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Status of SRF Reviews in Region 4

Status of SRF Reviews in Region 4. Mark Fite Office of Environmental Accountability EPA Region 4 May 22, 2012. SRF Purpose & Goals. To help EPA and the states achieve, through review and discussion: a consistent level of activities in the state & locals;

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Status of SRF Reviews in Region 4

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  1. Status of SRF Reviews in Region 4 Mark Fite Office of Environmental Accountability EPA Region 4 May 22, 2012

  2. SRF Purpose & Goals • To help EPA and the states achieve, through review and discussion: • a consistent level of activities in the state & locals; • a consistent level of oversight by EPA; • a consistent level of environmental protection across the country.

  3. SRF Process • The SRF Review utilizes • Data in AFS that has been verified by state/local program • Information from file reviews • Review of negotiated commitments (Air Planning Agreement, CMS Plan) • Management and staff discussions with the state • Any other existing assessments relevant to the SRF elements

  4. Elements Evaluated in SRF • Data Integrity • Data completeness • Data accuracy • Timeliness of data • Inspections • Completion of commitments • Inspection coverage • Quality of inspection reports • Enforcement • Identification of violations • Identification of HPVs • Enforcement that promotes compliance • Timely & appropriate action • Penalties • Penalty calculation • Final penalty assessment & collection

  5. Key Aspects of Round 3 • Streamlined number of metrics • Annual data verification performed by states & locals • Annual data review by EPA, with quadrennial SRF review • Possible incorporation of permit quality review (starting with CWA program) • Increased oversight of process by OECA • Greater transparency and public dissemination of data

  6. Current Status in Region 4 • Round 1: • 3 year cycle FY 04-07; • Reviewed all 54 states and territories (Nationally) • Region 4 evaluated the following programs: • all 8 states • Jefferson County, AL; Forsyth County, NC; Louisville; & Memphis • Round 2 • 4 year cycle ending September 30, 2012 • In Region 4, 7 states and 3 locals evaluated

  7. Current Status in Region 4 • Round 2 reviews have been completed for • SC, AL, NC, GA, KY, MS, Huntsville & Louisville • Round 2 reviews are in progress for • TN and Knoxville • FL SRF was recently kicked off using Round 3 metrics and FY 11 “verified data”

  8. Round 2 Recommendations – R4 • Region 4 is currently tracking 22 CAA recommendations from Round 2 reviews: • Most prevalent elements being tracked are: • Element 3 – timeliness of data entry (5 programs) • Element 2 – data accuracy (4 programs) • Element 11 – penalty calculations (4 programs) • Element 10 – timely & appropriate action (3 programs) • Element 1 - data completeness (2 programs) • Potential issues identified in 2 remaining draft reports: • Element 2 – data accuracy (2 programs) • One recommendation also included for Elements 1, 3, 5, & 10

  9. Improvements resulting from SRF • Enhanced penalty documentation • More consistent consideration of economic benefit • Better documentation of FCE components • Enhanced understanding of HPV policy and Federally Reportable Violations guidance • Correction of process issues that cause delays in data entry • Data system improvements

  10. Questions? • My contact information: Mark Fite 404.562.9740 fite.mark@epa.gov

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