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How EPA SNC designations and WDR thresholds feed California's "inadequate" facility list
Summary
Project staff said NPDS/NPDES facilities are flagged if in an active EPA significant noncompliance streak; WDR facilities are flagged by effluent exceedances (staff-recommended percent thresholds), active enforcement orders, or weighted monitoring/reporting violations.
Project analysts told advisory-group members the inadequate-facility methodology builds on existing regulatory designations and staff-recommended thresholds.
Grace Harrison said the NPDS (NPDES) criteria lean on EPA's "significant noncompliance" (SNC) designation: facilities in an active SNC streak (SNC two or more consecutive quarters) are commonly added to the inadequate list, and facilities with a recent SNC plus any prior SNC in the last five years may also be flagged.
For WDR-permitted facilities, Harrison said the inadequacy…
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