hpv policy evaluation
Download
Skip this Video
Download Presentation
HPV Policy Evaluation

Loading in 2 Seconds...

play fullscreen
1 / 16

HPV Policy Evaluation - PowerPoint PPT Presentation


  • 120 Views
  • Uploaded on

HPV Policy Evaluation. Update on Workgroup Progress R4 Air Enforcement Workshop November 2012. The HPV Policy- Background. Issued in 1998 as revision to Significant Violator policy Contains criteria for defining an HPV

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about ' HPV Policy Evaluation' - cassandra-hardin


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
hpv policy evaluation

HPV Policy Evaluation

Update on Workgroup Progress

R4 Air Enforcement Workshop

November 2012

the hpv policy background
The HPV Policy- Background
  • Issued in 1998 as revision to Significant Violator policy
  • Contains criteria for defining an HPV
  • Establishes expectations for addressing HPVs in a timely & appropriate manner
  • Serves as “a tool for prioritizing which violations receive the highest scrutiny and oversight”
epa inspector general report
EPA Inspector General Report
  • EPA IG report in October 2009 criticized EPA & state handling of HPVs
  • Key findings included:
    • Regions and States did not follow the HPV policy
    • EPA HQ did not oversee regional & State performance
    • Regions did not oversee State HPV performance
  • IG Recommendations:
    • direct regions to comply with the HPV policy
    • make needed revisions to the policy
    • implement proper management controls over HPVs
hpv policy evaluation workgroup
HPV Policy Evaluation Workgroup
  • Created in early 2010 in response to IG Report
  • Led by Terri Dykes of OCE
  • Originally included representatives from all regions and several HQ offices
  • National organizations, state and local representatives invited to join in November 2010
    • NESCAUM, NACAA
    • SC, OK, ME, NH, CO, Puget Sound, San Diego
  • Mission
    • Evaluate what revisions might be necessary to ensure the most effective implementation of an HPV policy
workgroup approach to evaluate policy
Workgroup Approach to Evaluate Policy
  • Workgroup’s current strategy is in two phases:
    • First, revise what violations are covered under the policy
      • Primary Goal: identify the most environmentally important violations that warrant additional oversight & intervention
      • Focusing on “providing an increased degree of agency flexibility in identifying . . . HPVs.”
    • Second, revise the “process” for oversight & intervention
      • Secondary Goal: document key federal, state & local agency actions on these most “environmentally important” violations.
      • Focusing on “providing an increased degree of agency flexibility in . . . resolving HPVs.”
analysis of current hpv policy
Analysis of Current HPV Policy
  • Currently, an HPV is identified in 1 of 3 ways:
      • Ten General Criteria
      • A Matrix of Criteria (generally a 4-by-5 matrix)
      • A Discretionary Option
  • As of 2/2/10 - there were 3,016 active HPVs.
      • Too many violations captured in HPV ‘net’ - Each region had to discuss hundreds of cases on a monthly basis according the current policy.
      • 429 of these cases remain unaddressed < 270 days
      • Regions should “take over” these cases under current policy
hpv designations
HPV Designations
  • Over the 5 year period ending in Feb, 2010 - some 9409 HPVs recorded:

GC1 – 570 or 6% GC6 – 774 or 8%

CG2 – 626 or 7% GC7 – 2217 or 24%

CG3 – 363 or 4% GC8 – 1042 or 11%

CG4 – 193 or 2% GC9 – 281 or 3%

CG5 – 1020 or 11% GC10 – 14 or 0.1%

Discretionary – 1120 or 12%

Matrix – 1097 or 12%

hpv definition revised criteria workgroup recommendations
HPV Definition- Revised CriteriaWorkgroup Recommendations

Eliminate the following as General Criteria

Title V certification violations

Failure to submit Title V application violations

Violation of any local, state or federal order

Violation of SM where actual emissions do not exceed major or significant thresholds

Delete the Matrix, and accommodate emission violations into revised General Criteria

Move Opacity violations to “discretionary”

8

hpv definition revised criteria workgroup recommendation oeca feedback
HPV Definition- Revised CriteriaWorkgroup Recommendation & OECA feedback

GC1 –Failure to obtain a NSR permit (and/or install BACT/LAER) for new major source or modification

Include SM w/ actual or expected exceedance of threshold

GC2 – Violation of emission limit, standard or parameter of NESHAP (parts 61 & 63) resulting in illegal emission of a HAP

Exceeds EPCRA RQ for 7 days or more

GC3 – Violation by SM of Major source limit/condition

NSR included above – keep for Title V or NESHAP?

GC4 – Violation of terms of order/decree – Eliminated

OECA may want to reinstate – perhaps discretionary?

9

hpv definition revised criteria workgroup recommendation oeca feedback1
HPV Definition- Revised CriteriaWorkgroup Recommendation & OECA feedback

GC5 – Violation of T5 cert. obligation – Eliminated

Include as discretionary, with mutual consent of Region

GC6 – Violation of obligation to submit T5 application – Eliminated

Include as discretionary, with mutual consent of Region

GC7 – Violations involving testing, monitoring, record-keeping that interfere with enforcement

Case-by-case determination of “substantial interference”

Does not include emission limit violations

10

hpv definition revised criteria workgroup recommendation oeca feedback2
HPV Definition- Revised CriteriaWorkgroup Recommendation & OECA feedback

GC8 – Continuous violation of emission limit, standard or parameter in permit or NSPS

Violation lasts more than 7 days

Results in excess emissions exceeding threshold

Option A: any exceedance

Option B: % of the limit (e.g. 5% or 15%)

Option C: exceed significance threshold (none exists for opacity)

GC9 – Violation by chronic/recalcitrant source – Eliminated

Include as discretionary, with mutual consent of Region

GC10 – Violations of CAA 112(r) - Eliminated

Further discussion with RMP program needed

11

hpv definition revised criteria workgroup recommendation oeca feedback3
HPV Definition- Revised CriteriaWorkgroup Recommendation & OECA feedback

Matrix Criteria – Eliminated

Incorporated elsewhere

Discretionary

Requires mutual agreement of State/Local & Region

National Initiative Violations – Eliminated

Workgroup proposal with OECA suggested including as discretionary, as appropriate

12

hpv definition revised criteria workgroup recommendation oeca feedback4
HPV Definition- Revised CriteriaWorkgroup Recommendation & OECA feedback

GC8 – Continuous violation of emission limit, standard or parameter in permit or NSPS

Violation lasts more than 7 days

Results in excess emissions exceeding threshold

Option A: any exceedance

Option B: % of the limit (e.g. 5% or 15%)

Option C: exceed significance threshold (none exists for opacity)

GC9 – Violation by chronic/recalcitrant source – Eliminated

Include as discretionary, with mutual consent of Region

GC10 – Violations of CAA 112(r) - Eliminated

Further discussion with RMP program needed

13

oversight process
Oversight Process
  • Some discussions to date – no working framework as yet
next steps
Next Steps
  • December call – finalize criteria & process
  • Brief Cynthia Giles
  • Draft policy for workgroup review in January
  • Request extension from IG deadline – currently February 2013
questions discussion
Questions & Discussion
  • Concerns about work to-date on criteria?
  • Key considerations for process development?
ad