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Module 8 - RNC Overview

Module 8 - RNC Overview. Recording of BAH Demo (Optional). https://epawebconferencing.acms.com/pqj8q6zpcbu0/. What is RNC?. Reportable Noncompliance (RNC) is a regulatorily defined term for doing something bad enough to be reported on the Quarterly Noncompliance Report (QNCR)

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Module 8 - RNC Overview

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  1. Module 8 - RNC Overview

  2. Recording of BAH Demo (Optional) • https://epawebconferencing.acms.com/pqj8q6zpcbu0/

  3. What is RNC? • Reportable Noncompliance (RNC) is a regulatorily defined term for doing something bad enough to be reported on the Quarterly Noncompliance Report (QNCR) • RNC that is really bad is defined in policy as Significant Noncompliance (SNC); this term has program implications but not ICIS system implications • The goal for a facility and the Regulatory Authority is to either have no RNC violations or to have addressed all RNC violations and get back into compliance • Violation severity is assessed for RNC and SNC • Not all violations are RNC, and not all RNC is SNC • RNC and SNC violations appear on the QNCR

  4. Permit RNC Status Permit RNC Status - Sets the automatic Permit RNC Status of a Permit for each QNCR Quarter based on the status of its Violations

  5. RNC Detection Codes and Descriptions

  6. RNC Resolution Codes and Descriptions

  7. Permit RNC Status Codes in Hierarchy Level

  8. Quick DMR Violation Overview • DMR Violations are grouped into two categories: • DMR Non-Receipt Violations (D80 and D90) • Effluent Violations (E90) • DMR Non-Receipt Violations cannot be manually detected by the user. They are generated/updated/deleted by three processes: • DMR Non-Receipt Violation Nightly Processing • DMR Non-Receipt Violation Update (part of the DMR Update process) • Enforcement Action RNC

  9. RNC Data Elements for Violations • RNC data elements on Violations are determined by a combination of several different ICIS background processes and may also be manually updated by the user • The four RNC Data elements for Violations (icis_npdes_violation) are: • RNC Detection Code: describes the type of RNC for which the violation was detected (rnc_detection_code) • RNC Detection Date: the date the RNC detection code was determined (rnc_detection_date) • RNC Resolution Code: describes the resolution status of the violation’s RNC (i.e., Noncompliant (NC), Resolved Pending (RP), Resolved (RE)) (rnc_resolution_code) • RNC Resolution Date: the date of the current resolution status of the violation’s RNC (rnc_resolution_date) Display Violation Search NCRNC001, 01/01/2016 – 01/01/2018,

  10. RNC Detection for DMR Non-Receipt Violations • D80 and D90 Violations are automatically detected for RNC by the system upon generation of the Violation according to the following: • If the DMR Value is for a Monthly Average (i.e., the Limit Value’s Statistical Base Code is a Monthly Average in the reference table), the RNC Data are set to: • RNC Detection Code = N (Non-Receipt of DMR/Schedule Report) • RNC Detection Date = DMR Due Date + 31 • RNC Resolution Code = 1 (NC - Unresolved RNC) • RNC Resolution Date = RNC Detection Date Monthly Average: REF_STATISTICAL_BASE.STATISTICAL_BASE_MONTHLY_AVG = A Examples: 30 Day Average, Monthly Average NCRNC001|001|S|04240 Review how the Detect Date for Non-Receipts is 2 months after the MPED (ex. A non-receipt date for October 2017 would have a January detect date, and be in Quarter 2, not Quarter 1)

  11. Example: RNC for DMR Non-Receipt Monthly Average

  12. RNC Detection for DMR Non-Receipt Violations • If the DMR Value is for a Non-Monthly Average (i.e., the Limit Value’s Statistical Base Code is a non-monthly average in the reference table), the RNC Data are set to: • RNC Detection Code = K (Non-Receipt Violation, Non-Monthly Average) • RNC Detection Date = DMR Due Date + 31 • RNC Resolution Code = 1 (NC - Unresolved RNC) • RNC Resolution Date = RNC Detection Date • Non-Monthly Average: REF_STATISTICAL_BASE.STATISTICAL_BASE_MONTHLY_AVG = N • Examples: Daily Max, 7 Day Maximum • NCRNC001|001|S|01051

  13. Example: RNC for Non-Monthly Average

  14. Non-Receipt Violation Resolutions • RNC Resoution Codes for Non-Receipt Violations: • Resolution Code 1 (NC – Unresolved): The violation has been detected but no action has been taken to get the violation addressed • Resolution Code 2 (RE – Back in Compliance): The violation has been detected and complete action has been taken to address it (e.g., a missing DMR value has been submitted) • Resolution Code 3 (RP - Due to Formal Enforcement Action Final Order with Compliance Schedule): The violation has been detected and some action has been taken to address it (e.g., the Volation has been linked to a Final Order) but it is not yet fully complete (e.g., the Final Order is still open) • Resolution Code 5 (RE - Resolved RP by NPDES Closure of Enf. Action Final Order with Comp. Schedule): The violation has been linked to a Final Order and the Final Order has been closed

  15. Examples of RNC Resolution - DMR Non-Receipt Violations • RNC Resolution examples for a DMR Non-Receipt Violation: • Entry of the DMR Value Received Date > Due Date + 31 days, and if NODI is entered, the NODI is Valid: • RNC Resolution Code = 2 (Resolved) • RNC Resolution Date = DMR Value Received Date • Linkage of a D80 or D90 Violation to a Final Order that has a Compliance Schedule (sets linked Violations to Resolved Pending) • RNC Resolution Code = 3 (Resolved Pending) • RNC Resolution Date = linked Final Order Issued/Entered Date of linked Final Order • NPDES Closure of the Final Order linked to a D80 or D90 Violation (sets linked Violations to Resolved) • RNC Resolution Code = 5 (Resolved) • RNC Resolution Date = linked Final Order NPDES Closure Date

  16. DMR Non-Receipt and Invalid NODI • Explain how NODIs that are “invalid” would show up in RNC (including which quarter they would be in) • If an Invalid NODI code is entered (i.e., REF_NODI.VALIDATION_FLAG = N), then the presence of NODI and the DMR Value Received Date does not suppress DMR Non-Receipt Violation generation. • DMR Non-Receipt Violation due to invalid NODI, RNC Resolution = 1 (NC - Unresolved RNC) • It will have to be manually resolved by the user or linked to a Final Order – the Violation RNC Resolution Code will never = 2 (RE - Back into Compliance)

  17. Quick Effluent Violation (E90) Overview • The basic rules for generating Effluent (E90) Violations for DMR Values are: • The Limit Type is Enforceable • The entered DMR Value violates the entered Limit Value, which means: • For Maximums and Averages: DMR Value is greater than the Limit Value • For Minimums and Averages: DMR is less than the Limit Value OR • The DMR Value is blank and the DMR Value Qualifier is T (Too Numerous to Count)

  18. RNC Detection for Effluent (E90) Violations • When an Effluent Violation of an Enforcement Action Limit is first generated (when the data is first entered into ICIS), ICIS automatically detects it for RNC (unless RNC Tracking is OFF or the Statistical Base Code for the violated Limit Value is not a Monthly Average or Non-Monthly Average). • Any Effluent Violation of an Enforcement Action Limit is considered to be RNC that is also SNC (Significant Noncompliance). • Effluent Violations of Permit Limits must meet a threshold of magnitude and number of occurrences to be considered RNC or SNC. They are also resolved differently. (Details on this functionality can be discussed at a later time if necessary) • The Official and Unofficial RNC process runs detect and resolve Effluent Violations of Permit Limits and resolves Effluent Violations of Enforcement Action Limits. (Details on this functionality can be discussed at a later time if necessary)

  19. RNC Detection for Effluent Violations of Enforcement Action Limits • An Effluent Violation of an Enforcement Action Limit Value is detected by the system at the time of data entry • If the DMR Value is for a Monthly Average (i.e., the Limit Value’s Statistical Base Code is a Monthly Average in the reference table), the RNC Data are set to: • RNC Detection Code = A (Enforcement Order) • RNC Detection Date = Monitoring Period End Date • RNC Resolution Code = 1 (NC - Unresolved RNC) • RNC Resolution Date = RNC Detection Date • Example: NCRNC0001|002|S

  20. Example: RNC Values for Monthly Average

  21. Example: RNC Values for Non-Monthly Average • If the DMR Value is for a Non-Monthly Average (i.e., the Limit Value’s Statistical Base Code is a Non-Monthly Average in the reference table), the RNC Data are set to: • RNC Detection Code = P (Enforcement Order, Non-Monthly Average) • RNC Detection Date = Monitoring Period End Date • RNC Resolution Code = 1 (NC - Unresolved RNC) • RNC Resolution Date = RNC Detection Date

  22. Example: RNC Values for Monthly Average

  23. Effluent Violations – RNC Resolution (continued) • Effluent Violations of Enforcement Action Limits • Linkage of an E90 Violation to a Final Order with a Compliance Schedule (sets linked Violations to Resolved Pending) - RNC Resolution Code = 3 (RP - Due to Formal Enforcement Action Final Order with Compliance Schedule) - RNC Resolution Date = linked Final Order Issued/Entered Date of linked Final Order • NPDES Closure of the Final Order linked to an E90 Violation (sets linked Violations to Resolved Pending with new date) - RNC Resolution Code = 3 (RP - Due to Formal Enforcement Action Final Order with Compliance Schedule) - RNC Resolution Date = linked Final Order NPDES Closure Date • NPDES Closure of the SOURCE Final Order of the E90 (sets Violations to Resolved) - RNC Resolution Code = 5 (RE - Resolved RP by NPDES Closure of Enf. Action Final Order with Comp. Schedule) - RNC Resolution Date = SOURCE Final Order NPDES Closure Date

  24. Auto and Manual RNC Detection and Resolution Types of Violations and whether they have Auto or Manual RNC Detection and Resolution

  25. Permit RNC • RNC for a Permit is assessed on a quarterly basis to produce the QNCR • ICIS–NPDES will assess the Violations for a Permit based on the RNC Detection Code, RNC Detection Date, RNC Resolution Code, and RNC Resolution Date and will assign the automatic Permit RNC Status Flag • Every quarter the Permit and its violations are evaluated and given a ranking • When a Permit has one or more RNC violations in a quarter, the Permit itself is flagged for that quarter • The QNCR quarters are equivalent to fiscal quarters

  26. Permit RNC Status Codes in Hierarchy level

  27. Permit RNC Status • Permit RNC Status Section on the Basic Permit Information Screen

  28. Permit RNC • Permit RNC Status (icis_perm_rnc_history) • RNC Status (Automatic): calculated by ICIS during an Official or Unofficial RNC run based on the “worst” eligible violation for the permit (perm_rnc_auto_status_code). • Corrected RNC Status (Automatic): determined when a user invokes the process on the Permit screen for a past quarter (perm_rnc_corr_auto_status_code). • RNC Status (Manual): manually entered by the user during the current QNCR quarter (perm_rnc_man_status_code). • Corrected RNC Status (Manual): manually entered by the user after a QNCR quarter has officially been run to reflect information received/entered late (perm_rnc_corr_man_status_code).

  29. Permit RNC Status Overview • The job of the Permit RNC Status process is to: • Create quarterly Permit RNC Status Rows for each Permit in the system • Set the RNC Status (Automatic) for a Permit as a whole for each QNCR quarter based on the RNC status of its Violations • This process is run as part of either an Official or Unofficial RNC processing run on a scheduled basis. It can also be invoked by the user on the Permit Screen. • The system will assess each Permit’s Violations based on the following data elements: • Violation Code • RNC Detection Code • RNC Detection Date • RNC Resolution Code • RNC Resolution Date • The Permit will then be assigned a Permit RNC Status based on its worst Violation.

  30. Permit RNC Status – The Basic Rules • The Permit RNC Status process will generate Permit RNC Status rows for all Permits in the system with the exception of the following: • Master General Permits (both NPDES and Non-NPDES) • Unpermitted Facilities • Permits Terminated Prior to the start of the Quarter • Permits not originally Effective before the end of the Quarter • The process will evaluate the following Violations for each Permit to determine the Permit’s RNC Status for a given Quarter: • Noncompliant and Resolved Pending Violations with Detection Dates before the end of the Quarter • Resolved Violations with • Resolution Date => Quarter Start Date • Detection Date before the end of the Quarter

  31. Permit RNC Status • Explain how SNC and RNC are assigned to facilities for DMR Non-Receipt Violations • Permit RNC Status: • D - SNC DMR Non-Receipt Violation • N - RNC Violations Only

  32. Permit RNC Status • Whole Permitted Feature Sub process • D - SNC DMR Non-Receipt Violation • The only way to get the ‘D - SNC DMR Non-Receipt Violation’ code is to have an entire missing Permitted Feature by: • Identifying any Permitted Features||Monitoring Period End Date (MPED) combinations with DMR Non-Receipt Violations • For each Permitted Feature||MPED combination, the system counts: - Total Number of D80/D90 Violations - Total number of limited and required monitoring DMR values with stat base code of monthly average or non-monthly average (i.e., ref_statistical_base.monthly_average_flag = A or N) • If the Count is equal, and all of the Violations are Noncompliant (i.e., Resolution Code = 1), the entire Permitted Feature is Noncompliant • Example: NCRNC004|002|01/31/2018 (Will show examples)

  33. Permit RNC Status • Check Whole Parameter Sub process • N - RNC Violations Only • This sub process will find out if there is any whole Parameter Noncompliant (with D80/D90) and set the Noncompliant Flag to True or False accordingly. For each distinct combination of NPDES ID, Permitted Feature, Monitoring Period End Date (MPED), Parameter Code and Monitoring Location Code, find out the total number of D80/D90 and the total number of limited and required monitoring DMR values which have a statistical base code monthly average flag of A or N. If the count is equal, then check if any of the D80/D90s does not have RNC Resolution Code in (1, A). If there are any DMR Non-Receipt Violations associated with a DMR value that has NODI code = L, then whole parameter cannot be set. If it is true, then the whole parameter is NC. • Example: NCRNC005|002|01/31/2018 (Will show examples)

  34. Submitted Questions – this screen will be removed 1. Explain how SNC and RNC are assigned to facilities for DMR Non-Receipt Violations 2. Review how the Detect Date for Non-Receipts is 2 months after the MPDED (ex. A non-receipt date for October 2017 would have a January detect date, and be in Quarter 2, not Quarter 1) 3. Explain how NODIs that are “invalid” would show up in RNC (including which quarter they would be in) • Invalid NODI • If an Invalid NODI code is entered (i.e., REF_NODI.VALIDATION_FLAG = N), then the presence of NODI and the DMR Value Received Date does not suppress DMR Non-Receipt generation • DMR Non-Receipt Violations due to invalid NODI will have to be manually resolved by the user or linked to a Final Order – they cannot get a 2 Resolution Code

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