IDEM Compliance/Enforcement Priorities Felicia Robinson Deputy Commissioner of Legal Affairs Indiana Department of Environmental Management

Compliance/Enforcement Priorities National Priorities Region 5 Priorities Agency Priorities

National Priorities Objective 5.1: Improve Compliance by 2008 b b 5% increase in pounds of pollution reduced b b 5% increase in regulated entities making improvements in environmental management practices b b Using: compliance assistance, compliance incentives, and enforcement

National Priorities b b Objectives: Strengthening Science – –enhancing field and lab science Conducting Research – –pollution prevention, new technology, socio- economics & decision making b b Conceptual & General Roadmap b b Data & ECHO, Watch List, Smart Enforcement

Region 5 - Strategies for Compliance & Environmental Stewardship b b Performance partnership agreements: –Provide the agreement for the actual work that the state is to do under its various delegations. – Sets out communication protocols. – Provides the vehicle for payment of grant funding. – Sets out the state’s commitments to abide by EPA policies, guidance, etc. in the compliance and enforcement (and other) areas.

Region 5 - Strategies for Compliance & Environmental Stewardship (Continued) b b Audits and evaluations: – EPA itself is audited by the Office of the Inspector General in terms of how it is overseeing the work that states do in environmental compliance and enforcement. – EPA has come up wanting in those reviews.

Region 5 - Strategies for Compliance & Environmental Stewardship (Continued) b b Air – 8 hour ozone, PM 2.5 NAAQS b b Land UST LUST/RCRA Corrective Action TSCA cleanup sites

Region 5 - Strategies for Compliance & Environmental Stewardship (Continued) b b Water Drinking Water PCB’s Mercury CSO’s SSO’s Stormwater Runoff

Region 5 - Strategies for Compliance & Environmental Stewardship (Continued) b b Communities & Ecosystems Pesticides Blood - lead levels in children Environmental justice

IDEM Priorities b b Office of Air Quality Implement CMS Policy – –Result of IG Report criticizing OECA – –All states & local agencies subject to policy – –Covers all Title 5 & FESOP sources Uses: – –Full compliance evaluations – –Partial compliance evaluations – –Investigations HPV

IDEM Priorities b b Office of Air Quality (continued) Frequencies: – –Title 5 - FCE every 2 years – –Mega - sites - FCE every 3 years – –Synthetic minors - FCE every 5 years – –Compliance status reverts to unknown if frequencies aren’t met

IDEM Compliance Enforcement Priorities b b Office of Water Quality What: – –CSO, SSO, CAFO, Stormwater Why: – –Significant threat to public health & the environment Result/Goal: All CSO communities under an enforceable plan – –CSO & SSO communities addressed – –All CAFO’s inspected – –All regulated facilities have permits & comply – –Working w/EPA to prioritize inspections of NPDES permitted facilities SNC

IDEM Compliance Enforcement Priorities (Continued) b b Office of Land Quality UST Inspection Program Grant Commitments & Core Program CAFO Inspections Waste Tire Piles RCRA SNC

IDEM Priorities Focus Areas b b Compliance Planning Process b b Auto Salvage Yards b b Steel Mills/Foundries b b Multi-media Screening Checklist b b Data