Limit Sets groups monitoring amp 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 ID: 674508
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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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