Inspectors Compl
Assistance Resou
vlv PiiuLfcjd on paper that contains at least
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Office of Enforcement and Compliance Assurance
National Compliance Monitoring Policy Branch (NCMPB)
(MC 2223A)
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
Note: Send any comments or contact name changes
to NCMPB at address to left, ATTN: Inspectors
Compliance Assistance Resource Guide or submit
to the Inspector Website at: http://intranet.epa.gov/
oeca/inspector/.
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i traduction
What is the purpose of this guide?
This guide provides information to environmental inspectors
on how to use the compliance assistance resources that have
been developed by EPA's Office of Enforcement and Compliance
Assurance (OECA) and other EPA program offices. Inspectors
may use this guide to prepare for facility inspections, to refer
to during facility inspections, to provide a list of compliance
resources to the facility, and to prepare inspection reports. The
guide may also be useful to others who do on-site work
directly with the regulated community.
EPA developed these compliance assistance resources,
which range from hard-copy documents to interactive on-line
tools, to help both inspectors and the regulated community
understand environmental compliance issues. This guide dis-
cusses these resources in detail and presents examples of how
they can be used by inspectors. Within these resources,
inspectors should be able to find:
~ Compliance assistance tools developed by EPA, states,
local agencies, and other groups;
~ Regulatory requirement summaries;
~ Industrial process and waste generation descriptions;
1
~ Pollution prevention opportunity descriptions; and
~ Analyses of current compliance status.
This guide is organized into the following sections:
~ Introduction;
~ Section 1 - EPA Sector Notebooks;
~ Section 2 - EPA Compliance Assistance Centers-,
~ Section 3 - National Environmental Compliance Assistance
Clearinghouse;
~ Section 4 - EPA Audit Protocols;
~ Section 5 - EPA compliance Incentives and Auditing;
~ Section 6 - Other Tools-,
~ Attachment 1 - Sector-Specific Tools Summary; and
~ Attachment 2 - List of EPA Regional Compliance
Assistance Coordinators.
How can these compliance assistance tools
help me?
Below is a brief description of the compliance assistance
tools available. Sections 1 through 6 provide more details on
these tools and examples of how you can use them.
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Sector Notebooks: The notebooks describe the opera-
tions performed at facilities within various industrial sec-
tors. They describe the regulatory requirements and com-
pliance status for the sectors. This information can be use-
ful when you are unfamiliar with an industrial sector and
can help target potential areas of noncompliance.
Compliance Assistance Centers: The Centers provide
compliance assistance for specific industry sectors heavily
populated with small businesses and other entities facing
federal environmental regulation. The Centers provide
information through Web sites, hotlines, training sessions,
and fax lines. This information can help you locate com-
pliance information and inspection tools for certain indus-
try sectors.
National Environmental Compliance Assistance
Clearinghouse: The Clearinghouse is an interactive tool that
allows you to access compliance assistance resources quick-
ly and interact with other assistance providers easily. You
can find compliance information by topic (e.g., sector, geo-
graphic location, environmental concern), share your know-
ledge with others on the web site, or find out what EPA and
others are planning to do. You can also download relevant
compliance information prior to an inspection.
Audit Protocols: These protocols provide information on
specific federal statutes or regulations. You can review
the protocols to identify records and process areas to
inspect and can use the audit checklist during inspections.
Please note that inspections should be conducted in
accordance with procedures in the compliance inspection
manual.
~ Compliance incentives and Auditing: These include EPA's
policies and programs that eliminate, reduce, or waive
penalties under certain conditions for business, industry,
and government facilities that voluntarily discover,
promptly disclose, and expeditiously correct environmen-
tal noncompliance. You can use the incentives and audit-
ing policies to encourage self-policing of environmental
programs.
~ Other Tools: These include the following: the OECA Web
site, including other compliance assistance tools, the
Online Tracking Information System (OTIS), and the Sector
Facility Indexing Project; and other EPA program office
web sites, including EPA's Toxic Release inventory program
with guidance manuals for certain industries and the
Pollution Prevention Resource Exchange Web site.
The following example demonstrates how you can use the
compliance assistance tools prior to an inspection.
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Example - How to Use Compliance Assistance Tools Prior to an Inspection
You are planning an inspection at a shipyard. You look through each of OECA Compliance Assistance Tools available for
information prior to inspection.
1. Sector Notebook
(http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/) - You can find the
following information in the Sector Notebook, Profile of the Shipbuilding and Repair Industry.
• A description of the industry (process, products, raw materials);
• Pollutant outputs-,
• Chemical release and transfer quantities;
• Applicable regulations;
• Pollution prevention opportunities-, and
• Compliance assurance activities.
2. Compliance Assistance Centers - You browse the Paints and Coatings Resource Center (http://www.paintcenter.org)
for information on regulations, pollution prevention activities, and typical emissions that occur during the coating of
ship parts and materials.
3. National Environmental Compliance Assistance Clearinghouse (http://www.epa.gov/clearinghouse/) - The
Clearinghouse provides links to regulations so that you can determine the requirements for the shipyard. You will also
identify over 20 resources that may be useful to the site for future compliance assurance.
3
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Example - How to Use Compliance Assistance Tools Prior to an Inspection (continued)
4. Audit Protocols - You know the shipyard is subject to Emergency Planning and Community Right-to-Know Act (EPCRA)
reporting; therefore, you print a copy of the audit protocol for this regulation as a reference
(http://www.epa.gov/compliance/incentives/auditing/protocol.html). You can use the lists of records and areas to
inspect and the checklist during the inspection.
5. Compliance Incentives and Auditing - You use the Compliance Incentives and Auditing Web Site
(http://www.epa.gov/compliance/incentives/index.html) to identify any applicable compliance incentives, environ-
mental management systems (EMS), and pollution prevention resources.
6. Other Tools r You use the OECA Web site and On-Line Tracking System (OTIS) (http://www.epa.gov/idea/otis)
to generate reports on the facility to be inspected. You can identify any previous noncompliance issues or
enforcement actions.
For an index of compliance assistance tools by industry sectors and corresponding resources Web sites, see Attachment 1.
4
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EPA/OECA TOOLS
Section 1 Sector Notebooks
1.1 What are the Sector Notebooks? What is
their purpose?
The Sector Notebooks (Notebooks) are a growing series of
industry-specific documents developed by EPA to provide staff
and managers with a consolidated source of compliance-relat-
ed information for specific industry sectors. Each document
contains a lay person's explanation of the major environmental
challenges facing the industry A wide range of users, including
government agencies, facility managers, researchers, educa-
tors, and environmental professionals, refer to the Notebooks
for sector environmental information. The Notebooks assist
users to:
~ Research an industry its environmental problems, its
compliance history and environmental regulations that
apply to it;
~ Understand compliance issues;
~ Design comprehensive, common-sense environmental
protection measures for specific industries;
~ Build a foundation for developing solutions to environ-
mental problems;
~ Create and improve pollution prevention programs; and
~ Develop industry-specific training sessions and programs.
1.2 What information do the Notebooks contain?
Each Notebook contains the following sections:
~ Introduction to the industry - Provides an overview of
the industry (e.g., product types, industry size, geographic
distribution, economic trends);
~ Description of industry processes - Details specific
industrial processes, raw materials, pollution outputs, and
chemical and waste management practices;
~ Chemical release and transfer profile - Provides infor-
mation gathered as part of EPA's Toxic Release Inventory
(TRI) program, discussions of specific chemicals released,
other release information, and industry comparisons;
~ Pollution prevention opportunities - Describes the pol-
lution prevention opportunities that have been demon-
strated in the sector;
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~ Summary of applicable federal statutes and regulations
- Describes statutes and regulations, including pending or
proposed regulations, and industry-specific requirements;
~ Compliance and enforcement history - Describes the
sector's compliance history comparison of enforcement
activity between selected industries, and review of major
legal actions;
~ Compliance assurance activities and initiatives -
Describes government and industry initiatives for compli-
ance assurance and technical assistance; and
~ Resource materials and contacts.
Table 1
Industrial Sectors For Which OECA Has Developed Sector Notebooks
Industry Sector (Profile of the ...)
Sector Includes:
Aerospace Industry
Manufacture and assembly of aircraft, space vehicles, guided missiles, and
associated parts.
Agricultural Chemical, Pesticide,
and Fertilizer Industry
Manufacture and production of fertilizers, the formulation of pesticide
chemicals (agricultural and nonagricultural) manufactured at separate facili-
ties, and the production of other miscellaneous agricultural chemicals. This
notebook does not include information on use, sale, distribution, or storage
of such chemicals.
6
1.3 For which sectors are Notebooks available?
Table 1 identifies the industrial sectors for which OECA has
developed sector notebooks. EPA maintains a growing series
of profiles of major U.S. industries. To download copies of the
Notebooks or for information on obtaining printed copies, visit
the Notebook Web site at: http://www.epa.gov/compliance/
resources/publications/assistance/sectors/notebooks/.
Printed copies are available free of charge to government per-
sonnel at (800) 490-9198; ask for Sector Notebooks or by title,
Profile of the XXXX Industry.
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TdblC 1 (continued)
Industry Sector (Profile of the ...)
Sector Includes:
Agricultural Crop Production Industry
Crop production, greenhouses and nurseries, and forestry and logging.
Agricultural Livestock Production Industry
A wide range of agricultural livestock facilities.
Air Transportation Industry
Establishments furnishing domestic and foreign air transportation, operating
airports and flying fields, and furnishing terminal services.
Dry Cleaning Industry
Commercial, industrial, and coin-operated dry cleaning.
Electronics and Computer Industry
Manufacture of electrical distribution equipment, household appliances, com-
munication equipment, electrical industrial apparatus, radio and television
receiving equipment, electronic components and accessories, electrical
wiring and lighting equipment, and other electrical equipment and supplies.
The electronics/computer industry comprises five major sectors:
telecommunications, computers, industrial electronics, consumer
electronics, and semiconductors.
Fabricated Metal Productions Industry
Forming of metal shapes and performing metal finishing operations.
7
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Table 1 (continued)
Industry Sector (Profile of the ...)
Sector Includes:
Fossil Fuel Electric Power Generation
Industry
Facilities that use coal, petroleum, or natural gas as fuel to generate
electricity This Notebook does not include information on facilities that use
nuclear or renewable (e.g., wood or solar) energy sources exclusively
Ground Transportation Industry
Rail transportation, trucking, and pipelines.
Inorganic Chemical Industry
Production of inorganic chemicals.
Iron and Steel Industry
Steel works, blast furnaces, and rolling and finishing mills.
Local Government Operations8
Activities managed or operated by local governments, including construction/
property management, pesticide/vector management, public safety solid
waste management; wastewater management, water resources
management, water supply and vehicle equipment maintenance.
Lumber and Wood Production Industry
Cutting timber and pulpwood and manufacturing finished articles made
entirely or predominantly of wood or related materials; sawmills, lath mills,
shingle mills, cooperage stock mills (wooden casks or tubs), planing mills, and
plywood mills.
0 Part of government series Notebooks; included with the Sector Notebooks for your convenience.
8
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TablG 1 (continued)
Industry Sector (Profile of the ...)
Sector Includes:
Metal Casting Industry
Casting of ferrous and nonferrous products.
Metal Mining Industry
Exploration for metallic minerals, mine development, and mining of ores.
Motor Vehicle Assembly Industry
Manufacture and assembly of equipment for the transportation industry (by
air, land, or water).
Nonferrous Metals Industry
Primary and secondary smelting and refining of nonferrous metals from ore
or scrap.
Non-Fuel, Non-Metal Mining Industry
Mining and quarrying of nonmetallic minerals, except fuels.
Oil and Gas Extraction Industry
Exploration for petroleum deposits through transport of product from the
production site.
Organic Chemical Industry
Production of organic chemicals.
Petroleum Refining Industry
Separation of crude oil into its major distillation fractions and processing of
petroleum products.
9
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Table 1 (continued)
Industry Sector (Profile of the...)
Sector Includes:
Pharmaceuticals Industry
Fabrication and processing of medicinal chemicals or pharmaceutical products.
Plastic Resin and Man-made Fiber Industry
Production and processing of plastic resin and man-made fibers.
Printing Industry
Printing operations, platemaking, book binding, and publishers.
Pulp and Paper Industry
Notebook focuses primarily on pulp processes; also contains a limited
discussion on papermaking.
Rubber and Plastics Industry
Manufacture of products from plastic resins, natural and synthetic rubber,
gutta percha, balata, and gutta siak.
Shipbuilding and Repair Industry
Building and repair of ships, barges, and other large vessels (self-propelled
or towed).
Stone, Clay, Glass, and Concrete Industry
Manufacture of flat glass; pressed or blown glass and glassware; glass prod-
ucts; hydraulic cement; structural clay products; pottery and related products;
concrete, gypsum, and plaster products; cut stone and stone products; and
abrasives, asbestos, and miscellaneous nonmetallic mineral products.
1 0
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Table 1 (continued)
Industry Sector (Profile of the...)
Sector Includes:
Textile Industry
Spinning of natural and man-made fibers into yarn or thread; weaving and
knitting of fabrics; and dyeing and finishing of fabrics.
Transportation Equipment Cleaning
Industry
Cleaning operations performed at a variety of facility types (e.g., petroleum
refineries, marine cargo facility).
Water Transportation Industry
Freight and passenger transportation on the open seas or inland waters and
incidental services (e.g., lighterage, towing, and canal operations).
Wood Furniture and Fixtures Industry
Manufacture of household, office, store, public building, and restaurant furni-
ture and fixtures.
Refer to Web sice (http://www.epa.goV/compliance/resources/publicai:ions/assistance/seaors/notebooks) for additional
sectors that have been added.
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1.4 How do I use the Notebooks?
For compliance inspections, you can use the Notebooks to:
1. Learn about industry processes, raw materials, and
pollution outputs. The Notebooks discuss the major
industry processes, chemicals and/or materials used,
and common pollution outputs (including type of out-
put and location).
2. Identify chemical releases. The Notebooks list the
common chemicals released and the type of releases
(i.e., air, water, or land disposal).
3. Identify statutes and regulations applicable to the
industry. The Notebooks provide a starting point for
identifying statutes and regulations that apply to the
sector, along with industry requirements. To identify
specific requirements under the statutes and regula-
tions, you may need to do additional research.
4. Locate common discharge locations and compli-
ance and enforcement history. The Notebooks can
help identify major sources of environmental problems
common at most sites. However, keep in mind that not
all processes or process configurations may be present
at a specific facility The enforcement history for the
industry can also provide a starting point to targeting
potential noncompliance areas. Data in this section
come from EPA's Integrated Compliance Information
System (ICIS), formerly the Integrated Data for
Enforcement Analysis (IDEA) system. You can search
the ICIS system for a specific facility to determine past
noncompliance and enforcement areas. See the dis-
cussion of EPA's Online Tracking Information System
(OTIS) in Section 6.1.
The following example illustrates how you can use the
Notebooks when planning a site visit.
Example - How to Use Sector Notebooks Prior to Inspections
You plan to inspect a steel facility that operates an electric arc furnace (to melt a scrap steel feed) and a caster (to form the
molten steel), and forms carbon steel strip products, You review the Sector Notebook, Profile of the Iron and Steel Industry
(E PA/310- R-95-005), to:
1 2
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Example - How to Use Sector Notebooks Prior to Inspections (continued)
1. Familiarize yourself with the operations and pollution outputs;
2. Identify chemical releases;
3. Identify applicable statutes and regulations; and
4. Determine compliance status of industry and potential noncompliance areas.
1. Familiarize yourself with the operations and pollution outputs.
Sections II and III of the Notebook include an introduction to the iron and steel industry and industrial process descriptions.
Exhibit 5 of the Notebook provides an overall flow diagram for the electric arc furnace, or EAF, steelmaking process. The
facility performs EAF steelmaking, continuous casting, and hot forming.
In the text of Section III, you find that the EAF steelmaking process produces metal dusts, slag, and gaseous products. The
facility uses a gas cleaning process to convey particulate matter and gases. The EAF dust is a listed hazardous waste (RCFiA
waste code K061) and is primarily composed of iron or iron oxides. Lead and cadmium are the primary hazardous materials
in EAF dust. Depending on the scrap composition, lime and/or fluorspar (flux), zinc, and other metals may be present. Oils
from the scrap may be burned off during the process. The melting process generates nitrogen oxides and ozone.
Continuous casting and hot forming operations use process contact water to cool the steel. The water becomes contami-
nated with oil, grease, and mill scale (usually settled from the process water). If the facility treats wastewater on site, it gen-
erates wastewater treatment sludge.
From Section III.B, you find that raw materials to the EAF include scrap metal, electric energy, graphite electrodes, and fluxes
and alloys (e.g., fluorspar, dolomite, aluminum, manganese).
1 3
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Example - How to Use Sector Notebooks Prior to Inspections (continued)
2. Identify chemical releases.
Section IV of the Notebook presents a chemical release and transfer profile of the industry. The data presented from TRI
include all iron and steel facilities. Because the facility you are inspecting contains only a subset of all industry processes,
the information may not be applicable to your site. Keeping this in mind, you note some of the highlights in the Notebook:
• Over half the releases are to on-site land disposal;
• Manganese, zinc, chromium, and lead account for over 90 percent of on-site land disposal (note: from Section II,
you know that chromium is more common for specialty steel production, not carbon steel);
• One-quarter of the releases are either fugitive or point source air emissions;
• Particulates, carbon monoxide, nitrogen oxides, and sulfur compounds are released to the air due to combustion;
and
• Eighty percent of off-site transfers are recycled (primarily metals).
3. Identify applicable statutes and regulations.
Notebook Section VI.B identifies environmental statutes and regulations applicable to the sector. You discover the following
apply to the facility you plan to inspect:
• Clean Air Act (CAA)
- Title I of the CAA requires attainment and maintenance of National Ambient Air Quality Standards. For your
facility, nitrogen oxide, lead, and particulate matter are usually affected.
- Maximum Achievable Control Technology (MACT) standards identify EAFs as possible sources of hazardous air pollutants.
1 4
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Example - How to Use Sector Notebooks Prior to Inspections (continued)
- New Source Review (NSR) requirements apply to your facility if it has expanded or performed process modifica-
tions. The NSR may require a permit prior to construction or operation.
- New Source Performance Standards apply to EAFs.
• Clean Water Act (CWA) - 40 CFR 420 establishes limits on certain pollutants for continuous casting and hot forming
operations.
• Resource Conservation and Recovery Act (RCRA) - EAF emission control dust and sludge is a hazardous waste (K061)
and subject to RCRA requirements.
• Emergency Planning and Community Right-to-Know Act (EPCRA) - Sections 301 -313 of EPCRA include requirements
for release notification and inventory reporting.
4. Determine compliance status of the industry and potential noncompliance areas.
Section VII provides a compliance and enforcement history for the iron and steel industry. You learn that 115 of the 275 facil-
ities (42 percent) inspected in the five-year period received one or more enforcement actions. However, the enforcement-
actions-to-inspections ratio was only 0.14. Overall, most inspections were split between the CAA, the CWA, and RCRA, with
recent emphasis on the CAA. The facility must comply with all three regulations; therefore, a multimedia inspection cover-
ing all three regulations may be prudent.
The Notebook does not list specific noncompliance areas; however, it does include a review of some enforcement actions.
You can contact the Office of Civil Enforcement at (202) 564-2220 for additional information or summaries of actions
taken. Other resources include the Online Tracking information System (OTIS) and Enforcement and Compliance History
Online (ECHO). For more information regarding OTIS or ECHO, please contact Rebecca Kane at (202) 564-5960.
1 5
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1.5 Who should I contact about the Notebooks?
To download copies of the Notebooks or for information on
obtaining printed copies, visit the Notebook Web site at:
http://www.epa.gov/compliance/resources/publications/
assistance/sectors/notebooks/index.html. Printed copies
are available free of charge to government personnel at
(800) 490-9198; ask for Sector Notebooks or by title, Profile
of the XXXX Industry.
16
The EPA contact for the Sector Notebook project
Seth Heminway (MC 2224A)
Phone: (202) 564-7017
E-mail: heminway.seth@epa.gov
U.S. EPA Headquarters
Ariel Rios Building ,
1200 Pennsylvania Avenue, NW
Washington, DC 20460
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Section 2 Compliance Assistance Centers
2.1 What are Compliance Assistance Centers?
What is their purpose?
The Compliance Assistance Centers (Centers) are a partner-
ship between EPA's Office of Compliance, industry academic
institutions, environmental groups, and other federal and state
agencies. The purpose of the Centers is to provide compliance
assistance to industry sectors heavily populated with small
businesses and other entities facing federal environmental reg-
ulation. The Centers provide information through:
~ Web sites (http://www.assistancecenters.net provides
links);
~ Hotlines;
~ Publications;
~ Training sessions; and
~ Fax lines (including Web fax back).
2.2 What information do the Centers contain?
The Centers are designed to provide:
1
~ Comprehensive, easy-to-understand compliance informa-
tion by industry sector (primarily for small businesses and
technical assistance providers);
~ Links via the Internet between the small business com-
munity and their technical and regulatory assistance
providers and between the providers themselves to share
tools and knowledge and prevent duplication of efforts;
~ Compliance assistance tools (e.g., guides, consolidated
checklists, and fact sheets);
~ Access to information and technical assistance on pollu-
tion prevention and compliance goals to help minimize
waste production and maximize environmental perform-
ance;
~ Ways to reduce the costs of compliance through technolo-
gies and best management practices that reduce pollution
while saving money; and
~ Communication between the sectors and EPA and the
opportunity for small businesses to increase their under-
standing of EPA policies and programs and for EPA to
increase its understanding of sector-related issues.
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2.3 For which sectors
EPA has developed Centers
~ Agriculture;
~ Automotive recyclers;
~ Automotive services
and repair;
~ Chemical manufacturers;
~ Colleges & universities;
~ Construction;
~ Federal facilities;
~ Healthcare;
are Centers available?
for many sectors including:
~ Local governments;
~ Metal finishing;
~ Paints and coatings;
~ Printed wiring boards;
~ Printers;
~ Transportation;
~ Tribal; and
~ U.S./Mexican Border.
Many of the Centers are described in the following sub-
section.
1
Agriculture-National Agriculture Compliance Assistance
Center (Ag Center) (http://www.epa.gov/agriculture)
The Ag Center offers the following through its Web site and
fax-back line, (913) 551-7270:
~ Compliance news (e.g., fact sheets, manuals, links to
Federal Register notices);
~ information on over 30 environmental topics;
~ Laws, policies, and guidance;
~ Environmental requirements by agricultural sector and
pesticide industry; and
~ Publications and resources.
The Ag Center also has a toll-free phone number for questions:
(888) 663-2155. You may find the following sections of the Ag
Center's Web site useful for inspections:
1. Topics - You can search for environmental requirements
background information, compliance aids, and resources
for information and assistance, as shown in Figure 1.
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One of the key topics includes "compliance and enforce-
ment" Compliance and enforcement information available
from the Center includes:
~ Audit policy and related publications;
~ Small business links;
~ Statute-specific policies and guidance; and
~ Links to further information.
Figure 2 shows the "compliance and enforcement" topic
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. Publications - You can find publications on a wide selec-
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21
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Automotive Services and Repair-CCAR-GreenLink®
(http://www.ccar-greenlink.org/)
CCAR-GreenLink'9 offers, through its Web site and phone line
((888)-GRN-LINK), compliance information on:
~
Used oil and filter
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management
~
~
Underground storage
~
tanks
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~
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Antifreeze;
~
Motor vehicles;
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~
Batteries,
~
~
Brake pads;
procedures; and
alternatives.
CCAR-GreenLink® provides graphic depictions of a virtual colli-
sion repair shop, a spray booth, a paint mixing booth, and an
automotive repair shop. You can click on objects in the virtual
shops and booths to obtain information on applicable require-
ments. For example, in the virtual automotive repair shop shown
in Figure 3, clicking on the used oil drum in the picture links
users to a guide book, fact sheet and article about used oil.
22
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to get to the Liforaiation Index Page regarding that item.
CoFjnsta© 1996-2006, CCAR*.
Absorbents
Air Conditioning
Antifreeze
Batteries
8rw"
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Emergency Soill Procedures
Emissions
Fueling/Painting
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Metal Finishing
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Figure 3. CCAR-GreenLink® Auto Repair Shop
23
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Chemical Manufacturers - ChemAlliance
(http://www.chemalliance.org/)
The ChemAlliance Web site directs chemical manufacturers
to:
~ Plain language regulatory requirements;
~ Regulatory and industry news/events;
~ Environmental articles;
~ Pollution prevention alternatives;
~ Best management practices; and
~ Unit operation requirements and alternatives.
Figure 4 presents the ChemAlliance home page.
You may find the following sections of the ChemAlliance
Center useful for inspections:
1. The ChemAlliance Regulatory Handbook includes:
~ Virtual plant tour - review of operations from a regulatory
standpoint;
~ Regulatory tour - summary of regulations;
~ Background and history of environmental regulations;
~ Glossary of terms;
~ List of EPA hotline phone numbers; and
~ Links to laws and regulations.
Figure 5 presents the virtual plant tour screen.
24
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Welcome to our new "Look & Peel"!
. Remember,
| We hope you enjoy our minor face I'iftl WeVe tried to keep the same useful information, but organize it in a little easier-to-use format. New upgrades include:
• Weblinks - We have a much updated and expanded set of on-line resources available for text searching, or browsing
i • Virtual Plant Tour ¦ New and improved virtual plant tour, including about 550 case studies, plus a "Search Case Study" feature, so you can hone in on the specific
process or problem you want to solve.
Upeonting Regulatory events
« a 7 ?w?l hteCherr07; Security. Stewardship Supsly Chain IMearalirg Security into Management Systems fOct 1-3. 2007 Baltimore MP';
. .» ?i >»»?• SOCMA Golf Tournament to Benefit ACS Scholars Program. September 11 2007 Chesterfield. NJ
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. Itii ?w?t Partners in Environmental Technolooy Technical Symposium & Workshop. December 4-6. 2007 Washington 0 C.
. i-l >?»07l 7 Essential Uocomino EH&S Trainings at NC Stale
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Figure 4. ChemAlliance Home Page
25
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Figure 5. ChemAlliance Virtual Plant Tour
26
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You can select the following areas of the plant for which you
would like more information:
~ Cooling towers;
~ Construction;
~ Boilers/furnaces;
~ Loading station;
~ Vent/flare;
~ Warehouse;
~ Storage tanks;
~ Remediation;
~ Piping;
~ Hazardous waste shed;
~ Distillation/separation;
~ Laboratory;
~ Reactors;
~ Incinerator;
~ Equipment cleaning;
~ Landfill; and
~ Wastewater treatment;
~ Office.
~ Neighboring town;
2. The Solutions and Supports Web page under the
Handbook includes links to:
~ EPA program offices and regional/state contacts;
~ Compliance support Web sites including OECA, other EPA
programs, and OSHA;
~ Industry and trade association Web sites;
~ Pollution prevention and voluntary program Web sites; and
~ Environmental management system (EMS) Web sites.
3. The Toofs in Review Web page under the Handbook
includes links to tools for:
~ Compliance self-assessment;
~ Risk management assessment;
~ Environmental management systems; and
~ Pollution prevention opportunities.
-------
Federal Facilities - Federal Facilities Assistance Center
(FedSite) (http://www.fedcenter.gov)
FedSite provides information about environmental laws and
regulations that affect federal departments and agencies,
including the following:
~ Virtual facility regulatory tour;
~ Links to federal agencies and state compliance programs;
~ Training resources; and
~ Review of EPA demonstration and compliance assistance
projects.
Inspectors may find the "Virtual Facility Regulatory Tour"
helpful for inspections. This tour covers compliance issues and
topics common to federal agencies. Figure 6 lists the T1 topics
covered.
Tours of each topic area highlight environmental issues. For
example, the virtual tour for construction sites lists six compli-
ance issues: National Environmental Policy Act (NEPA), construe
tion and demolition (C & D) debris, asbestos, stormwater, lead
paint and green construction.
Also included with the virtual facility tour are pollution pre-
vention templates for:
~ Building renovation;
~ Electronics shop;
~ Ground maintenance;
~ Hazardous waste;
~ Laundry and dry cleaning;
~ Manufacturing shops;
~ Medical clinics; and
~ Vehicle maintenance.
28
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Air Emission Sources
Cleanup Sites
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Landfills
Medical Facilities
Solid Waste Storage
Storage Tanks
Vehicle Maintenance
Wastewater Treatment
Facilities
EPA Enforcerrtent
Focus
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Comments/Suggestions?
Click here for a Text Version of the facility tour.
Home About Us Site Map Important Notices Privacy Contact Us
ag] Menu ready for use £ Internet
Figure 6. FedSite Virtual Facility Regulatory Tour
29
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Local Governments - Local Government Environmental
Assistance Network (LGEAN) (http://www.lgean.org/)
The LGEAN site provides environmental management, plan-
ning, and regulatory information for local government officials,
managers, and staff, including the following:
~ Environmental and regulatory news by topic (e.g., air,
brownfields) and topic search;
~ Regulatory information; and
~ Consultant directory.
Inspectors may find the "Tools & Resources - Toolbox" use-
ful for inspections. This feature is an interactive tool that
guides users through reporting requirements. The topic areas
include:
30
~ Air
~ Drinking water
~ Energy
~ Financing
~ General
~ Hazardous waste
Figure 7 displays the
~ Pesticides
~ Small communities
~ Smart growth
~ Solid waste
~ Stormwater
~ Urban forestry
home page for this Center.
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31
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Metal Finishing - National Metal Finishing Resource Center
(NMFRC) (http://www.nmfrc.org/)
The NMFRC Web site provides comprehensive environmental
compliance, technical assistance, and pollution prevention
information to the public and subscribers. Public information
includes:
~ Environmental news;
~ Center news articles;
~ Information on current EPA regulations (including pending
regulations);
~ Vendor and shop databases;
~ A member list; and
~ Common Sense Initiative information (includes reports on
pollution prevention, risk characterization, and other
topics).
Figure 8 highlights the "Public Area" of the Web site.
The NMFRC provides links to state environmental agencies,
contacts, and on-line regulations. Included on the links page
for each state are links to various resources provided by the
states, such as fact sheets, compliance assistance guidance,
permit guidance, and permit and reporting forms. The
resources are organized by industry sector and include sectors
in addition to metal finishing.
The NMFRC also includes an area containing additional tech-
nical information regarding the metal finishing sector for which
subscribers pay an annual fee.
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Paints and Coatings - Paints and Coatings Resource Center
(http://www.paintcenter.org/)
The Paints and Coatings Resource Center provides regulatory
compliance and pollution prevention information including:
~ Regulatory and compliance assistance - plain language
guides, state regulation locator, federal regulations, com-
pliance incentives for small businesses, EPA self-audit and
inspection guide for organic finishing of metals, and regu-
latory determinations;
~ Technical information;
~ Environmental news; and
~ Vendor directories.
This Center also includes an "Ask the Expert" feature. Users
can e-mail questions on paints and coatings to an industry
expert and search the "Ask the Expert" archives (under
Technical Info) for answers to previous questions. Other fea- .
tures of the Center are the "VOC Calculators" (under
Regulations), which estimate VOC emissions based on user
inputs. The Web site presents a variety of calculators so that
VOC emissions can be estimated for different types of coatings
and in various terms (for example, pounds per volume of solids
or pounds per volume of coating).
Figure 9 shows an example of a VOC calculator.
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Printed Wiring Boards - Printed Wiring Board Resource
Center (PWBRC) (http://www.pwbrc.org)
The PWBRC provides public and member regulatory compli-
ance and pollution prevention information including the public
items listed below:
~ Technical document database;
~ Information on current EPA regulations (including pending
regulations);
~ Compliance assistance;
~ State regulation information;
~ Vendor, facility and recycler databases;
~ Pollution prevention tools; and
~ Environmental news.
You may find the following sections of the PWBRC useful for
inspections:
1. Frequently Asked Questions - The following questions are
answered:
~ What is a printed wiring board (PWB)?
~ How are PWBs manufactured?
~ What is the regulatory status of PWB by-products?
~ What pollution prevention options are available?
~ Where can I recycle PWB waste?
2. Public Resources - Figure 10 displays the public resources
available on the PWBRC, which include the following:
~ List of recent updates (What's New and Headlines);
~ Information on ongoing rulemakings (e.g., proposed rules);
~ Vendor database;
~ Facility directories; and
~ Compliance assistance resources including a plain lan-
guage guide to the regulations, state and federal regula-
tions, RCRA information, and small business policies.
Using the plain language guide to the regulations search
(shown in Figure Tl), you can find information on:
- Air emissions - CAA overview, state and regional agen-
cies, regulated PWB processes, accidental releases,
and air pollution abatement equipment.
- Wastewater discharges - CWA overview, federal laws
and regulations, local and state rules, prominent
wastewater issues, and additional resources.
- Solid and hazardous waste management - overview,
federal laws and regulations, state regulations, man-
agement and shipment of wastes, reporting and
36
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recordkeeping, recycling under RCRA, prominent
issues, and additional resources.
- Toxic chemical reporting - requirements under EPCRA
Sections 3TI/312 and 313 and TRI chemicals common to
PWB manufacturing, state requirements, and other
resources.
- Policy on compliance incentives for small businesses.
37
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Figure 11. PWBRC - Compliance Information
39
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Printers - Printers' National Environmental Assistance
Center (PNEAC) (http://www.pneac.org/)
The PNEAC site offers:
¦ i
~ Fact sheets and case studies;
~ Training (video conferences and tapes);
~ Federal and regional environmental program information
and guides;
~ National and state compliance information;
~ State regulations locator;
~ E-mail discussion groups on technical and regulatory
issues;
~ Industry news;
~ Pollution prevention opportunities; and
~ Vendors and suppliers database.
A fax-back document line is also available: (888) 87-76322
((888) US-PNEAC).
Figure 12 shows the' PNEAC Web site.
You may find the following sections of the PNEAC Web site
useful for inspections:,
1. Compliance Information - This area of the Web site pro-
vides the plain language guide to the regulations, compli-
ance assistance resources, and other information. You can
look for tools based on operation, medium, or program.
2. Fact Sheets and Case Studies - This area of the Web site
provides information on printing operations including
gravure, flexography lithography and screen printing.
40
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41
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Transportation - Transportation Environmental Resource
Center (TERC) (http://www.transource.org/)
The TERC Web site provides:
~ Compliance assistance information for each mode of
transportation-air, shipping and barging, rail, and trucking;
~ Information on environmental topics (e.g., air pollution,
storage tanks, water pollution, hazardous materials, fuels
management);
~ Audit guides; and
~ Videos and forums.
You may find the following sections of TERC useful for
inspections:
1. Compliance Resources by Sector - The Web site provides
links to information by transportation sector (e.g., aviation,
barging, or rail). By clicking on one of these links, you will find:
~ Compliance checklists and guides;
~ Sector notebook;
~ Regulatory issues;
~ List of resources; and
~ Regulatory links.
TERC includes environmental screening checklist workbooks for:
4
~ Airports and tenant operations;
~ Water transportation industry;
~ Short line railroads;
~ Trucking industry; and
~ Terminal operations.
One of the transportation sector links, "Aviation," is shown
in Figure 13 as an example.
2. Regulations - You can find how federal EPA regulations
apply to the transportation industry by choosing one of the
following options on the Web site:
~ Air - small business guide and CAA applicability;
~ Hazmats - hazardous waste transport rules, managing
hazardous wastes, and information for hazardous waste
generators (by size);
~ Water - wastewater and stormwater permits and regula-
tory updates (e.g., proposed rules);
~ Tanks - above-ground and underground storage tanks; and
~ Fuels - reporting oil spills, used oil mixing requirements,
and final rule on flammable fuels.
3. The Audit section of the Web site provides compliance
assistance checklists and guides (including applicable
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Integrated Contingency Plan "One Plan" Guidance (PDF)
October 01, 2000
GAO Report on Aviation and the Environment (Results from a
Survey of the Nation's 50 Busiest Commercial Service
Airports) (PDF) Seatember 08, 2000
GAO Report on Av:aticn and the Environment (Airport
Operations and Future Growth Present Environmental
Challenges) (PDF) September 08, 2000
Enclosures with EPA Letter to .Airports (PDF) July 24, 2000
EPA Letter to Airports on Voluntary Disclosures and
Environmental Auditing (PDF) July 24, 20C0
EPA Announcement on Environmental Audits and Voluntary
Disclosures (PDF) Jul* 24, 2QG0
Aviation Noise Abatement Policy 2000 (PDF) July 14, 2000
GAO Report on Aviation and the Environment (PDF) May 16,
2000
Water Pollution Contacts
State Storm Water Contacts
Storm Water Contacts: EPA Regional Offices
Call For Nominations her the 2000 AIAA/AAAE/ACC Jay
HoJIingsworth Spsas Airport Award (PDF)
¦ |
Sector Notebook
Figure 13. TERC - Aviation Screen
43
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The "Trucking" link connects the user to the Green Truck Web site (http://www.greentruck.com/) for regulatory and compli-
ance assistance information, as shown in Figure 14.
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44
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2.4 How can the Centers help me in performing inspections?
The following example demonstrates how you can use the automotive repair facility. Please note that the specific infor-
CCAR-GreenLink® Web site to prepare for an inspection at an mation available may vary from one Center to another.
Example - How to Use Compliance Assistance Centers Prior to Inspections
You plan to inspect an automotive repair facility. You review the CCAR-GreenLink® Center to:
1. Find applicable statutes and regulations;
2. Identify potential noncompliance areas; and
3. Find applicable checklists for your inspection.
1. Find applicable statutes and regulations.
At the CCAR-GreenLink® Web site, you search for federal regulations. The articles cover the following topics:
• State programs {e.g., state scrap tire programs);
• EPA regulatory requirements;
• Underground storage tank requirements; and
• Other management standards (e.g., used oil management).
45
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Example - How to Use Compliance Assistance Centers Prior to Inspections (continued)
In addition, you find articles about waste generation, pollution prevention, and compliance assistance, including the topics below:
• Hazardous waste sources and minimization programs;
General waste management practices (e.g., stormwater, operations, spill management);
Pollution prevention and waste minimization (including volatile organic compound (VOC) emissions);
• Best environmental practices for a variety of topics;
Compliance assistance;
Fact sheets on used oil management absorbents, antifreeze, paint waste, spent solvents;
Alternative chemicals; and
• Worker's health protection.
2. Identify potential noncompliance areas.
You can use the information from Item 2 to identify noncompliance areas for auto repair shops. From the items listed in
the compliance report, absorbent management is the most likely source of noncompliance. All the other areas listed are
potential sources since 25 percent or more of the shops are not 80 percent compliant or better.
Under the CCAR-GreenLink® News section, you can identify potential areas of noncompliance based on EPA regulatory activi-
ties. Articles include violations concerning:
• Oil spill prevention regulations; • Underground storage tanks;
46
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Example - How to Use Compliance Assistance Centers Prior to Inspections (continued)
RV refrigeration units;
Hazardous waste;
Oil and diesel fuel dumping;
Oil spills;
Other CAA, CWA, and RCRA violations; and
Illegal imports.
• PCB violations;
3. Find applicable checklists for your inspection.
Under the "Env. Checklist" link, you find EPA's Consolidated Screening Checklist For Automotive Repair Facilities.
For more specific topics, you can browse or search articles, where you find a number of checklists, including the following:
• Pollution Prevention/Waste Minimization Checklist for the Automotive Repair and Maintenance Industry;
• Hazardous Wastes, Self-Audit Checklist for Generators of;
• Used Oil, Self-Audit Checklist for Generators of;
• Underground Storage Tank (UST) Compliance Self-Checklist;
• Air Quality - Self-Evaluation Checklist; and
• Environmental Self-Assessment for Vehicle Maintenance Shops.
4 7
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2.5 Who should I contact about the Centers?
The Compliance Assistance Centers Web site is
http://assistancecenters.net.
The EPA contact for the Compliance Assistance Centers is:
Tracy Back (MC 2224A)
Phone: (202) 564-7076
E-mail: back.tracy@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
48
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Section 3 National Environmental Compliance Assistance Clearinghouse
3.1 What is the National Environmental
Compliance Assistance Clearinghouse? What
is its purpose?
The National Environmental Compliance Assistance
Clearinghouse (Clearinghouse) is a Web-based clearinghouse
designed to provide quick access to compliance assistance
tools, contacts, and planned activities across the U.S. The
Clearinghouse also serves as a forum to collaborate and
exchange information. The Clearinghouse is designed for users
from a variety of backgrounds.
3.2 What information does the Clearinghouse
contain?
The Clearinghouse provides links to compliance assistance
activities, tools, or technical assistance that:
1 Assist the regulated community in understanding and
complying with environmental regulations; or
2. Assist compliance assistance providers in helping the
regulated community comply with environmental
regulations.
49
Information in the Clearinghouse includes:
~ Experts Directory;
~ Frequently asked questions;
~ Environmental news - includes regulatory updates and dis-
cussions;
~ Planned and ongoing activities;
~ Compliance assistance tools (e.g., checklists, electronic
compliance and reporting tools, environmental manage-
ment systems, expert systems and "smart" advisors,
guidance materials, policy documents, quick references,
training resources, Web site links, and other tools);
~ Program overviews - EPA projects, state and local govern-
ment projects, and other organization projects; and
~ Pollution prevention information.
You can search the Clearinghouse using the "Search" function or
by the topics button located on the left navigation bar, such as:
~ Industry and government sectors;
~ Environmental focus area (e.g., pollution prevention);
~ EPA region and states; and
~ Compliance assistance tool types (e.g., case studies,
checklists).
-------
Figure 15 shows the Clearinghouse home page.
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3.3 What sectors are included in the
Clearinghouse?
By clicking on the "Industry & Gov't Sectors" button, you
can search for the following industry sectors:
~ Aerospace
~ Agriculture
~ Automotive
~ Chemical manufacturing
~ Computer and electronics
~ Construction
~ Dry cleaning
~ Federal facilities
~ Food processing
~ Furniture manufacturing
~ Hazardous waste management
~ Healthcare
~ Laboratories
~ Leather tanning and finishing
~ Local government
~ Metals
~ Metal services and finishers
~ Minerals, mining, and processing
~ Petroleum
~ Pharmaceuticals
~ Power generation
~ Printing
~ Pulp, paper, and lumber
~ Rubber, plastics, and fibers
~ Schools
~ Shipbuilding and repair
~ Small business
~ Textiles
~ Transportation
~ Tribal
~ Other
3.4 How can the Clearinghouse help me with
inspections?
The following example demonstrates how you can use the
Clearinghouse to prepare for an inspection at a construction
site.
51
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to Inspections
You plan to inspect a construction site in Maryland. You review the National Environmental Compliance Assistance
Clearinghouse to:
1. Find applicable compliance assistance links using various search criteria to:
• Determine applicable statutes and regulations; and
• Find and download relevant compliance assistance tools for an industry program, or specific facility (e.g., check-
lists) for inspections.
2. Identify pollution prevention opportunities.
3. Talk to other experts using the Experts Directory.
4. Find out what compliance assistance activities EPA, states, and industry are planning for in the near future.
5. Share information or checklists with the public or other inspectors by adding a link.
1. Find applicable compliance assistance links.
You perform two searches in the Clearinghouse - one for the construction industry and one for the state of Maryland. Your
search under "Industry & Gov't Sector" for the construction industry leads to 150 links. You narrow your search by
"Geographic Area."
e o
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to Inspections (continued)
• For Region 3, you find 2 relevant documents:
- EPA Region 3 Water Protection Division Stormwater Pollution Prevention Web Site; and
- U.S. EPA Region 3 Air Protection Division - Construction Permits.
• For Maryland, you find 2 relevant documents:
- Maryland CET "Environmentally Sound Practices in the Homebuilding Industry" Video; and
- Low Impact Development: A New Paradigm for Stormwater Management (Prince George's County MD:
slide show).
53
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to Inspections (continued)
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Department of the Environment Web site. For example, one link goes to Maryland's Stormwater Management Program. You
can also search the entire Maryland Web site for construction sector information or environmental topic information.
C A
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to Inspections (continued)
To identify applicable compliance assistance resources, you search the "Compliance Assistance Tools" topic. If you know what
type of too! you would like to identify you can narrow your search. For example, you want to find a checklist for the construc-
tion industry in Maryland. As shown below, a search on construction industry checklist does not result in a hit. So instead, you
can review non-industry-specific compliance checklists to determine if any of them are useful for your inspection.
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55
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to Inspections (continued)
2. Identify pollution prevention opportunities.
Under the "Environmental Topics" button, you can search for a list of pollution prevention links, which results in over 100
matching resources. When you check this page, you find:
• EPA pollution prevention resources;
• EPA regional pollution prevention centers;
• CLEAN pollution prevention pilot project (EPA Region I program that offers small- and medium-sized businesses free, on-
site compliance and pollution prevention audits - and enforcement amnesty for any violations discovered in process - in
exchange for an agreement to correct violations and undertake a "beyond compliance" pollution prevention project); and
• Other applicable Web sites.
3. Talk to other experts using the Experts Directory.
You can identify experts on various topics through the Experts Directory or communicate with other assistance providers
through bulletin boards (see item 5 below). Under the Experts Directory you search for experts using a location-based query
for EPA Region 3. You identify over 20 resources for the Region - some are specific to environmental issues and some are spe-
cific to states or regions. Chatting with these experts may resolve questions you have for the facility you are about to visit
4. Find future compliance assistance activities.
If you want to know what tools will be coming down the pike, you can click on the "Planned and Ongoing Activities" topic.
If a facility has a problem that is not addressed by current resources, you may find a future tool that will address the prob-
lem. For example, you can find planned EPA activities by fiscal year and EPA region as shown below.
c c
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to inspections (continued)
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57
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Example-How to Use the National Environmental Compliance
Assistance Clearinghouse Prior to Inspections (continued)
5. Share information by adding a link.
If you know of a useful compliance assistance tool that is not currently on the Clearinghouse, you can add it to the site by
clicking on "Add Your Information." This allows you to share your information with a broader audience. The "Add a
Resource" Web page is shown below.
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3.5 Who should I contact about the
Clearinghouse?
The Clearinghouse Web site is http://www.epa.gov/
clearinghouse/. The interactive features on the Clearinghouse
allow users to add related links, join forums, and report specif-
ic compliance needs.
The EPA contact for the Clearinghouse is:
Tracy Back (MC 2224A)
Phone: (202) 564-7076
E-mail: back.tracy@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
59
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Section 4 Audit Protocols
4.1 What are the Audit Protocols? What is their
purpose?
OECA developed audit protocols under its Strategies and
Policies - Cross Program/Multimedia program
(http://www.epa.gov/compliance/incentives/auditing/
protocol.html). Each Audit Protocol presents a single federal
statute or regulation (e.g., CERCLA Section 103) and provides back-
ground and checklists for the user. The purpose of the Audit
Protocols is to encourage the regulated community to develop
self-assessment programs at individual facilities. Voluntary audit
programs help facilities comply with regulations and identify pol-
lution prevention opportunities. You can use these protocols
when inspecting a facility; you may suggest the use of the proto-
cols to facilities not currently performing voluntary audits. You
can also check state Web sites for additional checklists. Note that
the audit protocols should not be a substitute for having a good
understanding of the applicable regulations. Please also note that
inspections should be conducted in accordance with procedures
in the compliance inspection manual.
4.2 What information do the Audit Protocols
contain?
6
Each Audit Protocol introduces the protocol program and
presents the Audit Protocol specific to that statute or regula-
tion. The Audit Protocol contains the following information:
~ Checklist - provides items for reviewer to inspect (should
be used for all inspections when available);
~ Index for checklist user;
~ Applicability - what activities the protocol applies to;
~ Review of federal legislation - summary of the statute or
regulation;
~ State and local regulations - notice of whether state or
local regulations may apply;
~ Key compliance requirements;
~ Key terms and definitions;
~ Typical records to review - list form;
~ Typical physical features to inspect - list form;
~ List of acronyms and abbreviations; and
~ Applicable reference appendices (e.g., list of substances or
chemicals reportable under the regulation).
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4.3 For which statutes and regulations are Audit
Protocols available?
Audit Protocols are currently available for the following
statutes and regulations:
~ RCRA:
- Used oil and universal waste generators
- Facilities regulated under Subtitle D
- Storage tanks
- Treatment, storage, and disposal facilities (TSDFs)
- Hazardous waste generators;
~ Comprehensive Environmental Response, Compensation,
and Liability Act (CEF3CLA);
~ EPCRA and CEFJCLA Section 103;
~ Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA);
~ Public water systems under the Safe Drinking Water Act
(SDWA);
~ Municipal facilities under U.S. EPA's wastewater regula-
tions; and
~ Facilities with PCBs, asbestos, and lead-based paint under
TSCA.
Each document title is Protocol for Conducting Environmental
Compliance Audits under the XXXX, where XXXX refers to the
statute or regulation listed above.
4.4 How do I use the Audit Protocols?
The following example demonstrates how you can use the
Audit Protocols to prepare for an inspection at a site subject to
the RCRA Subtitle D requirements.
Example - How to Use the Audit Protocols Prior to Inspections
You plan to inspect a facility regulated under Subtitle D of RCRA. You refer to the Protocol for Conducting Environmental
Compliance Audits of Facilities Regulated under Subtitle D of RCRA. After reading through the introduction, you use the Audit
Protocol to:
1. Identify applicable statutes and regulations;
2. Review requirements of the regulation(s); and
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Example - How to Use the Audit Protocols Prior to Inspections (continued)
3. Determine information needed from site and areas to inspect to determine site compliance.
1. Identify applicable statutes and regulations.
You determine that the facility is subject to RCRA Subtitle D - collection, treatment and disposal of nonhazardous solid
waste.
2. Review requirements of the regulation.
The facility operates a solid waste incinerator and is located in a state where the U.S. EPA has delegated its authority to
implement RCRA provisions. The facility must have a state permit to operate. The federal regulation establishes minimum
standards, but the state permit should specify the requirements for the facility. Key compliance issues include:
• Collection and storage requirements;
• Recycling requirements depending on facility size;
•. Open dumping restrictions;
• Landfill restrictions (not applicable to the site); and
• Thermal processing facility requirements.
A hotline is also provided for further questions.
3. Determine information needed from the facility and areas to inspect to determine site compliance.
63
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Example - How to Use the Audit Protocols Prior to Inspections (continued)
The Audit Protocol presents a list of records to review and physical areas to inspect to determine compliance with Subtitle D
of RCRA. Using the Index for Checklist Users, you determine which part of the checklist applies to the facility (e.g., the land-
fill checklists on pages 25 - 61 do not apply to the site, so you do not need to review them).
At the inspection, you may use the checklist to perform your inspection. For example, the facility should store solid waste
in a manner to prevent a fire, health, or safety hazard (Part of SO. 10.1., page 19 of document).
4.5 Who should I contact about the Audit
Protocols?
The EPA contact for the Audit Protocols is:
Sharie Centilla (MC 2224A)
Phone: (202) 564-0697
E-mail: centilla.sharie@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
C A
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Section 5 Compliance Incentives and Auditing
5.1 What are Compliance Incentives and
Auditing? What is their purpose?
Compliance incentives and Auditing (http://www.epa.gov/
compliance/incentives/index.html) are policies and pro-
grams that eliminate, reduce, or waive penalties under
certain conditions for business, industry, and government
facilities that voluntarily discover, promptly disclose, and
expeditiously correct environmental problems. The audit-
ing renders formal EPA investigation and enforcement
action unnecessary.
5.2 What information do the Compliance
Incentives and Auditing contain?
EPA's Compliance Incentives and Auditing Web site provides
information on:
~ Compliance incentives-,
~ Innovations-,
~ Auditing;
~ Environmental Management Systems (EMS)-,
~ Pollution prevention;
~ Small business compliance policy-, and
~ Small local governments compliance assistance policy.
Compliance Incentives
In connection with the Audit Policy, EPA has established, and
continues to establish, programs for promoting environmental
compliance and violation correction by offering incentives to
the regulated community in exchange for agreements to per-
form self-assessment, disclosure, and the correction of viola-
tions. These incentives may involve reduced penalties for viola-
tions, extended time for correction, reduced inspections, and/or
other considerations. Tools used for compliance incentives (e.g.,
innovations, auditing) are discussed below.
Innovations
EPA innovations explore new and creative ways of achieving
positive environmental results and making them a routine. EPA
has adopted a problem-solving approach to address environ-
mental problems that involves compliance assistance, incentives
and auditing, compliance monitoring, and civil and criminal en-
forcement. EPA uses a number of innovative tools as part of its
core program to ensure compliance, including:
65
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~ EMSs - discussed below;
~ Environmental Results Programs - partnership with
states to develop self-certification;
~ Audit program - discussed below;
~ Market-based mechanisms - working with the Security
and Exchange Commission (SEC) to use these mechanisms
to promote environmental compliance; and
~ National Performance Track - offers participating mem-
bers low inspection priority for routine inspections (com-
pliance incentives).
Auditing
EPA's Audit Policy, Incentives for Self-Policing: Discovery,
Disclosure, Correction and Prevention of Violations, has been in
effect since 1995. It reflects input from industry trade associa-
tions, state environmental programs, and public interest
groups. The Audit Policy is designed to provide incentives for
regulated entities to comply with the federal environmental
laws and regulations. These incentives are for regulated enti-
ties that voluntarily discover, promptly disclose, and expedi-
tiously correct noncompliance, making formal EPA investiga-
tions and enforcement actions unnecessary.
EPA has also developed a series of Environmental Auditing
Protocols to assist the regulated community in developing self
audit programs at individual facilities to evaluate their compli-
ance with the environmental requirements under the federal
laws and regulations. The protocols are intended solely as
guidance in this effort. The regulated community's legal obliga-
tions are determined by the terms of applicable environmental
facility-specific permits and underlying statutes, as well as the
applicable state and local laws. See Section 4 for further
details.
EMSs
The International Organization for Standardization (ISO)
defines environmental management systems as "that part of
the overall practices, procedures, processes and resources for
developing, implementing, achieving, reviewing and maintain-
ing the environmental policy" EMSs focus on environmental
management practices rather than the activities themselves.
They provide the structure by which certain activities can be
carried out; they ensure operator training and that proper pro-
cedures are in place but don't specify methods or frequency of
sampling. EMSs allow federal agencies and facilities flexibility
to adapt the system to their needs and priorities. Publications
are available on the OECA Web site that further discuss EMSs.
Pollution Prevention
EPA designed its pollution prevention program to help incor-
porate pollution prevention concepts and principles into the
66
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daily operations of government agencies, businesses, manu-
facturers, nonprofit organizations, and individuals.
The Web site includes links to the State Pollution Prevention
Programs and the Pollution Prevention Information Clearing-
house (PPIQ. These links provide information on agencies and
organizations that provide pollution prevention assistance. The
Web site also links to EPA's Pollution Prevention Grants; these
grants are designed to promote pollution prevention concepts
and practices.
Small Business Compliance Policy
The Small Business Compliance Policy promotes environ-
mental compliance among small businesses (those with 100 or
fewer employees) by providing incentives to discover and cor-
rect environmental problems. EPA will eliminate or significantly
reduce penalties for small businesses that voluntarily discover
violations of environmental law and promptly disclose and cor-
rect them. For additional information on the Policy, see
http://epa.gov/compliance/incentives/smallbusinesses/
index.html. Those businesses with more than 100 employees
may be eligible for the Audit Policy.
A wide range of resources are available to help small busi-
nesses learn about environmental compliance. These resources
include-, training, checklists, compliance guides, mentoring pro-
grams, and other activities. Businesses can find more informa-
tion through links on the Web site to EPA's Centers (see Section
6
2), Clearinghouse (see Section 3), and EPA's Small Business
Ombudsman's Office (http://www.epa.gov/sbo).
Small Local Governments Compliance Assistance Policy
The 2004 Small Local Governments Compliance Assistance
Policy (which replaced the Small Communities Policy) encour-
ages states to respond to a small community's environmental
violations with comprehensive compliance assistance. EPA will
defer to a state's decision to reduce or waive penalties for a
small local government (a unit of local government defined by
the state's constitution with 3,300 or fewer permanent residents)
if the local government either achieves or commits to achieve
compliance with all of the environmental requirements that
apply to its governmental operations; or commits to correct all
of its known violations and to develop and implement an
environmental management system (EMS) for its governmental
operations.
Under a second tier of eligibility, the revised Policy also
applies to local governments with more than 3,300 but fewer
than 10,000 permanent residents if the state performs a con-
forming capacity test and determines that the local govern-
ment is unlikely to achieve and sustain compliance without
the state's assistance.
For more information on the Policy, refer to the Small Com-
munities Compliance and Enforcement Web site (http://epa.gov/
compliance/incentives/smallcommunities/index.htmi).
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5.3 How do I use Compliance incentives and
Auditing?
For compliance inspections, you can use the Compliance
Incentives and Auditing to:
1. Prepare information for the site about compliance
incentives that may apply. The site may be unaware of
resources available to perform self-audits and the EPA
incentives for voluntarily discovering, promptly disclosing,
and expeditiously correcting environmental problems.
Sites may be eligible for the Small Business Compliance
Policy or Small Local Governments Compliance Assistance
Policy.
2. Review EMS information. Inspectors or site personnel
can use EMS publications or general information to develop
procedures to achieve environmental compliance.
3. Identify applicable pollution prevention resources. You
can identity pollution prevention resources or practices for
specific industries or operations.
The following example demonstrates how you can use
the Compliance incentives and Auditing to prepare for an
inspection.
Example - How to Use the Compliance Incentives and Auditing Prior to Inspections
You plan to inspect an automobile repair shop in Arizona with less than 100 employees. To assist the shop in complying
with statutes and regulations, you find EPA incentives and auditing policies applicable to the facility. You use the Compliance
Incentives and Auditing Web site (http://www.epa.gov/compliance/incentives/index.html) to:
1. Prepare information for the facility about compliance incentives that may apply;
2. Review EMS information; and
3. Identify applicable pollution prevention resources.
68
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Example - How to Use the Compliance Incentives and Auditing Prior to Inspections (continued)
1. Prepare information for the facility about compliance incentives that may apply.
Because the shop employs less than 100 employees, it is eligible for EPA's Small Business Compliance Policy. You can provide
the site with links to the Small Business Ombudsman office (http://www.epa.gov/sbo), which provides information on
environmental assistance, auditing, and directory of assistance providers. The Web page also provides details on the incen-
tives and auditing policies.
2. Review EMS information.
The EMS publications Web page (http://www.epa.gov/compliance/resources/publications/incentives/ems/index.html)
includes a link to EMS guide entitled An Implementation Guide for Small and Medium-Sized Organizations along with other
publications the site may find useful to assist with environmental compliance.
3. Identify applicable pollution prevention resources.
EPA's Pollution Prevention Program includes small business programs and initiatives (http://www.epa.gov/compliance/
incentives/smallbusiness/index.html). EPA aims to streamline and coordinate technical assistance from small business
development centers and to provide small businesses a voice in EPA's rulemaking process. Small businesses are an important
target for pollution prevention outreach because they typically lack resources to fund their own environmental personnel,
but collectively are responsible for a large percentage of waste.
The Pollution Prevention Web page provides regional and state contacts the shop can use to identify pollution prevention
practices. Contacts include the EPA Region 9 Pollution Prevention Program, Arizona's Department of Environmental Quality,
and other Arizona program contacts.
69
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5.4 Who should I contact about the Compliance
Incentives and Auditing?
The EPA contact for the Compliance Incentives Audit
Policy is:
Philip Milton (MC 2248A)
Phone: (202) 564-5029
E-mail: milton.philip@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Quick Response Team:
Roy Kime
Phone: (202) 564-2539
The EPA contact for the Small Business Compliance
Policy is:
Beverly Updike (MC 2224A)
Phone: (202) 564-7142
E-mail: updike.beverly@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
The EPA contact for the Small Local Governments Compliance
Assistance Policy is:
Ken Harmon (MC 2224A)
Phone: (202) 564-7049
E-mail: harmon.kenneth@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
-------
Section 6 Other Tools
Other compliance assistance tools available for multiple sec-
tors include:
~ OECA Web site - Compliance Assistance Web page, the
Online Tracking Information System, the Inspector Web
Site, the Sector Facility Indexing Project, the Environmental
Management Application and Pollution Prevention Tool,
and the Water Compliance Assistance Web site discussed
in Section 6.1; and
~ Publications, fact sheets, and training available on EPA pro-
gram Web pages (e.g., for effluent limitations and guide-
lines under the CWA, the Office of Water's Office of
Science and Technology Web page includes publications
for over 70 sectors).
6.1 OECA Web Site
The OECA Web site (http://www.epa.gov/compliance
/index.html) includes information concerning:
~ Planning and results;
~ Compliance assistance;
~ Compliance incentives and auditing;
7
~ Compliance monitoring;
~ Civil enforcement;
~ Cleanup enforcement;
~ Criminal enforcement;
~ Environmental justice;
~ NEPA;
~ Information resources;
~ Newsroom;
~ Where you live-link to environmental data related to your
neighborhood and surrounding area; and
~ Training.
The "Compliance Assistance" Web page on the OECA Web
site provides links to compliance assistance resources dis-
cussed previously in this document to compliance assistance
planning tools, and to other available tools by industry and
government sectors, as listed in Figure 16.
Below are descriptions of the compliance tools available on
the OECA Web site.
-------
ft Industry and Government Sectors Compliance Assistance \ Compliance and Enforcement i US CPA • Microsoft Internet I xpiorer
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EPA provides compliance assistance on a sector-by-sector basis in order to efficiently reach facilities with similar operations, processes or practices.
A sector is a distinct part of the economy that shares.
Similar operations, processes or practices
Similar environmental problems and impacts
Similar compliance issues and either distributes goods or performs services More. ..
Additional information that may affect your sector can be found in compliance assistance bv statute.
Sector-Based Compliance Assistance Tools:
Select a sector from the list on the right for these compliance assistance tools relevant to that sector.
Compliance Assistance Centers provide comprehensive, easy to understand compliance information targeted to specific industry
and government sectors.
Sector Notebooks plain language books each of which describes a major U. S industry and the environmental regulations that apply to its
activities
Compliance Assistance and Inspection Publications also are available including guides, manuals, fact sheets and brochures that pertain to an
individual sector or a specific regulation.
National Compliance Assistance Clearinghouse links to public and private compliance assistance materials. Users may post documents and
interact with assistance providers, both within and outside of EPA The Clearinghouse allows users to search for relevant material on new and
existing regulations, pollution prevention opportunities, and voluntary programs that were created by other parts of EPA, other federal agencies,
tribes, states and local agencies, industry and other organizations.
Sectors
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Compliance Monitor im» - Assuring compliance through etlective monitoring arid assessment
Compliance ln
-------
Online Tracking Information System (OTIS)
The OECA Web site provides historical information on facility
and industrial sector compliance and enforcement The Online
Tracking Information System (OTIS) is one tool that provides
multimedia environmental performance data for facilities regu-
lated by EPA.
OTIS is a high-speed retrieval tool that allows EPA and state
environmental personnel to access integrated enforcement
and compliance data via the Internet. This collection of search
engines enables EPA staff, state/local/tribal governments, and
federal agencies to access a wide range of data relating to
enforcement and compliance. OTIS can be used for many func-
tions, including planning, targeting, analysis, data quality
review, and pre-inspection review. EPA launched OTIS'Version 4.0
in November 2001. Version 4.0 adds a statistical interface (OTiS
Management Reports), provides several search enhancements
to EPA's multimedia environmental performance database
interfaces, and supports on-line error correction. The search
limit for queries has been expanded to 1,000 records. OTIS is
located at http://www.epa-otis.gov/otis/. Figure 17 displays
the home page of the OTIS Web site.
-------
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With OTIS you can obtain a comprehensive historical profile
of inspections, enforcement actions, penalties assessed, toxic
chemicals released, and emergency hazardous spills for any
EPA regulated facility This single point of access provides infor-
mation from the Agency's Air, Water, Hazardous Waste, TRI,
and Emergency Response Notification Systems. You can use
OTIS to:
~ Produce the compliance history on a specific facility;
~ Retrieve data for performing multimedia analysis of regu-
lated facilities;
~ Identify a group of facilities that meet a specific criteria;
and
~ Produce aggregated data on selected industries.
Inspector Web Site
EPA's Inspector Web Site, http://intranet.epa.gov/oeca
/inspector/, is available to EPA personnel. It is a single compre-
hensive resource tool for EPA inspectors where information
about inspections, health and safety policy and regulatory
issues, technologies, and compliance assistance can be easily
located. The Web site is organized into the following topic
areas:
~ Reference Desk (including pollution prevention);
~ Checklists and Workbooks;
~ EPA Investigations;
~ Health and Safety;
~ Manuals and Protocols;
~ Training; and
~ Additional Resources and Links.
Figure 18 shows the Inspector Web Site home page.
The EPA contact for the Inspector Web Site is:
Rafael Sanchez (MC 2223A)
Phone: (202) 564-7028
E-mail: sanchez.rafael@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
5
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7 6
-------
Sector Facility Indexing Project (SFIP)
Another data source within the OECA Web site is the
Sector Facility Indexing Project (SFIP). This Web page
(http://www.epa.gov/sfipmtn1) allows users to obtain
environmental and other information from a number of
data systems to produce facility-level profiles for the
following five industry sectors:
~ Petroleum refining;
~ iron and steel production-,
~ Primary nonferrous metal refining and smelting;
~ Pulp manufacturing; and
~ Automobile assembly.
SFIP also includes a subset of major federal facilities. These
facilities belong to a variety of federal agencies including the
Department of Defense (DoD), Department of Energy (DoE),
National Aeronautical and Space Administration (NASA), and
the Department of the Interior (Dol).
SFIP provides environmental data about each facility, such
as the number of inspections, compliance with federal regula-
tions, enforcement actions taken, chemical releases, and spills.
SFIP also includes background information on the location of
each facility and its environmental conditions, as well as infor-
mation on the population of the surrounding area. Production
capacity is provided for industry facilities but not for federal
facilities, due to the diversity of their operations.
You can view and sort the data in a number of ways, by
selecting standardized report formats or by creating your own
analyses. For example, you can check on a particular facility's
record of compliance with environmental regulations, compare
the performance of one facility to other similar facilities in that
sector, look at data across an entire sector, or analyze the
environmental performance of the facilities in a given state.
To guarantee useful facility-level information on SFIP, EPA
works to identify the correct universe of facilities to be includ-
ed in analyses and ensures the accuracy of the data. As part of
this effort, all facilities have an opportunity to review the data
and provide comments. EPA and the states then review the
responses and make changes to the data as appropriate.
SFIP also maintains a hotline: (617) 520-3015.
The EPA contact for the SFIP is [Program merged with ECHO]:
Rebecca Kane (MC 2222A) - ECHO Contact
Phone: (202) 564-5960
E-mail: kane.rebecca@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
-------
Environmental Management Application and Pollution
Prevention Tool (EMAPT)
EPA and the National Center of Manufacturing Sciences
{NCMS) are developing the Environmental Management
Application and Pollution Prevention Tool (EMAPT) to assist
businesses in complying with federal and state regulations.
The Web-based tool identifies compliance information for
various process activities that occur across industry sectors
{e.g., tank management, pesticides management). For each
process activity, you can find the following information:
~ Applicable federal and state regulations;
~ Audit information; and
~ Pollution prevention opportunities.
EMAPT also provides a RCRA database that inspectors can
use to identify whether RCRA requirements apply to a facility
The tool can be accessed through the EPA Compliance Assist-
ance Centers.
For more information, you can contact
Tracy Back (MC 2224A)
Phone: (202) 564-7076
E-mail: back.tracy@epa.gov
U.S. EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Water Compliance Assistance
The Water Compliance Assistance Web site (http://epa.gov/
compliance/assistance/bystatute/cwa/index.html) shown in
Figure 19, focuses on EPA's outreach of compliance assistance
tools and materials and enforcement information supporting
the Clean Water Act It enhances the access to water-related
environmental compliance assistance, compliance monitoring,
and enforcement information by providing links to documents,
tools, information, and other related and linked Web sites for
compliance with environmental requirements to protect water
resources.
7 8
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6.2 EPA Program Office Web Pages
what are the EPA program office web pages
and what information do they contain?
The Web pages for the EPA program offices include:
~ Office of Air and Radiation (http://www.epa.gov/air)
- oversees air and radiation protection activities, including
policies and regulations-, provides tools and technical infor-
mation and covers topics such as:
- Air quality-,
- Transportation and fuels-,
- Acid rain-,
- visibility;
- Toxic air pollutants; and
- Radiation.
The Technology Transfer Network (TTN) provides users
access to air quality data.
~ Office of Water (http://www.epa.gov/OW/) - includes
publications and training and environmental topics such
as:
- Drinking water-,
a
- Industry sectors (e.g., coal mining and animal feeding
operations);
- Effluent guidelines;
- Enforcement;
- Permit program-, and
- stormwater.
Office of Prevention, Pesticides and Toxic Substances
(http://www.epa.gov/opptsmnt/) - develops national
strategy for toxic substance control, promotion of pollution
prevention, and public right-to-know of chemical risks. The
Web site provides:
Information sources;
Laws and regulations;
Right-to-know initiatives including guidance documents
and fact sheets;
Pollution Prevention Information Clearinghouse;
Pollution Prevention Resource Exchange
(http://www.p2rx.org/); and
Information on specific toxic pollutants (e.g., polychlorin-
ated biphenyls (PCBs) data (http://www.epa.gov/pcb/).
-------
~ Office of Solid Waste and Emergency Response
(http://www.epa.gov/swerrims/) - Includes informa-
tion resources and laws and regulations.
~ Office of Environmental Information
(http://www.epa.gov/oei/) - Provides environmental
information to the public and assists EPA in collecting
high-quality analysis data. This information includes
TRI program data submitted by certain manufacturing
sectors to inform EPA (and the public) of the use, release,
and transfer of certain listed chemicals
(http://www.epa.gov/tri/).
~ American Indian Environmental Office
(http://www.epa.gov/indian/) - Oversees Agency-wide
effort to strengthen public health and environmental
protection in Indian country. The site includes regulations
affecting Indian land and related publications.
~ Small Business Ombudsman (http://www.epa.gov/sbo/)
- Includes a Web site, newsletters, publications, and con-
tacts to assist small businesses in complying with
environmental regulations.
81
~ Office of Underground Storage Tanks
(http://www.epa.gov/swerust1 /cmplastc/index.htm) -
Includes links to compliance assistance tools, including
checklists for operating and maintaining underground
storage tank systems.
In addition to the specific program office Web pages, you
can search the entire EPA Web site (http://www.epa.gov/) for
information on a particular subject or sector.
How can I use the EPA program office Web
pages?
You can use the EPA program office Web pages to find infor-
mation related to the sector of interest including applicable
regulations and their requirements, compliance assistance
materials for sites, pollution prevention opportunities, common
chemical releases, and potential noncompliance areas.
The following example shows what type of information you
may find when searching the EPA Web site prior to an inspection.
-------
Example - Using the EPA Web Site to Prepare for Inspections
Prior to inspecting an automotive recycling facility you search for environmental information on the EPA Web site
(www.epa.gov). The search by keyword "automotive recycling" yields 36 documents. {Note: the number of results may
change as EPA adds or modifies resources on the Web site.) You look at the documents to see if they are relevant to your
inspection by reading the summary or checking the document for key words (e.g., use the Find function to match the par-
tial word "auto"). The following documents provide the following information to you prior to your inspection:
1. Final Rule: Handling of HFC-134a and Other Substitutes for CFC-12 - final rule establishes requirements for selling
refrigerant from motor vehicle disposal facilities;
2. Question and Answer document (memorandum) concerning the collecting, storing, transporting, and recycling of
mercury switches at automotive recycling yards:
3. EPA Sector Notebook, Profile of the Motor Vehicle Assembly Industry, (discussed in Section 2.1 of this document).
4. EPA Region 6 stormwater database - auto salvage sector;
5. Brochure on the removal of mercury switches from automobiles; and
6. Wisconsin Mercury Sourcebook - Automotive Sector.
Who should I contact about the EPA program
offices?
Each EPA program office Web page includes contacts for the
office and/or specific programs.
82
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Attachment 1. Sector-Specific Tools Summary and Corresponding
Resources Web Sites
This attachment assists inspectors and facilities in locating
compliance assistance tools for specific sectors. The table lists
the compliance assistance tools available by sector. You can
use these tools prior to inspections to identify:
~ Process descriptions, pollutant outputs, chemical releases;
~ Applicable North American Industry Classification System
(NAICS) Codes and Standard Industrial Classification (SIC)
Codes {note that the NAICS codes replaced the SIC codes);
~ Applicable regulations and statutes;
~ Compliance history;
~ Potential areas of noncompliance;
~ Pollution prevention opportunities; and
~ Tools available to the regulated community to assist them
in complying with regulations.
83
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Compliance Assistance Tools by Sector
Sector
Sector
Notebooks
(Section 1}
Compliance
Assistance
Centers
(Section 2)
National
Compliance
Assistance
Clearinghouse
(Section 3)
Audit
Protocols
(Section 4)
OECA Web
Page: Industry
and
Government
Sectors
(Section 6.1)
TRl
Guidance
Manual
(Section 6.2)
Pollution
Prevention
Resource
Exchange
(Section 6.2)
Applicability
Determination
Index (ADI)a
Aerospace
X
X
X
X
X
Agriculture
X
X
X
X
X
Automotive
X
X
X
X
X
X
Chemical (includes
Rubber and Plastics)
X
X
X
X
X
X
X
X
Construction
X
X
X
X
Dry Cleaning
X
X
X
X
X
Electronics
& Computers
X
X
X
X
X
Federal Facilities
X
X
X
X
X
Food Processing
Pending
X
X
X
X
-------
Compliance Assistance Tools by Sector (continued)
Sector
Sector
Notebooks
(Section 1)
Compliance
Assistance
Centers
(Section 2)
National
Compliance
Assistance
Clearinghouse
(Section 3)
Audit
Protocols
(Section 4)
OECA Web
Page: Industry
and
Government
Sectors
(Section 6.1)
TRI
Guidance
Manual
(Section 6.2)
Pollution
Prevention
Resource
Exchange
(Section 6.2)
Applicability
Determination
Index (ADI)°
Furniture
Manufacturing
X
X
X
X
Hazardous Waste
Management
X
X
X
X
X
Healthcare
X
X
Laboratories
X
X
Leather Tanning
& Finishing
X
X
Local Government
X
X
X
X
X
X
Lumber, Wood
Products, & Forestry
X
•
X
X
X
X
Metals
X
X
X
X
X
X
85
-------
Compliance Assistance Tools by Sector (continued)
Sector
Sector
Notebooks
(Section 1)
Compliance
Assistance
Centers
(Section 2)
National
Compliance
Assistance
Clearinghouse
(Section 3)
Audit
Protocols
(Section 4)
OECA Web
Page: Industry
and
Government
Sectors
{Section 6.1)
TRI
Guidance
Manual
(Section 6.2)
Pollution
Prevention
Resource
Exchange
(Section 6.2)
Applicability
Determination
Index (ADI)"
Minerals/Mining/
Processing
X
X
X
X
Paints & Coatings
X
X
X
X
X
Pesticides
X
X
X
X
X
X
Petroleum
X
X
X
X
X
X
X
Pharmaceuticals
X
X
X
X
X
Printing
X
X
X
X
X
X
X
Pulp & Paper
X
X
X
X
Schools
X
X
Shipbuilding
& Repair
X
X
X
X
X
-------
Compliance Assistance Tools by Sector (continued)
Sector
Sector
Notebooks
(Section 1)
Compliance
Assistance
Centers
(Section 2)
National
Compliance
Assistance
Clearinghouse
(Section 3)
Audit
Protocols
(Section 4)
OECA Web
Page: Industry
and
Government
Sectors
(Section 6.1)
TRI
Guidance
Manual
(Section 6.2)
Pollution
Prevention
Resource
Exchange
(Section 6.2)
Applicability
Determination
Index (ADI)J
Small Business
X
Stone, Clay Glass,
& Concrete
X
X
X
Textiles
X
X
X
X
X
Transportation
X
X
X
X
Utilities/Power
Generation
X
X
X
X
X
X
X
' ADI - Searchable database that provides regulatory applicability determinations for the Clean Air Act,
http://www.epa.gov/compliance/planning/data/air/adi.html.
X - Applicable to this sector.
87
-------
Resources Web Sites
EPA Sector Notebooks -
http://www.epa.gov/compliance/resources/publications/
assistance/sectors/notebooks/
EPA Compliance Assistance Centers -
http://www.assistancecenters.net
EPA National Environmental Compliance Assistance
Clearinghouse - http://www.epa.gov/clearinghouse/
EPA Audit Protocols - http://www.epa.gov/compliance/
incentives/auditing/protocol.html
EPA Compliance Incentives and Auditing -
http://www.epa.gov/compliance/incentives/index.html
EPA Office of Enforcement and Compliance Assurance
(OECA) Web Site -
http://www.epa.gov/compliance/index.html
Online Information Tracking System (OTIS) -
http://www.epa-otis.gov/otis
Inspector web Site -
http://intranetepa.gov/oeca/inspector/
~ Sector Facility Indexing Project (SFIP) -
http://www.epa.gov/sfipmtn 1
EPA Program Office Web Pages
~ Office of Air and Radiation -
http://www.epa.gov/air
- Technology Transfer Network - http://www.epa.gov/ttn/
~ Office of Water - http://www.epa.gov/0W/
~ Office of Prevention, Pesticides and Toxic Substances -
http://www.epa.gov/opptsmnt/
- Pollution Prevention Resource Exchange -
http://www.p2rx.org/
~ Office of Solid Waste and Emergency Response -
http://www.epa.gov/swerrims/
~ Office of Environmental Information -
http://www.epa.gov/oei/
- EPA Toxics Release inventory - http://www.epa.gov/tri
~ American Indian Environmental Office -
http://www.epa.gov/indian/
~ Small Business Ombudsman - http://www.epa.gov/sbo/
-------
Attachment 2. List of EPA Regional Compliance Assistance
Coordinators
Region 1
Region 4
Region 7
Region 9
Larry Wells (MC SPP)
Wes Hardegree
Neal Gilbert
Angela Baranco (MC SPE-1)
Phone: (617) 918-1876
Phone: (404) 562-9629
Phone: (913) 551-7985
Phone: (415) 947-4262
E-mail: wells.larry@epa.gov
E-mail: hardegree.wesley@epa.gov E-mail: gilbert.neal@epa.gov
E-mail: baranco.angela@epa.gov
U.S. EPA Region 1
U.S. EPA Region 4
U.S. EPA Region 7
U.S. EPA Region 9
1 Congress Street
61 Forsyth Street, SW
901 North Fifth Street
75 Hawthorne Street
Suite TIOO
Atlanta, GA 30303-8960
Kansas City KS 66101
San Francisco, CA 94105
Boston, MA 02114-2023
Region 5
Region 8
Region 10
Region 2
Eileen Deamer (MC E-13J)
Liz Rogers (MC 8ENF-PT)
Robyn Hoffman
Linda Longo
Phone: (312) 886-1728
Phone: (303) 312-6974
Phone: (206) 553-7154
Phone: (212) 637-3565
E-mail: deamer.eileen@epa.gov
E-mail: rogers.liz@epa.gov
E-mail: hoffman.robyn@epa.gov
E-mail: longo.linda@epa.gov
U.S. EPA Region 5
U.S. EPA Region 8
U.S. EPA Region 10
U.S. EPA Region 2
77 West Jackson Boulevard
999 18th Street
1200 Sixth Avenue
290 Broadway
Chicago, IL 60604-3507
Suite 300
Seattle, WA 98101
New York, NY 10007-1866
Region 6
Denver, CO 80202-2466
Region 3
Israel Anderson (MC 6EN-HS)
Betty Barnes (MC 3EC00)
Phone: (214) 665-3138
Phone: (215) 814-3447
E-mail: anderson.israel@epa.gov
E-mail: bames.betiy@epa.gov
U.S. EPA Region 6
U.S. EPA Region 3
1445 Ross Avenue
1650 Arch Street
Suite 1200
Philadelphia, PA 19103-2029
Dallas, TX 75202-2733 8 9
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