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Every three years, EPA announces its key focus areas for NEIs whereby a national enforcement team is deployed to intensely scrutinizes, and penalize if necessary, entities that violate environmental regulations.
Last year, EPA announced its intention to maintain the previous NEI focus areas through fiscal year 2016. That means the current focus areas will remain the same:
- Keeping raw sewage and contaminated stormwater out of our nation’s waters
- Preventing animal waste from contaminating surface and ground waters
- Cutting toxic pollution that affects communities’ health
- Reducing widespread air pollution from the largest sources, especially the coal-fired utility, cement, glass, and acid factories
- Reducing pollution from mineral processing operations
- Assuring energy extraction sector compliance with environmental laws
While NEI activities and EPA generally focus on higher impact cases, it is important to note that EPA also relies heavily on state, local, and tribal agencies to lead enforcement activities for regional or local sources.
To gain a greater understanding of EPA’s enforcement strategies and how to prepare for associated inspections, it is valuable to be familiar with EPA’s enforcement training programs for state, local and tribal authorities.
5 Compliance Tips
Here are 5 tips to get you started on how to ensure your compliance for 2015:
- Know what inspectors are looking for, so you can look for the same thing. If a particular EPA region or area is keenly interested in a certain source of pollution, it’s good to know.
- Assesses environmental compliance by asking hard questions and digging deep into historical records and expansion projects. EPA has broad authority to ask for very detailed records (including financial records)-and they exercise this authority.
- Look for environmental compliance issues that are potentially enterprise-wide. EPA takes particular interest in non-compliance items that indicate a system-wide deficiency across multiple facilities.
- Know your protections under state-level and EPA self-audit and self-disclosure policies. Following prescriptive requirements can limit potential risk when environmental compliance audits are handled the right way.
- Develop an action plan and allocate the resources to put the plan into place. EPA (and other agencies) expect operators to not only address non-compliance, but to identify how compliance will be consistently achieved.
Join Georgette Reeves, EPA’s Compliance Hit List for 2015: Enforcement Outlook and Trends to Watch on January 29. She’ll provide an overview of EPA’s national inspector training and the key areas of focus during that training. She will also review EPA’s recently released 2014 enforcement data (including penalties assessed), and provide a comparison of enforcement activities dating to 2008.
This webinar is intended to help operators determine what areas could be the largest areas of risk (from an enforcement perspective), and to provide recommendations on reducing that risk.
Register now for this timely and insightful event!
Georgette Reeves, MPA, serves as the national Oil and Gas Sector Leader and Managing Consultant based in Trinity Consultant’s Austin office. Since joining the company in 2007, Reeves has been overseeing business development activities and project execution related to the oil and gas industry. Based in New Mexico until 2014, she continues to be an active member and committee member of the New Mexico Oil and Gas Association (NMOGA) and the Independent Petroleum Association of New Mexico (IPANM), and participates in various other industry organizations throughout the country.
As a managing consultant, Reeves has experience in compliance assistance and review, emissions quantification and inventories, regulatory analysis and interpretation, greenhouse gas (GHG) reporting for the oil and gas industry (O&G), and New Source Performance Standards (NSPS) for the O&G industry. She also instructs various Trinity courses regarding GHG reporting for the oil and natural gas industry, as well as air quality regulations specific to the O&G industry. Reeves holds a master’s degree in Public Administration from the University of New Mexico.