Workshop H Sur Surface W ace Water Compliance Initiativ r Compliance Initiatives, s, Notice of Violation (NO Notice of Violation (NOV) and R ) and Resolution solution of Violation (R of Violation (ROV) Pr ) Processes … ocesses … Proactive Strat Proactiv e Strategies t gies to A Avoid NO oid NOVs Vs Thur Thursda sday, July 25, 20 , July 25, 2019 19 8:45 a.m. t 8:45 a.m. to 1 10:1 :15 a.m. 5 a.m.
Biographical Information Hope Manning, Senior Project Manager/Multi-Media Leader Environmental Quality Management, Inc. 1800 Carillon Boulevard, Cincinnati, Ohio 45240 513-742-7238 hmanning@eqm.com Hope has over 16 years of technical and compliance management experience in the environmental field in both consulting and industry. She has been involved in a broad range of programs including air compliance and permitting, NESHAP Boiler GACT compliance, NPDES permitting and compliance, SPCC, and SWPP Plans generation, and EPCRA SARA Title III, Section 312 and 313 reporting, and auditing. Currently Hope leads the Multi-Media group at EQM which is comprised of individuals who have expertise in air, water, SPCC, and EPCRA reporting. She is also the primary environmental auditor for EQM. Prior to her joining EQM in 2015, Hope was the Corporate Environmental Compliance Manager at Darling Ingredients, Inc., and was responsible for environmental compliance to federal, state, and local requirements for over 50 locations in over 15 states. These activities included assisting in minor and major permitting, regulatory compliance, regulatory interpretation, regulatory reporting, permit compliance and internal auditing. Prior to her time at Darling Ingredients, Inc., Hope was the Water Quality Specialist for The Seminole Tribe of Florida. She was responsible for the water quality program for all surface waters on the Seminole Tribe of Florida reservation lands. Because the Seminole Tribe of Florida is a federally recognized Indian Tribe, she dealt directly with USEPA Region 4 personnel on behalf of the Seminole program. Hope holds a Bachelor of Science Degree in Chemical Engineering from The University of Cincinnati. Scott Sheerin, Compliance Coordinator, Ohio EPA, Division of Surface Water, Central Office 50 W. Town Street, Ste 700, Columbus, OH 43216 614-728-2397 scott.sheerin@epa.ohio.gov Scott has worked for the Ohio EPA, Division of Surface Water since August 2015 as a compliance coordinator in Central Office. His main responsibilities include coordinating with district offices to ensure statewide consistency in the compliance program and coordinating with the USEPA on federal compliance and inspection initiatives. Prior to working for the Ohio EPA, Scott worked as a consultant for over 10 years. During this time, his primary work included assisting facilities with industrial storm water compliance, SPCC compliance, Phase I and Phase II Environmental Site Assessments, underground storage tank (UST) closures, leaking UST remediation, and UST permitting and testing management. Scott is a graduate of The Ohio State University with B. S. in Natural Resource Management. In addition, he has an A.A.S. in Natural Resources from Hocking College.
Biographical Information Bill Palmer, Compliance Manager Ohio EPA, Division of Surface Water, Central Office 50 W. Town Street, Ste 700, Columbus, OH 43216 614-644-2031 william.palmer@epa.ohio.gov Bill has 25 years of experience working at Ohio EPA and started his career in 1988 as a criminal investigator in the Special Investigations Unit. This involved investigating environmental crimes in all program areas. Bill left the Ohio EPA in 1998 and worked for two years at the Wyoming Department of Environmental Quality as the Emergency Response Coordinator. Bill’s primary responsibilities included developing and managing the state’s spill response program. Bill returned to Ohio and worked for five years in the private sector as a Territory Manager for Chemtron Corporation. Bill’s responsibilities included expanding their waste disposal and industrial cleaning services to central and southern Ohio. Bill returned to Ohio EPA in 2004 and was Manager of the Special Investigations Unit for 12 years. Bill joined the Division of Surface Water in 2016 as the Compliance Manager working out of Central Office. Bill oversees the Division of Surface Water compliance program and works closely with USEPA and all Ohio EPA district offices. Bill is a graduate of the University of Wyoming with a B. S. in Fisheries Management from The University of Wyoming.
Surface Water Compliance Initiatives in Cooperation with U.S. EPA and the Ohio NOV Process and Proactive Methods to Avoid Them Workshop H – 1 July 25, 2019
Presenters • Bill Palmer, Compliance Manager, Ohio EPA – Division of Surface Water • Scott Sheerin, Compliance Coordinator, Ohio EPA – Division of Surface Water • Hope Manning, Senior Project Manager, Multi-Media Group Leader, EQM Workshop H – 2 July 25, 2019
Presentation Content • U.S. EPA strategic plan for reducing noncompliance • Ohio EPA’s incorporation of initiative • NOV/ROV procedures • How Ohio EPA and industry can work together • Proactive approach to avoid compliance issues Workshop H – 3 July 25, 2019
Topics • U.S. EPA initiatives • Significant Noncompliance • National Compliance Initiative (NCI) • Ohio Significant Noncompliance Project Workshop H – 4 July 25, 2019
Bill Palmer Central Office Manager Division of Surface Water Workshop H – 5 July 25, 2019
U.S. EPA Initiative U.S. EPA’s (2018‐2022) Strategic Plan identified a new priority to increase compliance with environmental laws. Maximize compliance over the next five years by focusing on areas with significant noncompliance (SNC) issues. Workshop H – 6 July 25, 2019
U.S. EPA Initiative U.S. EPA selected the Clean Water Act (CWA), NPDES as the first program because states and U.S. EPA now have fairly complete compliance data for permitted facilities. Workshop H – 7 July 25, 2019
U.S. EPA Initiative Reduce the national rate of NPDES Significant Non‐ Compliance (SNC) by 50% by Federal Fiscal Year (FFY) 2022 29.4% to 14.7% U.S. EPA developed an Agency Priority Goal to Reduce the SNC rate to 25.7% by September 30, 2019 Workshop H – 8 July 25, 2019
What is Significant Noncompliance (SNC)? • Failure to submit a discharge monitoring report • Failure to meet a permit compliance schedule milestone • Violations of formal enforcement actions • Significant permit effluent violations Workshop H – 9 July 25, 2019
What is Significant Noncompliance (SNC)? Permit effluent limit violations • Violations Exceeding Technical Review Criteria • 40% exceedance for conventional pollutants (e.g. BOD, TSS, ammonia, oil and grease) • 20% exceedance for toxic pollutants (e.g. copper, cyanide, chlorine) Trigger — Two or more months in a six-month period • Chronic violations: any monthly effluent limit by any amount. Trigger — Four or more months in a six-month period Workshop H – 10 July 25, 2019
U.S. EPA Initiative • In context of this new strategic priority to increase NPDES compliance, U.S. EPA will measure success based on the results obtained – the rate of permittees not in SNC. • Increase the percentage of NPDES permittees not in SNC with their permit limits to 85% from a baseline of 71%. This is an approach to measurement that states have consistently proposed to U.S. EPA. Workshop H – 11 July 25, 2019
U.S. EPA Initiative U.S. EPA recognizes the role of authorized states in the NPDES program as the primary implementers and as critical players in the success of this effort. The goal of increasing the compliance rate for this program can be achieved only with substantial, collaborative effort on the part of the states and U.S. EPA, working together. Accordingly, U.S. EPA has engaged states in developing tools and approaches for increasing compliance rates in the NPDES program. Workshop H – 12 July 25, 2019
U.S. EPA Initiative Transition from National Enforcement Initiative (NEI) to National Compliance Initiative (NCI). The name is being changed to convey the message that increased compliance is the goal and enforcement actions are not the only tool for achieving this goal. Workshop H – 13 July 25, 2019
U.S. EPA Initiative In the transition to NCIs, U.S. EPA wants to engage more fully with the states and enhance the full range of compliance assurance tools. Workshop H – 14 July 25, 2019
U.S. EPA Initiative U.S. EPA plans to meet quarterly with states to discuss: • The SNC rate and direction of the rate (is it going down?) • The root cause of the SNC and strategies to reduce the rate • The most serious SNC violators and how they will be addressed Workshop H – 15 July 25, 2019
Ohio SNC State Permits Permit % SNC Effluent Schedule Non in SNC Universe Rate violations violations Receipt DMRs OHIO 569 3,245 17.5 146 109 314 Region 5 1110 8,023 13.8 368 155 584 Ohio has 40% of the permit universe in all of Region 5 (Region 5 consists of: Ohio, Indiana, Illinois, Michigan, Wisconsin, and Minnesota) Workshop H – 16 July 25, 2019
Ohio SNC Permits in Ohio Universe Effluent SNC 4.50% Non submittal SNC 9.68% Schedule SNC 3.36% Not in SNC 82.47% Workshop H – 17 July 25, 2019
Ohio SNC Ohio SNC Effluent 25.66% Non submittal 55.18% Schedule 19.16% Workshop H – 18 July 25, 2019
Recommend
More recommend
