1. Module 1e – Narrative Conditions/Permit Schedule
Welcome to the module for entering schedules contained in a permit. In ICIS, schedules in a permit have been separated from schedules in an enforcement action. Permit schedules are referred to as Narrative Conditions.

2. Narrative Conditions
Narrative Conditions -text-based permit requirements, Permittee must comply
Two types of Narrative Conditions
Date Based
Non-Date Based
Narrative conditions are text based permit requirements in which the permittee must comply. There are two types of Narrative Conditions. Non-date based and date based. Most schedule requirements are date based narrative conditions. However ICIS was built to handle narrative conditions in the permit that do not contain a specific due date.

3. Narrative Conditions Date-Based Begin Construction End construction
Submit progress reports quarterly.
An example of a date based narrative condition is a requirement to begin or end construction of a waste water treatment unit with specific deadlines. Another example, it is requirement to submit quarterly progress reports detailing their progress toward meeting the construction schedule. When schedule records were migrated from the legacy database, all events were date based narrative conditions.

4. Non-Date Based Narrative Condition
Do not contain a schedule or reporting condition
Requirement to follow Best Management Practices (BMPs)
Special Condition 2. The use or operation of this facility shall be by or under the supervision of a Certified Class 2 operator.
Non-date based narrative conditions do not contain a schedule or reporting condition such as a specific date when the event is due. An example of a non-date based narrative condition is that the permittee must follow Best Management Practices. Another example is from our General Foods permit that you may be interested in entering into ICIS is the Special Condition number 2. This requirement states that the use or operation of this facility shall be by or under the supervision of a Certified Class 2 operator. Having this event in the database may enable an inspector easy access to conditions of the permit they need to verify during the inspection of the facility.

5. Non-Date Based Narrative Condition
Use Single Event Violations to track noncompliance
Ex. Management Violation Practices - Best Management Deficiencies
If the non-date based schedule event is not met, there is no way the system would know they were out of compliance with this event and therefore the violation would not be automatically generated. You will need to manually create a Single Event violation if they are not in compliance. There are several single event violations related to Management Violation Practices. Here is an example of a Single Event Violation that you may use to create a violation for failing to follow best management practices.

6. Date-Based Narrative Condition
Must contain at least one date-driven schedule or reporting condition
Begin Construction 4/1/2014
End Construction 6/15/2015
Violations are automatically generated in ICIS
Date based narrative conditions must contain at least one date driven schedule or reporting condition. Schedule events will have a specific due date and violations will be automatically generated in ICIS if these dates are not met. Examples of a date based narrative condition is to Begin construction by April 1, 2014 and end construction by June 15, Violation detection will be discussed in a separate module.

7. Date Based Schedule Events
When adding a Date-Based Narrative Condition users are able to enter
Non-Recurring Events (i.e., one-time occurences)
Hire a Consulting Engineer
Recurring Events (e.g., Reports that must be submitted monthly, annually, etc.)
Submit Progress Reports Quarterly until entire schedule is met
To improve data entry efficiencies, date based narrative condition events can be entered in 2 ways. One of the options is to enter a non-recurring event which is a one time occurence. An example may be that you hire a consulting engineer. The other option is for entering recurring events. These are reports that must be submitted multiple times either monthly, quarterly, yearly, etc. For instance, the facility may be required to submit Progress Reports every quarter for the 5 year permit timeframe. Rather than enter 20 Progress Reports one by one, you can enter a range and frequency once and the 20 progress reports will be automatically generated.

8. Schedule Event Types
Events are either Schedule Events (S) or Report (R) Events
Impacts RNC detection and overall status of a facility on the Quarterly Non-compliance Report
When selecting the schedule event, it is important to note that some of them are Schedule events and others are Reports. Schedule events are usually considered milestones and violations are more significant that missing a report.

9. Schedule Event Types
The Schedule Event Table in ICIS will show which events are considered reports (R) or schedules (S). Notice that Advertise for Bids is considered a schedule, and the TRC Evaluation Report is a report.

10. Schedule Key Dates There are three critical dates for Schedule Events
Schedule Date – the date the event must be completed
Actual Date – the date the event was completed / achieved
Report Received Date – the date the regulatory authority received notification from the permittee about completion/achievement of the event
ICIS will evaluate these dates to create and update Schedule Violations
Schedule Violation evaluation will be discussed during the Violations module
There are three critical dates for schedule events. The scheduled date (often referred to as the due date) is the date the event must be completed by. The actual date is the completion date when that specific activity was met. The report received date is the date the regulatory authority received notification from the permittee about the completion of the event. ICIS will evaluate the critical dates and will create or update schedule event violations. Based on whether the event is a schedule or report will impact the Reportable Noncompliance (RNC) detection and overall status of a facility on the Quarterly Non-compliance report. Schedule and report violations will be discussed further in the Violation Processing module.

11. Management of Narrative Conditions
The Narrative Conditions Screen captures the following information
Narrative Condition Information
Recurring Event Information
Non-Recurring Event Information
The Narrative Conditions data entry screen captures the following information. Narrative condition information, recurring event and non-recurring event information.
Narrative Conditions

12. Special Conditions
NPDES Permit No. XX00000ZZ
Special Conditions
Special Condition 1. This Permit may be modified to include different final effluent limitations
or requirements which are consistent with applicable laws, regulations, or judicial orders. The
Agency will public notice the permit modification.
Special Condition 2. The use or operation of this facility shall be by or under the supervision of
a Certified Class 2 operator.
Special Condition 3. The Agency may request in writing submittal of operational information
in a specified form and at a required frequency at any time during the effective period of this
Permit.
Special Condition 4. The Agency may request more frequent monitoring by permit
modification pursuant to 40 CFR and Without Public Notice in the event of operational,
maintenance or other problems resulting in possible effluent deterioration.
Before reviewing the data entry screens, let’s take a look at our General Foods permit to see if there are any schedule requirements. Sometimes the permit will contain a section for Schedules and other times the schedules will be included in the Special Conditions area. Let’s review all the special conditions to see if there are date based or non-date based conditions. Normally all date based conditions are entered into ICIS. Special condition 2 could be coded in as a non-date based condition. Conditions 1, 3, and 4 do not have any specific requirements or deadlines.

13. Special Conditions
Special Condition 5. For Discharge No. 001, any use of chlorine to control slime growths,
odors or an operational control, etc. shall not exceed the limit of 0.05 mg/l (daily maximum)
total residual chlorine in the effluent. Sampling is required on a daily grab basis during the
chlorination process. Reporting shall be submitted on the DMR’s on a monthly basis.
Special Condition 6. During January of each year the Permittee shall submit annual fiscal data
regarding sewerage system operations to the Agency/Division of Water Pollution
Control/Compliance Assurance Section. The Permittee may use any fiscal year period provided
the period ends within twelve (12) months of the submission date.
Special Condition 5 involves a limit to be included on the DMR form. Special condition 6 – This is a schedule requirement with a specific deadline. Is the event recurring or non-recurring schedule event? What is your guess? (pause) Recurring… annual fiscal report has to be submitted in January of each year for the lifetime of the permit. We will code this schedule event a little later on.

14. Special Conditions
Special Condition 7. For the duration of this Permit, the Permittee shall determine the quantity of sludge produced by the treatment facility in dry tons or gallons with average percent total solids analysis. The Permittee shall maintain adequate records of the quantities of sludge produced and have said records available for Agency inspection. The Permittee shall submit, at a minimum, a semi-annual summary report of the quantities of sludge generated and disposed of, in units of dry tons or gallons (average total percent solids) by different disposal methods including but not limited to application on farmland, application on reclamation land, landfilling, public distribution, dedicated land disposal, sod farms, storage lagoons or any other specified disposal method. Said reports shall be submitted to the Agency by January 31 and July 31 of each year reporting the preceding January thru June and July thru December interval of sludge disposal operations.
Special condition 7 – Is this a narrative condition that should be entered into ICIS? (pause) Yes. Is the event a non-recurring or recurring schedule event? How often are the reports due? You will be coding this event on your own at the end of this module.

15. Special Conditions
Special Condition 8. The Permittee is required to submit a Facility Expansion Plan one year
after the effective date of this permit. This Plan should include plans for expansion, estimated
population growth for the next 10 years, and how necessary funds will be obtained to ensure
compliance.
Special Condition 9. The Permittee shall record monitoring results on Discharge Monitoring
Report (DMR) forms using one form for each outfall each month.
The completed DMR forms shall be submitted to the Agency no later than the 15th of the
following month, unless otherwise specified by the permitting authority.
Permittees shall mail DMRs with an original signature to the Agency at the following address:
Agency
Division of Water Pollution Control
1021 North Grand Avenue East
City, State 22277
Special condition 8 and 9. Are they Narrative Conditions? (pause) Special condition 8 is a narrative condition. Is this event a one time event or recurring? Special condition 9 captures the DMR submittal information and a specific due date for the DMR form. Let’s start entering the event that is required in Special condition 8.

16. Special Condition 8 Scheduled Date? __ __ / __ __ / __ __ __ __
Special Condition 8. The Permittee is required to submit a Facility Expansion Plan one year after the effective date of this permit. This Plan should include plans for expansion, estimated population growth for the next 10 years, and how necessary funds will be obtained to ensure compliance.
Scheduled Date? __ __ / __ __ / __ __ __ __
Non-recurring
Recurring or non-recurring event?
Read special condition 8. Is this a recurring or non-recurring event? (pause) The answer is non-recurring event. They have to submit a Facility Expansion Plan one year after the effective date of the permit. As a reminder the important permit dates for our General Foods permit are displayed. What is the scheduled (or due date) for the Facility Expansion Plan? One year after the effective date. The scheduled date is July 1, Let’s code this event into ICIS.
Issue Date: June 16, 2012
Effective Date: July 1, 2012 Expiration Date: June 30, 2017

17. Narrative Condition Description
This section captures the general information about the Narrative Condition
The first required field is the Description. The Description is used to identify the type of permit schedule. This field can be used to separate different types of schedules in a permit. For instance if you have a construction schedule and a pretreatment schedule, you may want to separate the requirements. In other situations, you may want to put all the schedule requirements under one narrative condition description. For the description, lets choose Permit Schedule. We will enter all the requirements for General Foods under one Permit description. The first schedule event we are coding is for a Facility Expansion Plan
Narrative Conditions

18. Narrative Condition Date Based
If schedule events are Date Based, check the box
When the Date Based Checkbox is selected, either the Recurring Event or Non-Recurring Event radio button must be selected next
The comment field is available for you to add more specific details about the schedule. Since we are entering a date based event, the checkbox must be checked. Decision time, are we entering the recurring or non-recurring event. The Facility Expansion plan is a one time event, so click on the radio button for non-recurring event.

19. Non-Recurring Event Information
This section captures the information for scheduling one time, Non-Recurring Events
The next step is to select the type of event and enter the scheduled date. Click on the Select icon.
Narrative Conditions

20. Non-Recurring Event Information
Facility
On the left you will see the list of all the schedule events in alpha order and the list is quite lengthy. You can enter a description or code to narrow down your search. On the right, the word Facility was entered and you can see the critieria is down to 2 choices. I can search for any part of the phrase. Remember if you are trying to search for the word, such as Plan anywhere in the name, add the wildcard percent sign at the beginning of the description. We are in luck, as there is a choice for Facility Expansion Plan. Highlight and click Done.
Narrative Conditions

21. Non-Recurring Event Information
Enter the scheduled date from the Permit
Special Condition 8. The Permittee is required to submit a Facility Expansion Plan one year after the effective date of this permit. This Plan should include plans for expansion, estimated population growth for the next 10 years, and how necessary funds will be obtained to ensure compliance.
The scheduled date is a required field. What is the date we should enter? One year from the effective date of this permit which is July 1, 2013.
07/01/2013

22. Add Events to Schedule
When you save your first event, you will be taken back to this screen. If you wanted to create a different schedule for instance a Pretreatment schedule, you would “Add Narrative Condition”. However we want to put all the schedule events together under the Permit schedule we just created. Click on the Narrative Condition Number one to get back into the Permit Schedule so we can add the other events.

23. Permit Schedule – Add Event
You will be able to add the rest of the events from this screen. Note that the Annual Fiscal Report is displayed below the description and comment field. We will click “Add Event” to add other schedule events.

24. Other Schedules in Permit?
Do we have other events to add or other types of schedules?
Now back to the permit, do we have any other permit schedule events?

25. Special Condition 6
Special Condition 6. During January of each year the Permittee shall submit annual fiscal data regarding sewerage system operations to the Agency/Division of Water Pollution Control/Compliance Assurance Section. The Permittee may use any fiscal year period provided the period ends within twelve (12) months of the submission date.
Yes, special condition 6. Is this a recurring or non-recurring event? (Pause)
Recurring or non-recurring event?
Recurring

26. Recurring Event Determine Recurring or Non-Recurring Event
We are ready to enter our first Recurring Event. We will search for the schedule event the same way we did for non-recurring. The next step is to enter the scheduled start date. Notice there are a couple new fields; frequency and Duration. Let’s enter Special Condition 6.
Narrative Conditions

27. Recurring Events Annual %Fiscal
To enter the schedule event, we entered the search criteria “fiscal” in the description field and got no results. The next search we tried was the description equal to “Annual”, which returned 7 results. When the wildcard (percent sign) was added to the description field with word - fiscal, the list was reduced to one result. Highlight Annual Fiscal Report and click done.
%Fiscal

28. Recurring Event Effective Date: July 1, 2012
Now that we have selected the event – what is the schedule Start date? The report is due in January of each year. Looking at the important permit dates, when would the first report be due? It may depend. Was this a requirement from a previous permit? If so, you will definitely want the report in January If this is the first time this requirement has been in a permit, would the facility have to submit the report in January 2013? The permit was effective July 1st, so that would only be 6 months. You may need to talk with the permit writer or enforcement officer to see if that report must be submitted. For this training we will start with January What day of the month should I choose? If we enter January 1st and the facility submits the report on January 20th – are they late? A violation will be generated in ICIS because they were over 14 days late. That is not valid. If a day of the month is not mentioned, you must enter the last day of that month in order to prevent an invalid violation. We will enter January 31, 2013.
Effective Date: July 1, 2012

29. Recurring Event
What is the frequency of this report? Monthly, quarterly, yearly? Special condition 6 states it is an annual report. Choose Annually from the pull down menu.

30. Recurring Event Duration Choose number of occurrences or end date
We need to choose the duration. You can enter the number of occurrences, such as 5 for a 5 year permit, or enter an end date which would most likely be the permit expiration date. We will enter the expiration date of the permit which is June 30, Watch what happens when we save.

31. Recurring Event
Notice that 5 Annual Fiscal Reports were generated automatically. Now that we have demonstrated how to enter a recurring and non-recurring event, you can enter the requirements for Special 7.

32. Special Condition 7
Special Condition 7. For the duration of this Permit, the Permittee shall determine the quantity of sludge produced by the treatment facility in dry tons or gallons with average percent total solids analysis. The Permittee shall maintain adequate records of the quantities of sludge produced and have said records available for Agency inspection. The Permittee shall submit, at a minimum, a semi-annual summary report of the quantities of sludge generated and disposed of, in units of dry tons or gallons (average total percent solids) by different disposal methods including but not limited to application on farmland, application on reclamation land, landfilling, public distribution, dedicated land disposal, sod farms, storage lagoons or any other specified disposal method. Said reports shall be submitted to the Agency by January 31 and July 31 of each year reporting the preceding January thru June and July thru December interval of sludge disposal operations.
If you would like to enter this schedule event on your own, we will show the entire schedule at the end of this module so you can check your work. Now that we have finished entering the requirements of the permit schedule, we will discuss a couple of important points about editing your schedule event.

33. Editing Permit Events
As the milestones and schedules are met, you will need to edit the schedule events in order to enter the received and actual dates.

34. Editing Schedule Events
Current Permit Previous Permit
You can edit schedule events on the current permit under the narrative conditions hyperlink. It is important to know that you can also edit schedule event from a previous permit under the History hyperlink. Many times the schedule violations on the QNCR may have been required in the previous permit. It is important to enter the achieved and received dates to prevent inaccurate violations from appearing in ICIS and on the public website, ECHO. We will edit one of the schedule events now. Click on the number one hyperlink under the narrative condition number.

35. Edit Schedule Event
Click on the radio button for Facility Expansion Plans and the edit icon at the bottom of the page. Notice that several of the events have violations detected on the right.

36. Editing Schedule Events
Enter the actual and report received dates and save. Notice the report came in before the due date.

37. Editing Schedule Events
Once the actual and received dates were entered, the facility is no longer in violation of this event.

38. Editing Schedule Events
Edit a Schedule Event on an Old Permit
From the “History” Link
Select the version of the historical permit
Select the Narrative Condition from the View Permit History screen
Select the Schedule Event to edit
Enter the Actual and Report Received dates
To edit a schedule event from a previous permit, click on the History Link. Select the version of the historical permit. Select the Narrative Condition from the View Permit History screen. If there are multiple narrative conditions, may take a minute or two to locate the schedule event that is in violation. Select the schedule event to edit. Enter the actual and report received dates.

39. Editing Schedule Events
Historical Schedule Events
Schedule events from previous permit
Will no longer be tracked starting with the day before the effective date of the new permit
Violations will not be generated
You will only be able to change the actual and received dates
Delete transaction is not allowed
Schedule events from the previous permit will no longer be tracked starting with the day before the effective date of the new permit. Violations will not be generated, and it is not necessary to remove the schedule events from the database. They will be ignored. You will only be able to change the actual and received dates for the historical schedule events. Delete transactions are not allowed for the historical schedules.

40. Editing Schedule Events
The following rules apply to Schedule Events
If the Actual Date is entered, the Report Received Date must be entered
If the Report Received Date is entered the Actual Date can be blank or entered
If both are entered, the Report Received Date must be greater than or equal to the Actual Date
There are some business rules that you need to be aware of that apply to schedule events. If the actual date is entered, the report received date must be entered. If the report received date is entered the actual date can be blank or entered. If both dates are entered, the report received date must be greater than or equal to the actual date.
Narrative Conditions

41. Copying from an MGP
Narrative Conditions can be copied from Master General Permits (MGPs) to associated General Permit Covered Facilities (GPCF)
Changes made to a Narrative Condition in the MGP after the condition has been copied to a GPCF will not trickle down to the GPCF
One of the features of schedules is the ability to copy from a Master General Permit ( M G P) to an assocaited General Permit Covered Facility (G P C F) Once you have copied the schedules to the GPCF, it is important to know that if any changes are made to the Master General Permit’s schedule, they do not trickle down to the General Permit Covered Facilities. You would have to make the changes for each G P C F one by one.

42. Contact Information
Contact ICIS Customer Support at (202) or at
This concludes the narrative conditions module. If you coded the Special Condition number 7 from our General Foods permit, the answers are on the next page. If you need any assistance, please contact ICIS Customer Support at the phone or address displayed.

43. Special Condition 7
Special Condition 7 is a recurring event. There are a couple of options you could have used for the sludge reports. We searched sludge and biosolids to determine the best schedule event to use. On the next slide is the completed schedule for our General Foods permit.

44. Special Condition 7
The Biosolids Analysis Report is required every 6 months. You may have used a slightly different description for the sludge requirements in the permit which is okay. There are 15 schedule events which takes 2 pages to display.

45. Special Condition 7
Recommend that you add the last Biosolids report due on July 31, the permit expired on June 30th which includes the period of time that should be reported on the July 31, 2017 report. Add event.