ENV-99-190 Insights To Be Gained From Multimedia Investigation Reports: A Review of Issues Raised

Description:

As part of investigation and enforcement process, the Agency prepares a Multimedia Investigation Report that includes a description of the facility, the objective of the audit, the investigation methods used, and the findings of the audit. Both areas of noncompliance and areas of concern are described for each media audited: air, water, and hazardous waste. The reports also include a description of the documents reviewed and a summary of information gained from interviews. The U.S. EPA desires settlements that improve the environment by reducing emissions and providing a disincentive to poor environmental compliance performance. About 46 percent of civil enforcement settlements require violators to change the way they manage their facilities or reduce emissions and discharges into the environment. The remainder require violators to improve their environmental management systems, take preventive action to avoid future noncompliance, and/or enhance the publics right-to-know. For this paper, we have built on our experience assisting clients and reviewed 15 Multimedia Investigation Reports in detail. The information and examples presented here are intended to provide insight into the investigation and enforcement process. We also include a summary of compliance issues raised.