Significant Noncompliance(SNC) Reduction Initiative

Sherri Tilley

Environmental Protection Specialist

Oklahoma DEQ

Water Quality Division

Phone: 405.702.8218

E-mail : Sherri.Tilley@deq.ok.gov

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)