Enforcement Management System. Within one hundred and twenty (120) calendar days of the execution of this MOA or as otherwise established in the PPA and IPDES CMS, IDEQ agrees to submit to EPA for review and comment a current Enforcement Management System (EMS). The EMS is a document outlining procedures, policies, timelines, etc., to be used by IDEQ in conducting official business (e.g., inspections, tracking and evaluating compliance enforcement actions, assessment of penalties, etc.). Such procedures and policies with respect to compliance and enforcement should take into consideration EPA’s current NPDES national enforcement guidance and policies and should include application of criteria for screening the significance of violations, procedures and time frames for selecting appropriate initial and follow-up response options to identified violations, and procedures for maintaining a chronological summary of all violations. IDEQ agrees to implement its EMS. IDEQ agrees to submit any changes to the IPDES EMS to EPA for review and comment upon request.
Enforcement Management System. Within one hundred and twenty (120) calendar days of the execution of this MOA or as otherwise established in the PPA and State Clean Water Act CMS, the State agrees to submit to EPA for review and comment a current Enforcement Management System (EMS), or verify that the existing Compliance Assurance Manual(s) EPA has on record are current and in effect. The EMS is a document outlining procedures, policies, timelines, etc., to be used by the State in conducting official business (e.g., inspections, tracking and evaluating compliance enforcement actions, assessment of penalties, etc.). Such procedures and policies with respect to compliance and enforcement should take into consideration EPA’s current NPDES national enforcement guidance and policies and should include application of criteria for screening the significance of violations, procedures and time frames for selecting appropriate initial and follow-up response options to identified violations, and procedures for maintaining a chronological summary of all violations. The State agrees to implement its EMS. The State agrees to submit any changes to its EMS to EPA for review and comment upon request.
