STATE REVIEW FRAMEWORK
Wyoming
Clean Water Act, Clean Air Act, and
Resource Conservation and Recovery Act
Implementation in Federal Fiscal Year 2017
U.S. Environmental Protection Agency
Region 8
Final Report
June 19, 2019

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I. Introduction
A.	Overview of the State Review Framework
The State Review Framework (SRF) is a key mechanism for EPA oversight, providing a nationally
consistent process for reviewing the performance of state delegated compliance and enforcement
programs under three core federal statutes: Clean Air Act, Clean Water Act, and Resource Conservation
and Recovery Act. Through SRF, EPA periodically reviews such programs using a standardized set of
metrics to evaluate their performance against performance standards laid out in federal statute, EPA
regulations, policy, and guidance. When states do not achieve standards, the EPA will work with them to
improve performance.
Established in 2004, the review was developed jointly by EPA and Environmental Council of the States
(ECOS) in response to calls both inside and outside the agency for improved, more consistent oversight
of state delegated programs. The goals of the review that were agreed upon at its formation remain
relevant and unchanged today:
1.	Ensure delegated and EPA-run programs meet federal policy and baseline performance standards
2.	Promote fair and consistent enforcement necessary to protect human health and the environment
3.	Promote equitable treatment and level interstate playing field for business
4.	Provide transparency with publicly available data and reports
B.	The Review Process
The review is conducted on a rolling five-year cycle such that all programs are reviewed approximately
once every five years. The EPA evaluates programs on a one-year period of performance, typically the
one-year prior to review, using a standard set of metrics to make findings on performance in five areas
(elements) around which the report is organized: data, inspections, violations, enforcement, and
penalties. Wherever program performance is found to deviate significantly from federal policy or
standards, the EPA will issue recommendations for corrective action which are monitored by EPA until
completed and program performance improves.
The SRF is currently in its 4th Round (FY2018-2022) of reviews, preceded by Round 3 (FY2012-2017),
Round 2 (2008-2011), and Round 1 (FY2004-2007). Additional information and final reports can be
found at the EPA website under State Review Framework.
II. Navigating the Report
The final report contains the results and relevant information from the review including EPA and
program contact information, metric values, performance findings and explanations, program responses,
and EPA recommendations for corrective action where any significant deficiencies in performance were
found.
A. Metrics
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There are two general types of metrics used to assess program performance. The first are data metrics,
which reflect verified inspection and enforcement data from the national data systems of each media, or
statute. The second, and generally more significant, are file metrics, which are derived from the review
of individual facility files in order to determine if the program is performing their compliance and
enforcement responsibilities adequately.
Other information considered by EPA to make performance findings in addition to the metrics includes
results from previous SRF reviews, data metrics from the years in-between reviews, multi-year metric
trends.
B.	Performance Findings
The EPA makes findings on performance in five program areas:
•	Data - completeness, accuracy, and timeliness of data entry into national data systems
•	Inspections - meeting inspection and coverage commitments, inspection report quality, and
report timeliness
•	Violations - identification of violations, accuracy of compliance determinations, and
determination of significant noncompliance (SNC) or high priority violators (HPV)
•	Enforcement - timeliness and appropriateness of enforcement, returning facilities to compliance
•	Penalties - calculation including gravity and economic benefit components, assessment, and
collection
Though performance generally varies across a spectrum, for the purposes of conducting a standardized
review, SRF categorizes performance into three findings levels:
Meets or Exceeds: No issues are found. Base standards of performance are met or exceeded.
Area for Attention: Minor issues are found. One or more metrics indicates performance issues
related to quality, process, or policy. The implementing agency is considered able to correct the issue
without additional EPA oversight.
Area for Improvement: Significant issues are found. One or more metrics indicates routine and/or
widespread performance issues related to quality, process, or policy. A recommendation for corrective
action is issued which contains specific actions and schedule for completion. The EPA monitors
implementation until completion.
C.	Recommendations for Corrective Action
Whenever the EPA makes a finding on performance of Area for Improvement, the EPA will include a
recommendation for corrective action, or recommendation, in the report. The purpose of
recommendations are to address significant performance issues and bring program performance back in
line with federal policy and standards. All recommendations should include specific actions and a
schedule for completion, and their implementation is monitored by the EPA until completion.
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III. Review Process Information
Clean Water Act (CWA)
Review period: FY 2017
Key dates:
•	SRF Kick-Off Letter: March 15, 2018 (See Appendix)
•	CWA NPDES File Review: April 2-4, 2018
•	CAA File Review: August 13-15, 2018
•	RCRA File Review: Done remotely - May 2018
State and EPA key contacts for review:
Key EPA Review Contacts
•	David Piantanida, SRF Coordinator and NPDES File Reviewer: (303) 312-6200,
piantanida.david@epa.gov
•	Linda Jacobson, RCRA Lead: 303-312-6503, jacobson.linda@epa.gov
•	Laurel Dygowski, NPDES Lead: (303) 312-6144, dygowski.laurel@epa.gov
•	Michael Boeglin, NPDES File Reviewer, Boeglin.michael@epa.gov
•	Bob Gallagher, CAA Lead: (406) 457-5020, gallagher.bob@epa.gov
Key EPA and State Contacts:
•	Kevin Wells (CWA): kevin.wells@wyo.gov
•	Lars Lone (CAA): 1 ars. 1 one@wvo.gov
•	Ann Shed (CAA): ann.shed@wvo.gov
•	Robert Breuer, (RCRA): robert.breuer@wyo.gov
•	Charles Plymale (RCRA): charles.plymale@wvo.gov
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Introduction
Executive Summary
The EPA Region 8 enforcement staff conducted a State Review Framework (SRF) enforcement program
oversight review of the Wyoming Department of Environmental Quality in 2018.
The EPA bases SRF findings on data and file review metrics, and conversations with program
management and staff. The EPA will track recommended actions from the review in the SRF Tracker
and publish reports and recommendations on the EPA's Enforcement and Compliance History Online
(ECHO) web site.
Areas of Strong Performance
The following are aspects of the program that, according to the review, are being implemented at a high
level:
Clean Water Act (CWA)
•	The state's penalty calculations documented and included gravity and economic benefit,
documented the rationale for the difference between the initial penalty and final penalty, and
documented proof that penalties were collected.
•	The state's permit limit data entry rate exceeded the national goal.
•	The state met or exceeded its inspection commitments for majors, non-majors, stormwater
construction and industrial stormwater.
•	The state's inspection reports are generally complete and sufficient to determine compliance at
the facility.
•	The state generally completes inspection reports within the goal set by their Enforcement
Management System (EMS).
Clean Air Act (CAA)
•	The state achieved FCE Coverage of Majors and Mega-sites with results entered into ICIS Air
for 100% of inspections conducted.
•	The state achieved FCE Coverage of SM-80s with results entered into ICIS Air for 100% of
inspections conducted.
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•	The state reviewed Title V Annual Compliance Certifications with results entered into ICIS Air
for 98.2% of the certifications.
•	The state achieved appropriate documentation of the FCE Elements for 95.8% of FCEs
reviewed.
•	The state had appropriate information for compliance determination for 95.8% of CMRs
reviewed.
Resource Conservation and Recovery Act (RCRA)
•	The state entered 100% of information in RCRAInfo based on files reviewed.
•	All of the data elements required to be entered into RCRAInfo had been entered in a timely and
accurate fashion for the 41 files reviewed by EPA.
•	The state does an excellent job of LQG inspections, with an annual inspection coverage for BR
LQGs of 40.90%) compared to a national average of 16.10%>. They also had a 25% annual
inspection coverage for active LQGs. Additionally, the state met the TSDF requirement by
inspecting the two operating TSDFs in the state.
•	Inspection reports are timely and thorough allowing appropriate violation determination.
•	The state takes timely and appropriate enforcement actions to address identified violations.
•	The state requires corrective measures to return facilities to compliance and follows up through
required submittals or onsite inspections to verify return to compliance has occurred.
Priority Issues to Address
The following are aspects of the program that, according to the review, are not meeting federal standards
and should be prioritized for management attention:
Clean Water Act (CWA)
•	ICIS did not contain complete and accurate data for all facilities.
•	The state did not meet its commitment for a municipal separate storm sewer system (MS4) audit
and has not been conducting MS4 inspections for several years.
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Included below is a brief overview of the WY CWA past performance issues from previous State
Review Framework (SRF) reviews. This overview demonstrates that issues from previous reviews have
been resolved while some of the same issues have continued. The metric and finding level from Round
3 as compared to Round 4 are provided below - starting with the Clean Water Act Program.
Metric
Round 3 Finding Level
(FY12)
Round 4 Finding Level
(FY17)
2b Files reviewed where
data are accurately
reflected in the national
data system
Area for State Improvement
Area for State Improvement
4a7 Number of Phase I and
IIMS4 audits or
inspections.
Meets or Exceeds
Expectations
Area for State Improvement
6a Inspection reports
complete and sufficient to
determine compliance at
the facility
Area for State Improvement
Meets or Exceeds Expectations
7e Inspection reports
reviewed that led to an
accurate compliance
determination
Area for State Improvement
Meets or Exceeds Expectations
8b Single-event violations
accurately identified as
SNC or non-SNC
Area for State Improvement
N/A*

8c Percentage of SEVs
identified as SNC reported
timely at major facilities
Area for State Improvement
N/A **

9a Percentage of
enforcement responses that
return or will return source
in violation to compliance
Area for State Improvement
Meets or Exceeds Expectations
lOal Major facilities with
timely action as
appropriate.
Area for State Improvement
N/A **

10b Enforcement
responses reviewed that
address violations in a
timely and appropriate
manner.
Area for State Improvement
Area for State Attention
1 la Penalty calculations
reviewed that consider and
include gravity and
economic benefit
Area for State Improvement
Meets or Exceeds Expectations
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12a Documentation of the
difference between initial
and final penalty and
rationale
* Analysis of SEV data entry is evaluated under Round 4 metric 2b
**CWA metric is now a review indicator in Round 4. A review indicator is not used to develop findings.
It is used to identify areas for further analysis during the file review. When an indicator diverges significantly
from the average, EPA should ensure that it pulls a sufficient sample of files to evaluate the issue during the
file review.
Clean Air Act (CAA)
•	The state showed penalty calculations documenting gravity and economic benefit in 0% of cases
reviewed.
•	The state showed documented rationale for difference between initial and final penalty
calculations in 0% of cases reviewed.
• The state achieved appropriate enforcement responses for 33% (5 out of 15) of the reviewed
HPVs.
• Data entered into the national compliance database needs improvement.
Included below is a brief overview of the WY CAA past performance issues from previous State Review
Framework (SRF) reviews. This overview demonstrates that issues from previous reviews have been
resolved while some of the same issues have continued. The metric and finding level from Round 3 as
compared to Round 4 are provided below.
Metric
Round 3 Finding Level
(FY12)
Round 4 Finding Level
(FY17)
3a2 Timely reporting of HPV
determinations
Area for State Improvement
Area for State Improvement
2b Files reviewed where data
are accurately reflected in the
national data system
Area for State Improvement
Area for State Improvement
3b 1 Timely Reporting of
Compliance monitoring
MDRs
Area for State Improvement
Meets or Exceeds
Expectations
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3b2 Timely reporting of stack
test dates and results
Area for State Improvement
Meets or Exceeds
Expectations
3b3 Timely Reporting of
enforcement MDRs
Area for State Improvement
Meets or Exceeds
Expectations
7b 1 Violations reported per
informal actions
Area for State Improvement
Meets or Exceeds
Expectations
Metric
Round 3 Finding Level
(FY12)
Round 4 Finding Level
(FY17)
7b3 Violations reported per
HPV identified
Area for State Improvement
Meets or Exceeds
Expectations
8a HPV discovery rate at
majors
Area for State Improvement
Meets or Exceeds
Expectations
10b Percent of HPVs that
have been have been
addressed or removed
consistent with the HPV
Policy
Meets or Exceeds
Expectations
Area for State Improvement
1 la Penalty calculations
reviewed that document
gravity and economic benefit
Area for State Improvement
Area for State Improvement
12a Documentation of
rationale for difference
between initial penalty
calculation and final penalty
Area for State Improvement
Area for State Improvement
Resource Conservation and Recovery Act (RCRA)
• There were no priority areas to address in the RCRA Subtitle C Program.
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Clean Water Act Findings
CWA Element 1 - Data
Finding 1-1
Meets or Exceeds Expectations
Summary:
The state's permit limit data entry rate exceeded the national goal.
Explanation:
The state's permit limit data entry rate was 100%, above the national goal of 95% and above the national
average of 88.10%>.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
lb5 Completeness of data entry on major and non-
major permit limits. [GOAL]
>95%
88.1%
514
514
100%
CWA Element 1 - Data
Finding 1-2
Area for Attention
Summary:
The state's DMR data entry rate for major and non-major facilities did not meet the national goal.
Explanation:
The state's DMR data entry rate for major and non-major facilities was 77.70%>, below the national goal
of 95% and the national average of 90.60%>. This is due to two things. First, when the state creates permit
modifications it creates a duplicate parameter requirement in ICIS. The other issue is that the state's eDMR
batching system is not sharing with ICIS in all instances. The state has committed to looking to this and
we will discuss on the quarterly calls.
State Response:
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Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
lb6 Completeness of data entry on major and non-
major discharge monitoring reports. [GOAL]
>95%
90.6%
28725
36967
77.7%
CWA Element 1 - Data
Finding 1-3
Area for Improvement
Summary:
ICIS did not contain complete and accurate data for all facilities.
Explanation:
Files reviewed did not meet the data requirements of EPA's NPDES electronic reporting rule (40 CFR 127
- Appendix A) in the following ways: There were three letters of violation (LOVs) that were not entered
into ICIS but were issued. There were fourteen instances where the date for a notice of violation (NOV)
or LOV was not correct in ICIS. There was one inspection where the monitoring data from a spiked sample
was misinterpreted and was logged as a single event violation (SEV) in ICIS. There was one facility that
did not have the latitude or longitude entered into ICIS. There was one facility where the inspection was
not entered into ICIS. There were three inspections that were entered as a reconnaissance with sampling
and audit but these should have been entered as a compliance sampling inspection. There was one
unpermitted facility reviewed and it was determined that the inspection was not entered into ICIS. The
state said that inspections done at any unpermitted facilities were not entered into ICIS. There were two
penalties collected but they were not entered into ICIS. Also, 35 files were reviewed to determine if
required data was reflected in the national data system (ICIS). Only 9 files had complete and accurate data
in the national data system which equates to a state percentage of 25.71. This is significantly below the
national goal of 100%.
State Response:
Recommendation:
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Rec
#
Due Date
Recommendation
1
03/29/2019
Enter enforcement actions from FY17 to present in ICIS and ensure future
enforcement actions are entered into ICIS with the date of the action. Submit
to EPA verification of the FY17 data entry into ICIS and a procedure or
summary of how the state will ensure the dates being entered for enforcement
actions are accurate.
2
10/16/2018
Provide training to staff on the minimum required data elements expected for
all facilities in ICIS. Report to EPA a summary and date of training provided.
WY has been proactive with this recommendation and has met the
requirements. Email shared with EPA on Feb 13, 2019 summarizing training
points that were covered with staff. This recommendation is complete.
3
05/31/2019
Enter inspections of unpermitted facilities into ICIS for FY17 and ensure
future inspections of unpermitted facilities are entered into ICIS. Submit to
EPA verification of the FY17 data entry into ICIS and a procedure or
summary of how the state will ensure the inspections for unpermitted facilities
will be entered into ICIS.
4
02/14/2019
Enter penalties assessed and collected into ICIS for FY17 and ensure future
penalties are entered into ICIS. Submit to EPA verification of the FY17 data
entry into ICIS and a procedure or summary of how the state will ensure
penalties assessed and collected will be entered into ICIS.WY has been
proactive with this recommendation and accomplished this recommendation in
March 2019.
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
2b Files reviewed where data are accurately reflected
in the national data system [GOAL]
J 100%

9
35
25.71%
CWA Element 2 - Inspections
Finding 2-1
Meets or Exceeds Expectations
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Summary:
The state met or exceeded its inspection commitments for majors, non-majors, stormwater construction
and industrial stormwater. The state's inspection reports are generally complete and sufficient to determine
compliance at the facility. The state generally completes inspection reports within the goal set by their
Enforcement Management System (EMS).
Explanation:
The state committed to inspecting 24 majors, 175 non-majors, 10 concentrated animal feeding operations
(CAFOs), 63 stormwater construction sites, and 126 industrial stormwater sites. The state completed the
following inspections: 24 majors, 236 non-majors, 9 CAFOs, 77 stormwater construction sites, and 131
industrial stormwater sites. Inspection reports were concise and well written with appropriate checklists
and supporting information including photographs. The state also samples at every inspection where there
is a discharge which provides more information about compliance during the inspection. Reports for 27
of the 30 inspections reviewed were completed within the 45-day goal in the state's EMS. One observation
to enhance the state's inspection program would be to include in the narrative of the inspection report a
description of each area of the facility that was inspected, which was absent in some reports.
State Response:
Relevant metrics:
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Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State %
4al0 Number of comprehensive inspections of
large and medium concentrated animal feeding
operations (CAFOs) [GOAL]
100
CMS%

9
10
90%
4a8 Number of industrial stormwater inspections.
[GOAL]
100
CMS%

131
126
103.97%
4a9 Number of Phase I and Phase II construction
stormwater inspections. [GOAL]
100
CMS%

77
63
122.22%
5al Inspection coverage of NPDES majors.
[GOAL]
100%
54.2%
24
24
100%
5b 1 Inspections coverage of NPDES non-majors
with individual permits [GOAL]
100%
22%
236
175
134.86%
5b2 Inspections coverage of NPDES non-majors
with general permits [GOAL]
100%
5.9%
208
189
110.05%
6a Inspection reports complete and sufficient to
determine compliance at the facility. [GOAL]
100%

28
30
93.33%
6b Timeliness of inspection report completion
[GOAL]
100%

27
30
90%
CWA Element 2 - Inspections
Finding 2-2
Area for Improvement
Summary:
The state did not meet its commitment for a municipal separate storm sewer system (MS4) audit and has
not been conducting MS4 inspections for several years.
Explanation:
The state committed to performing one MS4 desk audit in FY17, but none were completed. The state
committed to two MS4 desk audits in FY18, but none were completed. There are seven MS4s in the state.
Based on data in ICIS, the state has never inspected an MS4. Expectations for NPDES inspection
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frequencies are set forth in the Clean Water Act National Pollutant Discharge Elimination Compliance
Monitoring Strategy issued in 2014 (CMS). The CMS provides a framework for the EPA to evaluate state
inspection frequencies that do not align with the national goals and flexibilities of the CMS. Although a
stated purpose of the CMS is to better focus inspection resources, the lack of inspection resources focused
by the state on MS4 inspections over time is a concern especially given that a strong MS4 program can
have significant water quality impacts partially due to, among other factors, increased compliance of
construction and industrial stormwater sites within an MS4's jurisdiction.
State Response:
Recommendation:
Rec
#
Due Date
Recommendation
1
10/01/2019
The state should evaluate what resources they have for MS4 inspections and
undertake an analysis of whether the state needs to add or shift resources to
address MS4 inspections. Provide to EPA the analysis, including a timeline for
adding or shifting resources if that is deemed necessary.
2
10/01/2019
Implement the timeline submitted to EPA and provide a report by October 1 of
each year starting in 2019. This recommendation will be considered complete
if no changes are needed as a result of recommendation 1 or when the resource
additions or shifts have been made.
3
10/01/2019
Conduct on-site inspections at a minimum of 20% or 2 of the MS4s in FY19
and FY20. Provide EPA a copy of the inspection reports within 30 days of
completing each inspection report. This recommendation will be considered
complete upon EPA review of the inspection reports and a determination
based on the reports that the scope of the inspections and the findings of the
report are complete and accurate. If a determination is made that the
inspection(s) and the findings of the report(s) in a given year are not complete
and accurate, inspection reports for on-site MS4 inspections shall continue to
be provided to EPA within 30 days of completion each subsequent FY until
such a determination is made.
Relevant metrics:
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Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
4a7 Number of Phase I and IIMS4 audits or
inspections. [GOAL]
100
CMS%

0
1
0%
CWA Element 3 - Violations
Finding 3-1
Meets or Exceeds Expectations
Summary:
The state accurately determined compliance for all the files reviewed.
Explanation:
Thirty of thirty files reviewed indicated that the state accurately identified violations, both for significant
noncompliance and single event violations. The state's percentage for metrics 7kl and 8a3 (see table
below) are a little higher than the national average due to data batching issues that the state and EPA are
working on to resolve.
State Response:
Relevant metrics:
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Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
7e Accuracy of compliance determinations
[GOAL]
100%

30
30
100%
7j 1 Number of major and non-major facilities
with single-event violations reported in the
review year




70
7kl Major and non-major facilities in
noncompliance.

18.5%
540
2614
20.66%
8a3 Percentage of major facilities in SNC
and non-major facilities Category I
noncompliance during the reporting year.

7.5%
239
2611
9.15%
CWA Element 4 - Enforcement
Finding 4-1
Area for Attention
Summary:
The state generally addressed violations in an appropriate manner according to their EMS, but there were
eight instances where this was not the case.
Explanation:
EPA used WY's EMS guidance to evaluate their state program performance. EPA found the EMS
Guidance at least as stringent as the NPDES EMS. The following are instances where enforcement did
not address violations in an appropriate manner: One facility had significant noncompliance (SNC)
violations in all four quarters of FY2017 for effluent limit violations of the chlorine limit. The state did
not take any formal enforcement action. The state's Enforcement Management System (EMS) states that
continuing effluent limit violations warrant a NOV or referral to the attorney general. An illicit discharge
was noted for a facility in a March 2, 2017 inspection and the NOV was sent on June 27, 2017, which did
not meet the 60-day goal of the EMS. (Turner). A LOV was issued to a facility on June 15, 2017, but the
facility did not comply. The state's EMS states that a second LOV or NOV should have been sent within
60 days. The state did not issue a second LOV or a NOV. For one facility, a LOV was issued on November
7, 2016, based on a records review during an inspection but the source did not respond until January 17,
2017. If the facility does not respond within the 30 days allowed by the LOV, the state's EMS states that
a second LOV should have been sent 60 days from the date of the violation. The state did not issue a
second LOV. For one facility, there was an exceedance of the pH limit in the first quarter of FY17 but
there was no LOV sent by the state. The state's EMS states that for even minor effluent violations, a LOV
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will be sent. For one facility, the state issued a LOV dated April 25, 2017 that addressed the previous
year's exceedances for biochemical oxygen demand (BOD), nitrogen and e. coli. The state's EMS states
that a LOV should be issued for minor or infrequent/isolated violations within 30 days. The state's EMS
also states that for continuing violations like these, an NOV or referral is appropriate. Note that a similar
letter was sent to the facility for similar exceedances on December 1, 2014. One facility had BOD
violations beginning in the summer of 2016 continuing through September 2017, including three quarters
of Category I non-compliance. The state has not issued any enforcement action. The state's EMS states
that at least a LOV should have been issued. The facility is on record for undergoing a system upgrade,
but operational problems have been recurrent and ongoing. One facility was issued a LOV on March 23,
2016 but did not respond. The state should have sent a second LOV per its EMS within 60 days but did
not do so. The table below shows that for metric lOal, the state had 0% of eleven major facilities with
formal enforcement taken in response to SNC violations. These SNC violations were all DMR non-receipt
violations. The state looked into this and determined that for three of the facilities when late DMR data is
entered into the state's database (WYPDES) this data is uploaded to ICIS during the nightly batch loads.
However, since ICIS has already determined a SNC violation even if the data does upload to ICIS the
SNC violation is not resolved. It appears the state would have to manually resolve the SNC violation in
ICIS, because violations are not linked to data in WYPDES, therefore, without the possibility of linking
violations to data in WYPDES, ICIS sees the missing data entered but cannot resolve the SNC violation
for lack of linked data to the late violation. For three of the facilities, WYPDES shows that all DMRs were
submitted on time but this is not reflected in ICIS. For two facilities, the state indicated there is something
wrong with the electronic submittals for these facilities as they are in SNC status in eDMR. The state and
EPA are working to resolve the data transfer issues. For the facilities that had late DMRs, the state did call
the facility or issued a LOV per the goals of the state's EMS.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
lOal Percentage of major NPDES facilities with
formal enforcement action taken in a timely manner
in response to SNC violations

14.3%
0
11
0%
10b Enforcement responses reviewed that address
violations in an appropriate manner [GOAL]
100%

25
33
75.76%
CWA Element 4 - Enforcement
Finding 4-2
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Meets or Exceeds Expectations
Summary:
The state had enforcement actions that directed facilities to come back into compliance or to start
complying with requirements.
Explanation:
All of the files reviewed demonstrated that the state's enforcement actions directed facilities on how to
come back into compliance or to start complying with requirements. The state included a date by which
compliance must be achieved.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
9a Percentage of enforcement responses that returned, or
will return, a source in violation to compliance [GOAL]
100%

29
29
100%
CWA Element 5 - Penalties
Finding 5-1
Meets or Exceeds Expectations
Summary:
The state's penalty calculations documented and included gravity and economic benefit, documented the
rationale for the difference between the initial penalty and final penalty, and documented proof that
penalties were collected.
Explanation:
For the four files reviewed that had a penalty action, all of the calculations included gravity and economic
benefit (Saratoga, Turner Sands, Sheep Creek, and River Road CBM). For two of the files, the state did
not collect the penalty for which the reason why was documented. The reason for one facility was that
they went out of business and for the other facility, the state allowed the facility to use the money to fix
the issue and come back into compliance. For the other two files, the penalty was collected and
documented.
State Response:
19

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Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
1 la Penalty calculations reviewed that document and
include gravity and economic benefit [GOAL]
100%

4
4
100%
12a Documentation of rationale for difference between
initial penalty calculation and final penalty [GOAL]
100%

2
2
100%
12b Penalties collected [GOAL]
100%

2
4
50%
20

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Clean Air Act Findings
CAA Element 1 - Data
Finding 1-1
Area for Improvement
Summary:
The state achieved timely reporting for HPVs in 70% (7 out of 10) HPVs entered into ICIS Air.
Explanation:
WDEQ enters HPV information into ICIS AIR after an NOV is issued. In some cases, more information
and more time may be needed in order to determine the status of compliance at a facility; therefore, the
HPV may be considered untimely depending on how long the process of gathering information takes.
State Response:
AQD enters information into ICIS at the final step in the process of the determination of HPVs, which is
when final signatures are affixed to the NOV. The metric does not accurately reflect how the Wyoming
Air Quality Division operates.
Recommendation:
Rec
#
Due Date
Recommendation
1
10/01/2019
An audit should be performed on all recent HPVs and an ICIS Air report
should be sent to EPA by August 1, 2019 demonstrating that recent HPVs
have achieved timely reporting corrections that will be reviewed by EPA
within 60 days of receipt or October 1, 2019, at the latest.
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
3a2 Timely reporting of HPV determinations [GOAL]
100%
40.5%
7
10
70%
CAA Element 1 - Data
21

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Finding 1-2
Meets or Exceeds Expectations
Summary:
The state achieved timely reporting of compliance monitoring MDRs into ICIS Air for 92% of files
reviewed. The state achieved timely reporting of stack tests and stack test results into ICIS Air for 90.9%
of reports reviewed. The state achieved timely reporting of enforcement MDRs into ICIS Air for 94% of
reports reviewed.
Explanation:
The state is doing well at timely reporting of information into ICIS Air. WDEQ has inspectors that review
stack test reports and timely entered that information into ICIS AIR.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
3b 1 Timely reporting of compliance monitoring
MDRs [GOAL]
100%
82.3%
176
191
92.15%
3b2 Timely reporting of stack test dates and results
[GOAL]
100%
67.1%
241
265
90.94%
3b3 Timely reporting of enforcement MDRs
[GOAL]
100%
77.6%
16
17
94.12%
CAA Element 1 - Data
Finding 1-3
Area for Improvement
Summary:
Data entered into the national compliance database needs improvement.
Explanation:
A comparison of information in the files with data from the ICIS database revealed some deficiencies in
data entry of the Minimum Data Requirements. Some of the Address-field information was inaccurate,
22

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for example, no street address or mailing address, counties listed as the city, incorrect zip codes listed as
99999. EPA realizes the rural nature of many of these facilities; however, section-township/range or
latitude/longitude coordinates could be used to better identify the location of these facilities.
State Response:
As Region 8 is aware, Wyoming is the 9th largest state in the nation with the lowest population, thus the
majority of the industrial facilities are located in rural areas that do not have postal service or street
addresses. Some Wyoming counties are larger than some east coast states, therefore it is inaccurate to use
a postal zip code. Recognizing the need to identify the location of facilities, the Division previously came
to an agreement with Region 8 staff to use 99999 and county names when no postal zip code or city were
applicable. After receiving the preliminary draft SRF, the Division performed an audit and updated the
facility information with the section-township-range or latitude/longitude coordinates.
Recommendation:
Rec
#
Due Date
Recommendation
1
10/01/2019
The state should correct any inaccurate Address-field information by
providing either a street address or section-township/range or
latitude/longitude coordinates. An audit should be performed of all facilities
and an ICIS Air facility report should be sent to EPA by August 1, 2019
demonstrating the corrections that will be reviewed by EPA within 60 days of
receipt or October 1, 2019, at the latest.
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
	<
2b Files reviewed where data are accurately reflected
in the national data system [GOAL]
100%

15
27
55.56%
CAA Element 2 - Inspections
Finding 2-1
Meets or Exceeds Expectations
Summary:
23

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The state achieved FCE Coverage of Majors and Mega-sites with results entered into ICIS Air for 100%
of inspections conducted. The state achieved FCE Coverage of SM-80s with results entered into ICIS Air
for 100% of inspections conducted. The state reviewed Title V Annual Compliance Certifications with
results entered into ICIS Air for 98.2% of the certifications. The state achieved appropriate documentation
of the FCE Elements for 95.8% of FCEs reviewed. The state had appropriate information for compliance
determination for 95.8% of Compliance Monitoring Reports (CMRs) reviewed.
Explanation:
The state has done well at conducting FCEs and reviewing Annual Certifications.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
5a FCE coverage: majors and mega-sites [GOAL]
100%
88.7%
60
60
100%
5b FCE coverage: SM-80s [GOAL]
100%
93.7%
8
8
100%
5c FCE coverage: minors and synthetic minors (non-
SM 80s) that are part of CMS plan or alternative
CMS Plan [GOAL]


0
0
0
5e Reviews of Title V annual compliance
certifications completed [GOAL]
100%
76.7%
107
109
98.17%
6a Documentation of FCE elements [GOAL]
100%

23
24
95.83%
6b Compliance monitoring reports (CMRs) or
facility files reviewed that provide sufficient
documentation to determine compliance of the
facility [GOAL]
100%

23
24
95.83%
CAA Element 3 - Violations
Finding 3-1
Meets or Exceeds Expectations
24

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Summary:
The FRV discovery rate based on inspections at active CMS sources was 6.9% and the HPV discovery
rate at majors was 7.8%. The state achieved Timeliness of HPV Identification with results entered into
ICIS Air 100%) of the time. The state achieved accurate compliance determinations for 100%> of CMRs
reviewed. The state achieved accurate HPV determinations for 100%> of HPVs reviewed.
Explanation:
The state has done well with HPVs identifications and determinations as well as compliance
determinations for CMRs. The air staff at WDEQ are aware and knowledgeable of the FRV and HPV
policies. They are fully implementing them as well.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
13 Timeliness of HPV Identification [GOAL]
100%
87.7%
9
10 90%
7a Accurate compliance determinations [GOAL]


29
29 100%
7al FRV discovery rate based on inspections at active
CMS sources

6.2%
10
145 | 6.9%
8a HPV discovery rate at majors

2.3%
10
128
7.81%
8c Accuracy of HPV determinations [GOAL]


15
15
100%
CAA Element 4 - Enforcement
Finding 4-1
Meets or Exceeds Expectations
Summary:
The state addressed HPVs within 180 days for 100%> of HPVs reviewed. The state achieved corrective
action to return to compliance in a specified timeframe for 100% of reviewed enforcement actions. The
state achieved timeliness of addressing HPVs 100%> of reviewed HPVs. The state achieved HPV Case
Development and Resolution Timeline with required policy elements for 100% of reviewed HPVs. The
Rate of managing HPVs without formal enforcement action was 0% (0 out of 9).
25

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Explanation:
The state has done well with numerous aspects of HPVs, see the Summary above for Finding 4-1.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
10a Timeliness of addressing HPVs or alternatively
having a case development and resolution timeline in
place
100%

15
15
100%
lOal Rate of Addressing HPVs within 180 days

63.7%
9
9
100%
lObl Rate of managing HPVs without formal
enforcement action

12.9%
0
9
0%
	1
14 HPV case development and resolution timeline in
place when required that contains required policy
elements [GOAL]
100%

11
11
100%
9a Formal enforcement responses that include required
corrective action that will return the facility to
compliance in a specified time frame or the facility
fixed the problem without a compliance schedule
[GOAL]
100%

15
15
100%
CAA Element 4 - Enforcement
Finding 4-2
Area for Improvement
Summary:
The state achieved appropriate enforcement responses for 33% (5 out of 15) of the reviewed HPVs.
Explanation:
26

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After reviewing the ECHO website, it appeared that 10 of the 15 HPVs were still showing as active or
ongoing HPVs. Most of the HPVs still showing in ECHO as active were near the end of the enforcement
process, or near closure by the Attorney General's (AG) office. The AG's office was short staffed and
therefore, closure of the enforcement actions was taking longer than usual.
State Response:
Under state law and practice, an NOV remains open until all payments are received, injunctive relief is
completed, and the court has dismissed the case. The specific 10 facilities of concern were provided to the
Division on Dec. 12, 2018 and were addressed in a response on Jan. 3, 2019. Since the time of the SRF,
one correction to a facility enforcement status has been made in ICIS and four additional NOVs were
closed between Aug. 13 and Dec. 7, 2018.
Recommendation:
Rec
#
Due Date
Recommendation
1
10/01/2019
The state should review the ICIS AIR database for HPVs. If there are HPVs
that have been closed, but are listed as ongoing, please update in the ICIS AIR
database to better reflect the current status of HPVs. EPA will review the ICIS
Air database to see that the status of HPVs are up to date prior to October 1,
2019.
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
10b Percent of HPVs that have been have been
addressed or removed consistent with the HPV Policy
[GOAL]
100%

5
15
33.33%
CAA Element 5 - Penalties
Finding 5-1
Area for Improvement
Summary:
27

-------
The state showed penalty calculations documenting gravity and economic benefit in 0% of cases reviewed.
The state showed documented rationale for difference between initial and final penalty calculations in 0%
of cases reviewed.
Explanation:
The state did not allow access to the documents for the calculation and assessment of penalty. No penalty
calculation worksheet or summary was observed. EPA was not allowed access to any documentation that
showed whether economic benefit was sought, or whether gravity was factored into the penalty amount
proposed. Therefore, EPA was unable to determine if there was a justification for the difference between
initial proposed penalty and final penalty. WDEQ noted that the state of Wyoming has state statutes that
consider penalty settlements and related information to be confidential.
State Response:
The Division uses the CAA civil penalty policy initially in calculating monetary settlement amounts. In
each calculation, AQD takes into account economic benefit, looking at such factors as how much an entity
saved during their time of non-compliance (e.g. not having a permit or conducting required testing).
Stipulated settlement amounts are considered to be confidential settlement negotiations. Wyoming state
statute 35-11-90 l(a)(ii) states "Penalties and injunctive relief under this subsection are to be determined
by a court of competent jurisdiction in a civil action, provided that nothing herein shall preclude the
department from negotiating stipulated settlements involving the payment of a penalty, implementation
of compliance schedules or other settlement conditions in lieu of litigation."
Recommendation:
Rec
#
Due Date
Recommendation
1
10/01/2019
The state should routinely document penalty calculations, including initial
proposed penalty and final assessed penalty. The state should explain any
differences between the initial and final penalty amounts. The penalty
documentation should routinely include the calculation of economic benefit
and a gravity component. If economic benefit is excluded, a rationale should
be provided. EPA recommends the state create a penalty calculation worksheet
that records all the basic elements of the penalty for enforcement actions. The
written penalty worksheet will help ensure penalty amounts are fair,
predictable, and appropriate. The worksheet need not be lengthy but must
contain sufficient information for an EPA evaluation. A general penalty
worksheet and explanation would give EPA the fundamental information as to
how the state calculates penalties. Please provide by August 1, 2019. EPA will
review the general penalty worksheet and explanation thereof, and provide
comments by October 1, 2019.
Relevant metrics:
28

-------
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
1 la Penalty calculations reviewed that document gravity
and economic benefit [GOAL]
100%

0
7
0%
12a Documentation of rationale for difference between
initial penalty calculation and final penalty [GOAL]
100%

0
7
0%
CAA Element 5 - Penalties
Finding 5-2
Area for Attention
Summary:
The state showed penalty collected in 85.7% of cases reviewed.
Explanation:
In the one case where WDEQ did not assess a penalty, compliance discretion was used because of
circumstances surrounding the issue of non-compliance. Some of the circumstances include: the
equipment had been received, but not operated, prior to the air permits being final; and facility was a
government run facility.
State Response:
Division records indicate that a monetary settlement amount is collected on HPVs. The Division does not
collect a monetary settlement on NOVs with Order (when the desired result is for a timely correction to
the violation). The Division had one case with an NOV and Order. AQD personnel incorrectly entered the
closure in ICIS. EPA provided AQD with assistance on the entry, and the entry was corrected in ICIS.
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
12b Penalties collected [GOAL]
100%

6
7
85.71%
29

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Resource Conservation and Recovery Act Findings
RCRA Element 1 - Data
Finding 1-1
Meets or Exceeds Expectations
Summary:
All of the data elements required to be entered into RCRAInfo had been entered in a timely and accurate
fashion for the 41 files reviewed by EPA.
Explanation:
The mandatory data was complete and accurate.
State Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
2b Accurate entry of mandatory data [GOAL]
100%

41
41
100%
RCRA Element 2 - Inspections
Finding 2-1
Meets or Exceeds Expectations
Summary:
The state meets or exceeds the national goals for all inspection coverage areas.
Explanation:
The state does an excellent job of LQG inspections, with an annual inspection coverage for BR LQGs of
40.90% compared to a national average of 16.10%. They also had a 25% annual inspection coverage for
active LQGs. Additionally, the state met the TSDF requirement by inspecting the two operating TSDFs
in the state. Inspection reports are timely and thorough allowing appropriate violation determination.
State Response:
Relevant metrics:
30

-------
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
5a Two-year inspection coverage of operating
TSDFs [GOAL]
100%
88.1%
2
2
100%
5b Annual inspection of LQGs using BR universe
[GOAL]
20%
16.1%
9
22
40.91%
5b 1 Annual inspection coverage of LQGs using
RCRAinfo universe [GOAL]
20%
10.7%
10
40
25%
5d I Number of SQGs inspected




12
5e5 One-year count of very small quantity
generators (VSQGs) with inspections [GOAL]




62
5e6 One-year count of transporters with inspections
[GOAL]




5
5e7 One-year count of sites not covered by metrics
5a - 5e6 with inspections [GOAL]




57
6a Inspection reports complete and sufficient to
determine compliance [GOAL]
100%

33
33
100%
6b Timeliness of inspection report completion
[GOAL]
100%

33
33
100%
RCRA Element 3 - Violations
Finding 3-1
Meets or Exceeds Expectations
Summary:
The state accurately identifies violations in their inspection reports and enters these in the national
database. There were no SNCs identified during this review period which included prior years.
Explanation:
31

-------
The state accurately identifies violations. Inspection reports document the violations, allowing accurate
compliance determination.
Stale Response:
Relevant metrics:
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
2a Long-standing secondary violators


10

10
7a Accurate compliance determinations [GOAL]
100%

32
32
100%
7b Violations found during CEI and FCI inspections

34.9%
51
140
36.43%
8a SNC identification rate at sites with CEI and FCI

1.5%
0
269
0%
8b Timeliness of SNC determinations [GOAL]
100%
84.9%
0
0
0
8c Appropriate SNC determinations [GOAL]
100%

15
15
100%
RCRA Element 4 - Enforcement
Finding 4-1
Meets or Exceeds Expectations
Summary:
The state takes timely and appropriate enforcement actions to address identified violations. The state
requires corrective measures to return facilities to compliance and follows up through required submittals
or onsite inspections to verify return to compliance has occurred.
Explanation:
Seven informal actions and eight formal actions were reviewed as part of this SRF. The enforcement
actions returned violators to compliance. The enforcement actions were timely and appropriate for the
violations identified.
State Response:
Relevant metrics:
32

-------
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
10a Timely enforcement taken to address SNC
[GOAL]
80%
81.1%
0
0
0
10b Appropriate enforcement taken to address
violations [GOAL]
100%

15
15
100%
9a Enforcement that returns sites to compliance
[GOAL]
100%

15
15
100%
RCRA Element 5 - Penalties
Finding 5-1
Meets or Exceeds Expectations
Summary:
The state appropriately assesses penalties, when warranted, and considers collection of both a gravity and
economic benefit component. The penalty collection, including performance of a supplemental
environmental project, is documented.
Explanation:
Eight penalties were collected for the review period evaluated. Four of these were tied to an earlier
settlement. The other four penalties considered both the gravity and economic benefit of the violations.
State Response:
Relevant metrics:
33

-------
Metric ID Number and Description
Natl
Goal
Natl
Avg
State
N
State
D
State
%
11 a Gravity and economic benefit [GOAL]
100%

8
8
100%
12a Documentation of rationale for difference between
initial penalty calculation and final penalty [GOAL]
100%

1
1
100%
12b Penalty collection [GOAL]
100%

8
8
100%
34

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8
1595 Wynkoop Street
Denver, CO 80202-1129
Phone 800-227-8917
www.epa.gov/region8
March 15, 2018
Ref: 8ENF-PJ
Mr. Todd Parfitt, Director
Department of Environmental Quality
122 W. 25th Street
Cheyenne, Wyoming 82002
Re: 2018 State Review Framework Inspection of Fiscal Year 2017
Dear Mr. Parfitt:
It was nice to connect recently during the oil and gas meetings at our regional office. As an integral part
of our U.S. Environmental Protection Agency - State of Wyoming partnership, Region 8 will be
conducting a State Review Framework (SRF) review of the Wyoming Department of Environment
Quality (WY DEQ) this year. Specifically, the EPA will be looking at the Resource Conservation and
Recovery Act (RCRA) Subtitle C, Clean Water Act (CWA) National Pollutant Discharge Elimination
System (NPDES) and Clean Air Act (CAA) Stationary Source enforcement programs in 2018. We will
review inspection and enforcement activity from fiscal year 2017.
An important part of the review process is the visit to your state agency office. Through this visit, which
will likely take place in May or June (to be scheduled), the EPA can have face-to-face discussions with
enforcement staff and review their respective files to better understand the overall enforcement program.
State visits for these reviews will include:
•	discussions between Region 8 and WY DEQ program managers and staff;
•	examination of data in EPA and WY DEQ data systems; and,
•	review of selected WY DEQ inspection and enforcement files and policies.
Following our visit to your office, the EPA will summarize findings and recommendations in a draft
report. Your management and staff will be provided with an opportunity to review and comment on this
draft by late summer. The EPA expects to complete the WY DEQ review, including the final report, by
April 30, 2019. If any areas for improvement are identified in the SRF, we will work with you to address
them in the most constructive manner possible. Region 8 and WY DEQ are partners in carrying out the
review, and we intend to assist you in meeting both federal standards and goals agreed to in WY DEQ's
Performance Partnership Agreement.
Region 8 has established a cross-program team of managers and senior staff to implement the WY DEQ
review. David Piantanida, SRF Coordinator at (303) 312-6200, will be your primary contact at Region 8
35

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and will coordinate overall logistics for the EPA. I am Region 8's senior manager with overall
responsibility for the review. We request that you also identify a primary contact person for the EPA to
work with and provide that name to Mr. Piantanida. The Region 8 program leads on the 2018 SRF
review team are:
Linda Jacob son
Laurel Dygowski
Mike Boeglin
Scott Whitmore
RCRA	(303)312-6503
NPDES (Lead) (303)312-6144
NPDES
CAA
(303)312-6250
(303) 312-6317
jacobson.linda@epa.gov
dygowski.laurel@epa.gov
boeglin.michael@epa.gov
whitmore.scott@epa.gov
These program leads will be contacting WY DEQ enforcement managers and staff to schedule a meeting
to discuss expectations, lessons learned from previous reviews, procedures and scheduling for the
review. The EPA will also send its analysis of the SRF data metrics and list of selected facility files prior
to the on-site visit. General SRF review planning and logistics steps can be found in the attachment.
Other documents used to evaluate the state's programs can be found on the EPA's ECHO website at
https://echo.epa.gov/. Links to past SRF reports and recommendations can be found at the EPA's State
Review Framework web page at http://www.epa.gov/compliance/state/srf/.
Please do not hesitate to contact me at (303) 312-6925, or have your staff contact David Piantanida
(piantanida.david@epa.gov) at (303) 312-6200 with any questions about this review process. We look
forward to working with you on the 2018 SRF review, and furthering our critical EPA-State partnership.
Sincerely,
Suzanne J. Bohan
Assistant Regional Administrator
Office of Enforcement, Compliance
and Environmental Justice
Enclosure
cc: Via email
Elizabeth Walsh, Headquarters SRF Liaison
Office of Compliance, OECA
Doug Benevento, Regional Administrator
Region 8
Deb Thomas, Deputy Regional Administrator
Region 8
Kim S. Opekar, Deputy Assistant Regional Administrator
Enforcement, Compliance and Environmental Justice - Region 8
David Piantanida, SRF Coordinator
Enforcement, Compliance and Environmental Justice - Region 8
36

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Attachment
WY DEQ SRF Review Planning & Logistics
As the EPA begins this review process, WY DEQ can expect the following:
•	The EPA will contact WY DEQ enforcement managers and staff to schedule a meeting or
conference call to discuss expectations, procedures and scheduling for the review if this
has not already occurred.
•	The EPA may ask for preliminary information that is readily available such as
descriptions of agency and program structures, agency enforcement policies, staffing
numbers and other organizational information.
•	The EPA will send WY DEQ a list of data metrics and conduct a data metric analysis.
•	The EPA will send WY DEQ a list of requested files for review at least two weeks in
advance of onsite file reviews.
•	The EPA will set up a call with WY DEQ to verify that files in the EPA's requested file
list will be available; where the files will be located; and to confirm review dates, arrival
times, and logistics.
•	The EPA will conduct an entrance conference for the review upon arrival at the WY
DEQ offices and an exit meeting for WY DEQ managers and staff prior to the EPA's
departure. It is possible that the RCRA file review will be conducted remotely.
•	The EPA will draft a report of its review findings, share the draft report with WY DEQ,
and request comments.
•	Once the report is final, the EPA will add the report, and any recommendations in the
report, to the SRF Tracker.
•	Once the report is final, the EPA will consult with the state and add agreed-upon action
items in the report to the Action Item database.
The EPA will initiate periodic follow-up discussions with WY DEQ to monitor progress on
report recommendations.
37

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