STATE REVIEW FRAMEWORK

Pennsylvania
Philadelphia Air Management Services

Clean Air Act
Implementation in Federal Fiscal Year 2020

U.S. Environmental Protection Agency

Region 3

Final Report
March 22, 2022


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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.

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A.	Metrics

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

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specific actions and a schedule for completion, and their implementation is monitored by the
EPA until completion.

III. Review Process Information

Clean Air Act (CAA)

Dates of Virtual File Review: August 23-26, 2021

Environmental Protection Agency (EPA) contacts include:

Enforcement and Compliance Assurance Division
Erin Malone, Air Inspector & State Liaison (Lead)

Kurt Eisner, Senior Environmental Engineer
Carly Joseph, Air Inspector
Isabella Powers, Air Inspector

Air and Radiation Division
Riley Burger, Permit Specialist

Air Management Services (AMS) contacts include:

Thomas Barsley, Chief for Facility, Compliance & Enforcement

Daniel Henkin, Engineering Supervisor


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Executive Summary

Areas of Strong Performance

The following are aspects of the program that, according to the review, are being implemented at
a high level:

Clean Air Act (CAA)

•	The EPA Review Team found AMS's ICIS-Air data entry to be timely for compliance
and enforcement minimum data requirements (MDRs) as well as stack tests and stack test
results.

•	AMS's inspection program conducted all full compliance evaluations (FCEs) committed
for major, mega, and synthetic minor 80% (SM-80) sources1. Compliance Monitoring
Reports (CMRs) reviewed provided sufficient documentation to determine compliance
and the EPA Review Team commented that the CMRs were well-written, organized, and
thorough.

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 Air Act (CAA)

•	While data has been entered timely, as described above, the EPA Review Team found
inaccurate data entered into ICIS-Air throughout the file review process. Inaccuracies
were noted for Title V Annual Compliance Certifications, stack test results, penalty
amounts, and formal enforcement actions.

•	AMS's enforcement actions did not consistently include corrective actions (e.g.,
injunctive relief or demonstration of compliance) to return the facility to compliance. A
majority of the enforcement actions reviewed were penalty-only orders with nearly 20%
of the actions not achieving or documenting compliance prior to close out of the action.

•	AMS's penalty matrix does not include a section for an economic benefit component.
All penalty calculations reviewed included a gravity component, however, an economic
benefit component was not included in the matrix.

1 AMS conducted virtual inspections in FY2020 per the Susan Bodine memo titled Recommended Processes for
Adjusting Inspection Commitments Due to the COVID-19 Public Health Emergency dated July 22, 2020.

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Clean Air Act Findings

CAA Element 1 - Data

Finding 1-1

Meets or Exceeds Expectations

Recurring Issue:

No

Summary:

AMS entered all compliance monitoring minimum data requirements (MDRs), stack tests, and
stack test results into ICIS-Air in a timely manner. Greater than 95% of FY2020 enforcement
MDRs were entered timely into ICIS-Air. Furthermore, two of the three late enforcement MDRs
were late by just two days. AMS did not have any HPVs in FY2020 or FY2019, therefore, the
EPA Review Team looked at FY2016, FY2017, and FY2018 data to evaluate HPV timeliness.
This supplemental review indicated that AMS entered all HPVs into ICIS-Air in a timely manner.

Explanation:

AMS demonstrated that their data is entered timely into ICIS-Air on a consistent basis. The data
metric analysis found that 100% of the 62 MDRs were timely reported to ICIS-Air. Likewise,
AMS also timely reported their stack tests and stack test results into ICIS-Air 100% of the time
for FY2020. Lastly, AMS timely entered greater than 95% of FY2020 enforcement MDRs into
ICIS-AIR. There were only three late entries for metric 3b3 for FY2020 and two of the three were
merely two days late. AMS did not identify any HPVs in FY2020 so metric 3a2 could not be
evaluated for FY2020. However, AMS had identified a total of three HPVs in FY2016, FY2017,
and FY2018. All three of the HPVs identified were timely reported to ICIS-Air. Therefore, the
complete evaluation of metric 3a2 is that AMS meets or exceeds expectations.

The EPA Review Team evaluated 32 FRVs from FY 2020 to ensure that none of them should have
been elevated to HPV status. The team determined that all 32 FRV case files reviewed were
accurately determined not to be HPVs. Therefore, there were no HPVs to enter in relation to metric
3a2.

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Relevant metrics:

Metric ID Number and Description

Natl
Goal

Natl

Avg

State

N

State
D

State
Total

3a2 Timely reporting of HPV determinations
[GOAL]

100%

40.6%

0

0

N/A

3b 1 Timely reporting of compliance
monitoring MDRs [GOAL]

100%

74.3%

62

62

100%

3b2 Timely reporting of stack test dates and
results [GOAL]

100%

59.4%

33

33

100%

3b3 Timely reporting of enforcement MDRs
[GOAL]

100%

76.3%

64

67

95.5%

AMS Response:

AMS agrees with EPA findings and will strive to maintain timely data entry.

CAA Element 1 - Data

Finding 1-2

Area for Improvement

Recurring Issue:

Recurring from Rounds 2 and 3

Summary:

During the file review, the EPA Review Team found that only one third of files reviewed had
completely accurate MDR data in ICIS-Air.

Explanation:

The EPA Review Team found that only 35% of the facility files had completely accurate MDR
data entered into ICIS-Air. It should be noted that this was identified through the file review
portion of the SRF where the EPA Review Team compared the actual file to what was entered in
ICIS-Air. While the Data Metric Analysis found that the data was entered timely, as described in

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Finding 1-1, the file review identified the data entered was inaccurate. Although this is an
improvement from Rounds 2 and 3, it is still a significant issue with AMS's reporting of
compliance and enforcement activities to ICIS-AIR. Some of the issues that the EPA Review Team
found in Round 4 include:

•	Title V Annual Compliance Certification received and reviewed dates in ICIS-Air were
not aligned with the dates in the facility file;

•	Overdue stack test results showing as "pending" in ICIS-Air (the CMS Policy requires that
the date and result of all stack tests are entered into ICIS-Air within 120 days of completion
of the test. Timeliness was met, but data accuracy was not);

•	Assessed penalty amounts not entered into formal enforcement action case files in ICIS-
Air; Issued date of formal enforcement actions incorrectly listed as date the penalty was
paid in ICIS-Air; and

•	Some formal enforcement actions missing entirely from ICIS-Air.

AMS has experienced a loss of institutional knowledge over the past few years due to staff
turnover. Over the last few years since Round 3, AMS lost 14 experienced staff and managers that
were familiar with MDRs and ICIS-Air entry. Currently, AMS does not have a dedicated staff
person to enter MDRs into ICIS-Air and each inspector is responsible for entering their own data.
The limitations of new and inexperienced staff with ICIS-Air is causing data deficiencies. EPA
Region 3 generally recommends that one or two staff people act as gatekeepers to ensure ICIS-Air
data is entered timely, accurately, and consistently.

Entering accurate MDR data has been a historical issue for AMS. In Round 2, AMS was found not
to have accurately entered data for stack test results into the data system. Additionally, only 14%
of the files reviewed had accurate compliance monitoring and enforcement data in the data system.
In Round 3, less than 20% of the facilities reviewed were found to have completely accurate MDR
data in ICIS-Air when compared to the files.

Relevant metrics:

.. , . .. , . ,,	Natl Natl State State State

Metric ID Number and Description	„ ,	... _ < , ,

1	Goal Avg N D Total

2b Files reviewed where data are accurately
reflected in the national data system [GOAL]

100%	I 11 f 31

35.5%

AMS Response:

AMS agrees with EPA findings. AMS will follow EPA recommendations to reach the target of
minimum 85% accuracy.

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Recommendation:

U"' Due Dale

#

Recommendation

1 | 05/01/2022

No later than 60 days from final report issuance, AMS to provide
names of staff to EPA that will be dedicated to ICIS-Air entry and
quality control. EPA to provide ICIS-Air training for selected AMS
staff to be trained in entering data into ICIS-Air.

2 | 10/01/2022

After the first full quarter of implementation of the new data entry
procedures, EPA will review a representative number of files to
confirm that appropriate data is being accurately entered into ICIS-Air
with a result of 85% for metric 2b. Files will be reviewed at 6 months,
9 months, and 12 months following the ICIS-Air training.

CAA Element 2 - Inspections

Finding 2-1

Meets or Exceeds Expectations

Recurring Issue:

No

Summary:

AMS met the negotiated frequency for compliance evaluations of the Compliance Monitoring
Strategy (CMS). Additionally, all Compliance Monitoring Reports (CMRs) reviewed provided
sufficient documentation to determine facility compliance and document the Full Compliance
Evaluations (FCEs) elements. The EPA Review Team found that the CMRs were well-written,
organized, and thorough. AMS also reviewed all of the Title V Annual Compliance Certifications
(TVACCs) that were scheduled to be reviewed in FY2020.

Explanation:

Element 2 analyzes the file and data metrics regarding inspections to ensure that FCEs contain the
required documentation, CMRs have sufficient documentation to determine compliance, all major
and SM-80 sources on the CMS plan had an FCE in FY2020, and that all TVACCs due to be
submitted and reviewed in FY2020 were in fact submitted and reviewed. In all of these metrics,
AMS scored 100% for FY2020 achieving a level of meets or exceeds expectations for metrics
under Element 2.

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Metrics 5a and 5b ensure that all of the committed major and SM-80 sources on the CMS Plan had
completed FCEs during FY2020. AMS completed all CMS commitments for compliance
evaluations for major and SM-80 sources in FY2020. Metric 5c is not applicable to AMS as they
do not have an Alternative CMS plan. The final data metric for Element 2, Metric 5e, is to ensure
that all TVACCs that are due are received and reviewed. AMS reviewed all 28 TVACCs due to
be submitted and reviewed in FY2020.

The file review metrics for Element 2 are to ensure that all of the FCE elements are documented
(metric 6a) and that the CMRs and facility files provide sufficient documentation to determine
compliance of the facility (metric 6b). The EPA Reviewer Team found that all of the FCE elements
were well documented in the inspection reports and that there was sufficient documentation to
determine compliance of the facilities reviewed.

In FY2020, AMS conducted 13 FCEs at major sources, of which eight were conducted as off-site
FCEs per the Susan Bodine memo2. AMS also conducted three FCEs at SM-80 sources, of which
one was completed off-site per the Susan Bodine memo. Off-site activities included but are not
limited to:

•	A thorough prescreening review of facility file and records, including reports, emission
inventories, CEMs data, etc,

•	Extensive telephone interviews and discussions with facility representative,

•	Requesting and reviewing all records required to document facility compliance with
operating permit, and

•	Photographic documentation where necessary for additional verification.

2 AMS conducted virtual inspections in FY2020 per the Susan Bodine memo titled Recommended Processes for
Adjusting Inspection Commitments Due to the COVID-19 Public Health Emergency dated July 22, 2020

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Relevant metrics:











Metric ID Number and Description

Natl
Goal

Natl

Avg

State

N

State
D

State
Total

5a FCE coverage: majors and mega-sites
[GOAL]

100%

85.7%

13

13

100%

5b FCE coverage: SM-80s [GOAL]

100%

93.6%

3

3

100%

5e Reviews of Title V annual compliance
certifications completed [GOAL]

100%

82.8%

28

28

100%

6a Documentation of FCE elements [GOAL]

100%



19

19

100%

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

100%



19

19

100%

AMS Response:

AMS agrees with EPA finding.

CAA Element 3 - Violations

Finding 3-1

Meets or Exceeds Expectations

Recurring Issue:

No

Summary:

AMS made accurate compliance and HPV determinations.

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Explanation:

Since FY2015, AMS has been consistently above the national average for data indicator metric
7al (FRV 'discovery rate' based on inspections at active CMS sources). Therefore, no
supplemental files were pulled.

Regarding accurate compliance determinations, 36 of the 37 files reviewed had accurate
compliance determinations. Therefore, for metric 7a (accurate compliance determinations) AMS
achieved a score of 97%.

Metric 8a (HPV discovery rate at majors) is below the national average as AMS did not identify
any HPVS in FY2020. Supplemental files were pulled from FY2019 because all facility files with
activity to review were selected for FY2020 to evaluate the accuracy of HPV determinations. All
32 files reviewed had accurate HPV determinations. Therefore, the EPA Review Team concluded
that AMS is accurately making HPV determinations (i.e., metric 8c).

AMS did not identify any HPVs in FY2020 and therefore metric 13 could not be evaluated for
FY2020. However, in FY2016, FY2017, and FY2018 AMS identified an HPV in each fiscal year
and all three HPVs were timely identified (i.e., Day Zero was within 90 days of the discovery
date).

Relevant metrics:











Metric ID Number and Description

Natl
Goal

Natl

Avg

State

N

State
D

State
Total

7a Accurate compliance determinations
[GOAL]

100%



36

37

97.3%

7al FRV 'discovery rate' based on inspections
at active CMS sources



6.8%

13

34

38.2%

8a HPV discovery rate at majors [SUPPORT]



2.4%

0

0

N/A

8c Accuracy of HPV determinations [GOAL]

100%



32

32

100%

13 Timeliness of HPV Identification [GOAL]

100%

83.8%

0

0

N/A

AMS Response:

AMS agrees with EPA finding.

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CAA Element 4 - Enforcement

Finding 4-1

Meets or Exceeds Expectations

Recurring Issue:

No

Summary:

AMS took timely and appropriate enforcement actions consistent with the HPV policy3.

Explanation:

AMS did not identify any HPVs in FY2020, therefore, the EPA Review Team reviewed facility
files from FY2017, FY2018, and FY2021 to assess AMS's enforcement responses to HPVs. Five
HPVs were reviewed, and the EPA Review Team found that 100% of the reviewed HPVs had
appropriate enforcement responses. Therefore, achieving "Meets or Exceeds Expectations" for
metric 10b under the Enforcement Element.

Metric 14 is in place to review CD&RTs to ensure that they meet the required HPV policy
elements. Since AMS did not have any CD&RTs to evaluate the reviewed periods, metric 14 is
not applicable.

3 Timely and Appropriate Enforcement Response to High Priority Violations- 2014 dated August 25, 2014

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Relevant metrics:

Metric ID Number and Description

Natl
Goal

Natl

Avg

State

N

State
D

State
Total

lOal Rate of Addressing HPVs within 180
days [SUPPORT]



44.2%

0

0

N/A

10b Percent of HPVs that have been addressed
or removed consistent with the HPV Policy
[GOAL]

100%



5

5

100%

lObl Rate of managing HPVs without formal
enforcement action [SUPPORT]



11.8%

0

0

N/A

14 HPV case development and resolution
timeline in place when required that contains
required policy elements [GOAL]

100%



0

0

N/A

AMS Response:

AMS agrees with EPA finding.

CAA Element 4 - Enforcement

Finding 4-2

Area for Attention

Recurring Issue:

No

Summary:

AMS's formal enforcement documents do not always include corrective actions (e.g. injunctive
relief or demonstration of compliance) to return the facility to compliance or document compliance
prior to close out.

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Explanation:

Generally, the EPA Review Team found that enforcement actions included corrective actions in
formal enforcement responses. However, five enforcement actions were closed out only by
payment of a penalty with no documentation of injunctive relief or that compliance was achieved
prior to remittance of the penalty. It was not clear to the EPA Review Team that compliance was
achieved in the case file documents reviewed. After penalties were paid, the action was closed
without reassurance that the violations had been resolved and the facility returned to compliance.

While assessing a penalty for a violation is in line with the CAA, it is imperative for AMS to
confirm that the facility has demonstrated a return to compliance for the specific violation(s) cited
before the penalty has been remitted. Penalty-only orders are an important tool in enforcement
and compliance activities but must be used in conjunction with assurance and evidence that the
source has returned to compliance for the violation(s) cited. When appropriate, AMS should
utilize consent orders in consultation with their legal department to ensure that corrective actions
are/have been conducted, and enforcement actions are in line with the egregiousness of the
violation(s).

Relevant metrics:

Metric ID Number and Description

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]

AMS Response:

AMS agrees with EPA finding. AMS will update Assessed Penalty Letters to include language
that the source returned to compliance or set a requirement to return to compliance by a specified
time and add evidence of return to compliance in files.

Natl Natl State State State
Goal Avg N D Total

100%

24

29 82.8%

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CAA Element 4 - Enforcement

Finding 4-3

Area for Improvement

Recurring Issue:

Recurring from Round 3

Summary:

AMS addressed 50% of the HPVs timely or had a case development and resolution timeline
(CD&RT) in place prior to day 225 in accordance with the HPV policy.

Explanation:

AMS did not have any HPVs to assess during FY2020. In FY2020, there was one HPV that was
selected for off-ramping, meaning it is no longer subject to the HPV policy, but the state will still
ensure the facility's return to compliance. Therefore, supplemental files were selected to assess
AMS's performance of this element. HPVs from FY2017, FY2018, and FY2021 were selected. Of
the reviewed HPVs, AMS only addressed 50% of them in a timely manner or had a CD&RT in
place prior to day 225. However, there were extenuating circumstances surrounding the two HPVs
that were not addressed timely or had a CD&RT in place. Both were for a refinery around the time
of an explosion at the facility and its subsequent bankruptcy.

In Round 3, AMS addressed two HPVs before day 180 so there were no unaddressed HPVs that
required an HPV CD&RT during FY2015.

In Round 2, metric 10a was an area for potential concern as AMS addressed 77% of their HPVs
after 270 days after day zero or continue to be unaddressed and 270 days has passed. During the
Round 2 review, 35 HPVs were reviewed for timeliness.

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Relevant metrics:

Metric ID Number and Description

Natl Natl State State State
Goal Avg N D Total

10a Timeliness of addressing HPVs or
alternatively having a case development and
resolution timeline in place [GOAL]

100%

50%

AMS Response:

AMS agrees with EPA finding. AMS will institute an HPV tracking process to ensure that a case
development and resolution timeline (CD&RT) is in place prior to day 225 in accordance with the
HPV policy.

Recommendation:

Ucc

Due Dale

Recommendation

12/31/2022

AMS shall institute an HPV tracking process to ensure that
unaddressed HPVs do not reach day 225 without a CD&RT in place.

CAA Element 5 - Penalties

Finding 5-1

Meets or Exceeds Expectations

Recurring Issue:

No

Summary:

Nearly all of the final penalties that were reduced from the initial assessed penalties had adequate
justifications for those reductions. In addition, all penalties had documentation of penalty
remittance in the file.

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Explanation:

Metric 12a assesses the agency's ability to document the difference between initial penalty
calculation and final penalty. The EPA Review Team found that 15 of the 17 penalties collected
had documentation to explain the difference from initial penalty calculation to final penalty
collected. The EPA Review Team noted that in previous SRF rounds, this finding was an "Area
for Improvement" and the recommendation required an SOP. AMS has shown significant
improvement in this metric with the implementation of the SOP that was developed.

Metric 12b assesses the agency's ability to document that an assessed penalty was in fact collected.
AMS successfully provided documentation for all 26 files reviewed with penalties.

Relevant metrics:











Metric ID Number and Description

Natl
Goal

Natl

Avg

State

N

State
D

State
Total

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

100%



15

17

88.2% |

12b Penalties collected [GOAL]

100% |

26

26

100% 1

!
|

AMS Response:

AMS agrees with EPA finding.

CAA Element 5 - Penalties

Finding 5-2

Area for Improvement

Recurring Issue:

No

Summary:

AMS did not assess an economic benefit component.

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Explanation:

All penalty calculations reviewed included a gravity component, however economic benefit
components are not consistently included in AMS penalty calculations. The majority of penalty
matrices reviewed did not include a section for an economic benefit component. The 1991 Clean
Air Act Stationary Source Civil Penalty Policy requires that an economic benefit be included in
the penalty amount or a reason for mitigation to be documented in the case file. The AMS penalty
calculations reviewed did not document a justification to explain why an economic benefit
component was not assessed or applicable.

Relevant metrics:

Metric ID Number and Description

Natl Natl State State State
Goal Avg N D Total

1 la Penalty calculations reviewed that
document gravity and economic benefit
[GOAL]

100% 100%

28

7.1%

AMS Response:

AMS agrees with EPA finding. AMS will revise penalty calculation spreadsheet template to
include a section for assessing economic benefit as well as a comments section to include notes in
the event that the economic benefit component is mitigated.

Recommendation:

Ucc

#

Due Dale

Recommendation

1

07/31/2022

AMS shall revise their penalty calculation spreadsheet template to
include a section for assessing economic benefit as well as a comments
section to include notes in the event that the economic benefit
component is mitigated. EPA will review the revised spreadsheet prior
to instituting the new version.

2

07/31/2023

EPA to review random penalty calculations on a quarterly basis to
ensure that economic benefit is being considered and documented with
85%) accuracy percentage as the goal.

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