Avoiding Clean Air Act Enforcement Actions.

摘要

A 1993 Army Compliance Tracking System (ACTS) report indicates that 70 Army installations held Clean Air Act (CAA) permits; a total of 510 permits had been issued. The total number of air emissions sources was nearly 2,500 in 1989; but for convenience, multiple sources are generally included on a single permit. Some states issue a single permit for the entire installation. Regardless of how air emissions sources are counted, the Army is subject to the CAA on a large scale. The existence of many enforcement actions (EAs) must not obscure the reality that the overall compliance of the Army's air pollution sources has been very good. Compliance for major sources (generally heating plants and incinerators, emitting more than 100 tons per year of any of the primary pollutants) was even better. Recent modifications to ACTS included the addition of reason codes and corrective action codes for EAs. ACTS was used to review the EAs resulting from failure to meet the CAA standards during the period November 1990 through January 1993. THis analysis identified four primary underlying causes: lack of environmental knowledge, lack of management attention (poor supervision), contract problems, and lack of resources. THe underlying causes are often cited together as the joint causes of specific EAs.