Pretreatment Info of the Month
I was recently asked about SNC, specifically, what is it?
SNC or Significant Non Compliance is defined
by 40 CFR 403.8 under the following criteria:
40 CFR 403.8(f)(2)(vii)
(A) Chronic violations of wastewater discharge limits, defined here as those in
which sixty-six percent or more of all of the measurements taken during a six-month
period exceed (by any magnitude) the daily maximum limit or the average limit for
the same pollutant parameter;
(B) Technical Review Criteria (TRC) violations, defined here as those in which thirty-three
percent or more of all of the measurements for each pollutant parameter taken during
a six-month period equal or exceed the product of the daily maximum limit or the
average limit multiplied by the applicable TRC (TRC=1.4 for BOD, TSS, fats, oil,
and grease, and 1.2 for all other pollutants except pH.
(C) Any other violation of a pretreatment effluent limit (daily maximum or longer-term
average) that the Control Authority determines has caused, alone or in combination
with other discharges, interferences or pass through (including endangering the
health of POTW personnel or the general public);
(D) Any discharge of a pollutant that has caused imminent endangerment to human
health, welfare or to the environment or has resulted in the POTW's exercise
of its emergency authority under paragraph (f)(1)(vi)(B) of this section to halt
or prevent such a discharge;
(E) Failure to meet, within 90 days after the schedule date, a compliance schedule
milestone contained in a local control mechanism or enforcement order for starting
construction, completing construction, or attaining final compliance;
(F) Failure to provide, within 30 days after the due date, required reports such
as baseline monitoring reports, 90-day compliance reports, periodic self-monitoring
reports, and reports on compliance with compliance schedules;
(G) Failure to accurately report noncompliance;
(H) Any other violation or group of violations which the Control Authority determines
will adversely affect the operation or implementation of the local pretreatment
program.
What do you do when you find a company in SNC?
“…Comply with the public participation requirements of 40 CFR part 25 in the enforcement
of national pretreatment standards. These procedures shall include provision for
at least annual public notification, in the largest daily newspaper published in
the municipality in which the POTW is located.”
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