OBJECTIVE C - Management Action 2
Expand and strengthen enforcement of National Pollutant Discharge Elimination System (NPDES) permits. Increase site inspections and review of self-monitoring data to improve facility compliance by 1995.
Explanation:
Increasing the staff of the Division of Environmental Management's (DEM) Compliance Group would allow for more frequent site inspections and would enhance enforcement. More frequent inspections would improve communication between the Division and dischargers, and would help prevent some violations before they occur. Stronger enforcement would dampen incentives for dischargers to violate their permits.
Critical Steps:
- The General Assembly would be asked to increase permit fees for DEM in order to hire additional personnel for their compliance program.
- DEM would increase personnel in their central and regional offices to provide for more frequent and comprehensive inspections of permitted dischargers and provide more staff time to the Notice of Violation and assessment process.
- As required by the U.S. Environmental Protection Agency (EPA), DEM would maintain its Enforcement Management System, which is a complete set of written enforcement policies ensuring consistent and adequate enforcement procedures.
- When a facility is found in violation of its discharge permit, DEM's Facility Assessment Unit would investigate appropriate enforcement actions to achieve compliance as quickly as feasible.
- DEM would review the permits and effluent data for all facilities identified whose effluent concentrations could result in potential water quality exceedances.
- DEM would continue to investigate and propose innovative methods of enforcement to increase efficiency.
Evaluation Methods
DEM would continue to track on a quarterly basis the percentage of NPDES dischargers operating in violation of their permit. A decrease in permit violations would be considered successful implementation of this management action.
Costs and Economic Considerations
DEM would require $300,000 per year to hire six additional personnel and to purchase additional monitoring equipment. If facilities were aware that more frequent and comprehensive inspections of permitted dischargers were taking place, higher rates of compliance could be expected, which would result in lower governmental costs of pollution clean-up.
Funding Strategy
The hiring of six staff members by DEM would require a $300,000 appropriation from the General Assembly. Another possible source of funding for this action would be revenues generated from permit fees.