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.
DISCOVERY and DOCUMENTATION
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
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.
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.