SNC? Kristi Savage-Clarke Missouri Department of Natural Resources - - PowerPoint PPT Presentation

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SNC? Kristi Savage-Clarke Missouri Department of Natural Resources - - PowerPoint PPT Presentation

Aug 05, 2023 492 likes •675 views

What are we doing about SNC? Kristi Savage-Clarke Missouri Department of Natural Resources Compliance and Enforcement Sources of Significant Non- Compliance (SNC) Data errors in ICIS, false violations Missing or late discharge monitoring

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What are we doing about SNC?

Kristi Savage-Clarke

Missouri Department of Natural Resources Compliance and Enforcement

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Sources of Significant Non- Compliance (SNC)

Data errors in ICIS, false violations Missing or late discharge monitoring Reports Effluent limitation violations Scheduled Events not completed

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Data Errors

Data correction perpetually ongoing

All majors up to date, now scheduled to be checked for 2nd quarter 2020

  • Approx. 400 minors (218 MOR60A)

Issues

Modified and expired permits that don’t match ICIS Permits and reports must use allowable parameters and units

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Missing DMRs

Since October 2019 we have placed 3,456 calls to 2,178 Facilities

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Missing DMR Example

Facility was non-compliant with subdivision rule and after much work, the only remaining violation was missing DMRs We struggled to get this corrected. After several months of reminders they are now compliant.

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Effluent Limitation Violations

Not a quick fix Targeted inspections

Technical Assistance Guidance for planning improvements

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Scheduled Events

Enforcement Milestones Permit Scheduled Events Narrative Conditions

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FFY2020Q2 aka January to March 2020

Missing Reports-D Missing Scheduled Events-S Effluent Violations-E

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23.5% 26.6% 28.6% 26.7% 31.0% 33.0% 34.6% 35.1% 32.3% 32.1% 30.8%

0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0%

Missouri's Quarterly SNC Rates

Quarter Facilities with SNC Total Facilities Percentage UNOFFICIAL- FY2020Q3 (April-June 2020) 806 2620 30.8% FY2020Q2 (January-March 2020) 840 2619 32.1% FY2020Q1 (October-December 2019) 837 2589 32.3% FY2019Q4 (July-September 2019) 905 2582 35.1% FY2019Q3 (April-June 2019) 899 2597 34.6% FY2019Q2 (January-March 2019) 845 2559 33.0% FY2019Q1 (October-December 2018) 792 2551 31.0% FY2018Q4 (July-September 2018) 682 2556 26.7% FY2018Q3 (April-June 2018) 738 2576 28.6% FY2018Q2 (January-March 2018) 684 2568 26.6% FY2018Q1 (October-December 2017) 595 2535 23.5%

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SNC Metrics: July 2020

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Comparison to other States

Missing Reports-D Missing Scheduled Events-S Effluent Violations-E

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Comparable States

Missing Reports-D Missing Scheduled Events-S Effluent Violations-E

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What are the other states doing?

We looked at 21 states for common problems and tools effective in reducing SNC. Data correction was a common problem with 11

  • ut of 21 states citing this as an issue
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Other States Continued

Tools for SNC reduction PA emails inspectors when a facility exceeds permitted effluent limitations NY uses an expedited penalty which reduced their SNC by 50% Kentucky’s DMR automation has led its SNC rate fall 60% between FFY2011 and FFY2019 LA uses a calendar of team SNC tasks which lowered their SNC rate by 4% in just one quarter.

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Best Approach to SNC Reduction?

Data Clean-up Environmental Monitoring and Enforcement Compliance Assistance

  • Dr. Jay Shimshack, Frank Batten School of

Leadership and Public Policy, University of Virginia

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Questions?

  • Kristi.savage-clarke@dnr.mo.gov; 573-

522-4506