Limit Sets Limit Sets Defined

Presentation on theme: "Limit Sets Limit Sets Defined"— Presentation transcript:

Slide1

Limit SetsSlide2

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 WinterHigh production volume vs low production volumeFrequency of reporting (monthly, quarterly, yearly, etc)Limit Sets define Discharge Monitoring Reports (DMRs) What date range will be covered on the DMR formWhen the first DMR will begin when the DMRs are due to the Agency

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Limit Set Example

001 has monthly, quarterly, and yearly requirements

Create 3 Limit Sets - For Expected DMRs and Generation of Violations

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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

YearlySlide4

Actual Permit Language

General Foods, Permitted Feature 001

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Types of Limit Sets

There are two types of Limit Sets

Traditionally, Limit Sets are ScheduledDMRs are expected on a predictable basis Non-Receipt Violations are generated when 30 days late

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Unscheduled Limit Sets

Special Regulatory Programs may need Unscheduled Limit Sets

DMRs are entered on an as-received basisThere is no DMR Due DateDMR Non-Receipt Violations are never generatedUnschedule Limit Sets support the variable reporting needs of the Storm Water, Biosolids, and other programsAppropriate for event-based reporting, rather than a continuous discharge

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Comparison Chart

Scheduled Limit Sets

Unscheduled Limit Sets

Number of Report Units

Number of Report Units

Number of Submission Units

Modification Effective Date

Initial Monitoring Date

Modification Type

Initial DMR Due Date

Modification Effective Date

Modification Type

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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 dataScheduled Limit Sets get an Expected DMR Schedule when at least one Limit has been added to the Limit SetExpected DMRs are created one-at-a-time as they are received for Unscheduled Limit SetsThe Expected DMR Schedule will be discussed more during the Limits and DMR units

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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 quarterlyare the DMRs due on a specific date? (check permit)Yes. “no later than the 15th of the following month”Scheduled or Unscheduled?Scheduled

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Example of Report Units

Example of an actual permit with different reporting frequencies

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LimitsSlide12

Permit Limits in ICIS

How can I tell in ICIS if the Permitted Feature and Limit Sets have been entered?

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Parameter Limit Defined

A Limit is a parameter (something to be measured) with associated numerical limits or monitoring requirements for a release to the environment from a permitted feature

A parameter may be one of the followingChemical (e.g., phosphorus)Biological organism (e.g., fecal coliform)Physical condition (e.g., temperature)Characteristic (e.g., pH)

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Parameter Limits on DMR Form

Limit Values determine the data a Permittee has to report on DMRs for a parameter

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ICIS Columns Defined

ICIS refers to the value fields as Q1, Q2, C1, C2 and C3.

The terms “Average”, “Maximum” and Minimums” have no meaning as the Statistical Base code defines the type measurement taken for each value field. ICIS is more flexible than the DMR form, and will allow up to 5 minimums, 5 averages, or 5 maximum values for each parameter limit.

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Q1

Q2

C1

C2

C3Slide16

Limit Segments

Limits are organized within a Limit Set by Parameter (e.g., Ammonia Nitrogen)A Parameter is defined as a collection of Limit Segments that have matchingNPDES IDPermitted Feature IdentifierLimit Set DesignatorParameter CodeMonitoring Location CodeSeason ID

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Limit Segments

Segments are the actual Limits or monitoring requirements for a Parameter Usually Segments for a Parameter have different Limit Start and/or End DatesThere are three kinds of Limit SegmentsBase LimitsPermit Modification Limits (PML)Enforcement Action Limits (EA)

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Limit Segments

Base Limits are the Limits initially issued with the Permit

PMLs are Limits that result from a Permit ModificationEA Limits are the Limits applied by an Enforcement Action’s Final OrderLimits for Segments within a Parameter can overlap each otherWhen Limits overlap, there is a hierarchy that determines which segment applies for a given point in timeEA Limits supercede PMLs and Base LimitsPMLs supercede Base Limits

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Limit Segments for Arsenic

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Start

End

End

End

Start

Start

Value = 4

Value = 2

Value = 7

Base Limit

PML

Enforcement Action Limit

PARAMETER

(VA0000001, 001-A, Arsenic, Effluent Gross, Season 1)Slide20

Limit Segments

ICIS Example of Limit SegmentsBase LimitModificationEnforcement Action Limit

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Test Your Knowledge

Which limit is in effect for the month? Base, Mod, or Enf ActionJuly 2011March 2012September 2010December 2010October 2015

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Test Your Knowledge - Answer

Which limit is in effect for the month? Base, Mod, or Enf ActionJuly 2011 Enf ActionMarch 2012 ModSeptember 2010 BaseDecember 2010

Enf

Action

October 2015 Mod

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Expected DMRs

An Expected DMR Schedule is generated when Limits are added to a Limit SetParameters with a limit value or monitoring requirement will show on the expected DMRs

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Limit Segments

If DMR data have been received for a segment and a new segment is added, the data may be moved to the new segmentUpdates to Limits such as changing dates and months will result in updates to the Expected DMR ScheduleAny changes to the Expected DMR Schedule may result in updates to Violations for the received DMR dataAny change that will result in orphaned received DMR data will be rejected

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Limit Segments

When the Permit’s Expiration Date is reached its Limits remain in effectBase and PML segments with Limit End Date = Permit Expiration date are eligible for Administrative ContinuanceIf more than one Segment is eligible for Administrative Continuance for a Parameter, the one highest in the hierarchy will be continued

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