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IDEM Compliance/Enforcement
Priorities
Felicia Robinson
Deputy Commissioner of Legal Affairs
Indiana Department of
Environmental Management
Compliance/Enforcement Priorities
• National Priorities• Region 5 Priorities• Agency Priorities
National PrioritiesObjective 5.1:
Improve Compliance by 2008
5% increase in pounds of pollution reduced
5% increase in regulated entities making improvements in environmental management practices
Using: compliance assistance, compliance incentives, and enforcement
National Priorities
Objectives:• Strengthening Science
– enhancing field and lab science• Conducting Research
– pollution prevention, new technology, socio- economics & decision making
Conceptual & General Roadmap
Data & ECHO, Watch List, Smart Enforcement
Region 5 - Strategies for Compliance & Environmental Stewardship
Performance partnership agreements:
– Provide the agreement for the actual work that the state is to do under its various delegations.
– Sets out communication protocols.
– Provides the vehicle for payment of grant funding.
– Sets out the state’s commitments to abide by EPA policies, guidance, etc. in the compliance and enforcement (and other) areas.
Region 5 - Strategies for Compliance & Environmental Stewardship
(Continued)
Audits and evaluations:
– EPA itself is audited by the Office of the Inspector General in terms of how it is overseeing the work
that states do in environmental compliance and enforcement.
– EPA has come up wanting in those reviews.
Region 5 - Strategies for Compliance & Environmental Stewardship
(Continued)
Air
– 8 hour ozone, PM 2.5 NAAQS
Land• UST
• LUST/RCRA Corrective Action
• TSCA cleanup sites
Region 5 - Strategies for Compliance & Environmental Stewardship
(Continued)
Water• Drinking Water• PCB’s• Mercury• CSO’s• SSO’s• Stormwater Runoff
Region 5 - Strategies for Compliance & Environmental Stewardship
(Continued)
Communities & Ecosystems• Pesticides• Blood - lead levels in children• Environmental justice
IDEM Priorities
Office of Air Quality• Implement CMS Policy
– Result of IG Report criticizing OECA– All states & local agencies subject to policy– Covers all Title 5 & FESOP sources
• Uses:– Full compliance evaluations– Partial compliance evaluations– Investigations
• HPV
IDEM Priorities
Office of Air Quality (continued)• Frequencies:
– Title 5 - FCE every 2 years
– Mega - sites - FCE every 3 years
– Synthetic minors - FCE every 5 years
– Compliance status reverts to unknown if frequencies aren’t met
IDEM Compliance Enforcement Priorities
Office of Water Quality• What:
– CSO, SSO, CAFO, Stormwater
• Why:
– Significant threat to public health & the environment
• Result/Goal: All CSO communities under an enforceable plan
– CSO & SSO communities addressed
– All CAFO’s inspected
– All regulated facilities have permits & comply
– Working w/EPA to prioritize inspections of NPDES permitted facilities
• SNC
IDEM Compliance Enforcement Priorities (Continued)
Office of Land Quality• UST Inspection Program
• Grant Commitments & Core Program
• CAFO Inspections
• Waste Tire Piles
• RCRA SNC
IDEM PrioritiesFocus Areas
Compliance Planning Process
Auto Salvage Yards
Steel Mills/Foundries
Multi-media Screening Checklist
Data
