Virginia DEQ Strategic Priorities
Transition to a risk-based hazardous waste inspection schedule
| Agency Goal | Achieve focused, more efficient programs to meet or exceed environmental standards | |||||||
| Objective | Achieve certain, consistent, timely enforcement | |||||||
| Strategy | Transition to a risk-based hazardous waste inspection schedule | |||||||
| Team Lead | Frazier,Steven | |||||||
| Team Member(s) | ||||||||
| Opportunity | Hazardous Waste - 1: Transition to a risk-based inspection schedule | |||||||
| Created Date | 2/10/2006 | |||||||
| Last Update | 2/9/2007 | |||||||
| Complete | Active |  |
Strategic Plan | |||||
| # | Action | Owner | Comp | Target Date | Status | Comment | |
| 1 | Develop risk-based inspection plan, including inspection frequencies for different HW classifications (SQG, LQG, TSD, noncomplier) | Frazier,Steven | |
9/1/2006 | Completed 3/01/06. RCRA grant specifies inspection frequency by facility types; facilities in performance track, state sector CAVs, good compliance history are low risk. | ||
| 2 | Explore opportunities with USEPA in grant requirements to re-assign priorities to focus on noncompliant generators. | Frazier,Steven | |
11/1/2006 | Completed 3/01/06. Part of EPA Grant Workplan; prioritized based on SNC, national priority sectors, non-response to agency actions, complaints (high risk). | ||
| 3 | Incorporate environmental excellence into the risk criteria (VEEP, PT) for setting inspection frequency and scope. | Frazier,Steven | 11/1/2007 | Completed 3/01/06 for generators. Clarification needed from EPA -- inspection frequency may be extended for NPT or VEEP facilities up to 1 year, up to 2 yrs for generators. May not be extended for federal statutory mandated inspections at F/S/L and certain other TSD facilities. However, we are exploring use of "focused compliance inspections" for those facilities. | |||
| 4 | Cross-train inspectors to handle multi-media inspections at small facilities. Pilot this approach at specific industry sectors, e.g., parts washers, dry cleaners, auto body shops, laundry facilities. | Frazier,Steven | 9/1/2007 | Pilot study with Air program for drycleaners & autobody shops. Outreach with auto maintenance facilities in NRO. Scheduled for field testing follow-up during FY07. | |||
| Comments |
| 1. Completed 3/01/06. RCRA grant specifies inspection frequency by facility types; facilities in performance track, state sector CAVs, good compliance history are low risk. 2. Completed 3/01/06. Part of EPA Grant Workplan; prioritized based on SNC, national priority sectors, non-response to agency actions, complaints (high risk). 3. Completed 3/01/06 for generators. Clarification need from EPA -- inspection frequency may be extended for NPT or VEEP facilities up to 1 year, up to 2 yrs for generators. May not be extended for federal statutory mandated inspections at F/S/L and certain TSD facilities. However, we are exploring the use of "focused compliance inspections" at these facilities. 4. Pilot study with Air program for drycleaners & autobody shops. Outreach with auto maintenance facilities in NRO. Scheduled for field testing follow-up during FY07. |
| Resources |
| 1. Have made proposal to EPA and in this year’s grant to implement this strategy. 2.Tried to integrate with Opp 1, task 1 above, but had to split out. 3. Integrated w/ Opp 1, Task 1 above. 4. Discussed with HW inspectors during monthly calls in Nov & Dec '05 and soliciting comments. A pilot study will most likely involve coordination with Air for inspections at Drycleaners. Propose initiating field testing during 3rd and 4th quarters at a limited number of facilities in at least two regions to assess implementation on a wider scale during FY07. Ideally, we would like to try a double media approach, i.e. train RO air staff for HW, RO HW for Air and run the field pilot simultaneously. Recommend field testing during FY07, implementation for FY08. April'05 = VRO is looking at cross-training air & HW inspectors. |