Printreg Archive
Re: Non-Compliance Estimation


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From: VICTORIA STONE 608/266-1962, OFFICE OF POLLUTION PREVENTION (STONEV@dnr.state.wi.us)
Date: Wed Sep 18 1996 - 08:50:00 CDT


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Subj: Non-Compliance Estimation

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Message-ID: <DB1E863A019F59D9@tellus.com>
Date: 17 Sep 96 16:34:33 EST
From: Edward Reiskin <EREISKIN@tellus.com>
To: printreg@great-lakes.net
Subject: Non-Compliance Estimation
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--Ugate.Main.986E
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I am working on a project to help printers evaluate potential liability
for non-compliance penalties. For facilities that do not have historical
penalty data readily available, I am developing a worksheet (draft below)
to be used as a rough estimation of potential future liability.

The worksheet covers five categories - one general category, three
media-specific categories, and a reporting category. The intent is to
use facility-specific factors to weight industry-general data in order to
provide a very approximate estimation of non-compliance liability.

I would appreciate any input with respect (1) to the suitability of the
indicators selected for each category, (2) the sensibility of the
weighting factors accompanying each answer as shown in parentheses, and
(3) the overall concept for non-compliance liability estimation. The
idea is, for example, that if you are required to have a CAA Title V
permit, you are more likely to be penalized (because you are a large
emissions generator and you are subject to permit-compliance inspections,
etc.).

I realize that this worksheet is imprecise and subjective, but if a
reasonable estimation can be made, it might be better than no
consideration at all.

(If the worksheet below is not legible due to formatting difficulties,
please download the attachment which is a text file of the worksheet. If
all else fails, I am happy to fax it to anyone interested.)

Thanks!

Ed Reiskin
Research Associate
Tellus Institute
11 Arlington Street
Boston, MA 02116-3411
(617) 266-5400
(617) 266-8303 fax
ereiskin@tellus.com
--------------------------------------------------------------------------
--------------------
Worksheet

 general self-assessment
                                        below close to above
                                        average average average
environmental management (include commitment to waste reduction,
integrity of materials handling systems, etc.) O (1.5) O (1.0) O (0.5)
Wg1
rapport with regulators O (1.1) O (1.0) O (0.9) Wg2

        general weighting (Wg) = Wg1 * Wg2

air emissions (CAA)
                                                yes no
Are you required to have a Title V permit? O (1.5) O (0.1) Wa1
Have you incurred CAA fines/penalties in the last 3 years? O (1.5) O
(0.5) Wa2
Are you in a severe/extreme ozone non-attainment zone? O (1.5) O (0.5)
Wa3

        air weighting (Wa) = Wa1 * Wa2 * Wa3 * exp_CAA_fine

land emissions (RCRA)
                                        CESQG SQG LQG
What is your RCRA generator classification? O (0.5) O (1.0) O (1.5) Wl1
                                        yes no
Are you classified as a TSDF? O (1.5) O (0.5) Wl2
Have you incurred RCRA fines/penalties in the last 3 years? O (1.5) O
(0.5) Wl3
Do you have underground storage tanks? O (1.2) O (0.8) Wl4
Is your facility in a densely populated area? O (1.1) O (0.9) Wl5

        land weighting (Wl) = Wl1 * Wl2 * Wl3 * Wl4 * Wl5 * exp_RCRA_fine

water emissions (CWA)
                                                yes no
Do you have a NPDES and/or SIU permit? O (1.5) O (0.1) Ww1
Have you incurred CWA fines/penalties in the last 3 years? O (1.5) O
(0.5) Ww2
Is your facility near a public water supply? O (1.1) O (0.9) Ww3

        water weighting (Ww) = Ww1 * Ww2 * Ww3 * exp_CWA_fine

reporting (EPCRA, TSCA)
                                                yes no
Do you report emissions for TRI? O (1.5) O (0.1) We1
Have you incurred EPCRA fines/penalties in the last 3 years? O (1.5) O
(0.5) We2
Do you use substances that require TSCA reporting? O (1.5) O (0.1) Wt1
Have you incurred TSCA fines/penalties in the last 3 years? O (1.5) O
(0.5) Wt2

        EPCRA weighting (We) = We1 * We2 * exp_EPCRA_fine
        TSCA weighting (Wt) = Wt1 * Wt2 * exp_TSCA_fine

Total liability = Wg * ( Wa + Wl + Ww + We + Wt)

Note: exp_XXX_fine would be an estimated expected fine based on industry
average fine data

--Ugate.Main.986E
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Worksheet
*general self-assessment
                                                below close to above
                                                average average average
environmental management (include commitment to waste reduction,
integrity of materials handling systems, etc.) O (1.5) O (1.0) O (0.5) Wg1
rapport with regulators O (1.1) O (1.0) O (0.9) Wg2

        general weighting (Wg) = Wg1 * Wg2

*air emissions (CAA)
                                                                yes no
Are you required to have a Title V permit? O (1.5) O (0.1) Wa1
Have you incurred CAA fines/penalties in the last 3 years? O (1.5) O (0.5) Wa2
Are you in a severe/extreme ozone non-attainment zone? O (1.5) O (0.5) Wa3

        air weighting (Wa) = Wa1 * Wa2 * Wa3 * exp_CAA_fine

*land emissions (RCRA)
                                                        CESQG SQG LQG
What is your RCRA generator classification? O (0.5) O (1.0) O (1.5) Wl1
                                                                yes no
Are you classified as a TSDF? O (1.5) O (0.5) Wl2
Have you incurred RCRA fines/penalties in the last 3 years? O (1.5) O (0.5) Wl3
Do you have underground storage tanks? O (1.2) O (0.8) Wl4
Is your facility in a densely populated area? O (1.1) O (0.9) Wl5

        land weighting (Wl) = Wl1 * Wl2 * Wl3 * Wl4 * Wl5 * exp_RCRA_fine

*water emissions (CWA)
                                                                yes no
Do you have a NPDES and/or SIU permit? O (1.5) O (0.1) Ww1
Have you incurred CWA fines/penalties in the last 3 years? O (1.5) O (0.5) Ww2
Is your facility near a public water supply? O (1.1) O (0.9) Ww3

        water weighting (Ww) = Ww1 * Ww2 * Ww3 * exp_CWA_fine

*reporting (EPCRA, TSCA)
                                                                yes no
Do you report emissions for TRI? O (1.5) O (0.1) We1
Have you incurred EPCRA fines/penalties in the last 3 years? O (1.5) O (0.5) We2
Do you use substances that require TSCA reporting? O (1.5) O (0.1) Wt1
Have you incurred TSCA fines/penalties in the last 3 years? O (1.5) O (0.5) Wt2

        EPCRA weighting (We) = We1 * We2 * exp_EPCRA_fine
        TSCA weighting (Wt) = Wt1 * Wt2 * exp_TSCA_fine

Total liability = Wg * ( Wa + Wl + Ww + We + Wt)

Note: exp_XXX_fine would be an estimated expected fine based on industry average fine data

--Ugate.Main.986E--


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