and the entire description appears below in a yellow box.

16. SEV Dates
The single event violation date is a required field. This should be the date the violation first occurred or, if unknown, the date the violation was discovered (e.g. observed, reported, etc.) If the “start” and “end date in the “Duration” area (discussed later) are not populated, a single event violation with only a “violation date” populated is treated as a one-day only violation.

17. Required SEV Fields
The Single Event Agency Type is also required. This field is automatically generated with either State or EPA based on the ICIS user id of the person logged in. The Guide instructs you to enter the agency that discovered this violation in this field. These 4 fields are all that is required in order to save this record. We will also discuss some of the optional fields including the RNC fields which are used to flag the severity and resolution of Single Event Violations. The RNC fields are especially important for violations with significant environmental impact or that meet the Wet Weather Significant Non-Compliance criteria. The Interim Wet Weather SNC Policy was issued to EPA Regions only on October 23, 2007.

18. Saving Options
To record the violation, you can select “Save and Exit”, “save and continue (to admire your work and perform QC), or “Save and Add Another.”

19. Duration Data Fields 08/27/2015 08/29/2015
Optional, but still very important, are the duration data fields. They can be beneficial to track compliance. For example, the penalty may be significantly impacted if you can identify the number od days bypassed rather than the total number of bypasses.
08/27/2015
08/29/2015

20. Duration Data Fields 08/27/2015 08/29/2015
It is very important to enter the end date if the Single Event Start Date was entered in the Duration Section. The violation end date is used to show the length of time the facility was out of compliance. Facilities with open single event violations (meaning a start date was entered, but no end date) will continue to appear in violation in the national and public databases until the end date is entered. The regulatory authority should use its judgment in regards to “ending” a single event violation. Refer to the Single Event guidance for more details about the Violation End Date and examples of when the duration section is used.
08/27/2015
08/29/2015

21. Extended Date Ranges
You can also enter an extended date range. Rather than create 15 single event violations for each individual bypass, we entered one single event and in the comment field provided the details.

22. RNC Evaluation
Single event violations should be evaluated to see if they meet the criteria for RNC/SNC. In the case of Wet Weather, some violations have been identified in the interim Wet Weather SNC Policy that would need to be flagged as RNC/SNC. Agencies have the discretion to flag any violations of concern or environmental impact. Violations with the RNC fields entered may appear on the Quarterly Noncompliance Report.

23. RNC Detection Code
You must choose a reason why you are flagging this violation for RNC/SNC. As you can see the violation code and description are displayed. A list of RNC detection and RNC resolution codes are available thru the ICIS Business Objects Ad Hoc reports. In our example, we selected Code F for Violation of Concern.

24. RNC Detection Dates
The RNC Detection Date is normally the date that the regulatory authority “determines” that RNC (or SNC) criteria has been met (typically via a management review of inspector findings, etc.) If the date that the “RNC/SNC determination” is made is not known, the regulatory authority may use the violation start date, or the compliance monitoring/inspection date as the RNC Detection Date.

25. RNC Resolution Codes
To manually change the status, you must choose one of the codes from the pull down menu in the “RNC Resolution Code Entry” column. It is important that these violations are resolved when the facility returns to compliance or closure of a Formal Enforcement Action. When a formal enforcement action is issued, automatic resolution will occur if the single event violations are linked to the formal enforcement action – Final Order which must include at least one compliance schedule event. Once linked, the RNC Resolution will be automatically changed to Resolved Pending and the resolution will change automatically to “resolved” when the formal enforcement action is closed in ICIS.

26. RNC Resolution Date
In our example, the Resolution Code was manually set to Resolved Pending due to the issuance of a Formal Enforcement Action. The resolution Date is October 12, 2015 which is the issue date of the formal enforcement action. When this action is closed the RNC resolution code will change to resolved and the resolution date will be the date the formal enforcement action is closed.

27. User Defined Fields / Comment Field
User Defined fields are available for your use. The comment field is also available for you to enter any remarks regarding this violation. Please remember that Single Event Violation data is non-sensitive and any comments entered here can be made available to the public upon request.

28. Linking Violations
If an enforcement action (informal or formal) is issued, it is important to link the Single Event violations to that enforcement action. The Linking Violations Module includes the details on how to accomplish this task. Also, we recommend that you read thru the Single Event Data Entry guidance for more detailed instructions.