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Compliance Assistance and Enforcement

Joe Clayton

Section Chief

Water Pollution Control Branch, Compliance and Enforcement

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Um, why is the Enforcement guy here? Are we in trouble?

  • “I’m from the government, and I am here to help”
  • Large permit universe, lots of opportunity for noncompliance
  • Nearly 500 active cases
  • Lots of financial needs out there
  • Smaller pool of operators= competition for all of you

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Compliance Assistance

  • The preferred path to compliance

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  • Both for the regulator and regulated!

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“Many hands make light work”

  • Through cooperation and teamwork, we can accomplish large tasks with reduced effort. So long as we all work together to resolve the big, heavy tasks.
  • Wastewater improvements, in most instances, qualify as burdensome, heavy tasks.

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DNR Wastewater Compliance Assistance

  • DMRs, MoGEM accounts, resetting passwords, navigating between pages on MoGEM

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  • We standby ready to provide compliance assistance! We want you to be successful, we want you to be in compliance.

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  • Compliance assistance projects

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Optimization of Recirculating Media Beds

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Mobile MBBR

  • Municipality challenged to meet ammonia
  • DNR Water Specialist, E. C. West with show & tell
  • The portable system is made up of:
  • A 300 gallon tote – Free
  • Moving bed media – fills the tote ½ - - - Free
  • A sump pump - - - supplied by Asbury
  • Garden hose - - - supplied by Asbury
  • Milk crate with swimming noodles to float it their lagoon - - - supplied by Asbury
  • Two 9 inch diameter diffusers and one aerator (4.7 CFM) $599
  • Assorted PCV fitting, pipe and silicone - - - - $15

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Where to begin?

  • Call me. Call your regional contacts, 6 regional offices across the state.

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  • Together we can avoid the adversarial conversations.

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  • How often does a problem resolve itself?

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  • You know your facility; you may be able to anticipate where issues can manifest

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Compliance assistance didn’t work, what’s next?

  • Enforcement- compel compliance through corrective action and administrative penalties

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  • 2 flavors:
    • Referral-compel

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    • Voluntary Referral-cooperate

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Tips and Tricks to avoid referral

  • Permits
  • DMRs
  • Schedule of Compliance-can we extend?
  • Operational monitoring-foreshadows facility performance, address issues now during the grace period
  • Optimization webpage

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Why such an emphasis on compliance?

  • Protect human health and the environment!

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  • EPA is watching too. Remember SNC- significant noncompliance

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  • Formal orders linked in EPA-ICIS= SNC reduction

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The SNC Toolkit

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A.K.A. MOCWIS, the information system housing data related to water quality for the state of MO

The information system utilized by the U.S. EPA for processing national data related to NPDES water quality permits and air quality permits

Public-facing information system used by DEQ for the electronic submission of reports by permit holders

Public-facing information system for the access and analysis of national data from a variety of EPA data systems

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EPA-National Enforcement and Compliance Incentives

  • EPA is watching
  • Issuing emergency orders
  • SNC reduction-specifically functional SNC
  • Top 200 List

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Thank you, MRWA!

  • My team and I especially thank you all.

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  • Feel free to reach out whenever needed

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  • Keep up the great work and coordination with DNR

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Questions?

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  • Joe Clayton (573) 522-1120
  • joe.clayton@dnr.mo.gov

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