Work Plan & Progress Report - Rhode Island Department of ...

Attachment E - Compliance and Inspection Joint Evaluation
The joint DEM/EPA 2011 PPA joint program review was held as part of the 15 th New England Annual
Planning Meeting for Enforcement, Compliance and Assistance. The meeting took place on June 16,
2010 at the New Hampshire Department of Environmental Services in Concord, NH. The minutes for
the Rhode Island Break-out Session are enclosed below.
Dave Chopy provided general comments on the state budget and resources. He indicated the situation
is stable for the time being with respect to layoffs. After June 2011 things could change since
agreement between unions and governor expires and layoffs could be on the table to meet budget
deficits. RI is presently only filling fully federally funded positions. Since the office is working at
reduced personnel levels, DEM will need flexibility with respect to meeting their commitments.
Areas for cooperation include SSOs and CSOs (on-going) and help with the Portsmouth situation
(failing sub-surface systems affected by flooding).
FY 11 Priorities:
The parties agreed the following will constitute priorities in 2011:
Water:
• Plans to conduct ten construction/storm water inspections. For last few years DEM had been
doing 100 or so consistent with the approved ERP.
• Evaluation of fast track NOVs.
• There is a need to fix ECHO data which became evident after NY Times story.
• There is a problem with pH and fecal coliform data and how RI writes permit v/v these
parameters as well as 4 or 5 others.
• Wants to continue marina/pressure washing inspections but want to couple that with
enforcement discretion.
• RI finding MS4 inspection/audit most time consuming; has devoted 1 FTE for 1.5 years and the
work is still not completed.
• Encourages fixing of non-receipt issues in QNCR and other “quick-fixes” being proposed in
CWA Enforcement Action Plan.
Bottom line – need flexibility between permits and enforcement with respect to implementing
various strategies and conducting inspections.
Air:
• Will limit Title 5 inspections to synthetics and minors.
• Continues to find that data entry into AFS is time consuming and difficult.
• Will continue to need EPA assistance in FY 11 (same level as FY 10) on stack testing, although
DEM will continue to develop in-house capabilities as time/resources permit.
Enforcement:
• Air has 4 inspectors. The program is trying to get actions out the door more efficiently.
• RCRA staff is stable at present and will do what was committed to for FY 10. In 2011 the
program may be even exceed targets by a small amount.
• The program is actively working on a fast track enforcement process for FY 11 and beyond.
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