Enforcement in New England

Goal of Federal Facility Multi-Media Inspections Region I, New England

EPA will work to ensure that Federal agencies achieve compliance rates in each media program which meet or exceed those of major industrial and municipal facilities. EPA will use the full range of assistance opportunities and enforcement authorities to ensure compliance.

Program Fundamental Principle

Federal facilities must comply with all applicable Federal Environmental Statutes and Regulations, as well as applicable state and local requirements, in the same manner and degree as private facilities. The Regional Federal Facility Program Managers are responsible for many activities, including:

• Act as regional point-of-contact for Federal facilities;
• Identify "potentially environmentally significant" facilities annually;
• Provide outreach and environmental assistance. (For example, Federal Facility conferences, regular information mailings, training assistance, pollution prevention, Environmental Management Reviews);
• Target, coordinate and conduct multi-media inspections; and
• Track Federal facility compliance rates.

Program Purpose

• The purpose is to conduct multi-media inspections at Federal Facilities in order to obtain data for compliance monitoring and analysis.
• In addition, the program will identify any significant areas which may require follow-up enforcement actions.

Criteria for Inspection Targeting

• Multi-Media compliance history
• Environmental justice
• Urban ecosystems
• Environmentally sensitive areas
• Industrial sectors

Inspection Process

1. Annually select Federal facilities based on targeting criteria.
2. Organize multi-media team from the EPA Regional office.
3. Pre-inspection meeting with EPA personnel.
4. Plan and conduct the inspection with EPA and State staff
   1. In-briefing with top management
   2. Conduct inspection
   3. Out-briefing with top management
5. Preparation of the inspection report is done by EPA/States.
6. Inspection reports are compiled and sent to facility management.
7. Enforcement actions are taken as necessary.

Results of Multi-Media Inspections

• Direct the facility managements' attention to complying with environmental laws and regulations.
• Improve compliance rates, which are reflected in follow-up inspections.
• Contribute to increases in environmental staff, environmental program budgets, and additional environmental training.

Successful Environmental Program– Lessons Learned From Inspections

• Top management commitment required to achieve environmental compliance.
• Environmental manager needs direct access to top management.
• Environmental staff size and expertise need to match the environmental impact of the facility.
• Consistent and routine environmental training is required.