Significant Noncompliance(SNC) Reduction Initiative
Sherri Tilley
Environmental Protection Specialist
Oklahoma DEQ
Water Quality Division
Phone: 405.702.8218
E-mail : [email protected]
SNC
Reduction
Initiative
Priorities
Focus is to increase the compliance rate of
National Pollutant Discharge Elimination System
(NPDES) program
Strategic Plan’s 5-year goal is to reduce the
SNC/Category 1 noncompliance rate by 50% by
end of Federal Fiscal Year (FFY) 2022 to
approximately 12%
Agency Priority Goal (APG) objective is to
reduce the overall noncompliance rate 3% from
baseline (24% to 21%) by FFY2019
SNC Work
Group
SNC Work Group Objectives
➢ Identify violations that are meeting the SNC/ Category 1 criteria the most
▪ DMR non-receipt
▪ Effluent
▪ Schedules
➢ Identify causes & resolutions of SNC/Category I violation
➢ Share and develop best practices that would support SNC reduction
➢ Develop tools to prevent, provide earlier detection, and deter SNC
➢ Provide outreach and training
➢ Strong collaboration between state and EPA
SNC Work Group
(Dan Palmer-OC, Joe Theis -OCE, & Scott Gordon-R4)
SNC Sub-work Groups
Data Quality & DMR
Non-Receipt
(Beth Ragnauth- OC)
Federal
Facilities
(Dominique
Freyre-
FFEO)
Effluent Violation
Deterrence
(Seth Hemingway-
OC)
Communication,
Policy, and
Outreach
(David Piantida-
R8)
Reporting
Issues
Identified
Main issues for non-receipt DMRs
➢ DMR has not been submitted (DMR “True” Non-
Receipt)
➢ DMR was submitted greater than 30 days late
from their due date
➢ Improper use of the No Data Indicator Codes
(NODI)
➢ DMR submitted with an invalid NODI code for
non-sampling
Effluent
Issues
Identified
Main effluent Issues identified
➢ Lack of funding to update infrastructure
➢ Operator not certified
➢ Operator lacks knowledge of plant operations
➢ Inadequate planning and resource
management of finances
➢ Lack of training materials or tools to help
operator identify and resolve plant issues
Reducing
SNC
Success
Stories
Successful mechanisms to reduce SNC
➢ Reducing Non-Receipt Violations with E-mail
Notifications- OK
➢ 5 Keys to Compliance–OH
➢ Wastewater Triage-OH
➢ Best Practices for Reducing Non-Receipt
Violations - AL
➢ Point Assessment Criteria & CEDs Demo-VA
➢ EPA Tools
Enforcement
and
Compliance
History Online
(ECHO)
Tools
Dashboards
➢ NPDES DMR Non-Receipt Status Search
➢ NPDES eRule Readiness and Data
Completeness
➢ State Dashboards Water
➢ NPDES SNC/Category 1Violations
ECHO Tools
Analyze Trends: DMR Non-
Receipt Status Search
Dashboard
ECHO Tools
Analyze Trends: NPDES eRule
Readiness and Data
Completeness Dashboard
ECHO Tools
Analyze Trends: State Water
Dashboard
ECHO Tools
Data
Visualization
Gallery: NPDES
SNC/Category1
Violations
Dashboard
Other Items
Items being discussed or coming soon
➢ Technical assistance and training
➢ Develop SNC Prevention Algorithm
➢ Press announcements of SNC violators
➢ Run RNC processing more frequently and
make the process less manual
➢ Defining when manual resolution of DMR non-
receipt is allowed
➢ Compliance alert
➢ Automating informal enforcement
e-mails/letters
➢ New ECHO Tool-CWA NPDES New Effluent
Violation (beta)