Discovery and documentation
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DISCOVERY and DOCUMENTATION. Ah, hah! Uh-oh! Hmm…. Inspections result in verification of compliance OR…. Violations Three general categories: We can take care of it right away This is going to take some time This has to be stopped NOW. Informal.

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DISCOVERY and DOCUMENTATION

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DISCOVERY and DOCUMENTATION

Ah, hah!

Uh-oh!

Hmm…


Inspections result in verification of compliance OR…

  • Violations

  • Three general categories:

  • We can take care of it right away

  • This is going to take some time

  • This has to be stopped NOW


Informal

  • Things that are not causing damage to the POTW

  • Things that can be fixed using on-site resources under the authority of the site contact

  • Things that can be completed within six weeks


Follow your Enforcement Response Plan!

Investigate, remembering that it could end up in court.

Write it all down, especially if it gets taken care of while you’re still there!

If you photograph the violation, you will need to photograph compliance, once it happens.

Cite what was violated… 40CFR403, SUO, or Control Mechanism

So, what do we do about it?


Formal

  • Potential damage to POTW

  • Things needing resources… lots of resources

  • Things that take time

  • ERP may state some violations as formal by definition


As with informal, but you’re preparing the evidence justifying expenditure of resources

Make you citation air-tight! Quote the reg, SUO, control mech.

Accuracy is paramount

Be specific as you can. This make take more time. Don’t let situation hurry you.

Give your boss a head’s up

Remember the goal. Protect the POTW.

So, now what do we do?


Cease and Desist

  • Damage to POTW, damage to environment, public danger

  • “Exercise of emergency power”

  • Get help

  • Accuracy is essential (at the least, money is at stake)


Get the damage stopped!

Act within your authority.

Document, document, document, DOCUMENT!

You’re probably going to be there for awhile.

Don’t over-react. We’re still fitting the response to the situation.

Give your boss, the collections crew, and the plant operators a head’s up.

So, what do we do NOW?


Documenting

  • Get the basics right. Where are you? What time is it? Who are you talking to? Why are you there? What do you see?

  • Subtle things… what do you NOT see? What changed?

  • Describe situation and violation, including citing 40 CFR, SUO, and/or control mechanism provisions that apply

  • If you use photos, note what you’re taking pix of while you have the camera in your hand


Paperwork Violations

  • Prepare and use a checklist to review submittals

  • Follow your ERP

  • Close the loop. If no problems, acknowledge report

  • Pay close attention to meeting due dates


Questions?

  • Jeff Carter

  • UW – Burbank

  • (818) 972-1115 x17

  • [email protected]

  • 740 N LAKE ST BURBANK CA 91502


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