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The Delete Snapshot alert trigger management action does not delete snapshots of Hyper-V VMs. The issue can occur for more than one Hyper-V VM on the same host.
NPM on Hyper-V
The snapshots of the affected VMs are displayed with an incorrect creation date in the list of snapshots in the Delete Snapshots dialog.
When a virtual machine snapshot is created in a Hyper-V environment, the creation date of the snapshot is saved incorrectly. This is a known issue with Hyper-V.
If a virtual machine contains a snapshot with a creation date that is lower than the minimum SqlDateTime value (January 1, 1753), the date is considered invalid, and the Delete Snapshot action by design does not delete the snapshot.
For more information, see the Hyper-V documentation and the Microsoft Technet forums.