Significant Non-Compliance SNC Kristi Savage-Clarke Missouri - - PowerPoint PPT Presentation

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May 12, 2023 281 likes •495 views

Significant Non-Compliance SNC Kristi Savage-Clarke Missouri Department of Natural Resources Compliance and Enforcement Regulated Universe NC RNC SNC Why is SNC Important? Allows targeting of limited enforcement resources to those

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Significant Non-Compliance SNC

Kristi Savage-Clarke

Missouri Department of Natural Resources Compliance and Enforcement

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Regulated Universe

NC RNC SNC

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Why is SNC Important?

Allows targeting of limited enforcement resources to those violations posing the greatest risk to health and the environment

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What is SNC?

It’s all about the violations!

Reporting Effluent limitations Schedules Bypass Pass through Unpermitted discharge

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Majority of DNR’s SNC Violations?

60% of Missouri’s SNC Violations are related to reporting

Non-receipt, late and incomplete reports

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How does EPA Determine SNC?

Identifies violations based on data, compared to permit requirements in ICIS Evaluates whether required data was received on time Recognizes formal enforcement actions

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EPA SNC Data

Enforcement and Compliance History Online (ECHO)

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ECHO

Data available in ECHO 2.5 months after the end of the quarter Each state is responsible for quality assurance on its data Critical for batch submission states like Missouri

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ECHO Challenges

If we have data errors, and late submissions they must be entered by hand in order to be counted accurately Data errors corrected by batch take too long to re-run in ECHO, unlikely to be corrected before report is posted

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EPA National Compliance Initiative (NCI)

June 7, 2019 CWA NPDES SNC NCI 50% reduction NPDES SNC rate Reduce rate from 29.4% to 14.7% by end of FFY 2022

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87.90% 87.00% 86.17% 80.0% 82.5% 85.0% 87.5% 90.0% FY 2017 FY 2018 FY 2019

Wastewater Systems in Compliance with Effluent Limitations

FY 2017 FY 2018 FY 2019

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93.78% 83.68% 71.20% 70% 75% 80% 85% 90% 95% FY 2017 FY 2018 FY 2019

Wastewater Systems in Compliance with Reporting Requirements

FY 2017 FY 2018 FY 2019

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DNR Oct. 1, 2018 – Oct. 1, 2019, ECHO FFYQ4

64% 88% 30% 40% 50% 60% 70% 80% 90% 100% DNR Reporting (All Reports) DNR Exceedances

Compliance Rate

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DNR Oct. 1, 2018 – Oct. 1, 2019, ECHO FFYQ4

76% 50% 0% 10% 20% 30% 40% 50% 60% 70% 80% EPA National EPA MO

Compliance Rate (Rolling Four Quarters)

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How can DNR Help Facilities Get and Stay out of SNC?

Avoid SNC Prompt return to compliance Timely formal enforcement

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What is DNR Doing?

Data Targeting RNC Monitor progress monthly

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Tools

Compliance Assistance

Region staff Record Review letters Reminders

Formal enforcement

Abatement Orders etc. Litigation through AGO

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Tools continued

Data Changes

Corrections Additional Coding

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Missing DMR Data October to January 2020

1591 missing or late DMRs 1643 auto-dialer calls 999 calls answered 419 DMRs submitted Missing or late DMRs reduced by 26%

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