ansas Louisiana
jorna
Jexico Texas
US EPA Region 6
Compliance Assurance and Enforcement Division
2007 Annual Report
1445 Ross Ave., Suite 1200 (6EN)
Dallas, Texas 75202-2733
SB.
www.epa.gov/region6/6en
(214)665-2210
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US Environmental Protection Agency
Region 6
Compliance Assurance and Enforcement Division
1445 Ross Ave., Suite 1200
Dallas, Texas 75202-2733
Welcome to the Compliance Assurance and Enforcement Division's
(CAED) FY O7 annual report. This is the first annual report issued for
the Division under my management. As you will see documented in
this report, we had a very successful year. While this report focuses on
CAED, we could not have completed any of the work highlighted without
the support of our partners in the Office of Region Counsel's Enforcement
Group. We also could not have been successful without the involvement
and full support of staff in the Division's within the Region and our State
partners. My goals for the Division entering into FY 07, were to:
to be leaders in environmentally significant enforcement;
to be major players in the national priorities;
to improve State, Tribal and local partnerships;
to materially contribute to the success of the Region's other
Division's and Offices; and
to improve our work place and productivity by embracing our
People Plan.
I am pleased to present this report on our successes in these areas,
and credit my staff for their exemplary work. I hope to improve upon this
report for FY 08. Any ideas and suggestions that you have would be
appreciated. One area of improvement for next year will be the inclusion
of a vision and projections for FY 09.
Sincerely yours,
John Blevins
Director
Compliance Assurance and
Enforcement Division
Page 3
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Enforcement Strategy
1. Be Results Driven (Start with the end in mind)
i Significant injunctive relief
i Significant reduction in pollutants
i Meaningful message
2. Cover National Priorities
3. Cover Regional Priorities
4. Respond to Citizen's Complaints
5. Help the States
6. Find sector/facilities in non-compliance (aggressive screening)
7. Make sure Consent Decrees and Orders are being complied
with certify compliance/re-inspect if necessary.
Page 4
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Mission/Visions/Values 2
Introduction 3
Enforcement Strategy. 4
Table of Contents 5
Priorities, Measures and Results 7
300 Day Plan 7
Key Management Measures 8
Organizational Assessment:
Summary of Big 12 9
RCRA Commitments 10
Water Commitments 11
Air Commitments 12
Associate Director's Office
Commitments 13
Sample Monthly Charts 14
FY07 National Priorities 15
Regional Priorities 17
Judicial Conclusions 18
Highlights 19
FY07 Accomplishments 19
Initiatives 20
Numbers at a Glance 21
Management Systems 25
-------
Inspections 26
New Equipment 27
Referrals/Judicial Conclusions 28
Voluntary Audit Disclosures 29
Big Case Summaries 30
Supplemental Environmental
Projects 31
Tips and Complaints 32
Cease and Desist 33
Partnerships 34
Collaboration of Local Partners
and businesses 34
Pollution Prevention 35
Environmental Management
Systems 36
Performance Track 37
National Environmental
Policy Act 38
Federal/State Relations 39
Tribal 40
Tribal Capacity Building 41
-------
Priorities, Measures and Results
Regional Administrator's 300-Day Plan - 2007
6EN Activities
(Timeframe: March 1 - December 31, 2007)
Category
Make Compliance Our
Enforcement Objective
%'
Cir
<*
Promote Innovative
Approaches to
Environmental Problem-
solving
Assist Recovery Efforts in
Louisiana
Develop Collaborative
Networks
Oil and gas initiative
Assist Recovery Efforts in
Louisiana
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Commitment
Conduct 10 inspections and take 5 CAA Actions at
facilities in or affecting non-attainment areas
Jointly conduct 25 CAFO inspections in TX, NM
and OK
Take actions at 15 CAFO facilities in priority
watersheds
Complete development of the homebuilders storm
water compliance assistance pilot by September
2007
Issue 3 CAA 114 letters on NSR compliance
Focus 50% of NPDES enforcement actions to
support national priorities
Conduct 6 RCRA inspections in non-attainment
areas
Conduct 2 MS4 Audits trainings for phase 2 cities
in TX and NM
Refer 15 civil Judicial actions to DOJ
Issue 300 enforcement actions
Conduct 10 RCRA corrective action inspections
Enroll 7 new members to Performance Track
Increase the use of infrared camera and
phosphorus monitor as compliance tools
Partner with LDEQ to investigate 7 refineries to
support Refinery Initiative
Assist TX with risk-based investigations and
expedited enforcement actions to improve air
quality in major metropolitan areas; and NM in
increasing gas plan compliance
Provide compliance assistance at 15 oil and gas
facilities focusing on unaccounted emission
sources
Meet quarterly with LDEQ to review asbestos
demolition activity
Status
15 insp.
5 enf.
29
16
Complete
1
51%
6
2
18
474
12
7
22
7
On Target
27
On Target
Page 7
Green: Already Met or Exceeded Target
Light Blue: On Target to Meet
Yellow: Issues Could Impede Completion
Red: Will Not Meet Target
-------
Kev Manaaement Measures
o
TO
-------
Organizational Assessment
Summary on Big 12
1
2
3
4
5
6
OECA Top Tier Measures
% Compliance assistance recipients with improved EMP
Number of Civil Referrals to DOJ
Number of large concluded cases with more than 1 M Ibs. Pollution
reduced, $5M injunctive relief or $1 M penalty
Dollars invested in environmental performance or improved EMP as
a result of concluded enforcement
Pounds of pollution reduced by audit agreement or concluded
enforcement
Volume of contaminated media addressed
Status
100%
29 Total
22 Regulatory, 7 Superfund
18 Total
15 Regulatory
3 Superfund
$237.8 million
101 million Ibs
530K cubic yards
7
8
9
10
11
12
Big 12 Measures OECA Top Tier (see above) Plus :
# Entities Reached through Compliance Assistance
# Resolved Self-Disclosures
# Inspection/evaluations & investigations
% Facilities inspected (Fed and State)
SNC Status
# Civil Judicial and Administrative Conclusions
Status
9,391
55
1386 (as of 8/26/07)
See below
See below
669
% Facilities Inspected (State and EPA combined)
State
AR
LA
NM
OK
TX
CAA
Majors
100%
46%
43%
80%
59%
SM80s
96%
71%
71%
95%
40%
RCRA
TSDs
100%
97%
92%
100%
85%
LQGs
21%
10%
19%
37%
9%
CWA
Majors
96%
96%
21%
87%
21%
Page 9
SNC/HPV Status
State
AR
LA
NM
OK
TX
CAA
1%
3%
9%
15%
44%
RCRA
8%
0
3%
0
1 .7%
CWA
19%
21%
0
20%
19%
-------
RCRA
FY07 - RCRA Commitments Summary
Description
ACS COMMITMENTS
RCRA01 : # of federal TSDFs to be inspected during the year.
RCRA02: # of federal LQGs to be inspected during the year.
PBS-MNP04: Number of investigations in the non-phosphoric acid
mineral processing sector.
PBS-FA01: RCRA Closure and Post Closure - Number of Preliminary
Financial Assessments for Closure and Post-Closure Financial
Responsibility Requirements.
PBS-FA02: RCRA Closure and Post Closure - Number of
Owners/Operators in Complinace or on the path to compliance for
closure or post-closure financial responsibility requirements.
PBS-FA03: RCRA Corrective Action - Number of preliminary financial
assessments for corrective action financial assurance requirements.
PBS-FA04: RCRA Corrective Action - Number of owners/operators in
compliance or on the path to compliance for corrective action
financial assurance requirements.
FEDFAC04: # federal inspections to be conducted at federal RCRA
treatment, storage or disposal facilities.
Oct
2006
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
Nov
2006
0
0
0
0
0
1
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
Dec Jan
2006 2007
1 0
1 0
1 2
4 4
4 4
4 2
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 11
0 11
0 0
0 0
0 0
0 0
0 0
0 0
0 1
Feb
2007
2
2
2
4
4
1
1
1
0
9
9
0
5
5
0
0
0
0
0
0
0
0
0
1
Mar
2007
2
2
1
4
4
5
0
0
1
4
4
0
5
5
0
0
0
0
0
0
0
0
0
0
Apr
2007
2
2
1
0
0
3
0
0
0
4
4
0
10
10
0
0
0
0
3
3
0
0
0
0
May
2007
1
1
1
4
4
8
0
0
0
5
5
0
10
10
0
0
0
0
3
3
0
0
0
1
Jun
2007
2
2
2
4
4
2
0
0
0
5
5
0
0
0
0
0
0
0
3
3
0
0
0
2
Jul
2007
0
0
0
4
4
2
0
0
0
5
5
0
0
0
0
0
0
0
0
0
0
0
0
0
Aug
2007
0
0
1
2
2
3
0
0
0
5
5
193
0
0
78
0
0
15
0
0
12
0
0
0
Sep Total!
2007 FY07I
% of YTD
Completed
0 10 Total Projected
0 10 YTD Projected
0 11 YTD Completed
0 30 Total Projected
0 30 YTD Projected
0 31 YTD Completed
0 1 Total Projected
0 1 YTD Projected
0 1 YTD Completed
5 42 Total Projected
5 42 YTD Projected
0 193 YTD Completed
0 30 Total Projected
0 30 YTD Projected
0 80 YTD Completed
0 11 Total Projected
0 11 YTD Projected
0 15 YTD Completed
0 9 Total Projected
0 9 YTD Projected
0 12 YTD Completed
0 0 Total Projected
0 0 YTD Projected
0 5 YTD Completed
110.00%
103.33%
100.00%
459.52%
266.67%
136.36%
133.33%
% ofEOY
Completed
110.00%
103.33%
100.00%
459.52%
266.67%
136.36%
133.33%
SHELL COMMITMENTS
RCRA Hazardous Waste Inspections
RCRAAdminisrative Compliance Orders
RCRAAdminisrative Penalty Orders
RCRA Final Administrative Penalty Orders
RCRA Civil Judicial Referrals
RCRA Civil Judicial Case Conclusions
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
4
3
0
0
0
1
1
2
1
1
1
0
0
0
0
0
0
4 4
4 4
8 5
0 0
0 0
0 0
0 0
0 0
0 0
1 1
1 1
0 2
1 0
1 0
0 0
0 0
0 0
1 0
4
4
7
0
0
0
1
1
0
1
1
0
0
0
0
0
0
0
5
5
12
0
0
0
1
1
0
1
1
0
3
3
0
0
0
0
20
20
7
0
0
0
0
0
0
1
1
1
0
0
0
0
0
1
5
5
10
0
0
2
1
1
1
1
1
0
0
0
0
0
0
0
5
5
9
1
1
0
1
1
1
1
1
2
2
2
1
0
0
0
20
20
9
1
1
0
0
0
0
1
1
0
1
1
1
0
0
0
4
4
4
1
1
0
0
0
0
1
1
1
0
0
4
0
0
0
0 75 Total Projected
0 75 YTD Projected
3 78 YTD Completed
1 4 Total Projected
1 4 YTD Projected
0 2 YTD Completed
1 6 Total Projected
1 6 YTD Projected
0 4 YTD Completed
0 10 Total Projected
0 10 YTD Projected
0 7 YTD Completed
0 7 Total Projected
0 7 YTD Projected
0 6 YTD Completed
0 0 Total Projected
0 0 YTD Projected
0 2 YTD Completed
104.00%
50.00%
66.67%
70.00%
85.71%
104.00%
50.00%
66.67%
70.00%
85.71%
Page 10
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Water
2007 CWA & SDWA Commitments Summary
Description
CWA01 : Number of federal inspections at NPDES major
CWA03: Number of federal oversight inspections to be c
(CAFO OSIs from Jerry)
CWA05: No. federal inspections of POTWs w/approved
pretreatment program in approved & un-approve
PBS-CAFO02: Number of CAFO federal inspections
PBS-CAFO04: Number of joint EPA/state CAFO inspect!
PBS-CAFO05: Number of workshops, training sessions,
presentations given for AFO/CAFO operators, s
providers, andAo organizations.
PBS-SSO05: Number of medium systems (including sate
be addressed
PBS-STW01: Number of federal 2007 storrnwaterconstr
inspections.
PBS-STW02: Number of federal stormwater non-constru
industry inspections.
PBS-STW04: Number of MS4 Phase 1 audits.
PBS-TB05: Compliance assistance to 100% of tribal pub
systems.
PBS-TB06: Number of tribal public water system SNC ex
returned to compliance in FY07.
PBS-TB07: Number of nitrates and microbial violations a
in FY07.
SDWA01 : Number of surveys to be conducted where the
has direct implementation authority.
SDWA02: Public Water Systems listed on a 'Fixed Base
SNC/Exceptions list will be addressed or resolvec
or tribe with primacy, or by EPA.
SHELL PROJECTIONS
UIC Inspections. Shi
inspections.
CWA NPDES Administrative Compliance Orders.
CWA NPDES Administrative Penalty Orders
CWA NPDES Administrative Penalty Order Conclusions
CWANPDES Civil Judicial Referrals
CWANPDES Civil Judicial Conclusions
SDWA PWS Administrative Orders
SDWA PWS Administrative Penalty Orders
SDWA-PWS Administrative Penalty Order Conclusions
SDWAUIC Administrative Orders
SDWAUIC Administrative Penalty Orders
SDWA UIC Administrative Penalty Order Conclusions.
NPDES Inspections -Minors.
NPDES Inspections- Majors.
Pretreatment Inspections- IU.
Pretreatment Inspections - POTW.
SDWAUIC Civil Judicial Referrals
SDWAUIC Civil Judicial Conclusions
# CWA Cease and Desist Orders Issued
# SDWA Cease and Desist Orders Issued
Oct
2006
0
0
n
0
0
n
0
0
0
0
0
0
0
0
0
0
0
n
0
0
n
14
14
14
0
0
0
0
0
0
0
0
0
0
0
n
0
0
3
0
0
0
5
5
77
20
20
58
0
0
1
0
0
1
0
1
0
0
n
0
0
n
0
0
1
0
0
0
0
0
0
0
0
3
0
0
n
0
0
n
14
14
14
0
0
0
0
0
0
0
0
n
0
0
n
0
0
n
N/A
N/A
N/A
N/A
Nov
2006
0
0
n
6
6
7
0
0
0
5
5
7
0
0
0
0
0
n
0
0
n
0
0
1
1
1
0
0
0
0
0
0
0
0
n
0
0
93
0
0
7
5
5
91
20
20
3R
4
4
5
4
4
3
0
3
0
0
n
0
0
n
0
0
n
0
0
0
0
0
0
0
0
5
0
0
1
0
0
n
7
7
12
6
6
7
1
1
1
0
0
n
0
0
n
0
0
n
N/A
N/A
N/A
N/A
Dec
2006
1
1
1
3
3
5
0
0
0
8
8
6
0
0
0
0
0
n
0
0
n
0
0
0
0
0
0
0
0
0
0
0
0
0
n
0
0
n
0
0
0
5
5
18
20
20
98
4
4
5
3
3
3
3
6
0
0
n
0
0
n
2
2
7
0
0
0
0
0
0
2
0
0
0
0
n
0
0
n
a
9
13
4
4
6
0
0
0
0
0
n
0
0
n
0
0
n
N/A
N/A
N/A
N/A
Jan
2007
10
10
in
1
1
4
0
0
1
3
3
1
0
0
0
0
0
1
0
0
n
5
5
3
3
3
1
1
0
0
0
0
0
0
n
2
2
1
0
0
0
10
10
45
15
15
69
4
4
1
5
5
4
3
3
0
0
n
0
0
n
2
2
n
0
0
0
0
0
0
2
2
3
0
0
n
0
0
n
3
3
10
11
11
14
0
0
0
0
0
1
0
0
n
0
0
n
N/A
N/A
N/A
N/A
Feb
2007
3
3
7
4
4
5
1
1
1
7
7
10
0
0
0
0
0
n
0
0
n
1
1
2
2
1
0
0
0
0
0
0
0
0
n
0
0
n
0
0
0
30
30
3fi
20
20
57
10
10
8
5
5
2
3
2
0
0
n
0
0
n
2
2
n
0
0
0
0
0
0
2
2
4
0
0
n
0
0
n
10
10
16
8
8
8
0
0
0
1
1
1
0
0
n
1
1
1
N/A
N/A
N/A
N/A
Mar
2007
8
8
n
6
6
n
2
2
0
2
2
7
0
0
0
0
0
n
0
0
n
5
5
n
2
2
0
0
0
1
0
0
0
0
0
n
4
4
1
0
0
0
40
40
33
40
40
48
15
15
24
5
5
6
3
2
1
1
n
0
0
n
3
3
15
0
0
0
0
0
0
2
2
4
0
0
n
0
0
n
2
2
8
0
0
0
1
1
0
2
2
n
0
0
n
0
0
n
N/A
N/A
N/A
N/A
Apr
2007
8
8
fi
4
4
7
3
3
1
0
0
6
0
0
0
0
0
n
0
0
n
1
1
7
2
2
3
0
0
0
0
0
0
0
0
n
0
0
n
0
0
0
40
40
40
60
60
46
18
18
14
5
5
1
2
1
1
0
0
0
0
2
2
6
1
1
0
0
0
0
2
2
1
0
0
0
0
0
0
10
10
6
6
12
0
0
0
1
1
1
0
0
0
0
0
0
N/A
N/A
N/A
N/A
May
2007
5
5
5
5
5
11
2
2
1
0
0
6
2
2
1
0
0
0
0
0
0
5
5
0
2
2
0
0
0
0
0
0
0
1
1
0
2
2
1
1
1
0
35
35
35
60
60
46
15
15
15
5
5
11
8
1
1
0
0
0
0
2
2
0
0
0
0
1
1
0
2
2
0
0
0
0
0
0
0
10
10
5
5
16
0
0
0
2
2
1
0
0
1
0
0
0
N/A
N/A
N/A
N/A
Jun
2007
4
4
4
1
1
3
0
0
1
0
0
0
2
2
1
0
0
0
0
0
0
7
7
0
1
1
3
1
1
1
0
0
0
0
0
0
0
0
0
0
0
0
40
40
95
50
50
99
15
15
11
5
5
2
1
1
1
1
1
1
2
2
7
0
0
3
0
0
2
2
2
3
0
0
0
0
0
0
8
8
5
5
8
0
0
0
0
0
1
0
0
0
0
0
0
N/A
N/A
N/A
N/A
Jul
2007
4
4
4
3
3
9
0
0
2
0
0
0
0
0
2
0
0
0
0
0
0
7
7
1
1
0
0
0
0
0
0
0
0
0
0
2
2
0
1
1
0
30
30
91
60
60
63
15
15
20
4
4
5
1
1
1
0
0
0
2
2
0
0
0
0
0
0
0
2
2
1
1
1
0
0
0
1
7
7
5
5
6
0
0
0
0
0
0
0
0
0
0
0
N/A
N/A
N/A
N/A
Aug
2007
4
4
11
3
3
9
2
2
3
0
0
0
1
1
1
1
1
0
1
1
0
0
0
1
1
3
0
0
1
0
0
0
0
0
0
0
0
0
0
1
30
30
35
55
55
49
15
15
30
6
6
0
2
2
17
0
0
0
0
0
0
2
2
11
0
0
0
1
1
0
4
4
0
0
17
1
1
1
2
2
0
0
0
0
0
0
N/A
N/A
N/A
N/A
Sep
2007
3
3
7
0
0
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19
0
0
3
0
0
0
76
76
76
0
0
1
2
2
1
1
1
30
30
9
60
60
43
5
5
13
3
3
3
5
1
1
1
0
0
0
1
1
0
1
1
0
1
1
0
2
2
0
0
0
0
0
0
0
16
16
16
0
0
a
0
0
12
2
2
1
1
0
0
0
0
N/A
N/A
N/A
N/A
Total
FY07
50 Total Projected
50 YTD Projected
50 YTD Cnmnlptpri
36 Total Projected
36 YTD Projected
46 YTD Cnmnlptpri
1 0 Total Projected
10 YTD Projected
13 YTDComoleted
25 Total Projected
25 YTD Projected
43 YTD Comoleted
5 Total Projected
5 YTD Projected
YTD Comoleted
Total Projected
YTD Projected
YTD Cnmnletpri
Total Projected
YTD Projected
0 YTD Cnmnlptpri
45 Total Projected
45 YTD Projected
56 YTD Cnmnlptpri
1 5 Total Projected
15 YTD Projected
17 YTDComoleted
2 Total Projected
2 YTD Projected
3 YTD Comoleted
76 Total Projected
76 YTD Projected
76 YTD Comoleted
1 Total Projected
1 YTD Projected
1 YTD Cnmnlptpri
1 2 Total Projected
12 YTD Projected
3 Total Projected
3 YTD Projected
9 YTD Comoleted
300 Total Projected
300 YTD Projected
340 YTD Comrjleted
480 Total Projected
480 YTD Projected
567 YTD Cnmnlptpri
120 Total Projected
120 YTD Projected
147 YTD Comoleted
50 Total Projected
50 YTD Projected
51 YTD Comoleted
35 Total Projected
44 YTD Comoleted
7 Total Projected
7 YTD Projected
4 YTD Cnmnlptpri
2 Total Projected
2 YTD Projected
1 YTD Cnmnlptpri
20 Total Projected
20 YTD Projected
48 YTD Cnmnlptpri
2 Total Projected
2 YTD Projected
3 YTD Comoleted
2 Total Projected
2 YTD Projected
2 YTD Comoleted
20 Total Projected
18 YTD Projected
35 YTD Comoleted
1 Total Projected
1 YTD Projected
1 YTD Cnmnlptpri
1 Total Projected
1 YTD Projected
1 YTD Cnmnlptpri
100 Total Projected
100 YTD Projected
128 YTD Comoleted
50 Total Projected
50 YTD Projected
103 YTD Comoleted
3 Total Projected
3 YTD Projected
14 YTD Comoleted
1 0 Total Projected
10 YTD Projected
Total Projected
YTD Projected
YTD Cnmnlptpri
Total Projected
YTD Projected
YTD Cnmnlptpri
0 Total Projected
0 YTD Projected
46 YTD Cnmnlptpri
0 Total Projected
0 YTD Projected
17 YTD Comoleted
% of YTD
Comoletec
100.00%
127.78%
130.00%
172.00%
100.00%
100.00%
0.00%
12444%
113.33%
150.00%
100.00%
100.00%
308 33%
300.00%
113.33%
118.13%
12250%
102.00%
125.71%
57.14%
50.00%
240.00%
150.00%
100.00%
194.44%
100.00%
100.00%
128.00%
206.00%
466.67%
130.00%
100.00%
100.00%
% ofEOY
Comolete
100.00'
127.78'
130.00'
172.00'
100.00'
100.00'
0.001
1 24 44":
113.331
150.00'
100.00'
100.00'
308 331
300.00'
113.331
118.131
12250'
102.00'
125.71'
57.141
50.001
240.00'
150.00'
100.00'
175.00'
100.00'
100.00'
128.00'
206.00'
466.67'
130.001
100.00'
100.00'
Page 11
-------
FY07 CAA and TSCA Commitments Summary
Description
Oct
2006
Nov
2006
Dec
2006
Jan
2007
Feb
2007
Mar
2007
Apr
2007
May
2007
Jun
2007
Jul
2007
Aug
2007
Sep
2007
ACS COMMITMENTS
CAA 01: # of federal FCEs to be conducted at Title V majors
CAA 02: # federal FCEs at "80% synthetic minors" and other sources
CAA 03: # PCEs to be conducted by the regions (to Include ULSD &
Off Road Eng)
CAA 05: # of investigations to be initiated in FY 2007. (Anchor Glass -
Dec, Buzzi- Jan, Lyndell-Citgo - Feb. )
CAA 16: Ensure delegated agencies have written agreements to
provide complete, accurate, and timely data and provide copies
CAA17: Enter all MDRs in AFS. If a delegated agency does not
agree to enter the MDRs, the region is responsible for ensuring that
the data is entered
CAA 19: Conduct at least one in-depth evaluation of a delegated
program per year and provide the written results to HQ
PBS-ATX03: Number of MACT investigative activities
(Applicable/Non-Applicable National Priority MACTs only)
PBS-TB03: By September 30, 2007, Regions will provide compliance
assistance to Bureau of Indian Affairs (Bl A) and non-BIA schools.
TSC 03: Inspect 33% of the PCB commercial storage and disposal
facility universe
TSCA 05: Report the number of federal TSCA asbestos inspections
TSC 10: Number of 1018/402/406 federal inspections.
1
1
0
0
0
0
2
2
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
4
4
2
2
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
4
0
0
0
0
0
1
0
0
0
0
0
0
1
1
1
0
0
0
2
2
7
0
0
1
0
0
0
2
2
0
0
0
0
0
0
0
0
0
0
0
0
0
1
1
2
0
0
0
6
6
11
1
1
1
0
0
0
2
2
4
0
0
0
0
0
1
0
0
0
6
6
0
1
1
2
0
0
1
5
5
5
0
0
1
0
0
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
4
1
1
2
0
0
0
0
0
1
1
1
0
0
0
0
2
2
1
0
0
0
0
0
1
0
0
0
5
5
2
1
1
1
0
0
0
5
5
3
0
0
0
1
1
1
2
2
2
0
0
0
1
1
0
4
4
7
5
5
5
1
1
0
0
0
0
5
5
7
0
0
0
0
0
0
4
4
3
0
0
0
0
0
0
4
4
5
5
5
0
1
1
1
0
0
0
10
10
8
1
1
0
0
0
0
0
0
4
0
0
26
1
1
3
0
0
0
0
0
0
1
1
0
0
0
0
5
5
5
0
0
0
0
0
0
4
4
1
0
0
0
2
2
0
0
0
0
0
0
5
2
2
4
0
0
0
5
5
18
0
0
0
0
0
0
0
0
3
0
0
0
0
0
0
2
2
0
0
0
5
2
2
3
0
0
0
0
0
7
0
0
0
0
0
0
4
4
3
26
26
0
0
0
1
0
0
0
0
0
0
Total
2007
15
15
16
0
0
1
45
45
78
3
3
3
100%
100%
100%
0%
0%
0%
1
1
1
20
20
28
26
26
26
4
4
7
10
10
12
25
25
25
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
SHELL COMMITMENTS
CAA Stationary Inspections (FCE's & PCE's) Line total from
Lines 7,13,19
CAACFC Inspections
TSCA Inspections (Cumulative of All TSCA Actions)
I nspections / PCB count (Lines 58 , 61 ,64 total )
CAA Administrative Compliance Orders
CAA Administrative Penalty Orders
rii Final AHmimctratiuo Ronaltw nrrlart,
CAA Civil Judicial Referrals
CAA Civil Judicial Conclusions
TSCA Administrative Penalty Orders
TSCA Final Administrative Penalty Orders
# CAA Cease and Desist Orders Issued
3
3
1
0
0
18
4
4
4
0
0
0
0
0
0
n
0
0
0
0
0
0
0
0
0
0
0
0
0
1
N/A
N/A
0
2
2
5
0
0
1
0
0
1
0
0
0
0
0
0
n
0
0
0
0
0
0
0
0
0
0
0
0
0
0
N/A
N/A
0
3
3
8
2
2
0
0
0
0
0
0
0
0
0
0
-I
1
0
2
2
4
0
0
0
0
0
2
0
0
2
N/A
N/A
0
7
7
13
0
0
0
6
6
1
0
0
0
0
0
0
n
0
0
0
0
0
1
1
1
1
1
13
1
1
2
N/A
N/A
0
6
6
7
0
0
0
0
0
4
0
0
0
1
1
0
n
0
0
0
0
0
0
0
1
0
0
1
0
0
2
N/A
N/A
0
1
1
3
2
2
4
5
5
3
0
0
1
2
2
2
9
2
2
2
2
1
1
1
1
1
1
0
1
1
2
N/A
N/A
0
6
6
4
0
0
4
10
10
12
1
1
0
0
0
0
n
0
1
0
0
1
0
0
0
1
1
0
1
1
0
N/A
N/A
0
6
6
7
0
0
0
9
9
5
0
0
0
0
0
1
n
0
1
0
0
0
0
0
0
1
1
0
1
1
2
N/A
N/A
0
11
11
9
3
3
0
1
1
3
0
0
0
3
3
0
9
2
0
2
2
1
2
2
0
1
1
0
1
1
2
N/A
N/A
0
6
6
5
0
0
2
2
2
5
0
0
2
2
2
0
1
1
0
2
2
0
0
0
3
1
1
0
1
1
2
N/A
N/A
2
7
7
22
0
0
0
2
2
5
0
0
0
1
1
0
1
1
0
1
1
2
0
0
0
2
2
0
2
2
1
N/A
N/A
0
2
2
10
3
3
0
0
0
1
1
1
0
0
0
3
o
0
2
0
0
0
2
2
0
2
2
0
2
2
1
N/A
N/A
0
60
60
94
10
10
29
39
39
44
2
2
3
9
9
6
7
6
9
9
9
6
6
6
10
10
16
10
10
17
N/A
N/A
2
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Total Projected
YTD Projected
YTD Completed
Percent
YTD
106.67%
% ofEOY
Comoleted
106.67%
zero commitment
173.33%
100.00%
Not agreed
100.00%
140.00%
100.00%
175.00%
120.00%
100.00%
156.67%
290.00%
112.82%
150.00%
66.67%
85.71%
100.00%
100.00%
160.00%
170.00%
173.33%
100.00%
100.00%
140.00%
100.00%
175.00%
120.00%
100.00%
156.67%
290.00%
112.82%
150.00%
66.67%
85.71%
100.00%
100.00%
160.00%
170.00%
No projections, report on
Page 12
-------
Associate Director's Office
Associate Director's Office 6EN-X(P)
I Description
ACS COMMITMENTS
1 - Number of PT Applications received
2 - Number of States, tribes, or territories in which PT incentives have
been adopted and made available to PT members.
3 - Number of State environmental performance agreements that
incorporate PT (attempted)
ASST01 - Outcome measurement for 100% of all compliance
assistance workshops, training, onsite visits and revisits supporting
National Priorities
FEDFAC01 - Number of Compliance Assistance activities for
Federal Facilities to support the integrated strategy areas.
FEDFAC03 - Number multi-media inspections to support the
Integrated Strategy areas.
FEDFAC05- Number of single media inspections to be conducted by
EPA to upport Integrated Strategy areas
PBS-TB02 - Number of EPA-authorized tribal inspectors
PBS-TB03 - Number of compliance assistance activities at BIA and
non-BIA schools
PBS-TB08 - Number of waste management compliance and
technical assistance to tribes
PBS-TB09 - Number of open dumps on tribal lands assessed and
closed or brought into compliance
PBS-TB10 - Identify off-reservation regulated facilities that present the
top compliance priorities inside Indian country.
SRF-01 - Number of State Review Framework Reviews to be
Completed
(P2) 234A- Pounds of hazardous materials reduced/avoided through
pollution preventions efforts
(P2) 235 - Dollars saved through pollution prevention efforts
(P2) 239 - Gallons of water reduced or conserved through pollution
prevention efforts
(P2) 243 - Billions of BTUs of energy conserved
Oct
2006
0
b
b
0
0
0
0
b
b
1
i
i
0
b
b
0
b
0
0
0
0
0
0
0
0
0
0
0
b
b
0
0
0
0
0
0
0
0
0
0
0
0
0
b
b
Nov
2006
5
5
9
0
0
0
0
b
b
oioio
oioio
0
b
0
0
0
b
0
0
o
1
2
oioio
0
0
0
0
0
0
0
0
0
0
0
0
loioio
Dec Jan
2006 200
Oi
b]
b'i
Oi
Oi
Oj
Oi
b]
b'i
1
Oi
b'i
b'i
ii
it
ii
Oi
bi
Oi
Oi
Oi
bi
Oi
Oi
Oi
2i
21
ii
Oi
b]
2"i
I
Oi
Oi
Oi
Oi
Oi
0;
Oi
Oi
Oi
Oi
Oi
Oi
Oi
b]
b'i
r
0
b
b
0
0
0
OIOIO
0
b
i
1
i'
i
3
3
7
0
0
0
0
0
0
0
0
0
OIOIO
0
0
0
0
0
0
0
0
0
0
0
0
0
b
b
Feb Mar
2007 2007
Oi 0
bi b'
b'i b'
Oi 0
Oi 0
Oj 0
Oi 0.
Oi 0
bi 3"
i
1i 0
ii b
i'i b'
Oi 0
b! b'
b'i b"
Oi 0
b'i b'
Oi 2
Oi 0
Oi 0
b; b
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0,
b! b
Oi 0
bi b
b'i b'
I
Oi 1
Oi 1
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
bi b
b'i b'
Apr
2007
0
6"
6"
0
0
0
oioio
ololo
oioio
0
6"
0
0
0
b
0
0
0
0
0
0
ololo
0
0
0
0
0
0
0
0
0
0
0
0
lololo
May
2007
0
b
6
0
0
0
oioio
oioio
oioio
1
'i'
0
0
0
0
0
0
o
0
0
1
oioio
0
0
0
0
0
0
0
0
0
0
0
0
loioio
Jun Jul
2007 2007
5i 0
5 1 b
bi b
Oi 0
Oi 0
Oj 0
Oi 0
bi b
bi b
Oi 0
bi b
bi b
Oi 0
b! b
bi b
i'i b
Oi 0
Oi 0
Oi 0
bi b
Oi 0
Oi 0
26i 0
Oi 0
Oi 0
5l 2"
Oi 0
bi b
bi b
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
Oi 0
bi b
bi b
Aug
2007
1
0
0
1
i
b
0
b
b
0
b
0
0
0
0
26
76
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
Sep
2007
i 0
i b
i b
i 0
i 0
i ฐ
i 0
i b
i b
i 0
! b
i b
i 0
i b
i b
i 0
} b
i 0
i 1
i 1
i i
i 0
i 0
i 0
i 0
: 0
i b
i 1
1 1
i b
i 1
i 1
i 2
i 5000000
i 5000000
i 11113625
i 5000000
i 5000000
i 9692580
i 1000000
i 1000000
i 11500007221
i 25
! 25
i 106
Total 1
FY07 1
i 10iTotal Projected
i ibiYTD Projected'
i i'siYTDCbrnpie'te'd""
i i -ed
i ::i :: : : r-d
i i 9d
i 1 iTotal Projected
i i'lYTD' Projected'
i SiYTDCompie'te'd""
i 100%iTotal Projected
i ibb%'JYTD Projected
i 'ibb'%"iYTD"c'b'mp"l'e't'e'd""
i 2 iTotal Projected
! 2'iYTD Projected'
i 3"iYTDC'bmpie'te'd""
i 2 1 Total Projected
i 2'';YTD Projected'
i 2 iYTD Completed
i 6 iTotal Projected
} 5iYTD Projected'
i 9iYTD Completed
i 1 iTotal Projected
i 1 iYTD Projected
i 1 ;YTD Completed
i 26 iTotal Projected
i 26iYTD Projected
i 26iYTD Completed
i 3 iTotal Projected
i 3IYTD Projected
i 14iYTD Completed
i 1 iTotal Projected
I i iYTD Projected
i 2 iYTD Completed
i YesiTotal Projected
i Ye'siYTD Projected'
i Ye'sJYTDC'bmpie'te'd""
i 2 iTotal Projected
i 2iYTD Projected
i 2iYTD Completed
i 5000000 1 Total Projected
i SOOOOOOiYTD Projected
i 11113625iYTD Completed
i 5000000 iTotal Projected
i SOOOOOOiYTD Projected
i 9692580iYTD Completed
i 1000000 iTotal Projected
i 1000000iYTD Projected
i 11500007221 iYTD Completed
i 25 iTotal Projected
! 25'JYTD Projected'
i ibe'iYTDCbrnpie'te'd""
Percent YTD
Completed
150.00%
0.00%
300.00%
100.00%
150.00%
100.00%
180.00%
100.00%
100.00%
466.67%
200.00%
100.00%
222.27%
193.85%
1150000.72%
424.00%
% ofEOY
Completed
150.00%
0.00%
300.00%
100.00%
150.00%
100.00%
150.00%
100.00%
100.00%
466.67%
200.00%
100.00%
222.27%
193.85%
1150000.72%
424.00%
Page 13
-------
Sample Monthly Trackina Charts
CAA EPA INSPECTIONS OF TITLE V MAJORS
Oct-06 Nov-06 Dec-06 Jan-07 Feb-07 Mar-07 Apr-07 May-07 Jun-07 Jul-07 Aug-07 Sep-07 Total
NUMBEROF STORM WATER CONSTRUCTION INSPECTIONS
(ACS Performance Measure)
Oct-06 Nov06 Dec-06 Jan-07 Feb-07 Mar-07
May-07 Jun-07 Jul-07 Ajg-07 Sep-07 Total
RCRA REGIONS INSPECTIONS OF OPERATING TREATMENT, STORAGE
AND DISPOSAL FACILIITES
Dec-06 Jan-07 Fel>07 Mar-07 Apr-07 May-07 Jun-07 Jul-07 Aug-07 Sep-07 Total
FY2007 - Value of Injunctive Relief -Cummulative Totals
$237,722
$219,080 $220,742
$138,044 $139,880 $140,196 ^0,706 $141|308
OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEPT
Page 14
-------
FY07 National Priorities
Percentage of Enforcement Actions
Addressing National Priorities
Administrative Orders
APO Complaints
Core
391
96%
The large number of
APOs issued under
OPAandCAA112r
programs (274),
greatly affect this
Nat'I Priority ratio
Referrals
Nat'I
Priority
7
32%
Judicial Conclusions
Nat'l
Priority
7
64%
Page 15
-------
FY07 National Priorities
Percentage of Penalties and Injunctive Relief
Resulting from National Priority Cases
$ Value Administrative Penalties
Core
$1,812,49(
92%
Nat'l Priority
$150,036
8%
$ Value Judicial Penalties
Core
$434,333
10%
Nat'l Priority
$3,911,613
90%
$ Value Admin. Injunctive Relief
Core
$4,610,85
46%
Nat'l Priority
$5,456,300
54%
$ Value Judicial Injunctive Relief
Core
$184,394,OOC
81%
Nat'l Priority
$43,669,040
19%
Page 16
-------
Regional Priorities
CAED has exceeded its FY 2007 targets.
Measures
Water Quality - Mississippi River Basin
NPDES inspections - CAFOs, major municipals, major
industrials discharging into Miss. River
Number of compliance assistance - CAFOs, municipals,
States, Tribes regarding nutrient management in Miss. River
basin
Air Quality - DFW and Houston SIP
Partner with TCEQ - TAGA monitoring in Houston
Air inspections in Houston 2006 - 2007
Air inspections in DFW area 2006-2007
Energy - Oil and Gas Compliance
HH, HHH (O&G MACT) - site visits with on-site
compliance assistance
Target
12
report
only
12/31/06
10
4
15
Status
27
1
done
12
8
16
Page 17
-------
Judicial Conclusions
D # Conclusions - Official Count
# Conclusions - w/National non-Lead Cases
FY05
FY06
Examples of Results:
Total Petroleum
$2.9M Penalty
$89K SEP (Comparative Monitoring
using Infrared Camera)
$37M Injunctive Relief
1.6M Ibs Sulfur Dioxide
240K Ibs Carbon Monoxide
360K Ibs Nitrogen Oxides
E.I. Du Pont (Nat'l case)
Region 6 portion of settlement:
$618,750 Penalty
$66M Injunctive Relief
18M Ibs Sulfur Dioxide
Rhodia (Nat'l case)
Region 6 portion of settlement
$333,333 Penalty
$40M Injunctive Relief
36M Ibs Sulfur Dioxide
FY07
Seaboard Farms (combined
totals for 2 Settlements)
$345K Penalty
$5.4M Injunctive Relief
47K Cubic Yards Solid Sludge
4/7K Cubic Yards Nitrogen
(dissolved)
1.4M Ibs Sediment
9K Ibs Nitrate Compounds
969 Ibs Phosphorus
Village of Ft. Sumner
Administrative Order
$4,600 Injunctive Relief
18M Ibs Coliform & BODS
Alcoa
$131M Injunctive Relief
9M Ibs Nitrogen Oxide and
Sulfur Dioxide
Page 18
-------
Highlights
FY07 Accomplishments
Monthly Tracking Charts
Nationally recognized by OECA, used by Managers to plan and manage targets
and everyday workload.
Monthly Summary and Charts for ACS, Shell, 300 Day Plan, Regional Priorities,
Penalties and Injunctive Relief. You can view all the charts and summaries on the
6EN Division homepage of the Intranet at:
http://region6.epa.gov/intranet/6en/07-Monthlies/monthlies.html
Press Releases - Reporting Results
Region 6 Increases Outreach to the Press and Public
Press releases are important tool in getting the word out on the "results" of our
activities and they can serve as a too in promoting compliance. OECA asked
the Region to step up our efforts in issuing press releases, and we responded.
# Press Release
Page 19
-------
Oil and Natural Gas Initiative
Using the Infrared
EPA Region 6 used a two-prong
approach to reduce air toxic emis-
sions in the Oil and Natural Gas
(ONG) sector while at the same
time promoting energy production
and efficiency. The first approach
involved forming industry partner-
ships to identify ways to reduce fu-
gitive emissions through voluntary
and compliance assistance related
activities. The second approach
involved conducting ONG inspec-
tions, in collaboration with our state
partners, at targeted ONG facilities
to verify compliance and seek in-
junctive relief.
Issued the nations first Consent
Agreement and Final Order in the
natural gas production sector for air
violations which included enhanced
tank hatch monitoring.
Conducted 25 ONG inspections
with compliance evaluations pend-
ing at 10 facilities which include one
Administrative Order on Consent.
Reduced 31,500 pounds of vola-
tile organic compounds using en-
forcement and compliance assis-
tance efforts.
Surface Impoundments (SI) - Re-
gional Initiative
Surface impoundments (SI) can be
significant sources of air and ground
water pollution if not managed and
designed properly. Impoundment
management also directly affects
the compliance status of the im-
poundments.
Initiatives
In FY07, we inspected 12 facilities
to determine their impoundment
regulatory status. RCRA compli-
ance concerns were identified and
will be pursued in FY08.
A. Concentrated Animal Feeding
Operations
CAFO enforcement, nation-wide,
accounts for half of the pollutant
reductions in the water program.
Non-compliance among CAFOs is
exacerbating water quality prob-
lems in impaired water bodies. In
2007 the Region used compliance
assistance to the CAFO industry
and traditional enforcement to help
address these compliance and en-
vironmental issues.
Enforcement Actions result-
ing in 12 million pounds of pol-
lutant reductions in FY 2007.
Conducted 49 inspections di-
rected at CAFOs impacting im-
paired water bodies.
In partnership with TCEQ and
other Texas agricultural agencies,
held a February 2007 workshop to
strengthen regulatory collabora-
tion.
In August 2007, provided com-
pliance assistance to 14 New Mexi-
co dairies.
Issued 26 administrative en-
forcement actions, two judicial con-
sent decrees.
New Mexico Dairy Initiative
Some concentrated animal feed-
ing operations (CAFOs) are hav-
ing a detrimental affect on impaired
water bodies. The Region is using
outreach to the CAFO industry and
traditional enforcement to address
non-compliance issues and the as-
sociated environmental impacts.
During the week of August 13,
2007, we provided compliance as-
sistance to the owners, operators,
and consultants of 14 dairies lo-
cated between Las Cruces and An-
thony, New Mexico. The meetings
were held with each dairymen to
discuss the Clean Water Act.
Administrative Orders were is-
sued on August 17, 2007, tailored
to bring each dairy into sustained
compliance.
Safe Drinking Water Act
Disinfectant Byproduct Rule (DBPR)
(Stage 2)
We are addressing chronic non-
compliance with the DBPR Stage 2
through compliance assistance and
traditional enforcement.
We provided 1560 drinking water
system operators training and com-
pliance assistance at 26 workshops
in Arkansas, Texas, Louisiana and
New Mexico (Oklahoma workshops
are scheduled to begin in October
2007).
We have issued 28 Administrative
Orders and three Administrative
Penalty Orders to water systems
that failed to comply with the DBPR
(Stage 2) in FY 2007.
Page 20
-------
Numbers at a Glance
Measure
a Estimated Environmental Benefits of Enforcement Actions (Including
Supplemental Environmental Projects (SEPs)) obtained or committed to:
Pollutants Reduced (Pounds)
Contaminated Soil Cleaned (Cubic Yds) (SF & Corr. Action)
Contaminated Water Cleaned (Cubic Yds) (SF)
Stream Miles (Linear Feet) (Wetlands)
Wetlands Protected (Acres) (Wetlands)
People Protected by Safe Drinking Water Act (SDWA) Enforcement
a Value of Complying Actions
a Value of Supplemental Environmental Projects (SEPs)
a Cases with SEPs
a Voluntary Disclosure Program
Pollutants Reduced as a Result of Audits or Other Actions (Pounds)
Facilities Initiated
Companies Initiated
Notices of Determination (NODs)
Facilities Resolved
Companies Resolved
a Total Entities Reached by Compliance Assistance
a EPA Administrative Compliance Orders (ACOs)
a EPA Administrative Penalty Complaints (APCs)
a EPA Civil Judicial Referrals
a EPA Final Administrative Penalty Order (FAPO) Settlements
a EPA Civil Judicial Conclusions
a EPA Administrative Penalties
a EPA Judicial Penalties
a EPA Stipulated Penalties
a Inspections/Evaluations
a Civil Investigations
a Number of Regulated Entities Taking Complying Actions during EPA
Inspections/Evaluations
Number of Regulated Entities Receiving Assistance during EPA
Inspections/Evaluations
FY07 as of 10/10/2007
101,379,888
52,874
476,954
10,050
314
12,976
237,772,026
1,547,771
22
120,134
48
52
55
59
56
9391
254
408
32
(22 Program/ 10SF)
408
12*
(8 Program/ 4 SF)
$2,008,739
$4,345,946
$3,618,689
1684
14
73
795
NOTE: This represents preliminary data pulled from ICIS and the legacy data systems.
Final numbers will be available October 26th
* Conclusions do not include National Cases the Region participated (no credit)
There were two (2) National cases we did not receive credit (Bunge and Rhodia)
Page 21
-------
Numbers at a Glance State bv State
#AOs
LA
30
12%
45%
OK
113
# APO Conclusions
TX
215
53%
NM
34
Page 22
-------
Numbers at a Glance State bv State
# Judicial Conclusions
OK
3
37%
25%
LA
2
Penalties
TX
$4,341,237
64%
OK
$595,217
9%
GM
$186,600
$153,004
21% LA
$1,447,035
1% NM
$60,191
Page 23
-------
Numbers at a Glance State bv State
TX
$223,413,214 80%
Injunctive Relief
0%
GM
$59,600
0% AR
$123,126
ico/
1 O /O $42,275,042
2% NM
$4,287,132
L3% OK
$7,007,442
SEPs
TX
$1,428,423 92%
2%
GM
$23,625
AR
1 % $8,000
2% LA
$38,462
3% OK
$49,261
Page 24
-------
Management Systems
CAED has implemented a num-
ber of tracking systems and tools
to track cases, perform scientific
calculations, and process cases.
They include:
Enforcement Process Manage-
ment:
Referral Database
Tracks all critical milestones
for active referrals (once re-
ferred to DOJ)
Accessible by Region 6 and
OECA
Supports monthly ORC dock-
et and quarterly DOJ/OECA
docket reviews.
Consent Decree Tracking System
Tracks CD deliverables such
as monitoring reports, audits,
compliance assessment
Sends reminders to enforce-
ment officers via emails
Case Activities Database
Provides current status on
significant administrative and
all judicial cases
Accessible by Region 6 and
OECA
Supports monthly Branch/
ORC docket meetings
To Do Database
Tracks significant Division
activities at the Associate Di-
rector level
sends automatic reminders
to responsible Associate Di-
rector
Future Tools:
Self Disclosure Database
Track self disclosure audit re-
ports
provides history and status of
each open disclosure
identifies responsible staff
facilitates statistical analysis
and reporting
vvEPA
Self Disclosure
Audit Report Form
eRouting
Enforcement documents and
correspondence can be rout-
ed electronically thereby pro-
viding more accountability,
faster transport, and use less
paper.
Analytical Tools:
Cool Tool
Agronomic rate calculator
National Program Support
hosted national program
meeting
conducted CAFO inspections
in Regions 2 and 3 at request
ofHQ
provided technical review of
nutrient management plan in
support of Region 10 at re-
quest of HQ
developed Nutrient Manage-
ment Plan evaluation tool
which is undergoing peer re-
view nationally
NEPA Assist
provides preliminary assess-
ment of a facility's or project'
environmental footprint
can provide comparative risk
based analyses
web based, can be tailored
for a variety of applications
(e.g., inspection targeting,
NEPA, etc.)
exportable to States, Tribes
and other agencies
Survey Monkey
Employee survey tool
yearly subscription, available
upon demand
confidential
Inspection Targeting
target by facility, by sector or
geographically for greatest
potential environmental out-
comes
dedicated team and comput-
ing capabilities
Online Training Tools
CAED is now collecting presenta-
tion materials and videos of our ma-
jor training sessions and put them
on the web for additional access.
Basic Inspector Training
Air Inspector Workshop
RCRA Inspector Workshop
NPDES Inspector Workshop
Civil/Criminal Enforcement
Training
Additional online training tools are
anticipated for FY08.
Page 25
-------
Inspections
FY2007 # Inspection by Program
600
500
400
300
200
100
567
94
246
78
16
i,rn 166 166
it 58 6ฐ
. II n A i. n
<ง>
$ .^ Jr ^ <$
&
j? ^ ^ *
Preliminary Data - final numbers will be available 10/26/07
Combined Animal Feeding Operations: 49 Inspections
- 43 Federal Inspections (15 Oklahoma, 28 New Mexico)
- 6 Joint Inspections (all in Texas)
Storm Water: 73 Inspections
- 56 Construction
-17 Non-Construction
Clean Air Act: 94 Inspections
-16 Full Compliance Evaluations
- 78 Partial Compliance Evaluations
Toxics Substance Control Act: 44 Inspections
- 12AHERA
- 25 Lead
- 7 PCBs
16 inspections for drinking water were conducted against Jeff
Pruett water systems in Monroe, Louisiana
Page 26
-------
New Equipment
Cameras
Headquarters provided our
Surveillance team with eight
Samsung Digitmax S850 camer-
as, eight mega pixel, 5X optical
zoom, and two gigabyte secure
digital cards. They are being
used by five inspectors, two Un-
derground Injection Control staff,
and one person from wetlands.
Phosphorous Monitor
- Real time nutrient monitor was
received in April 2007. The unit
allows the region to detect very
small concentrations of phos-
phorus and nitrogen in streams
or receiving waters, help identify
unauthorized discharges, and
possible sources of surface wa-
ter pollutants. The unit is being
used in support of CAFO surveil-
lance and enforcement activities.
- To support usage of the phos-
phorus monitoring unit , the di-
vision has purchased standards
and reagents, tools for a tool kit
and a limited number of parts for
a small spare parts inventory.
- To support testing of a real
time enforcement pilot project,
the division has purchased two
satelite transmission systems
with two support telephones.
When the field printers that are
being purchased arrive, we will
begin the pilot project in FY08.
- Items to support continued use
of the hydrolab were also pur-
chased; the hydrolab is a small
hand held unit that can be used
to rapidly survey surface and
ground waters for ammonia or
nitrates to within 90-95% of true.
This is a very useful tool in track-
ing fate and transport of nitrogen
in surface and ground water.
Page 27
- Minor repair, and purchase of
batteries were also needed for
our survey equipment, which is
used in proving direction of sur-
face and ground water flows.
- Purchase of pressure transduc-
ers so slug tests and pump tests
can be conducted to determine
aquifer conductivity, transmissiv-
ity and flow velocity. This infor-
mation is very useful in linking
CAFO facilities to aquifer (and
well) contamination.
Hawk Camera
Region 6 is using the Hawk
Monitoring Camera during com-
pliance inspections to pinpoint
excess emissions from valves
and flanges and to determine
whether there is product/waste
in unidentified tanks. The in-
spector can see leaks through
the hand-held camera and show
the facility where leak repairs
need to be made. Since receiv-
ing the camera in January 2007,
the camera has identified emis-
sions concerns in 11 out of 24
inspections.
Bioreactor for Method 304A
It appears that enhanced bio-
degradation units (EBUs) are
significant sources of unregu-
lated benzene and other organic
hazardous air pollutant (HAP)
emissions. The concern is that
the EBUs are volatilizing rather
than biodegrading these organ-
ic compounds. Only analytical
method 304A is capable of dis-
cerning between volatilized and
biodegraded. This capability
could support huge HAP reduc-
tions through enforcement and
voluntary actions not only in Re-
gion 6, but nation-wide. In 2007,
the Region purchased the nec-
essary bioreactor and software
to facilitate this.
-------
Referrals/Judicial Conclusions
Region 6 = 13% of Nat'l FTEs
FY07 Referrals = 17% of Nat'l Referrals
ivy
Program ^^^
Clean Air Act
Clean Water Act (NPDES)
RCRA
SDWA-UIC
Oil Pollution Act
Total
# Referrals
9
4
6
1
2
22
FY05
FY06
FY07
More Substantial Enforcement Cases:
S Region 6 made a commitment to move towards more
environmentally substantial enforcement cases
S Conscious effort to increase the number of Referrals
S In FY07, Region 6 will issued 22 Referrals
S 5% increase over FY06 (21), 36% increase over FY05 levels (14)
S Fair Share of Referrals Nationally
> 17% without Superfund, 15% with Superfund
Page 28
-------
Voluntary Audit Disclosures
CAED serves as the central repository for all voluntary disclosures for the region.
Self Disclosures
Injunctive Relief
$57,565
$293,200
Non-CAED
CAED
Page 29
-------
Big Case Summaries
Why track Big Cases?
Most of the pollutants and injunctive relief/SEP dollars come from Big Cases
1 % of the cases produce over 90% of the Results
Projecting and Tracking Big Cases makes it easier for EPA's Managers to
forecast what our "Results" may be at the end of the year.
# Cases
15
10
5
0
15
11
Criteria for Non-Superfund
Civil Penalty amount of greater
than $1 million; or
Pounds of pollutants reduced,
estimated amount greater than
1 million pounds; or
Injunctive relief and SEP
combined, estimated amount of
more than $5 million
n Regulatory n Nat'l Cases not Lead Superfund n TOTAL
Types of Actions
Criteria for Superfund
Cost recovery of at least $5
million; or
PRP clean up commitment of
at least $5 million; or
Volume of contaminated soil
or water/aquifer clean-up
commitment of at least 1 million
cubic yards.
Judicial
Administrative Superfund
Big Case Results
$ Value of Penalties
$ Value of Injunctive Relief/SEP
Direct Pollutant Reductions
$6.3 Miilion
$217 Million
79.7 Million Pounds
Page 30
-------
Supplemental Environmental Projects
Supplemental Environmental Projects
(SEPs)
SEPs in R6
21 (136EN)
12% -Nat'l Total
$1,534,896
5 % of Nat'l SEP $
Case Name
Cost
Project(s)
Total Petrochemicals Inc.
$80K
Upgrade leak detection and repair practices. The company
will do comparative monitoring of method 21 using infrared
camera.
City of Baytown
$82K
Two activities. Educational workshop for the industrial
community on the Mult-Sector Industrial General Permit
(MSGP) and to increase awareness of the detrimental effect
that polluted storm water may have on surface waters. The
second activity of the project is to upgrade and expand two
existing city owned storm water detention basins.
Union Carbide
$165K
Purchase mobile command center and other emergency
response equipment for the local response agency and
provide training to the city's emergency response personnel.
TxDOT
$1M
Develop and implement a long term management system
focused on improving environmental compliance and
performance at all Road Construction Projects undertaken by
TXDOT or it's contractors.
Benefit the environment by aiding TXDOT in it's continued
commitment to environmental compliance.
Anadarko Petroleum
Corporation
(Gulf of Mexico)
environmental or public
health
$16,875
Purchase and donate, to the Trust for Public Lands, coastal/
inland wetlands in several counties located along the Gulf of
Mexico in Texas. Trust for Public Lands will maintain for
conservation purposes.
Page 31
-------
Tips and Complaints
Silverleaf Resorts
CFC Violations
Referred to DOJ
Jeff Pruett Public Water Systems
West Monroe, Louisiana
Safe Drinking Water violations
17 Administrative Orders
Rabun Dairy
Bashear, Texas
Animal Feeding Operations
Clean Water Act
Administrative Order
Mahard Egg Farms
Boogie Hill Facility
Sulphur, Oklahoma
Animal Feeding Operations
Clean Water Act
Administrative Order
Page 32
-------
Cease and Desist Orders
# Cease & Desist Orders
FY06: 7 issued - all under Clean Water Act
FY07: 65 issued
> 46 Clean Water Act
> 17 Public Water Supply
> 2 Clean Air Act
FY06
FY07
Goal: Immediately stop the release of significant quantities of pollutants
into the environment and to direct facilities to take quick actions to
remediate the environmental damages.
Benefits
Addresses critical environmental problems on a real time basis
Responsive to State needs
Center Point Dairy
Ordered to stop discharges of pollutants from its lagoon and domestic septic
systems, clean up areas where domestic septic waste has pooled, properly
remove solid waste from domestic septic tanks and repair septic waste
collection systems, and remove sediment buildup in its lagoon and restore
the lagoon to proper operating conditions
Lisbon
Ordered to cease all discharges and air
emissions and to remove and properly
store the hazardous waste.
Page 33
-------
Partnerships
Utilizing State, Local, Tribal, Private and Federal partnerships to aid
our mission to move facilities beyond compliance.
We partnered with the South Texas
Exploration and Production Safety
STEPS) network in Corpus Chris-
i, Texas, on June 20, 2007. This
sffort demonstrated to the Oil and
3as industry how to use an Infra
ped Camera to detect air emissions
and how vapor recovery units can
capture lost product.
Annual Region 6 CMOM Confer
ence
The Capacity, Management, Oper-
ations, and Maintenance (CMOM)
orogram was developed in con
unction with the creation of the
Sanitary Sewer Overflow (SSO)
pule as a methodology that can be
jsed to assess the need for re-
oairs and maintenance for sewage
collection systems. Although the
SSO rule has not been promulgat
3d at this time, we embraced the
MOM approach and have devel-
Dped the annual CMOM Confer-
nce in conjunction with the City o
and the Texas Commission
Environmental Quality (TCEQ)
The purpose of the workshop is tc
allow EPA and state regulators tc
come together with their municipa
oermit holders to discuss practi
za\ experiences related to CMOM
Since the inception of the work
shop in 2004, over 1500 hundred
people have attended.
fhe following numbers of Compli-
ance Assistance activities were
Derformed for the associated OECA
Slational Priorities in 2007:
No. of
National Priority Activities
Air Toxics 8
Petroleum Refining 1
Tribal 6
Wet Weather:
Combined Sewer Overflows... 1
Sanitary Sewer Overflows 1
Concentrated Animal
Feeding Operations 2
Storm Water:
Construction 5
Industrial (non-construction)..2
Municipal Separate
Storm Sewer Systems 8
We partnered with the Texas As-
sociation of Builders (TAB) and
the Texas Commission on Envi-
ronmental Quality (TCEQ) to de
velop another tool for the builder';
toolbox. From developing a storm
water pollution prevention plan
(SWPPP) to conducting site in-
spections to selecting the best ero
sion or sediment controls, the new
training tool developed by the part-
ners will help builders to achieve
compliance and will prevent many
tons of sediment and other pollut-
ants from reaching waters of the
United States. Twenty-eight work-
shops have been planned for ven-
ues across the state, with a targei
to train 3500 statewide builders
We provided $50,000 in Regiona
Geographic Initiative funds.
Fexas Manufacturing Assistance
enter (TMAC), a recipient ol
^Dilution Prevention grant dollars
rom EPA worked with industria
Facilities and their partners to link
nvironmental issues to core busi-
ness concerns by teaching P2
.echniques as part of lean manu-
facturing principles.
One of the industrial entities thai
FMAC worked with was Atlas Cop-
DO Drilling Solutions LLC. Atlas
opco demonstrated its commit-
ment to the environment by invest-
ng in both technology and people
The drilling equipment manufactur
r spent nearly $1 million upgrad-
ng lighting and air-conditioning
systems. This investment, alone
with other procedural changes, re-
duced electrical use by 25 percent
solid waste disposal was dropped
oy 65 percent, and water use was
Dut by 18 percent.
Copco also committed tc
work with TMAC to take a leader-
ship role in promoting the interna
.ional standard ISO 14001 and En-
vironmental Management Systems
EMS) to their suppliers. This efforl
serves as a model for building part-
nerships between a grant recipien
and an industrial entity. The efforl
of Atlas Copco earned them the
Texas Environmental Excellence
^ward, presented by Texas Gover-
nor Rick Perry and TCEQ on En-
vironmental Quality. The were also
selected by EPA as a Performance
Track member for their commit-
ment to environmental excellence
and improved performance.
Page 34
-------
Pollution Prevention
Pollution Prevention/Source
Reduction Grant Partners
[ nill<5IAMA^-
LOUISIANA
Them.e.t
CLEAN
TEXAS
fr,
Increasing the Global Competfttvenecc of Teitat Manufacturers
ADEQ
State of Arkansas
Department of Environmental Quality
To protect, enhance and restore trie natural environment for //?e well-being of a/Mricansans"
joals of Pollution Prevention Pro-
gram Grants, Source Reduction
^^ssistance Grants and Pollution
Drevention Information Network
3 rants:
1 Assist businesses and indus-
ries in identifying better environ-
nental strategies and solutions
or reducing or eliminating waste
at the source.
1 Work with business and indus-
ry to reduce the release of poten-
ially harmful pollutants across al
snvironmental media.
Grantees are required by the
EPA's Environmental Results Pol-
cy to submit outcome and output
neasurements.
Dollutant Reductions and out-
:omes reported by Grant Part-
ners in FY07:
Hazardous materials
11,113,625 pounds
P2 efforts saved
$9,692,580
Water conserved
11.5 trillion gallons
Energy conserved
105.963 billion BTUs
The Oil and Gas Environmental Results Program (ERP) project is using Louisiana Department of Environmenta
Quality (LDEQ) resources and leverages outside community partnerships including Louisiana Department ol
Natural Resources, USEPA Region 6, community organizations, local trade organizations and economic devel-
Dpments agencies. LDEQ will take a multimedia approach to prepare fact sheets, self-assessment checklists, a
workbook for guidance on how to complete the self-assessment checklists, and compliance assistance tools for
he industry sector on pollution prevention including release notification. Annual training will be provided through
Dn-site assessments and workshops. These tools will be made available as models for other states to use
Environmental results will be achieved by the outcomes of: reducing air emissions, reducing the threat of re-
eases of materials to groundwater (a significant source of drinking water in Louisiana) and soils through en-
nanced compliance with sector-specific BMPs. As minor sources these facilities are not subject to most state
and federal regulatory requirements for pollution reduction measures.
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Environmental Management Systems
City of Dallas ~-~-Z-
^^^^^MV
PEER
center
EMS Forum for Local Governments
A PEER to Peer Collaboration
June 26, 27 and 28th, 2007
Dallas City Hall Level LI 1500 Manila Street Dallas, TX
EMS Forum For Local Governments: Dallas, Texas,
June 26-28, 2007:
Staff from the Compliance Assurance and Enforce-
ment Division, Texas Commission on Environmental
Quality, North Central Texas Council of Governments,
and City of Dallas collaborated to conduct of an EMS
Forum for local governments June 26-28, 2007. This
forum relied on the participation of out-of-region local
government leaders who are veterans in developing
and implementing an EMS. They shared examples
of costs-savings, improved regulatory compliance, re-
duction of liability, and reduced environmental impact
with their North Texas Peers. These speakers con-
veyed how local governments, citizens, and the envi-
ronment can benefit from EMS implementation.
Workshop: Environmental Management Sys-
tems, Saving Money and Improving Compliance
and Performance: Austin, Texas, July 26, 2007.
This workshop for Central Texas Cities and gov-
ernments focused on how EMSs are helping
local governments and other organizations
in Texas and across the country reduce risks
and liabilities, improve compliance and envi-
ronmental performance, and reduce costs.
Learned what an EMS is and how it improves
an organization's efficiency
Learned from three Texas organizations why
and how they developed an EMS, the lessons
they learned and the benefits
Learned how to take the first steps toward im-
proving the organizations environmental per-
formance and reducing costs
Learned how to develop an EMS that compli-
ments the organization's existing internal im-
provement programs
Learned about available assistance, make
valuable contacts, and take away informative
materials
Learned about incentives in Texas to develop
an EMS that get results.
Seminar For City Managers on EMS:
rand Prairie, Texas, September 27, 2007
Staff from Compliance Assurance and Enforcement Division
Region 6, the North Central Texas Council of Governments
Texas Commission on Environmental Quality, and the North
entral Texas EMS Work Group hosted this seminar thai
Highlighted balancing growth, budget constraints, and envi
'onmental risks in city governmentsthe costs of not having
an EMS. The seminar featured W. Robert Herbert, a retiree
Dity manager of Roanoke, Virginia, with experiences associ-
ated with Not having an EMS in place. North Central Texas
governments learned how to Reduce Risks from operations
Reduce Impact to the environment and Save local tax dollars
jsing an EMS.
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Performance Track
National
Environmental
PerformanceTrack
U.S. Environmental Protection Agency
Fiscal Year 2007 New members
include:
US FAA Mike Monroney Aero-
natical Center Oklahoma City,
Oklahoma
Dallas Fort Worth International
Airport, Fort Worth, Texas
Aloe Vera of America, Inc., Dal-
las, Texas
Frito-Lay, Inc., Jonesboro, Ar-
kansas.
Bandelier Trading Company,
Los Alamos, New Mexico
University of Texas Medical
Branch, Galveston, Texas
Toshiba International Corpora-
tion, Houston, Texas
Firestone Building Products,
Corsicana, Texas
Sheppard Air Force Base, Tex-
as
Lockheed Martin Aeronautics
Company, Fort Worth, Texas
Eaton Hydraulics Operation,
Searcy, Arkansas
Atlas Copco Drilling Solutions,
Garland, Texas
Frito-Lay achievements:
Reduced total suspended solids in wastewater system by
234,914.85 (normalized) pounds (32.9%) through procedural
improvements.
Reduced total water usage by 172,471,233.86 (normalized)
gallons (45.2%) through implementation of a water re-use
system during production.
During 2007, Region 6 received
15 new applications. This exceed-
ed our ACS commitment goal of 10
new applications.
In 2007, Region 6 senior manag-
ers conducted Recognition Events
at two P-Track member's facili-
ties, DFW Airport, in March, and
Frito-Lay in August. We anticipate
conducting one additional on-site
event this year. We will also be
conducting a Regional Roundta-
ble meeting for P-Track members
within Region 6 in October 2007.
DFW Airport Achievements:
Reduced NOx emissions by 38.65 (normalized) tons (95.6%)
through equipment replacement/upgrades.
Reduced VOC emissions by 0.18 (normalized) tons (47.4%)
through participation in the Clean Fleet Program.
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National Environmental Policy Act
Significant NEPA/309 Project Re-
views:
In FY07, the Trans Texas Corridor
Interstate 69 Tier 1 Draft Environ-
mental Impact Statement and the
Trans Texas Corridor Interstate 35
Draft Environmental Impact State-
ment were review by Region 6 staff
for compliance with the National
Environmental Policy Act and the
Clean Air Act Section 309. These
two projects are significant trans-
portation projects for the State of
Texas to decrease congestion re-
lated to traffic created by the North
American Free Trade Agreement.
309 Review of the Preliminary Draft
Environmental Impact Statement
(DEIS) for the Trans Texas Corridor
- IH35 (TTC-35) proposed Oklaho-
ma to Mexico/Gulf Coast Element
Tier One system project to identify
a preferred corridor for a potential
TTC-35 alignment.
We participated in the Workgroup
for Review and Comment of the
Proposed Revision of 40 CFR Part
6 Procedures for Implementing
the Requirements of the CEQ on
NEPA. The draft amendments to
the procedures at 40 CFR Part 6
for implementing the requirements
of the Council on Environmental
Quality's (CEQ's) regulations for
the National Environmental Policy
Act of 1969 (NEPA) are undergoing
the finalization process.
We participated in the Workgroup
to Review and Comment on the
Preliminary Draft of the Special Ap-
propriation Applicant's Handbook.
Reviewed the Preliminary Draft of
Applicant's Guide The handbook
and the associated appendices are
designed for grant applicants who
are applying for funds for specific
projects identified in the annual
special appropriations.
We participated in the Workgroup to
Review and Comment of the Prelimi-
nary Draft of the Proposed Revision
of the 309 Environmental Review
Process Handbook. Reviewed the
Preliminary Draft of EPA's Environ-
mental Review Process Handbook
by a Task Force.
Environmental Impact Statement
(EIS) for the Outer Continental
Shelf (OCS) Minerals Management
Service (MMS) Oil and Gas Lease
Sales: 2007-2012.: Worked on the
coordination process associated
with the issuance of the Final NP-
DES permit for the Outer Continen-
tal Shelf (OCS) Oil and Gas activi-
TTC-35 reepm
preferred altsrnflrivfi
route
Proposed TTC-35 area
Proposed TTC-69 area
I Priority corridors
I New coiridnr
Existing highways
ties. We are a cooperating agency
in the MMS preparation of the EIS
for the Lease Sales: 2007-2012.
The Final General Permit was is-
sued in September 2007. The EPA
is participating as a cooperating
agency because of the National
Pollutant Discharge Elimination
System (NPDES) general permit
being proposed for the OCS, which
requires the NEPA review.
Environmental information docu-
ments received for review and as-
sessment:
Border Environment Cooperation
Commission (BECC) projects - 5
Special Appropriations - 19
Colonia - -1
Coastal Wetlands Planning,
Protection and Restoration Act
(CWPPRA) - 1
Completed Environmental Assess-
ments:
BECC projects - 5
Special Appropriations - 20
Outer Continental Shelf Produced
Water General Permit - 1
Environmental Impact Statement
(EIS) Accomplishments:
Draft EISs Received
Draft EISs Reviewed
Final EISs Received
Final EISs Reviewed
28
24
28
27
Projects with significant issues 4
Total EISs Reviewed 51
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Federal/State Relations
State Enforcement Review Framework Highlights
The first round of all States completed:
Arkansas Department of Environmental Quality (ADEQ)
Successful review in 2006 - SNC/HPV identification a strength; in-
spection/enforcement commitments met; data quality high. Action
- consider unifying penalty policy for greater consistency among me-
dia programs.
National Best Practice: Annual Title V Compliance Certification Re-
minder letters resulting in 100% compliance with reporting require-
ments
ADEQ is participating in the Framework Evaluation Work Group.
Louisiana Department of Environmental Quality (LDEQ)
Successful review in 2007 - inspection/enforcement commitments
met; data quality high; good consistency among media programs.
Action - consider options for more timely HPV/SNC identification in
national databases.
National Best Practices: Reports from the 2007 reviews are being
evaluated to identify Best Practices.
LDEQ is participating in the Framework Evaluation Work Group
New Mexico Environment Department (NMED)
Successful review 2006 - inspection/enforcement commitments met.
Action - data system conversion completed for improved data; action
needed for HPV/SNC identification.
National Best Practices: NMED Air Bureau's innovative filing system;
the Green Zia Pollution Prevention Program; Waste Bureau's timely
inspection reports.
Oklahoma Department of Environmental Quality (ODEQ)
Successful review in 2005 - inspection/enforcement commitments
met; data quality high; good consistency among media programs.
Action - new consolidated filing system implemented for improved
records management.
National Best Practices: ODEQ's use of portable testing analyzer
for its water compliance program; the availability/use of web-based
forms.
Texas Commission on Environmental Quality (TCEQ)
Successful review 2007 - inspection/enforcement commitments met;
good consistency among media programs. Action - additional mea-
sures to address data issues.
National Best Practices: Reports from 2007 reviews are being evalu-
ated to identify Best Practices.
TCEQ is participating in the Framework Evaluation Work Group.
Page 39
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worked with the Bureau of Indian Affairs to achieve the follow-
ng goal: Provide state-of-the-art training to individuals who are com-
mitted to fulfilling the government's responsibilities to Indian Country.
Staff from Region 6 Compliance Assurance and Enforcement Divi-
sion provided compliance assistance to BIA Tribal School facilities anc
nvironmental managers at the BIA Office of Facilities Management
and Construction, June 4th-8th. The assistance provided information
.o school managers in the Region 6 areas of New Mexico, Oklahoma
and Louisiana on the AH ERA (Asbestos) program, lead-based pain
and spent laboratory chemicals in schools program. The focus of the
oresentation was on regulatory requirements of these programs to en-
sure compliance with federal law, school safety, using less chemicals
and the interface with science curriculum in schools.
BP
Page 40
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Tribal Capacity Buildin
Before
Kickapoo Tribe in
continuous non-
compliance with the Safe
Drinking Water Act.
After
Technical assistance and
Compliance Agreement
resulting in compliance.
rribal Professionals Attended Region 6 In-
spector Workshops
i/Ve worked with Sandia Pueblo to credential
a tribal inspector for the NPDES program.
Provided all Tribes with information on report-
ng tips and complaints, compliance assis-
ance, and pollution prevention.
Safe Drinking Water for the Kickapoo and Nam be Tribes
Region 6 worked with the Nam be Pueblo in New Mexico and the Kicka-
DOO Traditional Tribe in Texas to address violations of the Safe Drinking
lA/ater Act (SDWA) and National Primary Drinking Water Regulations
Both Tribes had chronic violations of monitoring and reporting require-
ments and used unqualified operators. Through the technical assis-
ance provided by EPA and the Tribes' commitment to compliance, both
Tribes have achieved continuous compliance since issuance of the
compliance agreements. As a result, EPA has terminated the agreed-
o-orders in October 2007.
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