UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460

 May 22, 2006 

OFFICE OF 

ENFORCEMENT AND 

COMPLIANCE ASSURANCE 

MEMORANDUM 

SUBJECT: Final Single Event Violation Data Entry Guide for the Permit Compliance 

System (PCS) 

FROM: David A. Hindin, Director /s/ 

 Enforcement Targeting, and Data Division (ETDD) 

TO: Regional Water Branch Chiefs 

Regional Water Enforcement Branch Chiefs 

On September 30, 2005, we sent you an Interim Single Event Violation Data 

Entry Guide for PCS. Single event violations are one-time or long-term violations 

discovered by the permitting authority typically during inspections (and not through 

automated reviews of Discharge Monitoring Reports). The attached document is the final 

version of this Data Entry Guide, which includes changes made in PCS in response to 

comments received in the last five months, and will serve as the key reference document 

for tracking these violations in PCS. While none of the changes were major, we updated 

the Interim Single Event Violation Data Entry Guide to maintain its accuracy regarding 

several revised codes in the database. To summarize the key steps that have led to this 

point: 

• The list of single event violation codes was revised through a series of meetings 

and conference calls with States and Regions in Fall 2004. These new codes were 

added to PCS in March 2006, and we will also include them in the initial release 

of ICIS-NPDES. 

• This subject was presented at the last two PCS National Meetings, in 2004 and 

2005, with States and Regions in attendance. 

• The Interim Data Entry Guide was discussed on a series of conference calls with 

EPA Regions in May and June of 2005. 

• The Interim Single Event Violation Data Entry Guide for PCS was issued to 

Regional Water and Enforcement Branch Chiefs for distribution to their States on 

September 30, 2005. 

The Final Single Event Violation Data Entry Guide for PCS includes edits to 11 

single event violation codes descriptions, and the deletion of one code. This is reflected 

in Attachment 1, the Single Event Violation code table. There have also been some 
minor corrections to update and reorganize the information provided in Attachment 5, 

“Entering and Tracking Single Event Violations, Linking Them to Enforcement Actions, 

and Detecting and Resolving RNC in PCS”. Lastly, the Final Single Event Violation 

Data Entry Guide for PCS includes the revision of Section 7 “wet weather” violation 

scenarios to refer to specific universes such as CAFOs, CSOs, SSOs, and Storm Water. 

Please note that single event violations are currently a required (WENDB) data 

element for NPDES major and PL 92-500 (construction grant) non-major facilities in 

PCS. At facilities whose permits do not require DMRs, single-event violations are the 

ONLY source of national data regarding violations that are discovered by the permitting 

authority. The development and distribution of this Data Entry Guide emphasizes the 

growing importance of maintaining an electronic record of inspection-based violations. 

Now that the Single Event Violation Data Entry Guide is final, my Division will 

be monitoring the entry of single event violations. This is already one of the State 

Review Framework metrics. For calendar year 2005, we have noticed that only Regions 

3, 4, 6, and 8 entered any into PCS. In allocating our resources to manage core programs, 

it is important that we can demonstrate the outcome of our compliance monitoring 

investments. Tracking the violations arising from these investments will help us to 

demonstrate the importance of these activities. We realize that this will be somewhat of a 

“culture change” for the NPDES program in terms of data entry; however we believe 

that, with the new violations codes and this Data Entry Guide, any initial difficulties in 

adjusting to electronic tracking of these violations will be overcome to reveal the 

advantages of this approach. 

Please distribute the attached document to the appropriate Regional and state 

managers and data entry staff. Any questions may be directed to Amelie Van Den Bos at 

vandenbos.amelie@epa.gov. 

Attachments (1) 

cc: Kate Anderson, OCE 

Ken Gigliello, OC 

Daniel Palmer, OC 

Lucy Reed, OC 

PCS Data Stewards 
SINGLE EVENT VIOLATION DATA ENTRY GUIDE FOR THE 

PERMIT COMPLIANCE SYSTEM (PCS) 

May 22, 2006 

Table of Contents Page 

1. Introduction 

2. Background 

3. Entering a Single Event Violation 

4. Reportable Non-Compliance/ Significant Non-Compliance (RNC/ SNC) 

Determination 

5. Relationship of Single Event Violations to Quarterly Non-Compliance Report 

(QNCR) and Enforcement and Compliance History Online (ECHO) 

6. Traditional Program and Pretreatment Scenarios for DMR-submitting 

Facilities 

7. Violation Tracking for CAFOs, CSOs, SSOs, and Storm Water 

1 

1 

2 

3 

3 

6 

9 

Attachments: 

1 - Available Single Event Violation codes 

2 - Available RNC Detection codes 

3 - Available RNC Resolution codes 

4 - Available QNCR Status codes 

5 - Entering and Tracking Single Event Violations, Linking Them to Enforcement 

Actions, and Detecting and Resolving RNC in PCS 

USEPA/OECA/OC/ETDD 
1. Introduction 

Single event violations are violations of the CWA’s NPDES requirements that are 

documented during a compliance inspection, reported by the facility, or determined 

through other compliance monitoring methods by the permitting authority. Examples of 

single event violations include failure to obtain required permit, sampling wastewater in 

an unauthorized location, or an unauthorized wastewater bypass or discharge. Single 

event violations do not include violations generated automatically by either PCS or ICIS 

(e.g., effluent limit violation from a DMR, or compliance schedule violations). 

Single event violations include one-time events and long-term violations. Single-event 

violations are used by EPA to maintain and report the compliance status of a facility for 

violations that are not automatically flagged by the database. Methods of detection of 

single event violations include inspections, information collection requests, state/tribal 

referrals, DMR comments, annual reports, non-compliance reports, and other reports 

required under the permit, enforcement order, or regulation, facility self-audits, and 

citizen complaints. In the case of unpermitted facilities, single event violations may be 

entered in response to violations of CWA NPDES regulations. In certain cases, single 

event violations may also include violations of the NPDES permit or an enforcement 

order. The data are critical to forming an historical record of inspection findings and 

compliance determinations that are made by the NPDES permitting authority. 

Single Event Violations are required to be entered into the national Permit Compliance 

System (PCS) as defined in the Water Enforcement National DataBase (WENDB list) for 

NPDES major and PL 92-500 non-major permittees. EPA strongly encourages the entry 

of single-event violations at non-major facilities; however, at this time, there is no 

requirement for such entry. The purpose of this document is to provide guidance and 

clarification on the data entry and use of Single Event Violations in PCS so that the data 

elements are maintained in a nationally consistent way. Regions and states that are 

entering data into the single-event fields of PCS should follow this Guide. 

2. Background 

Violation tracking is important because it creates an historic electronic record of 

inspection or compliance monitoring findings. Tracking inspection results can impact 

future enforcement decisions, particularly when a permittee continues to exhibit the same 

violation over the course of several years. Repeat violations may lead the permitting 

authority to escalate or reclassify the violation (e.g. by designating Reportable NonCompliance or Significant Non-Compliance). Electronic documentation of violations 

also improves the accuracy of public information, particularly since the lack of any 

violations in the system is normally interpreted as full compliance by the database user. 

To harmonize the tracking of single-event violations with the violations and program 

areas that are of most importance to the NPDES program, EPA has taken several steps to 

improve reporting and tracking. First, the original list of single-event codes were redesigned to remove redundancies and to match more closely to program priority areas 

(see Attachment 1 for the list). Secondly, this guide has been prepared to offer practical 

1 
examples on how the data should be maintained in the system. The authorized permitting 

authority should consult the list of reportable single-event violations (Attachment 1), and 

enter any listed violation that is determined through inspections, review of self-reported 

information, or other means of discovery. If the permitting authority has the need to 

track additional violations beyond those listed on the table, the system provides the 

flexibility to enter an “other violation” code, which can be augmented with comment 

field narrative. 

3. Entering a Single Event Violation 

Single Event Violations must be entered manually (manually means the system does not 

automatically generate the violation using DMR information) by staff at the appropriate 

permitting authority. To enter a Single Event Violation into PCS, the permitting 

authority (i.e., region, state, tribe) needs to identify the following— 

• Either the specific permit that is being violated (i.e., NPDES ID) or, in the case 

where there is no permit, the violating facility or site (i.e., Unpermitted ID) 

• The type of the violation (Attachment 1 provides a list of codes and definitions) 

• The date on which the violation occurred or, if this is not available, date on which 

the violation was discovered (i.e., Violation Date). 

This is the minimum information required to enter a Single Event Violation for a specific 

permit in PCS. This can be accomplished through either batch or online (i.e., Web) data 

entry. These data elements in combination form a unique key by which the Single Event 

Violation can later be identified and retrieved in PCS. 

OECA recommends that single-event violations discovered by the permitting authority 

and listed on the single-event violation table should be: 

(1) tracked as a single event violation, 

(2) linked to the inspection if applicable, 

(3) if a quarterly non-compliance status is needed, placed in RNC or SNC (by entering 

an RNC detection code - see Attachment 2 - that will trigger “reportable 

noncompliance”), and 

(4) resolved (pending) with either a formal enforcement action or penalty order (linked 

to the violation), and a compliance schedule (if appropriate). 

Note: If the violation is entered for tracking purposes and will not receive action, 

steps 3 and 4 are not necessary. 

4. Reportable Non-Compliance/ Significant Non-Compliance (RNC/ SNC) 

Determination 

Should the region, state, or tribe determine that the Single Event Violation merits 

classification as RNC or SNC (e.g. meeting SNC definition), the RNC Detection 

Code/Date (see Attachment 2) should be entered. Once an enforcement action has been 

2 
taken, the RNC Resolution Code/Date (see Attachment 3) can be entered manually or 

automatically as a result of linking that Single Event Violation to a formal Enforcement 

Action Final Order that includes a Compliance Schedule. For more technical details, 

please see Attachment 5. 

5. Relationship of Single Event Violations to Quarterly Non-Compliance Report 

(QNCR) and Enforcement and Compliance History Online (ECHO) 

The following statements apply to QNCR processing and single event violation tracking 

in PCS: 

- facilities with any permit violation during a quarter are considered in violation 

- the “QNCR Status” field (see Attachment 4 for codes) is used in PCS to track 

the quarterly non-compliance status for both major and non-major permits; 

however, only major facilities with RNC or SNC-level violations will make 

the QNCR 

- non-major facilities that have violations will not go on the QNCR, (unless the 

permitting authority re-designates the facility as a major); however, the 

facility-level noncompliance status will be publicly available (via FOIA or 

web site such as ECHO) 

The PCS Quality Assurance Guidance Manual states that single event violations should 

be entered into PCS within 5 working days of notification of the violation event. If this 

does not happen, and an RNC or SNC level single event violation is entered retroactively 

after the quarter has been analyzed by PCS for RNC/SNC determination, then the user 

will be expected to manually populate the facility level QNCR status values with either N 

or E as appropriate for that quarter (see Attachment 4), in addition to the RNC detection 

and resolution codes. 

3 
The table below describes the most common PCS data entry progression as it relates to 

the violation review process outlined in the Enforcement Management System (EMS). 

All data entry should be done according to the targets for data quality set forth in the PCS 

Quality Assurance Guidance Manual. 

Table 1. Data Progression Example 1 

Activity Performed PCS Data Entry In Violation In SNC 

A Compliance 

Monitoring 

Enter Inspection - -

B Non-Compliance 

Determined 

Enter appropriate Single Event 

Violation(s) and link to 

Inspection record 

Yes No 

C SNC Determined Add appropriate RNC 

Detection and Resolution Code 

to Violation record Yes 

Pending 

systemgenerated 

RNC/ 

SNC 

Status 

D Notice of Violation 

(NOV) sent 

Add Enforcement Action Code 

and link to Violation record 

Yes 

Pending 

systemgenerated 

RNC/ 

SNC 

Status 

E RNC/SNC Processing System-generated. No data 

entry required. Yes Yes 

F SNC Addressed with 

Formal Enforcement 

Action and 

Compliance Schedule 

Enter Formal Enforcement 

Action and Compliance 

Schedule, and link to Violation 

for automatic RNC/SNC 

resolution 

Yes 

Systemgenerated 

“Resolved 

Pending” 

status 

G Completion of 

Compliance Schedule 

Complete schedule, close out 

action, and put end date on 

single event violation 

No No 

4 
Another variation on this progression is presented in the following table, where a facility 

returns to compliance before it is designated in SNC. 

Table 2. Data Progression Example 2 

Activity Performed PCS Data Entry In Violation In SNC 

A Compliance 

Monitoring 

Enter Unpermitted Facility 

data - -

B Non-Compliance 

Determined 

Enter appropriate Single Event 

Violation(s) “Failure to Apply 

for a Permit” 

Yes No 

C SNC Determined 

Add appropriate RNC 

Detection and Resolution Code 

to Violation record 

Yes 

Pending 

systemgenerated 

RNC/ SNC 

Status 

D Notice of Violation 

(NOV) sent 

Add Enforcement Action Code 

and link to Violation record Yes 

Pending 

systemgenerated 

RNC/ SNC 

Status 

Facility applies for a permit 30 days later. 

E Permit Application 

Enter Permit application data 

and link to Unpermitted 

Facility 

- -

F Non-compliance 

Resolved 

Put end date on single event 

violation for unpermitted 

facility and add manual RNC 

Resolution Code 

No 

Pending 

systemgenerated 

RNC/ SNC 

Status 

G 

RNC/ SNC 

Processing at 

Unpermitted Facility 

System-generated. No data 

entry required. No 

Systemgenerated 

“Resolved” 

status 

5 
The following scenarios demonstrate how PCS should be used to document a complete 

and consistent set of “pipeline” data (inspection, violation type/duration, action) that is 

necessary for inspection-driven programs. For “actionable” single event violations, 

authorized programs should use SNC designations consistent with the EMS. All 

scenarios assume timely data entry according to the standards set forth in the PCS Quality 

Assurance Guidance Manual. 

6. Traditional Program and Pretreatment Scenarios for DMR-submitting Facilities 

(practices for facilities that have automatic QNCR generation - major or non-major 

standard permits) 

Scenario 1 - Violation found via inspection at facility that submits DMRs - action 

required. 

Facts: On 1/1/05, state determines that sampling has been improperly 

conducted since 9/1/04, which produces DMRs that are not correct. State 

determines that detected violation has “masked” true SNC. Facility agrees to 

fix problem for future quarters beginning in the April 2005 quarter. Formal 

administrative enforcement action is completed on 5/1/05. 

PCS Data Entry: After the 1/1/05 inspection (INSP, INMY) is completed, the 

permitting authority enters the SEV (SVCD) and selects 9/1/04 as the violation 

date (SVDT). [Note that by entering the violation date as 9/1/04, this assumes 

the agency wants to “backdate” the violation to when it started.] The code 

“INS” may be entered into the SEV user-defined field (RDS1) to indicate that 

the violations were discovered through an inspection. Although the singleevent violation date is recorded as 9/1/04, the RNC detection code (SNCS) is 

entered with the detection date (SNDS) of 1/1/05. RNC entry will trigger SNC 

(QNCR status code=E) in the Jan-Mar reporting quarter. State takes a formal 

enforcement action (ENAC) on 5/1/05 (ENDT) and links the action to the 

single-event violation using EVTP/EVSC/EVSD fields in the enforcement 

action key record. RNC may be manually resolved (SRCS) with a date of 

5/1/05 (SRDS) and the enforcement action should be closed. If the 

enforcement action includes a response due from the facility that corrective 

measures have been taken, a compliance schedule (EVNT, DTSC) can be 

entered to resolve the SNC. The user enters compliance schedule code 

“compliance with final event” (62099), which moves the facility into 

“Resolved pending” until the enforcement action is closed (with ENST=CL 

and ESDT). 

6 
Scenario 2 - One time significant and preventable spill at major occurs with 

fishkill. 

Facts: Facility operator error causes spill on 1/1/05. Region determines spill is 

significant and that a penalty order is needed on 3/1/05. No injunctive relief 

was needed. 

PCS Data Entry: SEV code (SVCD) and date (SVDT) of 1/1/05 is entered. 

RNC Code (SNCS=“J”) entered indicating “unpermitted discharge” (other 

codes are available for different situations) that will trigger SNC (QNCR status 

code=E) in that quarter. The RNC detection date (SNDS) corresponds to the 

date that EPA first found out about the spill. Penalty order (ENAC) on 3/1/05 

(ENDT) is entered and tied to SEV in system using EVTP/EVSC/EVSD fields 

in the enforcement action key record. Since penalty actions don’t resolve 

SNC, the agency would manually resolve SNC by adding a resolution code 

(SRCS) and date (SRDS) of 3/1/05. Penalty order is closed out with status 

ENST=CL and date (ESDT). 

Note: If injunctive relief was needed, a formal action with extended 

compliance would be entered in addition to the penalty order. 

Scenario 3 - Multiple spills that are actionable are determined during facility audit 

or review of files. 

Facts: 150 spills are determined through a file review. 

PCS Data Entry: After the 1/1/05 inspection (INSP, INMY) is completed, 

agencies should enter two SEV “D0017” code entries for “Violation specified 

in comment”, with SVDT dates corresponding to the dates of the first and last 

spill. The code “INS” may be entered into the SEV user-defined field RDS1 

to indicate if the violations were discovered through an inspection and the 

SEV user-defined field RDS2 may be used to indicate “first spill” and “last 

spill” with the number of spills written afterwards. If appropriate, both SEVs 

would have RNC detection codes (SNCS). 

Note: Ideally, EPA recommends that all reported spills are entered into the 

system as they occur. This data will demonstrate a pattern of non-compliance 

which should be a factor in determining whether to take an enforcement 

action and what type of action to take. However, if this is not possible, we 

recommend “backdating” the noncompliance. In cases where the true 

detection date for the violation is not known, the earliest available date of 

discovery (e.g. inspection, data entry) should be used. 

7 
Scenario 4 - Minor violations found at facility requiring follow-up with 308 letter, 

but no action. 

Facts: Violations found on 1/1/05. On 2/1/05, inspector sends 308 letter to 

obtain more information in order to make a RNC determination. Response is 

due on 3/1/05, and inspector receives response to letter on 2/15/05. No formal 

action taken. 

PCS Data Entry: SEV code (SVCD) and date (SVDT) of 1/1/05 entered. 

308 letter should be recorded as enforcement action code (ENAC=10) with 

date (ENDT) of 2/1/05, and linked to SEV using EVTP/EVSC/EVSD fields in 

the enforcement action key record. Response due date (ERDT) should be 

entered as 3/1/05, with response received date (EADR) of 2/15/05. System 

will not automatically track need for report by 3/1, however this information 

should be entered for purposes of data completeness. 

Scenario 5 - Pretreatment Violation Tracked to Resolution with No Action 

Needed. 

Facts: The EPA Region is the control authority for a state in which an 

inspector finds a categorical industrial user (CIU) discharging to a publiclyowned treatment works (POTW) without an approved pretreatment program 

and not reporting as required under federal regulations, on 1/1/05. The 

reporting violation is corrected and verified (without inspection) on 3/1/05, no 

enforcement action needed. 

PCS Data Entry: Create a record by entering pertinent facility and address 

WENDB data elements as required by the system (i.e., NPID, FNMS, SIC2, 

CFRC, RNAM, RCTY, RSTT, RTEL, RZIP). Enter system-required 

violation code (SVCD) and date (SVDT) of 1/1/05. The code “INS” may be 

entered into the SEV user-defined field (RDS1) to indicate that the violation 

was discovered through an inspection. RNC detection code (SNCS) and date 

(SNDS) left blank. 

Scenario 6 - Tracking a facility in PCS as a known Categorical Industrial User, 

i.e., already is being tracked in PCS. 

Facts: During a Pretreatment inspection an inspector finds violations on 

1/1/05 for failure to submit Periodic Compliance Reports (PCR), not 

monitoring for all the required pollutants, not applying right standards, or 

sampling methods. Agency decides on 2/1/05 that violations are serious and 

action is required. Formal administrative action is taken on 3/1/05. The CIU 

submits the reports and corrects all the violations on 3/31/05. 

PCS Data Entry: Enter violation code(s) (SVCD) and date(s) (SVDT) of 

1/1/05 for each single event violation. The code “INS” may be entered into 

8 
the SEV user-defined field (RDS1) to indicate that the violation(s) was 

discovered through an inspection. On 2/1/05, manually enter RNC detection 

code(s) (SNCS) “Q” (see Attachment 2) and dates (SNDS) of “02/01/05”. 

Enter formal action (ENAC) on 3/1/05 (ENDT), enforcement action file 

number (ERFN), and tie the action to the single event violation(s), using 

EVTP/EVSC/EVSD fields in the enforcement action key record. Extended 

compliance schedule with compliance milestone (EVNT) and compliance 

schedule file number (CSFN) is entered indicating reports and corrective 

actions must be implemented and received by 3/31/05 (DTSC). Single event 

violations automatically become “resolved pending” (SRCS) due to entry and 

linkage of the formal enforcement action. After compliance with the 

enforcement action is achieved, it is closed out (ENST=CL & 

ESDT=03/31/05). Single event violations are automatically resolved with 

closeout of formal enforcement action and compliance schedule is completed 

using DTAC/DTRC. 

7. Violation Tracking for CAFOs, CSOs, SSOs, and Storm Water 

"Wet weather” regulated entities refer collectively to storm water runoff, discharges from 

concentrated animal feeding operations (CAFOs), combined sewer overflows (CSOs), 

and sanitary sewer overflows (SSOs) that are regulated under the Clean Water Act 

(CWA), 33 U.S.C. §§ 1251 et seq., and the National Pollutant Discharge Elimination 

(NPDES) Program, under CWA § 1342. Frequently – but not always – discharges of 

pollutants from these operations are related to weather events. The discharges can be 

non-weather related as well, e.g., illegal dry weather overflows from combined and 

sanitary sewer systems. Because many of the point sources in these four program areas 

do not meet the definition of NPDES “major”, SNC does not currently apply. However, 

this guide provides a framework for how the permitting authority can use PCS to track 

these violations. As part of its effort to update the NPDES program, EPA – in close 

consultation with the states – is currently developing supplemental national enforcement 

guidance to identify, prioritize, and track significant non-compliance (SNC) in the 

CAFOs, CSOs, SSOs, and Storm Water program areas. When this effort is completed, 

these scenarios will be updated to reflect the new policy. 

There may be some situations at Wet Weather facilities when the violation is considered 

SNC-level AND there is an appropriate RNC/SNC code combination (see Attachments 2 

and 3). In these situations, the authorized program could choose to make an SNC 

designation. When a single event violation occurs that will not be enforced against, 

OECA recommends that the permitting authority track this as a single event violation, but 

a RNC detection code is not needed. Entry of the single event violation will ensure an 

accurate database record, and will make EPA’s public access site reflect the inspection 

results. 

Note: All scenarios assume no other violation. 

9 
Scenario 7 - Violation Tracked to Resolution with No Action Needed. 

Facts: Inspector finds violation on 1/1/05. Violation is corrected and verified 

(without inspection) on 3/1/05, no enforcement action needed. 

PCS Data Entry: Violation code (SVCD) and date (SVDT) of 1/1/05 entered 

(system required). The code “INS” may be entered into the SEV user-defined 

field (RDS1) to indicate that the violation was discovered through an 

inspection. RNC detection code (SNCS) and date (SNDS) left blank. 

Scenario 8 - Violation detected with need for formal action. 

Facts: Inspector finds a violation on 1/1/05 for failure to submit report. On 

2/1/05, agency decides that violations are serious and action is required. 

Formal administrative action taken on 3/1/05. Facility submits report on 

3/30/05. 

PCS Data Entry: Violation code (SVCD) and date (SVDT) of 1/1/05 entered 

(system required). The code “INS” may be entered into the SEV user-defined 

field (RDS1) to indicate that the violation was discovered through an 

inspection. On 2/1/05, RNC detection code (SNCS) “F” (see Attachment 2) 

and date (SNDS) is entered indicating violations will trigger RNC (QNCR 

status code=N). Formal action (ENAC) tied to single event violation on 3/1/05 

(ENDT), using EVTP/EVSC/EVSD fields in the enforcement action key 

record. Compliance schedule milestone (EVNT) is entered indicating report 

must be received by 3/30/05 (DTSC). On 3/30/05 (ESDT), the enforcement 

action is closed out (ENST=CL), resulting in RNC resolution (SRCS) for this 

violation. Compliance schedule is completed using DTAC/DTRC. 

Scenario 9 - Violation is detected and then corrected before a penalty order is 

taken. 

Facts: Same scenario as #2, except penalty action is chosen, and facility 

returns to compliance on 2/1/05 (before the penalty action is taken). 

PCS Data Entry: Violation code (SVCD) and date (SVDT) of 1/1/05 entered 

(system required). The code “INS” may be entered into the SEV user-defined 

field (RDS1) to indicate that the violation was discovered through an 

inspection. Penalty action (ENAC) on 3/1/05 (ENDT), and tied to single event 

violation using EVTP/EVSC/EVSD fields in the enforcement action key 

record. Penalty order is closed out with status ENST=CL and date (ESDT). 

User Option A - RNC detection code (SNCS) is not entered since the agency 

decided an administrative action was not needed. User Option B -

alternatively, the user could enter an RNC detection code (SNCS) and then 

manually resolve it (with SRCS/SRDS) if at the time they made the 

10 
determination they were unsure whether an administrative or penalty action 

would be taken. 

Scenario 10 - Multiple violations discovered during facility inspection, action taken, 

long-term compliance schedule established. 

Facts: Violations detected on 1/1/05 and still continuing. State takes formal 

action against facility on 3/1/05 and puts the facility on a compliance schedule. 

PCS Data Entry: Violation codes (SVCD) and dates (SVDT) of 1/1/05 

entered (system required). The code “INS” may be entered into the SEV userdefined field (RDS1) to indicate that the violations were discovered through an 

inspection. RNC codes (SNCS) and detection dates (SNDS) of 1/1/05 entered. 

User enters enforcement action code (ENAC) and date (ENDT) of 3/1/05, and 

enters a compliance schedule (EVNT) on 6/1/05 (DTSC). Both are linked to 

the SEV records, using EVTP/EVSC/EVSD fields in the enforcement action 

key record. This puts the facility into the Resolved Pending category from 

January until the enforcement action is closed with activity status “CLS”. The 

compliance schedule actual/achieved dates are entered to complete the 

schedule. Individual SEVs may be manually resolved (SRCS, SRDS); this 

does not affect the facility quarterly non-compliance status code, which will be 

“resolved pending”. 

11 
Attachment 1 - Available Single Event Violation codes 

The codes and descriptions listed here may change slightly over time. Please consult PCS system documentation ICIS-NPDES for updated lists. 

Code Description Definition A0018 Effluent Violations - Approved Bypass A0013 Effluent Violations - Failed Toxicity TestA0023 Effluent Violations - Industrial Spill A0017 Effluent Violations - Inspection sample above historic DMR range A0022 Effluent Violations - Narrative Effluent Violation visible sheen/ scA0012 Effluent Violations - Numeric effluent violation A0016 Effluent Violations - Reported Fish Kill A0011 Effluent Violations - Unapproved Bypass A0015 Effluent Violations - Unauthorized Discharge of Brine B0019 Management Practice Violations - Best Management Practice Deficiencies B0024 Management Practice Violations - Biosolids/Sewage Sludge Violation (Part 503) B0026 Management Practice Violations - Failure to Allow Entry B0012 Management Practice Violations - Failure to Conduct Inspections B0027 Management Practice Violations - Failure to Develop Adequate SPCC Plan B0017 Management Practice Violations - Failure to develop any or adequate SWPPP/SWMP Includes Failure B0011 Management Practice Violations - Failure to Develop/Enforce Standards B0028 Management Practice Violations - Failure to Implement SPCC Plan B0018 Management Practice Violations - Failure to Implement SWPPP/SWMP Includes failure B0041 Management Practice Violations - Failure to Maintain Records B0040 Management Practice Violations - Improper Chemical Handling B0023 Management Practice Violations - Improper Land Application (non-503, non-CAFO) B0020 Management Practice Violations - Improper Operation and Maintenance B0025 Management Practice Violations - Inflow/Infiltration (I/I) B0021 Management Practice Violations - Laboratory Not Certified B0022 Management Practice Violations - No Licensed/Certified Operator B0042 Management Practice Violations - Violation of a milestone in an order C0017 Monitoring Violations - Analysis not Conducted C0011 Monitoring Violations - Failure to Monitor for non-Toxicity Requirements C0021 Monitoring Violations - Failure to Monitor for Toxicity Requirements C0015 Monitoring Violations - Frequency of Sampling Violation 
Code Description Definition 

C0018 Monitoring Violations - Improper Analysis or Lab Error C0014 Monitoring Violations - Invalid/Unrepresentative Sample C0016 Monitoring Violations - No Flow Measurement Device D0014 Permitting Violations - Application Incomplete D0011 Permitting Violations - Discharge Without a Valid Permit D0012 Permitting Violations - Failure to submit required permit application information This is a CWA D0015 Permitting Violations - Failure to Pay Fees D0016 Permitting Violations - Failure to Submit Timely Permit Renewal Application D0013 Permitting Violations - Unapproved Operation D0017 Permitting Violations - Violation Specified in Comment C0012 Pretreatment - Baseline Monitoring Report Violation B0P12 Pretreatment - Failure to Conduct Inspections B0P11 Pretreatment - Failure to Develop/Enforce Standards B0013 Pretreatment - Failure to Enforce Against I/U B0015 Pretreatment - Failure to Establish Local Limits C0013 Pretreatment - Failure to Establish Self-Monitoring Requirements B0014 Pretreatment - Failure to Issue SIU Permits B0016 Pretreatment - Failure to Meet Inspection and Sampling Plan for SIUs E0015 Pretreatment - Failure to submit required report (non-DMR) B0P40 Pretreatment - Improper Chemical Handling A0014 Pretreatment - IU Violation of Pretreatment Standards E0017 Reporting Violations - Failure to Notify E0012 Reporting Violations - Failure to Submit DMRs E0016 Reporting Violations - Failure to submit required report (non-DMR, non-pretreatment) E0013 Reporting Violations - Improper/ Incorrect Reporting E0011 Reporting Violations - Late Submittal of DMRs E0014 Reporting Violations - Noncompliance with Section 308 Information Request B0A19 WW CAFO - Best Management Practice Deficiencies B0038 WW CAFO - Direct Animal Contact with Waters of US D0A11 WW CAFO - Discharge without a permit B0A12 WW CAFO - Failure to Conduct Self-Inspections should include o

NOT date based 

B0032 WW CAFO - Failure to Develop or update NMP B0033 WW CAFO - Deficiencies in Implementing the NMP/ permit 
Code Description Definition 

B0A41 WW CAFO - Failure to Maintain Records or Meet Record Keeping Requirements includes SNC c

keeping require

B0043 WW CAFO - Failure to inform permitting authority of significant NMP changes C0A11 WW CAFO - Failure to Monitor D0A12 WW CAFO - Failure to submit required permit application or identifying information This is a CWA C0019 WW CAFO - Failure to Test Manure or Soil, as required B0A40 WW CAFO - Improper Chemical Handling B0A23 WW CAFO - Failure to implement land application BMPs, not including buffers/ setbacks B0039 WW CAFO - Improper Waste Management (not including land application) B0037 WW CAFO - Improper Mortality Management B0036 WW CAFO - Improper O&M E0A13 WW CAFO - Improper/Incorrect reporting B0034 WW CAFO - Insufficient Buffers/Setbacks B0035 WW CAFO - Insufficient Storage Capacity A0A22 WW CAFO - Narrative effluent violation E0A16 WW CAFO - No Annual or Other Required Report Submitted C0020 WW CAFO - No Depth Marker in Storage Pond E0A14 WW CAFO - Noncompliance with section 308 Information Request A0A12 WW CAFO - Numeric effluent violation Alternative techA0019 WW CAFO - Production Area Runoff B0A42 WW CAFO - Violation of a milestone or final compliance date in an order 

As stated in 40 means the inten

A0C18 WW CSO - Approved Bypass streams from an

facility. In CSO can only occur atreatment plant. For CSOs, Any 

A0024 WW CSO - Dry weather overflow combined sewag

weather 

B0030 WW CSO - Failure to Develop or Submit Adequate Long Term Control Plan (LTCP) B0031 WW CSO - Failure to Implement Long Term Control Plan (LTCP) B0029 WW CSO - Failure to Implement Nine Minimum Controls (NMCs) BC291 WW CSO - Failure to implement required NMC #1(Proper operation and maintenance) BC292 WW CSO - Failure to implement required NMC #2 (Maximum use of the collection system) 
Code Description Definition 

Includes failure 

BC293 WW CSO - Failure to implement required NMC #3 (Review pretreatment requirements) CSO discharge 

IU pretreatment 

BC294 WW CSO - Failure to implement required NMC #4 (Maximization of flow) 

includes failure 

BC295 WW CSO - Failure to implement required NMC #5 (Elimination of dry weather flow) prevent dry wea

include actual d

BC296 WW CSO - Failure to implement required NMC #6 (Control of solids) Includes floatabBC297 WW CSO - Failure to implement required NMC #7 (Pollution prevention programs) BC298 WW CSO - Failure to implement required NMC #8 (Public notification) BC299 WW CSO - Failure to implement required NMC #9 (Monitoring) B0C41 WW CSO - Failure to Maintain Records or Meet Record Keeping Requirements C0C11 WW CSO - Failure to monitor E0C16 WW CSO - Failure to submit required report (non-DMR) E0C13 WW CSO - Improper/Incorrect reporting B0044 WW CSO - LTCP implementation schedule milestone missed 

Such language i“boilerplate” of narratives may s

A0C22 WW CSO - Narrative effluent violation contributing to a

quality standardtoxic amounts, dodor, etc. 

E0C14 WW CSO - Noncompliance with section 308 Information Request 

This should be u

A0C12 WW CSO - Numeric effluent violation specific numeric 

outfall in the peAs stated in 40 means the inten

A0C11 WW CSO - Related Unapproved Bypass streams from an

facility. In CSO can only occur atreatment plant. 
Code Description Definition 

For CSOs, any ucombined sewer discharges from maximize flow 

A0021 WW CSO - Unauthorized CSO Discharge to Waters/Wet Weather discharges from 

covers, pump stdischarges can oheadworks of a comments field estimated total v

Does not includ

A0025 WW CSO - Operation and maintenance (O&M) violations resulting in unauthorized sewage 

spills or overflows to dry land or building backup 

Include in the coevents and estimperiod. 

B0045 WW CSO - Violation of a milestone in a permit B0C42 WW CSO - Violation of a milestone in an order 

As stated in 40 

A0S18 WW SSO - Approved Bypass means the inten

streams from anfacility. Include in the co

A0020 WW SSO - Discharge to Waters events and estim

period 

D0S11 WW SSO - Discharge without a valid permit (includes satellite systems) B0S41 WW SSO - Failure to Maintain Records or Meet Record Keeping Requirements C0S11 WW SSO - Failure to monitor 

Includes §122.4

E0018 WW SSO - Failure to report other violation report any SSO 

that may endang

E0019 WW SSO - Failure to report violation that may endanger public health 122.41(l)(7) Exclude §122.4

This is a CWA 

D0S12 WW SSO - Failure to submit required permit application info (includes satellite systems) any facility disc

application per 
Code Description Definition 

Frequent sewag

B0S20 WW SSO - Improper Operation and Maintenance land) may be in

and maintenancand implement 

Such language i“boilerplate” of narratives may s

A0S22 WW SSO - Narrative effluent violation contributing to a

quality standardtoxic amounts, dodor, etc. 

E0S14 WW SSO - Noncompliance with section 308 Information Request A0S12 WW SSO - Numeric effluent violation 

Frequent sewagland) may be in

A0026 WW SSO - Overflow to Dry Land or Building Backup and maintenanc

number of evenper reporting peAs stated in 40 

A0S11 WW SSO - Related Unapproved Bypass means the inten

streams from anfacility. 

BS42A WW SSO - Violation of milestone in an administrative order BS42J WW SSO - Violation of milestone in judicial decree B0046 WW SSO - Violation of sewer moratorium or restriction May also be a v

(d). 

D0R11 WW Storm Water Construction - Discharge without a permit No permit D0R18 WW Storm Water Construction - Failure to apply for a notice of termination Failure to submB0R12 WW Storm Water Construction - Failure to Conduct Inspections B0C17 WW Storm Water Construction - Failure to develop any or adequate SWPPP/SWMP B0C18 WW Storm Water Construction - Failure to Implement SWPPP/SWMP B0R41 WW Storm Water Construction - Failure to Maintain Records C0R11 WW Storm Water Construction - Failure to Monitor Where required BR19A WW Storm Water Construction - Failure to properly install/implement BMPs BR19B WW Storm Water Construction - Failure to properly operate and maintain BMPs 
Code Description Definition 

D0R12 WW Storm Water Construction - Failure to submit required permit application information This is a CWA E0R16 WW Storm Water Construction - Failure to submit required report (non-DMR) Where required A0R22 WW Storm Water Construction - Narrative effluent violation Where required E0R14 WW Storm Water Construction - Noncompliance with section 308 Information Request A0R12 WW Storm Water Construction - Numeric Effluent Violation Where required B0R42 WW Storm Water Construction - Violation of a milestone in an order D0M11 WW Storm Water MS4 - Discharge without a permit B0M12 WW Storm Water MS4 - Failure to Conduct Inspections B0M17 B0M18 B0M41 C0M11 

WW Storm Water MS4 - Failure to develop any or adequate SWPPP/SWMP 

WW Storm Water MS4 - Failure to Implement SWPPP/SWMP 

WW Storm Water MS4 - Failure to Maintain Records or Meet Record Keeping Requirements 

WW Storm Water MS4 - Failure to Monitor 

Includes failure any part of SWM

BM19A BM19B D0M12 E0M16 A0M22 E0M14 A0M12 B0M42 

WW Storm Water MS4 - Failure to properly install/implement BMPs 

WW Storm Water MS4 - Failure to properly operate and maintain BMPs 

WW Storm Water MS4 - Failure to submit required permit application information 

WW Storm Water MS4 - Failure to submit required report (non-DMR) 

WW Storm Water MS4 - Narrative effluent violation 

WW Storm Water MS4 - Noncompliance with section 308 Information Request 

WW Storm Water MS4 - Numeric Effluent Violation 

WW Storm Water MS4 - Violation of a milestone in an order 

Refers to structu

Refers to structu

This is a CWA 

Where required 

Where required 

D0N11 D0N18 B0N12 B0N17 B0N18 B0N41 C0N11 

WW Storm Water Non-Construction - Discharge without a permit No permit and nWW Storm Water Non-Construction - Failure to apply for a notice of termination Failure to subm

transferring auth

WW Storm Water Non-Construction - Failure to Conduct Inspections 

WW Storm Water Non-Construction - Failure to develop any or adequate SWPPP/SWMP 

WW Storm Water Non-Construction - Failure to Implement SWPPP/SWMP 

WW Storm Water Non-Construction - Failure to Maintain Records 

WW Storm Water Non-Construction - Failure to Monitor 

BN19A WW Storm Water Non-Construction - Failure to properly install/implement BMPs BN19B WW Storm Water Non-Construction - Failure to properly operate and maintain BMPs D0N12 WW Storm Water Non-Construction - Failure to submit required permit application information This is a CWA E0N16 WW Storm Water Non-Construction - Failure to submit required report (non-DMR) A0N22 WW Storm Water Non-Construction - Narrative effluent violation 
Code Description Definition 

E0N14 WW Storm Water Non-Construction - Noncompliance with section 308 Information Request A0N12 WW Storm Water Non-Construction - Numeric Effluent Violation B0N42 WW Storm Water Non-Construction - Violation of a milestone in an order 
Attachment 2 - Available RNC Detection codes (taken from PCS Table 195) 

Bold codes trigger SNC code “E- Effluent Violations” quarterly status for Single Event 

Violations. Italicized text codes trigger RNC code “N-Reportable Noncompliance” 

quarterly status for Single Event Violations. Note that “DIS” means “discretionary.” 

Code Description Definition Setting Type QNCR 

Category 

A ENF_ADMINISTRATIVE 

ORDER 

Measurement exceeded 

administrative monthly 

average limit set by a 

formal enforcement action 

Automatic I (A) 

B DIS_MANUAL 2A4 _ 

PASS_THROUGH 

Discretionary or manual 

entry of a violation of a 

pass-through of 

pollutants 

Manual II (A) (4) 

C CHR_CHRONIC VIOLATION Chronic violation of four 

or more violations of the 

monthly average occurring 

within a consecutive six 

month time frame. 

Automatic I (C) 

D DIS_MANUAL OTHER Discretionary or manual 

entry of violation of 

condition in enforcement 

orders except compliance 

schedules and reports 

Manual I (A) 

E DIS_MANUAL 2F _ PRMT 

NARRATIVE 

Discretionary or manual 

entry of a permit narrative 

violation 

Manual II (F) 

F DIS_MANUAL 2G _ VIO OF 

CONCERN 

Discretionary or manual 

entry of a permit violation 

of concern to the Director 

or Regional Administrator 

Manual II (G) 

G DIS_MANUAL 2A1 _ 

EFFLUENT VIOL 

Discretionary or manual 

entry of Category II 

permit limit violation 

Manual II (A) (1) 

H CHR_CHRONIC VIO, 

NON_MONTH AVG 

Chronic violation of four 

or more violations of the 

non-monthly average 

occurring within a 

consecutive six month time 

frame 

Automatic II (A) (1) 

I DIS_MANUAL 2A2 _ 

UNAUTH BYPASS 

Discretionary or manual 

entry of violations or an 

unauthorized by-pass 

Manual II (A) (2) 

J DIS_MANUAL 

2A3_UNPERM DISCH 

Discretionary or manual 

entry of violations of an 

unpermitted discharge 

Manual II (A) (3) 

K RPT_NONREC VIOL, 

NON_MONTH AVG 

Reporting violation was 30 

days overdue for the nonmonthly average or the 

DMR was incomplete 

where the non-monthly 

average was missing 

Automatic II (A) (1) 

2-1 
Code Description Definition Setting Type QNCR 

Category 

N RPT_NONRECEIPT OF 

DMR/CS RPT 

Reporting violation was 30 

days overdue for the 

monthly average or the 

DMR was incomplete 

where the monthly average 

was missing 

Automatic I (D) for DMR 

nonreporting 

& Cat. I 

nonreporting 

for 

compliance 

schedules; or 

II (D) for Cat 

II 

nonreporting 

for 

compliance 

schedules; or 

II (E) for 

incomplete 

DMRs 

P ENF_ADMIN ORDER, 

NON_MONTH AVG 

Measurement exceeded 

administrative nonmonthly average limit set 

by a formal enforcement 

action 

Automatic II (A) (1) 

Q DIS_MANUAL 2B _ 

PRETREATMENT 

Discretionary or manual 

entry of permit 

pretreatment 

Manual II (B) 

R TRC_TRC VIOL, 

NON_MONTHLY AVG 

TRC limitations were 

exceeded for two violations 

of non-monthly averages 

within a consecutive six 

month time frame or 

chronic violations 

Automatic II (A) (1) 

S SCH_COMPLIANCE 

SCHEDULE VIOL 

Compliance schedule 

violations were 90 days 

overdue 

Automatic I (B) for Cat. 

I, or II (C) for 

Cat. II 

T TRC_TRC LIMITATIONS 

EXCEEDED 

TRC limitations were 

exceeded for two violations 

of monthly averages within 

a consecutive six month 

time frame or chronic 

violations 

Automatic I (C) 

U EFF_OTHR VIO W/TRC 

NON_MNTH AV 

Effluent violations of the 

non-monthly average 

occurring within a 

consecutive six month time 

frame associated with TRC 

RNC 

Automatic II (A) (1) 

V EFF_OTHER VIOLATION 

WITH TRC 

Effluent violations of the 

monthly average occurring 

within a consecutive six 

month time frame 

associated with TRC RNC 

Automatic I (C) 

W DIS_MANUAL 2E _ 

DEFICIENT RPT 

Discretionary or manual 

entry of deficient report 

violations 

Manual II (E) 

2-2 
Code Description Definition Setting Type QNCR 

Category 

X EFF_MANUAL OTHER VIOL 

W/ TRC 

Discretionary or manual 

entry of effluent violations 

occurring within a six 

month time frame 

associated with TRC RNC 

Manual I (C) 

Y TRC_MANUAL TRC Discretionary or manual 

entry of TRC limitations 

that were exceeded for two 

violations of monthly 

averages within a sixmonth time frame or 

chronic violations 

exceeding TRC limitations 

Manual I (C) 

Z CHR_MANUAL CHRONIC Discretionary or manual 

entry of four or more 

violations occurring within 

a six-month time frame 

Manual I (C) 

2-3 
Attachment 3 - Available RNC Resolution codes (taken from PCS Table 390) 

Code Description Setting Type 

A NC - MANUAL UNRESOLVED RNC Manual 

B RE - MANUAL BY EPA/STATE ACTION Manual 

W NC - WAITING RNC RESOLUTION Automatic 

1 NC - UNRESOLVED RNC Automatic 

2 RE - BACK INTO COMPLIANCE Automatic 

3 RP - DUE TO FORMAL EA Automatic 

4 RP - IN COMPLIANCE LAST QTR Automatic 

5 RE - RESOLVED RP BY EA W/ CL Automatic 

6 RE - MANUAL RES BY EA W/ CL Manual 

7 RE - MANUAL RP IN COMP W/ADM LMT Manual 

8 RP - MANUAL DUE TO FORMAL EA Manual 

9 RE - MANUAL BY BACK INTO COMPL Manual 

3-1 
Attachment 4 - Available QNCR Status codes (taken from PCS Table 440) 

Those listed in bold below are the only ones that apply to Single Event Violations. 

C COMPLIANT 

D NC_SNC DMR NON_RECPT (SNC) 

E NC_SNC EFFLUENT VIOL (SNC) 

N NC_RNC VIOLTNS ONLY 

P RESOLVED PENDING 

R RESOLVED 

S NC_SNC COMP SCHD VIO (SNC) 

T NC_SNC COMP SCHD RPT (SNC) 

X NC_SNC EF NONMNTH AV (SNC) 

4-1 
Attachment 5 – Entering and Tracking Single Event Violations, Linking Them to 

Enforcement Actions, and Detecting and Resolving RNC in PCS (taken from PCS 

Data Entry, Edit, and Update Manual and modified) 

6.2.16 Single Event Violation Data Type 

Single event violation data in PCS contains information about violations that are neither 

effluent limit violations nor compliance schedule violations. For example, a single event 

violation record in PCS might contain information concerning an unauthorized bypass, or 

a violation detected during an inspection. 

Single event violation data is structured so that one record exists on the data base for each 

single event violation. Each record is uniquely identified by its key data elements, the 

facility NPDES Number, the Single Event Violation Code, and the Single Event 

Violation Date. 

Single Event Violation Code (SVCD): The Single Event Violation Code is used to 

describe the type of violation that has occurred. For example, the code 07099 indicates 

that the permittee failed to meet a Section 308 Request. 

Single Event Violation Date (SVDT): The Single Event Violation Date indicates the date 

that the violation took place. 

Quarterly Noncompliance Report (QNCR) Compliance Violation Data Elements: No 

automatic Reportable Noncompliance (RNC) detection is performed by the system for 

single event violations (however resolution is automatically performed by the system). 

All RNC for single event violations are manually entered and determined, with the 

exception that resolved pending violations are automatically resolved by the closure of a 

formal enforcement action. 

QNCR Single Event Violation Detection Code (SNCS): This data element contains a 

code which describes the type of RNC for the single event violation. 

QNCR Single Event Violation Detection Date (SNDS): The date that corresponds to the 

QNCR Single Event Violation Detection Code. 

QNCR Single Event Violation Resolution Code (SRCS): This data element contains a 

code which indicates the RNC resolution status, if appropriate, of a single event violation. 

QNCR Single Event Violation Resolution Date (SRDS): The date that corresponds to the 

QNCR Single Event Violation Resolution Code. 

8.4.3 Single Event Violations Independently Determined by the Agency 

Events that are independently determined by the Agency to be violating a permit, such as 

an unauthorized bypass, or a violation detected during an inspection, can be manually 

entered into the system by using input card '-N' or the SVIO screen on PCS-ADE. This 

information is entered using at least the NPDES Number (NPID), the Single Event 

5-1 
Violation Code (SVCD), and the Single Event Violation Date (SVDT). Two user data 

elements (RDS1 and RDS2) are available to further describe the violation. In addition, 

should the Agency or authorized State consider the violation to be Reportable 

Noncompliance (RNC), the QNCR Single Event Violation RNC Detection Code (SNCS), 

detection date (SNDS), resolution code (SRCS), and resolution date (SRDS) can be 

manually entered. Manual entry of RNC is discussed in the next section. 

Manual Detection/Resolution of RNC Violations 

For single event violations, reportable noncompliance must be set manually as no 

automatic RNC detection is performed. Automatic resolved pending and resolution is 

performed when the single event violations have been addressed by formal enforcement 

action and extended compliance schedule. 

Otherwise, single event violations must be manually resolved. The manual setting of 

RNC codes and dates is accomplished through designated codes for manual entry. The 

manually entered codes are identified in "RNC Detection Codes" in PCS Table 195 

(Attachment 2). All manually resolved violations require that the resolution date be 

entered. The system will not generate a date to accompany a user entered resolution 

code. 

In addition to batch cards, the user may use PCS-ADE to manually enter RNC codes and 

dates. The SVIO screen is used to manually enter RNC codes and dates for single event 

violations. The following step shows how to manually set RNC for single event 

violations: Enter into PCS a change to the single event violation contained in PCS. The 

following is a minimum number of data elements that must be entered. 

5-2 
Table 8-25. Coding Manual Detection/Resolution of Single Event Violations 

5-3 
3.2.36 Single Event Violations Screen (SVIO) 

If the user responds to the main menu prompt by entering 'SVIO' followed by <CR>, the 

system will respond by displaying the Single Event Violation Screen as shown in Figure 

3-59. 

Figure 3-59. Single Event Violation Screen (SVIO) 

The Single Event Violations Screen will prompt the user to enter data for a single event 

violation. 

1. Accept Options - after entering all single event violations on this screen, the user 

responds to the prompt 'ACCEPT? Y/N/M:' by entering one of the following choices 

followed by <CR>. 

Y - Scans the screen for errors. Data entered is saved and cleared in preparation for data 

entry for another single event violation. This value is automatically displayed and is the 

default if a value is not entered. 

N - Ignores any data entered on the screen. 

M - Returns the user to the Main Menu. All data entered on the screen is ignored. 

5-4 
2. Edit Check Criteria - the following edits are performed for data entered on this screen. 

a. The State Code (STTE) portion of the Permit Number (first two characters) is checked 

against the Region/State entering the data. The numeric portion is checked to ensure it is 

a valid permit number. 

b. The Single Event Violation Code (SVCD), the RNC Detection Code (SNCS), and the 

RNC Resolution Code (SRCS) are checked for valid codes. 

c. All dates are checked for valid date ranges. 

d. For a NEW transaction, the data base is checked to ensure that the key data elements 

do not already exist in the data base. 

e. For a CHANGE or DELETE transaction, the data base will be checked to ensure that 

the key data elements do exist in the data base. 

3. Key Data Elements - Automatic change option will retrieve the information for userentered data fields. 

6.2.13 Enforcement Action Data Type 

Enforcement Action records in PCS are structured so that one enforcement action record 

exists for each enforcement action issued. The Enforcement Action record contains 

general information about the action such as the type of action taken, the date the action 

was taken, and whether the EPA or a State issued the Enforcement Action. Enforcement 

Action Violation Key records ("ENFORCEMENT ACTION Sub-Menu" in topic 

4.3.11.3) contain information describing which violations are addressed by the 

enforcement action. 

There are two levels of enforcement response: 1) informal enforcement; or 2) formal 

enforcement. The informal enforcement response includes a phone call, an inspection, a 

letter of violation, a notice of violation, or an administrative penalty order. The formal 

enforcement response is an action that Arequires actions to achieve compliance, specifies 

a timetable, contains consequences for noncompliance that are independently enforceable 

without having to prove the original alleged violation and subjects the person to adverse 

legal consequences for noncompliance.@

1

 A formal enforcement response includes an 

unilateral administrative order or administrative order by consent (with or without a 

penalty), a civil judicial consent decree, a Court order, or a criminal action. 

Enforcement Action Code (ENAC): The Enforcement Action Code is a two character 

numeric code used to describe the nature of the enforcement action taken. For example, 

the code of '21' is used for an Administrative Order. In the Enforcement Action Codes 

Table, each Enforcement Action Code is identified by five numbers 1 to 5 as follows: 

1

 See NPDES Enforcement Management System, (1986, revised in 1989), Chapter 1, p. 24. 

5-5 
Code Nature of Action 

1 Informal Action 

2 Administrative Action 

3 Judicial Action 

4 Other Action 

5 Permit Modification 

P Penalty 

Types 2 and 3 are considered 'formal' enforcement actions. While all 5 types may be 

entered in PCS, only formal enforcement actions resolve violations for QNCR purposes. 

Please note that Type P refers to administrative penalty orders (APOs), which are 

regarded by PCS as informal actions because they do not resolve RNC. The Enforcement 

Action Code is one of the key elements on all Enforcement Action records. 

Enforcement Action Date (ENDT): The Enforcement Action Date is the effective date of 

the enforcement action being entered. For informal actions, such as phone calls, 

recommendations, etc., it is the date the action was taken. The Enforcement Action Date 

is one of the key data elements on all Enforcement Action records. 

Enforcement Action Type Order Issued (EATP): The Enforcement Action Type Order 

Issued code is used to indicate whether the action was issued by the EPA or by an 

authorized State. If the action was issued by the EPA, an 'E' is entered; if the action was 

issued by a State, an 'S' is entered. The Enforcement Action Type Order Issued is one of 

the key elements on all Enforcement Action records. 

Enforcement Action Status Code (ENST): The Enforcement Action Status Code is a nonkey data element used to indicate the status of a violation with respect to the enforcement 

action taken. If a minor or rare excursion has taken place, an appropriate response may 

be a phone call or letter to the permittee. The violation may then be considered resolved, 

in which case the code 'RE' may be entered. A more serious violation or series of 

violations may warrant some type of formal enforcement action. If a formal enforcement 

action is superceded by another formal enforcement action, then the code 'CS' should be 

encoded to show the enforcement action has been 'Closed, Superceded' by another formal 

enforcement action. After the enforcement action has been formally closed, the status 

code may be changed to 'CL' indicating closure. When the status code has been changed 

to 'CL' indicating closure of the enforcement action, any violations that were tied to the 

enforcement action through the Enforcement Action Violation Keys and were resolved 

pending will be resolved. 

Enforcement Action File Number (ERFN): The Enforcement Action File Number, also 

called the docket number, is a non-key data element established to contain a unique 

number identifying a formal enforcement action. If an enforcement action establishes 

interim effluent limits and/or a compliance schedule, the file numbers in these locations 

(the Limit File Number (PLFN) and Compliance Schedule File Number (CSFN)) should 

be identical to the Enforcement Action record (identifiers are used in automatic 

processing on the QNCR). If no docket number is available then one should be 

5-6 
fabricated. The Enforcement Action File Number is required for all formal enforcement 

actions for major facilities. 

Enforcement Action Comment (ECMT, ECM0-ECM9): The Enforcement Action 

Comment data element, composed of ten separate subfields, each independently 

retrievable, is used to load pertinent comments on the Enforcement Action record. When 

an enforcement action is listed on the QNCR, these comments will appear in their 

entirety. Generally, the comment data element should be used to explain information 

about the corresponding violations or the action itself. The enforcement action comment 

data element is required, if appropriate, for all formal enforcement actions taken against 

major permittees. Only one set of comments can be entered for each enforcement action. 

6.2.14 Enforcement Action Violation Key Data Type 

Enforcement action violation key records are used to relate an enforcement action to the 

violations it addresses. Because an enforcement action often addresses several types of 

violations, there may be many enforcement action violation key records for each 

enforcement action. This record contains the enforcement action key and whatever 

violation key data is necessary to identify the violations addressed. 

Enforcement action violation key records in PCS fall into four broad categories: 1) those 

that relate the enforcement action to compliance schedule violations, 2) those that relate 

to effluent violations, 3) those that relate to DMR non-receipt violations, and 4) those that 

relate to single event violations. In each category, the enforcement action may be 

associated with either each individual violation or with a broader grouping of violations. 

All data elements in the Enforcement Action Violation Key data type are key data 

elements. 

Enforcement Action Code (EKAC): This data element is always the same as the 

corresponding enforcement action data element (ENAC). 

Enforcement Action Type Order Issued (EKTP): This data element is always the same as 

the corresponding enforcement action data element (EATP). Enforcement Action Date 

(EKDT): This is always the same as the corresponding date on the enforcement action 

record (ENDT). 

Enforcement Action Violation Type (EVTP): The Enforcement Action Violation Type 

Code is used to indicate how the Enforcement Action is related to the violations it 

addresses. 

1. Effluent Violations: 

Code Description 

E1 Indicates that an enforcement action record is to be associated with all effluent 

violations prior to the date of the enforcement action, and after the last enforcement 

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action, if present. On PCS-ADE, this type of violation key record is generated by the 

system when the enforcement action record is entered, if the user enters 'X' in the 'ALL 

NUMERIC EFFLUENT' option under 'Violations that caused the enforcement action to 

be issued' data element. 

E2 Indicates that an enforcement action record is to be associated with all effluent 

violations during a particular monitoring period. In addition to the enforcement action 

key data elements, the monitoring period end date must also be entered. Optionally, an 

enforcement action could be associated with effluent violations for a particular outfall 

and monitoring period. In this case the outfall number (3-digit or 4-digit) would be 

entered with the monitoring period end date. 

E3 Indicates that the enforcement action record is to be associated with a particular 

effluent violation. All measurement/violation key data elements must be entered in 

addition to the enforcement action keys. If the measurement/violation record that the 

enforcement action key record addresses is deleted, then PCS will also delete the 

corresponding enforcement action key record. If any of the keys to the measurement/ 

violation record are changed by PCS during the reissuance process, then those key 

elements are also changed on the enforcement action key record to maintain the 

relationship between enforcement action and violation. See "Permit Reissuance 

Processing" in topic 6.3 for more information on the reissuance process. 

2. Non-reporting Violations 

Non-reporting violations are very similar to effluent violations. The codes N1 through 

N9 are used to indicate the categories of DMR non-reporting violations and authorized 

agencies. 

3. Compliance Schedule Violations 

Code Description 

C1 Indicates that the enforcement action relates to all compliance schedule violations 

prior to the date of the enforcement action. On PCS-ADE, this type of violation key 

record is generated by the system when the enforcement action record is entered, if the 

user enters 'X' in the 'ALL COMPLIANCE SCHEDULES' option under 'Violations that 

caused the enforcement action to be issued' data element. 

C2 Indicates that the enforcement action is related to an individual compliance 

schedule violation. The key data elements for the compliance schedule violation must be 

entered in addition to the enforcement action keys. 

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4. Single-Event Violations 

Code Description 

S1 Indicates that the enforcement action relates to all single event violations prior to 

the date of the enforcement action. On PCS-ADE, this type of violation key record is 

generated by the system when the enforcement action record is entered, if the user enters 

'X' in the 'ALL SINGLE EVENTS' option under 'Violations that caused the enforcement 

action to be issued' data element. 

S2 Indicates that the enforcement action is related to an individual single event 

violation. The key data elements for the single event violation must be entered in 

addition to the enforcement action keys. 

3.2.32 Enforcement Action Screen (ENAC) 

If the user responds to the main menu prompt by entering 'ENAC' followed by <CR>, 

PCS-ADE will respond by displaying the Enforcement Action Screen in Figure 3-49. 

Figure 3-49. Enforcement Action Screen (ENAC) 

1. Accept Options - After entering the Enforcement Action Screen data, the user 

responds to the prompt 'ACCEPT? Y/K/N/M:' by entering one of the following choices 

followed by a <CR>. 

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Y - Scans the screen for errors. If no errors are found, data entered is saved and the 

screen is cleared in preparation for data entry of another Enforcement action. This value 

is automatically displayed and is the default if a value is not entered. 

K - Scans the screen for errors. If no errors are found, the data is saved. All data 

elements except the key data and transaction codes are cleared so that another 

enforcement action may be entered for the same permit. Accept option 'K' retains key 

data fields (rather than defaulting to accept option 'Y') only if the user does not enter any 

enforcement action keys. If 'K' is entered and the user enters specific violation keys, 

when returning from the EAKS screen all the key information will remain. 

N - Ignores any data entered on the screen. All data elements are cleared so that the same 

screen can be reentered. 

M - Returns the user to the main menu. All data entered on the screen is ignored. 

2. Edit Check Criteria - Data entered on the Enforcement Action screen are edit checked 

as follows: 

a. The State Code (STTE) portion of the Permit Number (first two characters) is checked 

against the Region/State entering the data. The numeric portion is checked to ensure it is 

a valid permit number. 

b. The Enforcement Action Code (ENAC), Type Order Issued (EATP), and Status Code 

(ENST), are checked for validity in the PCS tables. 

c. Dates are checked for valid date ranges. 

d. For a NEW enforcement action, the data base is checked to ensure that the new 

enforcement action key data elements do not already exist in the data base. 

e. To CHANGE or DELETE an enforcement action, the data base will be checked to 

ensure that the enforcement action key data elements do exist in the data base. 

f. Confirmation Screen appears on MASS DELETE transactions for enforcement actions 

and related keys for compliance schedules, effluents, and single event violations. 

3. Key Data Elements - Automatic change option will retrieve the information for userentered data fields. 

4. Violations that caused the Enforcement Action to be Issued: 

a. If the user entered 'X' in any of the first six options addressing all violations, PCSADE automatically generates the appropriate enforcement action key records. If the user 

enters '*' in any of these options, PCS-ADE automatically deletes the appropriate 

enforcement action key records (if transaction code entered was 'C') 

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b. If the user enters 'X' in the Specific Violations Options, PCS-ADE will respond by 

displaying the Enforcement Action Key Screen #1 (EAKS), see "Enforcement Action 

Key Screen (EAKS)" in topic 3.2.33, where the user specifies the type of specific 

violations addressed, and enters the key information for those violations. Note: You can 

enter any of the first six options addressing all violations and also enter specific 

violations. 

Figure 3-50. Enforcement Action Key Screen (EAKS) 

1. Key Screen Accept Options - After entering the Enforcement Action Key Screen data, 

the user responds to the prompt 'ACCEPT? Y/N/M:' by entering one of the following 

choices followed by <CR>. 

Y - Scans the screen for errors. If no errors are found, the Extended Enforcement Action 

Key Screen is displayed. This value is automatically displayed and is the default if a 

value is not entered. 

N - Ignores any data entered on the screen. All data elements are cleared so that the same 

screen can be reentered. If this screen was invoked from the ENAC screen, then this 

option will return control to that screen. 

M - Returns the user to the main menu. All data entered on the screen is ignored. 

2. Cycle Option - In the Enforcement Action Key Screen, the user responds to the 

prompt 'DO YOU WISH TO CYCLE (Y/N)?' by entering one of the following choices: 

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Y - Choosing the cycle option allows the user to cycle through violations in PCS and to 

link the enforcement action to violations while cycling. 

N - Disables the cycle option for the Enforcement Action Key Screen. When the user 

enters <CR>, a data screen will appear as shown in Figure 3-56 in topic 3.2.33.2. The 

user must enter key information for the violations to be addressed. The cycle option may 

be used only if the Violation Type (EVTP) links the enforcement action to specific 

violations, for example, E3, C2, S2, N8, etc. The EAKS key screen will respond by 

EXPANDING the screen as shown in Figure 3-53. 

Figure 3-53. Expanded Enforcement Action Key Screen (EAKS/SV) --Expanded to limit 

Single Event violations displayed by the cycle option. 

1. Extended Key Screen Accept Options - After entering the Enforcement Action Key 

Screen data, the user responds to the prompt 'Accept (Y/N/M)? by entering one of the 

following choices followed by a <CR>. 

Y - Scans the screen for errors. If no errors are found, one of the three data screens is 

displayed. PCS-ADE chooses the data screen to be displayed based on the Violation 

Type (EVTP) the user has entered. For example, if the user has entered 'E3' in the 

Violation Type, the effluent screen is displayed, or if he has entered 'C2', the compliance 

schedule screen is displayed. 

N - Ignores all data entered and clears all data elements on the screen. If the user 

accessed the EAKS screen from the ENAC screen, the user is returned to ENAC. 

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M - Ignores all data entered and returns user to the main menu. These expanded versions 

of EAKS Key screen will only be seen if the cycle option is chosen. After the user has 

provided any applicable values, an EAKS data screen will appear, with the key data for 

the first violation in PCS as shown in Figure 3-56. 

Figure 3-56. EAKS Data Screen for Single Event Violations 

2. Data Screen Edit Check Criteria - data entered on one of the Enforcement Action Key 

Data Screens are edit checked as follows: 

a. All encoded values are checked against the PCS tables for validity. 

b. All dates entered are checked for valid date ranges. 

8.4.6.3 Detection/Resolution of RNC by EA - For Single Event Violations 

Single Event Violations are detected manually, but are automatically resolved by the 

system if the violations are addressed by a formal enforcement action. The PCS 

Reportable Noncompliance (RNC) tracking system will automatically set the single event 

violation resolution code and date to resolved/resolved pending when there is an 

associated enforcement action with an extended compliance schedule for either all or 

specific single event violations. For this to take place the below must be true: 

1. The RNC Detection Date must be less than or equal to the Enforcement Action Date. 

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2. A Formal Enforcement Action must be present. 

3. There must be an extended compliance schedule for either all or a specific single 

event violation (enforcement type = 'S1' or 'S2'). 

4. Matching Docket numbers must be entered in the Enforcement Action File Number 

(ERFN) field and in the Compliance Schedule File number (CSFN) field. 

Resolved pending resolution of RNC for single event violations occurs when an extended 

compliance schedule is entered into the system. The Compliance Schedule Number 

(CSCH) must be an Extended Compliance Schedule for resolution to take place (See 

Table 8-2 in topic 8.4.6.1 for specific codes). In addition to the extended compliance 

schedule, a formal enforcement action that contains the same Enforcement Action File 

Number (ERFN) as the extended Compliance Schedule File Number (CSFN) and relating 

to the type of individual violations must be in PCS. The enforcement action and 

extended compliance schedule can be entered in the same update. 

Table 8-2. Extended Compliance Schedule Codes (CSCH) 

CSCH Extended Compliance Schedule Description 

CC Schedule established by CCP 

CO Consent Order 

DA 309 (A) (5) (A) - Interim 

DB 309 (A) (5) (A) - Final 

DC 309 (A) (5) (A) - Municipals 

DD 309 (A) (5) (B) 

DE 309 (A) (6) 

DY Admin. Orders for Municipals 

DZ Admin. Orders for Industrials 

FF Fed. Facility Compliance Agreement 

GA Fed. Judicial Decrees 

HA State Judicial Decrees 

HC State Non-Judicial Decrees (Ind.& Mun.) 

VA State Admin. Decrees 

MC Enf. Schedule for Municipals Compliance Strategy 

PT Pretreatment, Enforcement Action 

If the QNCR Single Event Violation Resolution Code (SRCS) is '3' (resolved pending), 

the QNCR Single Event Resolution Date (SRDS) contains the Enforcement Action Date 

(ENDT). 

To resolve the single event violations, a formal enforcement action must be entered into 

PCS as follows: Enter a change to the formal enforcement action previously entered into 

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PCS with a status code indicating closure of the action. The following is the minimum 

amount of data elements that should be entered. 

Table 8-20. Coding Closure of an action for Single Event Violations 

When an enforcement action is closed out and the requirements of the formal 

enforcement action are satisfied, then all resolved pending violations are resolved. When 

a formal enforcement action is entered with an Enforcement Action Status Code (ENST) 

of 'CL' and a valid Enforcement Action Status Date (ESDT) covering the violation type 

or individual violations, the corresponding RNC Single Event violations are resolved 

with a QNCR Single Event Violation Resolution Code (SRCS) of '5' and the QNCR 

Single Event Violation Resolution Date (SRDS) equal to the Enforcement Action Status 

Date (ESDT). These violations will then be shown as resolved on the upcoming QNCR 

and be dropped from subsequent QNCRs. 

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If an enforcement action has not been added, an error message is generated on the update 

report to indicate that there is a missing enforcement action for the extended compliance 

schedule and that resolved pending resolution cannot take place. 

If the violation(s) are not resolved via a formal enforcement action (i.e. through an 

informal action, voluntarily, due to site closure, or for any other reason), the violations 

will have to be manually resolved as described earlier through the use of manual codes 

provided in PCS Table 390 (provided in Attachment 3). 

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ATTACHMENT 1 

FREQUENTLY ASKED QUESTIONS ABOUT SINGLE EVENT VIOLATIONS 

The Single Event Violation Data Entry Guide is a comprehensive document that examines most 

facets of reporting. This FAQ provides a management overview of the document in a 

question/answer format. 

What is a Single-Event Violation? 

A violation of regulatory/permit requirements under the CWA-NPDES program that is 

determined by means other than automated computer calculations of: a) a permit limit to a 

measurement; or b) a compliance schedule event due date to actual date. For example, a violation 

found during an inspection would be a single-event violation. 

Does Single-Event Violation Mean a One-Day Event? 

No. A Single Event Violation can occur on one day only, or across multiple days. 

What is the Importance of Tracking Single Event Violations? 

Single Event Violation tracking in the Permit Compliance System and the planned ICIS-NPDES 

databases provide the only national data fields that describe the findings of inspection or other 

monitoring activities. Single Event Violation tracking allows the permit authority to 

electronically record the finding, and allows the violation to be tracked through resolution (e.g., 

returned to compliance, enforcement action taken, etc.). 

Is Single Event Tracking Required by States? 

The current required data entry list (known as WENDB) includes Single Event Violations 

discovered at major facilities. To properly track resolution of violations discovered through 

means such as inspections, complaints, and facility self-audits, it is important that this 

information reside in the national system. 

How Does the Single Event Violation Guide Improve Data Tracking? 

In addition to standardizing the list of possible Single Event Violations, EPA has included text 

definitions (where appropriate) to help the permitting authority choose the right database code. 

Prior to issuance of this Guide, there were no national definitions and reporting guidance 

covering Single Event Violations. Code standardization and definitions were the primary barriers 

cited by PCS users to accurate reporting. 

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Does the Violation Have to Be Adjudicated before It is Entered into the Database? 

No. In fact, EPA and states routinely enter violations in other program databases that are not 

final legal determinations. EPA is very careful in its public web sites (see www.epa.gov/echo) to 

point out that violation status is a preliminary agency determination and not a legal finding of 

fact. 

Is an Enforcement Action Required to Close Out a Single Event Violation? 

No. EPA expects that many Single Event Violations will be resolved (returned to compliance by 

the permittee) without the need for formal enforcement. 

What are the Conventions for Entering Single Event Violations? 

There are three essential parts to the Single-Event Violation data, along with other related data. 

The first essential part is the start date of the violation, the second piece is the type of violation 

that occurred, and the third piece is the date the violation ended (sometimes items 1 and 3 are the 

same date). All violation types that should be entered into the system are included in PCS (and 

ICIS-NPDES). This new list is a “cleaned-up” version of the pre-existing values that were often 

poorly defined and/or redundant. Where possible, EPA has defined each violation in the Data 

Entry Guide. Supplemental information that is also critical for certain Single Event Violations 

are: the inspection or activity that led to discovery of the violation, and the resulting action taken 

by the permitting authority (if any). 

Which Violations Should Be Reported? 

If a violation is discovered that is listed on in the Data Entry Guide (as it reflects the database 

table values), it should be entered into the system regardless of whether enforcement response is 

planned. If the permitting authority finds violations that are not listed in the database table, there 

is an “other” violation category that can be optionally selected. 

What Level of “Proof” is Necessary to Turn Off a Single Event Violation? 

Because a wide array of violations are possible, there is no one threshold for what proof is 

needed. The permitting authority should make a judgment as to when it is satisfied the problem is 

fixed (EPA does not believe that a follow-up inspection is necessarily needed to close out a 

Single Event Violation). 

How can Single Event Violations Be Used by the Permitting Authority? 

Each permitting authority can use the data to determine where inspections most frequently turn up 

problems (e.g., analysis of sectors, watersheds, permit types, etc.). This in turn can lead to better 

use of resources. Additionally, the data can help the permitting authority spot trends such as 

frequent or repeat patterns of violation. While one small violation may not trigger enforcement 

response, repeated violations may. Single event violations allow you to analyze this information 

without looking through paper files. 

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How Does EPA Plan to Use Single Event Violations? 

EPA will use Single Event Violation data to better understand noncompliance rates within 

specific areas, permit types, or sectors. As is currently the practice in the CAA and RCRA 

programs, EPA assesses the percent of inspections that identify noncompliance as a measure of 

the noncompliance rate. Single Event Violations are also currently included in EPA’s public 

access site (ECHO) as a means to provide transparency regarding government findings. 

Do Single Event Violations Impact the Official QNCR? 

They can. If a Single Event Violation is entered at a major facility with an “RNC detection 

code,” it can cause the facility to appear on the Official QNCR. If the facility is a non-major, a 

Single Event Violation cannot place the facility on the Official QNCR, but it can cause the 

facility to appear in SNC or RNC (again if the proper RNC detection codes are chosen). This is 

described in more detail in the full Data Entry Guide. 

Are Single-Event Violations Publicly Accessible? 

Yes. EPA already makes these data available within ECHO, or via FOIA request. The Data 

Entry Guide will assist EPA and States in making the information more meaningful and 

complete. 

Can Single-Event Violations be Analyzed by Wet Weather Priority Area? 

Yes. The new list of code tables breaks violations down according to wet weather area. 

Violation data used in conjunction with permit type information will allow users to produce 

violator lists broken down by CAFO, CSO, Construction, and SSO universes. 

3