The presentation will include information about how efforts are prioritized under EPA’s Storm Water Enforcement Strategy, how EPA determines permit compliance, and the various enforcement responses to violations.
Finally, Region 4’s storm water inspection program will be addressed.
The focus was on major municipal wastewater treatment plants and industrial facilities which have discharges of over one million gallons per day.
Region 4’s state oversight responsibility includes mid-year and end-of-year review of each state’s enforcement program and oversight of state inspection programs.
EPA’s state oversight role also includes taking the enforcement lead in response to a state referral, when a state fails to take timely and appropriate enforcement action, when there are complex multimedia or national precedent issues requiring huge resources, or in response to citizen notices of lawsuits.
Class I Administrative Penalty Order (APO) – A Class I APO is a formal administrative penalty action which may seek penalties up to but under $27,500.
The state and EPA have performed 21 joint inspections in a targeted watershed focusing on state road projects, large construction sites, shipbuilding/repair facilities, and discharges to impaired waters.
With EPA’s assistance, the state issued six on-site needed to comply notices, three warning letters, and two notice of violation letters.
Also, EPA assisted in training several new state inspectors on conducting storm water inspections.
The goal of EPA’s inspection program is to be pro-active.
This can be accomplished by targeting inspection resources toward priority and/or impaired watersheds not meeting water quality standards, identifying industrial sectors with the greatest potential for contaminated storm water runoff, and conducting enforcement sweeps in a targeted area.
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