Supplemental Environmental Projects

United States 

Environmental Protection Agency

Office of Enforcement and 

Compliance Assurance (2248A) 

http://www.epa.gov/oeca/sep 

EPA 325-R-01-001 

January 2001 

Beyond Compliance:

Supplemental Environmental Projects

Beyond Compliance: Supplemental Environmental Projects 

TABLE OF CONTENTS 

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What is a SEP?. . . . . . . . . . . . . . . . . . . . . . . . . . 4

How do SEPs benefit the public?. . . . . . . . . . . . . 4

Who may do a SEP, and what is the benefit

for the violating company? . . . . . . . . . . . . . . . 4

What are the categories of acceptable SEPs? . . . . 4

Highlighted SEPs 

Involving the Community in Puerto Rico 

Electric Power Authority SEPs . . . . . . . . . . . . . . . 7

Returning an Abandoned Drive-In to its Natural 

State . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Crozer Chester Medical Center Teams with

Public Schools to Conquer Asthma . . . . . . . . . . 11

SEPs for Multiple Facilities: United Technologies

Corporation . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Setting a Goal Beyond Compliance - U.S. Mint,

Philadelphia . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Protecting New York City's Croton Water Supply. . . 16

Reducing Water Pollution in the City of Baltimore. . 17

Delmarva Power and Light Restores a Wetland. . . . 18

Town of Luray Restores Stream Quality . . . . . . . . . 18

Improving Water Quality in the City of Atlanta. . . . 19

Sewerage and Water Board of New Orleans

Works to Revitalize Lake Pontchartrain. . . . . . . . 21

Treating Baltimore’s Inner City Children

with Asthma . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Ashland Oil Company SEPs Reduce Pollution, 

Educate, and Preserve Nature . . . . . . . . . . . . . . 25

ASARCO's SEPs Protect Public Health and 

Restore Wetlands. . . . . . . . . . . . . . . . . . . . . . . 27

Brownfields Cleanup by Sherwin-Williams . . . . . . . 28

Simpson Paper Company Restores Salmon

Habitat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

International Cooperation on a Pollution 

Prevention SEP. . . . . . . . . . . . . . . . . . . . . . . . . 31

Safe Drinking Water for the City of Sandpoint,

Idaho. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Reducing Wastes at Spectrum Glass. . . . . . . . . . . . 33

PSC Preserves an Ecosystem and Reduces Air

Pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Restoring Fish Habitat in Montana . . . . . . . . . . . . . 36

Protecting Alaskan Wetlands. . . . . . . . . . . . . . . . . 36

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Page 1
Provide credible deterrent to 

pollution and greater 

compliance with the law. 
Beyond Compliance: Supplemental Environmental Projects 

INTRODUCTION 

Americans have the right to air that is clean, water 

that is safe to drink, food that is free from dangerous 

pesticide residues, and communities that are free of 

hazardous wastes. The United States Environmental 

Protection Agency (EPA) helps protect these rights 

through fair, effective enforcement of federal 

environmental laws, such as the Clean Air Act, Clean 

Water Act, Safe Drinking Water Act, Federal 

Insecticide, Fungicide and Rodenticide Act, Toxic 

Substances Control Act, and Resource Conservation 

and Recovery Act. 

If the Agency believes that an individual or company 

has failed to comply with Federal environmental laws, 

it may initiate an enforcement action. Enforcement 

actions are taken in order to compel the individual or 

company to return to compliance, and deter others 

from violating these laws. In settling an enforcement 

action, EPA usually requires individuals or companies 

to pay cash penalties and to take injunctive relief -

actions needed to eliminate noncompliance, correct 

environmental damage, and restore the environment. 

In addition, enforcement settlements may also include 

Supplemental Environmental Projects (SEPs). SEPs are 

actions taken by an individual or company that are in 

addition to what is required to return to compliance 

with environmental laws. SEPs benefit public health or 

the environment. They offer a unique opportunity to 

further our Nation’s goals of ensuring clean air and 

water, safe food, better waste management, and 

expanding the public’s right to know about their 

environment. 

EPA’s mission is to protect public health and the 

environment. 

1. Protecting and enhancing the quality of the 

Nation’s air resources; 

2. Maintaining the chemical, physical, and biological 

integrity of the Nation’s waters; 

3. Protecting the Nation’s food supply from pesticide 

residues; 

4. Preventing or reducing pollution at the source 

whenever possible; 

5. Reducing or eliminating the generation of 

hazardous waste; 

6. Reducing global and cross-border environmental 

risks; 

7. Expanding American’s right to know about their 

environment; 

8. Promoting sound science and improved 

understanding of environmental risk; 

9. Providing a credible deterrent to pollution and 

greater compliance with the law; and 

10. Implementing the highest quality standards for 

management and fiscal responsibility. 

EPA’s 

This mission is accomplished by: 

Mission 

SEP projects have existed since the early 1980s, and 

their use has increased steadily through the 1990s. 

For instance, while more than 200 SEPs were 

approved in 1992, a total of 336 SEPs were agreed to 

as part of 197 case settlements in fiscal year 1999. 

The total monetary value of these SEPs was over $230 

million. Approximately one half of these projects were 

classified as pollution prevention or pollution reduction 

activities. 

This booklet offers a description of SEPs, highlights a 

number of SEPs that have either been completed or 

are currently in progress, and discusses the benefits to 

public health and the environment that can be 

achieved through these projects. 

Page 3 
Beyond Compliance: Supplemental Environmental Projects 

What is a SEP? 

Through its SEP policy, EPA allows a violator of 

environmental laws to do more than simply correct its 

violation(s). A SEP is an environmentally beneficial 

project that a violator voluntarily agrees to perform, in 

addition to actions required to correct the violation(s), 

as part of an enforcement settlement. When 

volunteering to perform a SEP, a company must show 

that it can and will complete the project, and must 

provide all funds used to finance the project. EPA 

provides oversight to ensure that the company does 

what it promises to do. EPA, however, does not 

manage or control the funds. 

How do SEPs benefit the public? 

SEPs are designed to protect and improve the 

environment and public health, beyond that achieved 

by compliance with applicable laws. SEPs may directly 

or indirectly benefit the public by preventing pollution 

or addressing environmental justice concerns. Finding 

more effective ways to address community 

environmental concerns that result from a company’s 

violations is a major objective of EPA’s SEP policy. Not 

only can community involvement assure greater 

consideration of community needs in specific SEPs, but 

it can lead to increased communication and trust 

between all concerned parties—a foundation for longterm environmental improvement. 

Who may do a SEP, and what is the 

benefit for the violating company? 

In addition to correcting the violation(s), a violating 

company may propose one or more SEPs as part of a 

settlement. As the examples in this report 

demonstrate, SEPs have been implemented by large 

and small companies, hospitals, federal facilities, and 

state and local governments. To gain approval for 

conducting a SEP, a company must identify and 

demonstrate a willingness and ability to implement an 

appropriate project that primarily benefits public 

health or the environment. These projects must 

provide benefits beyond what compliance with the law 

requires. 

If a company performs a SEP, EPA may reduce the 

penalty assessed. In addition to this economic 

incentive, a company may improve the quality of life 

for the surrounding community and as a result, build a 

better relationship with the community. 

What are the categories of acceptable SEPs? 

As described below, EPA has seven specific categories 

of projects that can be acceptable SEPs. In addition to 

these SEPs, EPA allows companies to perform other 

types of projects that have environmental or public 

health benefits. 

Pollution Prevention: These SEPs involve changes 

that reduce or eliminate some form of pollution, or 

that reduce a pollutant’s toxicity prior to recycling, 

treatment, or disposal. Examples include use of less 

toxic materials to make products, modifications in the 

production process to reduce material losses, changes 

in product design which require less polluting 

processes, or improved housekeeping. EPA places a 

high priority on pollution prevention approaches, since 

these reduce the potential for future pollution, and 

may lead to more widespread, environmentallybeneficial changes in their business or industry 

activities. As a result, EPA may allow greater 

Page 4 
Beyond Compliance: Supplemental Environmental Projects 

mitigation in penalties for pollution prevention projects 

than for other SEPs. 

Pollution Reduction: These SEPs are similar to 

pollution prevention SEPs in terms of outcome. But 

instead of eliminating a source of pollution, they 

reduce the amount or danger of the pollution which 

reaches the environment. Examples include improved 

treatment or control of pollutants and recycling and 

reuse of chemicals or materials. 

Public Health: Such SEPs may include examining 

residents in the community put at risk by the 

violations to determine if anyone has experienced 

health problems related to the violation, as well as 

related medical treatment or rehabilitation therapy. 

Environmental Restoration and Protection: These 

SEPs improve the condition of the land, air, or water in 

the area damaged by the violation. For example, by 

purchasing land or developing conservation programs 

for the land, a company could protect a natural 

habitat for wildlife or a source of drinking water. 

Beyond preservation, such a SEP might involve 

restoring natural areas that are vital to long-term 

protection of the environment or public health. 

Assessments and Audits: Any violating company 

may agree to examine its operations for pollution 

prevention opportunities, and determine if it can 

reduce the use, production, or generation of 

hazardous materials and other wastes. These audits 

go well beyond standard business practices. In 

addition, small businesses (with less than 100 

employees) or small communities (less than 2,500 

residents) can receive credit for agreeing to conduct 

audits to determine their compliance with 

environmental laws in order to avoid future violations. 

Environmental Compliance Promotion: These are 

SEPs in which the violator helps other companies 

achieve compliance and reduce pollution related to the 

type of violation. For example, a company which 

violated the Clean Air Act may train other companies 

on how to comply with the Act. 

Emergency Planning and Preparedness: These SEPs 

provide technical assistance and training to state or 

local emergency planning and response organizations 

to help them better respond to chemical emergencies. 

For example, a company may provide a local fire 

department with additional equipment to deal with a 

hazardous waste situation. 

Your participation can have a beneficial impact in your 

community. 

adopted as part of final settlement agreements when 

they fall within the scope of the SEP policy. 

cases, SEP ideas have been modified to accommodate 

community priorities. 

strongly encouraged by EPA to participate in the SEP 

process. You can: 

• Attend public meetings to suggest SEPs or 

comment on proposed SEPs. 

• Provide comments on a proposed settlement 

published in the Federal Register. 

• Learn more about SEPs by visiting EPA's SEP 

Webpage at http://www.epa.gov/oeca/sep. 

How can I participate in the SEP Process? 

SEPs proposed by communities have been 

In other 

If you are interested, you are 

Other Types of Projects: Other acceptable SEPs 

would be those that have environmental merit but do 

not fit within the categories listed above. These types 

of projects must be fully consistent with all other 

provisions of the SEP Policy. 

Page 5 
“Never doubt that a small group of 

thoughtful, committed citizens can 

change the world, indeed, it’s the 

only thing that ever has.” 

Margaret Mead 

Writer and Teacher (1901-1978) 
Beyond Compliance: Supplemental Environmental Projects 

I

NVOLVING THE COMMUNITY IN 

PUERTO RICO ELECTRIC POWER 

AUTHORITY SEPS 

The Puerto Rico Electric Power Authority (PREPA) has 

several plants throughout Puerto Rico. In March of 

1999, PREPA and EPA entered into an agreement that 

resolved a Complaint which was pending in Federal 

District Court against PREPA at five of its facilities. As 

part of the agreement, PREPA agreed to perform two 

SEPs. The concerns and interests of the communities 

in the areas around the facilities helped to select and 

shape the SEPs. 

From the beginning, EPA felt that community 

involvement should be a key factor in resolving 

PREPA’s enforcement action. EPA's Regional 

Administrator initiated community involvement with a 

letter to community groups that had expressed 

interest in the case or were located near one of the 

PREPA facilities. These groups were presented with 

the details of the enforcement action and were given 

general information about the status of settlement 

discussions. Through a process facilitated by EPA, the 

community groups suggested numerous potential 

projects and reached consensus on community 

priorities. Two of the highest priority proposals were 

included in the settlement. 

Preserving a Natural Habitat 

As its first project, PREPA has committed to acquire 

and preserve a natural habitat near the Palo Seco and 

San Juan power plants over the next five years. This 

area has been described as one of the last selfsufficient ecosystems in the area near these power 

plants. By completing this SEP, PREPA will ensure that 

the natural environment in this area will survive. 

Hazardous Materials Training 

The second SEP to which PREPA has committed 

involves the development of a 40-hour hazardous 

materials technician-level training program. This 

program will be designed as an addition to fire 

department training programs throughout the island 

of Puerto Rico. PREPA will fund and present this 

course so that there will be trained chemical spill 

response teams throughout the island. 

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Beyond Compliance: Supplemental Environmental Projects 

Additional Measures to Improve 

Community-PREPA Communications 

Because all parties recognized the importance of 

improving relationships and communication between 

PREPA and the communities, PREPA agreed to hire a 

contractor who will work on community 

environmental issues related to PREPA over the next 

five years. While not a SEP, this measure, taken to 

ensure improved long-term environmental cooperation 

between PREPA and the communities, was a 

significant outcome of the SEP negotiation process. 

Page 8 
Beyond Compliance: Supplemental Environmental Projects 

RETURNING AN ABANDONED This purchase will include 30 acres which contains the 

DRIVE-IN TO ITS NATURAL Lonsdale Twin Drive-In Theater in Lincoln, RI. This 

drive-in theater is located in part of one of the largest STATE and most significant wildlife marshes in northern 

In October 1997, EPA, the State of Rhode Island and Rhode Island, and is a key stopover for migratory birds 

the Potentially Responsible Parties (PRPs) at the along the Atlantic flyway. The Army Corp of

Landfill & Resource Recovery Superfund site, entered Engineers is in the process of preparing plans to

into a settlement agreement which included a demolish the movie screens, remove the asphalt

commitment to purchase conservation easements parking lot, reconstruct wetlands and extend the

within the Blackstone River Valley National Heritage Blackstone River Park Bikeway. Remaining funds will

Corridor. This 380,000 acre corridor includes a string be used to purchase environmentally significant

of parks, museums, historic buildings and conservation wetlands, or create conservation easements near the

land along the Blackstone River covering 24 towns Superfund site.

from Worcester, MA to Providence, RI.

Page 9 

Beyond Compliance: Supplemental Environmental Projects 

CROZER CHESTER MEDICAL 

CENTER TEAMS WITH PUBLIC 

SCHOOLS TO CONQUER ASTHMA 

Within Pennsylvania’s

Chester-Upland Public

Schools, children with

asthma are receiving

treatment and education

about this devastating

disease. These students

were being diagnosed

with asthma at an

alarming rate, almost

twice the national

average. When the

Crozer Chester Medical

Center entered into a SEP agreement with EPA and

the Chester-Upland School District to resolve Clean Air

Act violations, the medical center agreed to implement

a comprehensive asthma detection and treatment

program in the Chester-Upland public schools. The

primary goal of this program was to reduce the long

term impact of asthmatic conditions in this student

population.

• increased exercise capacity 

• reduced time lost from school 

• reduced nocturnal asthma 

• reduced emergency room visits or hospitalizations 

• reduced effects from medications. 

Goals of the Asthma Management Program for 

children include: 

Under this program, all students in two successive

classes of grades 1, 6, and 11 are screened for asthma.

Depending on the diagnosis, a student suffering from

or at risk for asthma is placed in an appropriate

asthma management program. As a direct result of

these initiatives,

diagnosed students are

linked to medical care

programs designed to

enhance their asthma

management. The

students and their

families are educated to

improve daily asthma

management and to

reduce exposure to

environmental irritants. 

This SEP responds to a community-specific, environmentally-related need in this affected area. In

addition, it also meets the primary purpose of the SEP

policy—encouraging and obtaining environmental and

public health protection and improvements.

Page 11 
Beyond Compliance: Supplemental Environmental Projects 

SEPS FOR MULTIPLE FACILITIES: 

UNITED TECHNOLOGIES 

CORPORATION 

As part of a consent decree to resolve environmental 

violations at all of its New England facilities, United 

Technologies Corporation (UTC) agreed to perform 

two SEPs. The first SEP involves research into the 

replacement of chromium in their plating operations at 

Pratt & Whitney (a part of UTC), and the second SEP 

provides environmental restoration at Lord Cove, a 

large wetland in Connecticut. 

Preventing Pollution Using Innovative 

Technology 

Hexavalent chromium is used extensively in industrial 

coatings to protect metals operating at extemely high 

temperatures in harsh, corrosive environments. When 

released as a waste into the environment, hexavalent 

chromium is known to cause cancer and damage to 

DNA. Not only does Pratt & Whitney generate more 

than 10 tons of waste containing hexavalent 

chromium each year, its plating process generates 

thousands of gallons of acid and alkali rinse solutions 

which require treatment and disposal. New research 

into possible chromium substitutes or replacements 

could have far-reaching effects, not only for UTC, but 

also for the entire aerospace industry. 

UTC's first SEP allows for a systematic approach to 

developing and testing chromium substitutes. Pratt & 

Whitney, in conjunction with the University of 

Connecticut, has identified possible substitutes for 

chromium in various company operations. These 

include surface polymerized coatings, thin-film sulfuric 

acid anodized coatings, non-chromated conversion 

coatings, and nickel tungsten alloy electrodeposits. 

The testing and possible inclusion of these substitutes 

in manufacturing processes represent much needed 

change for the electroplating industry. 

This SEP will allow Pratt & Whitney to conduct 

ground-breaking research which may greatly benefit 

the environment. Because of the potential economic 

benefit to the company of a successful technology 

breakthrough, UTC has agreed that any first-year 

profits will be used to fund additional SEPs. 

Restoring Natural Environment on the 

Connecticut River 

The second SEP involves restoring tidelands on the 

Connecticut River by removing 200 acres of the 

invasive reed known as Phragmites australis. This SEP 

Page 12 
Beyond Compliance: Supplemental Environmental Projects 

will help reverse the damage caused by this invasive 

plant which is harming the native ecosystem and 

habitat. Lord Cove, an 1,100-acre brackish tidal 

marsh, is one of the core sites within the tidelands. 

Since 1968, the reed has taken over approximately 

half of Lord Cove and is considered to be an 

immediate threat to the marsh’s existence. UTC 

contracted with The Nature Conservancy to 

rehabilitate the marsh over a three-year period. The 

proposed completion date for this SEP is September 

2001. 

“one of the richest ecosystems in the northeast, 

providing habitat for hundreds of species, seven of 

them globally rare or endangered, and containing an 

extraordinarily unsullied wetland complex." 

The Nature Conservancy describes the tidal 

region of the lower Connecticut River as ... 

Page 13 
Protect and enhance 

the quality of the 

Nation’s air resources. 
Beyond Compliance: Supplemental Environmental Projects 

SETTING A GOAL BEYOND 

COMPLIANCE - U.S. MINT, 

PHILADELPHIA 

The first Clean Air Act penalty action EPA ever filed 

against a federal facility occurred on January 23, 1998 

in an administrative complaint against the U.S. Mint in 

Philadelphia, PA. The U.S. Mint is the world's largest 

manufacturer of coins, medals, and coin-based 

consumer products. The Philadelphia Mint facility is 

just one of two Mint facilities that creates the coins 

circulated for daily use in commerce. 

The administrative complaint was a result of a 1997 

inspection. During the inspection, EPA discovered 

violations of testing, monitoring, and operation and 

maintenance requirements for chromium 

electroplating. An additional violation included the 

lack of a certified technician being present during the 

servicing of equipment containing chlorofluorocarbons 

(CFCs). In order to come into compliance, the U.S. 

Mint upgraded the pollution control equipment for its 

chromium electroplating operations. As a SEP, they 

also agreed to install and operate a more efficient 

emissions control system for two hard chromium 

electroplating tanks, as well as a chromium strip tank. 

This system will significantly reduce chromium 

emissions beyond that required for compliance. 

Health risks associated with chromium compound air 

pollutants include lung cancer and other respiratory 

ailments. CFC emissions are believed to contribute to 

the depletion of the ozone layer which protects the 

Earth from harmful ultraviolet radiation. Loss of ozone 

may lead to an increase in skin cancer in humans, and 

cause damage to plant and animal life as well. 

Page 15 
Beyond Compliance: Supplemental Environmental Projects 

PROTECTING NEW YORK CITY'S 

CROTON WATER SUPPLY 

The drinking water supply for New York City and its 

surrounding counties comes from a large watershed 

spanning southern New York State. Drinking water is 

supplied by two providers, one of which is the Croton 

water supply. The Croton water supply consists of 10 

reservoirs and 3 controlled lakes which have the 

capacity to hold 95 billion gallons of water. Under 

normal conditions, this system provides 10% of the 

New York City water supply and up to 30% under 

drought conditions. Because of the dense population 

in this watershed, there is some concern about 

waterborne contaminants. 

In 1998, New York City agreed to build a filtration 

plant for its Croton Drinking Water System to reduce 

the risk of contaminants for its nearly one million 

residents. This agreement is part of a settlement that 

resolves Safe Drinking Water Act violations for failure 

to filter the Croton water supply. In addition, the City 

agreed to perform four watershed protection SEPs. 

The first SEP involves land acquisition in the Croton 

watershed area. The city has agreed to acquire fee 

title to or watershed conservation easements on 

vacant, undeveloped real property in the Croton 

watershed. This property will be kept in perpetuity in 

an undeveloped state to protect the Croton watershed 

and the New York City water supply. 

A second SEP addresses storm water runoff. Two 

communities, the Town of Patterson and the Village of 

Brewster, were chosen to participate in the study and 

in the implementation of storm water management 

district plans and necessary retrofits. 

The third SEP is the construction of a sewer line on the 

main street of the Village of Brewster which will 

connect to the wastewater treatment plant after it has 

been upgraded. The sewer line will make it possible 

to eliminate use of old, inadequate septic systems and 

eliminate potential contamination of leaks from those 

systems. 

The final SEP is a community project which will 

potentially impact the Bronx River. The city is 

currently in the process of seeking community input, 

and obtaining assistance from the Army Corps of 

Engineers. 

Page 16 
Beyond Compliance: Supplemental Environmental Projects 

REDUCING WATER POLLUTION 

IN THE CITY OF BALTIMORE 

As part of a settlement of Clean Water Act violations 

by city-owned filtration and wastewater treatment 

plants, the City of Baltimore, Maryland agreed to 

perform three SEPs. These SEPs are designed to 

improve water quality above and beyond what would 

be achieved by measures required to return to 

compliance. 

Controlling Pollution in Gwynns Run 

This pollution control project involves the construction 

of a storm water treatment system. The system 

consists of an artificially created wetland to slow the 

flow of water and precipitate out pollutants. It is 

located at the confluence of Gwynns Run and Gwynns 

Falls. 

Collecting Debris in Gwynns Falls 

For its second SEP, the City of Baltimore committed to 

installing a debris collection system along Gwynn Falls. 

This system will collect trash and debris and prevent it 

from being washed into the stream. 

Managing Storm Water in Brooklyn Park 

The third SEP involves installing a storm water pond in 

the Brooklyn Park area near the City of Baltimore. 

This pond, designed and built with appropriate flora 

and fauna, will collect storm water runoff to allow 

pollutants to precipitate out of the water. 

Page 17 
Beyond Compliance: Supplemental Environmental Projects 

DELMARVA POWER AND LIGHT 

RESTORES A WETLAND 

Delmarva Power and Light (Delmarva P&L) is a large 

electric power company with 198 distribution stations 

in the states of Delaware, Maryland, and Virginia. 

Delmarva P&L faced penalties for the discharge of oil 

by several of its facilities into rivers and other 

waterbodies. As part of the settlement for these 

Clean Water Act violations, Delmarva P&L agreed to 

conduct a SEP to restore a wetland. 

Delmarva P&L will restore approximately twelve acres 

of wetland in the Longfield area at the Blackwater 

National Wildlife Refuge in Cambridge, Maryland. 

The project involves excavating and grading the 

existing soil, and providing water control structures 

(i.e., pipes). When the project is completed, 

Delmarva P&L must provide expert documentation 

that the project has resulted in a functional wetland. 

This project is consistent with the Clinton 

Administration's Clean Water Action Plan, which has 

proposed a goal of no net loss of wetlands and, 

beginning in 2005, a net increase of 100,000 acres of 

wetlands per year. 

TOWN OF LURAY RESTORES 

STREAM QUALITY 

As part of its settlement for Clean Water Act 

violations, the Town of Luray, Virginia, agreed to 

perform a SEP which involved, among other actions, 

the restoration of a streambank in the town. Overall, 

the project consisted of the demolition and removal of 

the wastewater treatment facility and associated 

debris, the construction of a pond which is designed 

to collect runoff from a nearby parking lot, and the 

restoration of the native flora on the banks of 

Hawksbill Creek. The project will reduce erosion by 

stablilizing the streambank and help to improve the 

ecosystem affected by the violations. It will also 

enhance an open space area for the local community. 

Page 18 
Beyond Compliance: Supplemental Environmental Projects 

I

MPROVING WATER QUALITY IN 

THE CITY OF ATLANTA 

On September 24, 1998, the City of Atlanta, Georgia 

entered into an agreement that resolved Clean Water 

Act and Georgia Water Quality Control Act violations 

at all nine of its combined sewer overflow (CSO) 

facilities. CSO facilities discharge untreated 

wastewater directly to rivers, lakes, and estuaries 

during periods of heavy rainfall or snowmelt. These 

CSOs typically reduce water quality because they 

contain not only storm water but also untreated 

human and industrial waste, toxic materials, and 

floating debris. Because of this potential damage to 

water quality, the City of Atlanta agreed to perform 

two SEPs to cleanup and protect streams affected by 

CSOs as part of the settlement. 

Protecting Streams Through the Greenway 

Acquisition Project 

For this SEP, the City of Atlanta will acquire and 

maintain protected areas, called Greenway Properties, 

along selected portions of streams originating in or 

flowing through the City of Atlanta. The completion 

date for this project is March 31, 2007. 

Removing Debris Through the Stream 

Cleanup Project 

For this SEP, the City of Atlanta provided a one-time 

cleanup of trash and debris from the banks of selected 

streams affected by CSOs. 

Page 19 
Beyond Compliance: Supplemental Environmental Projects 

Concerns Regarding Environmental Justice 

These SEPs also included an environmental justice (EJ) 

component. Based on a preliminary analysis 

conducted in September 1998, EPA was concerned 

about the impact of CSOs on Atlanta’s minority 

and/or low income neighborhoods. The analysis 

demonstrated that two-thirds of the locations where 

CSOs occurred were in areas with minority 

populations exceeding 50%. In addition, seven of the 

nine CSO facilities were located in densely populated 

communities with minority populations ranging from 

82-100%. 

This EJ component of each SEP provided for the 

establishment of a SEP Advisory Committee (SAC). 

The City of Atlanta has selected a SAC from a broad 

cross-section of community stakeholders that includes 

minority representatives from neighborhoods impacted 

by the CSOs, community leaders, neighborhood 

planning units, business community leaders, and other 

interested community members. Under the terms of 

the consent decree, the SAC provides advice and 

recommendations to the City regarding suggestions 

from minority neighborhood groups in the 

development, management, and implementation of 

the Greenway Acquisition Project and the Stream 

Cleanup Project. Particular emphasis is placed on 

input from minority communities adjacent to 

designated streams and other streams affected by the 

discharges from the City’s CSO facilities. 

Page 20 
Beyond Compliance: Supplemental Environmental Projects 

SEWERAGE AND WATER BOARD OF 

NEW ORLEANS WORKS TO 

REVITALIZE LAKE PONTCHARTRAIN 

Through the 1970s, the Lincoln Beach area of Lake

Pontchartrain was known as a popular and safe

recreation spot. Families from the surrounding

neighborhoods used the beach and lake as a safe,

healthy place for swimming and other recreational

activities, such as fishing. By the early 1980s, however,

the lake became badly contaminated and could no

longer serve either purpose. Major sources of

contamination included both urban runoff from

surrounding areas, and overflows from New Orleans'

combined sanitary and storm sewer system. The

overflows occurred during storms which overwhelmed

the old system's capacity.

Prior to EPA's

involvement,

local

environmental

organizations

such as Save

Our Beach and

the Lake

Pontchartrain

Basin Foundation

went to great

lengths to establish conservation guidelines for the

neighboring communities. While water quality

gradually improved, bold efforts were necessary to

make greater improvements. 

In 1998, as part of the settlement for Clean Water Act

violations due to the old sewage system, the Sewerage

and Water Board of New Orleans proposed a SEP that 

would lead to the restoration of a viable fishery habitat 

and eventual re-opening of the Lincoln Beach recreation 

area. 

• Water quality improvement and public health 

protection. 

• Public access and use for education, recreation, 

swimming, and fishing. 

• Restoration, enhancement, and creation of 

wetlands and vegetative upland buffers and 

submerged aquatic beds. 

• Reduced runoff and erosion. 

The Sewerage and Water Board's specific goals 

for the Lincoln Beach SEP project include: 

To enhance the progress of water quality improvement 

in Lake Ponchartrain, the SEP included several 

measures: (1) planting submerged aquatic vegetation 

to serve as a habitat for native aquatic organisms and 

to enhance natural water quality; (2) constructing 

vegetative buffer zones on the lake shore to improve 

the quality of non-point source storm water runoff; and 

(3) enhancing wetlands through planting native wetland 

species. With their native indigenous ecosystems, these 

restored areas will also serve as an educational resource. 

In addition to these measures, the SEP includes the 

establishment of a unique continuous water quality 

monitoring system to track changes in the lake's water 

quality. After years of a community joining together to 

improve its environment, Lake Pontchartrain is on its 

way to again becoming a valuable recreational resource. 

Page 21 
Protect the Nation’s food 

supply from pesticide residues. 
Beyond Compliance: Supplemental Environmental Projects 

TREATING BALTIMORE’S INNER 

CITY CHILDREN WITH ASTHMA 

S.C. Johnson & Son resolved violations of the Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA) by 

paying a penalty and agreeing to assist the Asthma 

and Allergy Foundation of America (AAFA) with the 

purchase and staffing of a mobile asthma clinic (a 

Breathmobile®). Staffed by a physician, a nurse, and 

a respiratory therapist, the Breathmobile® will provide 

preventative health care as well as specialized asthma 

treatment to high-risk, inner-city children. The great 

advantage to this mobile asthma clinic is that it brings 

consistent state-of-the-art medical care to inner-city, 

underprivileged children right at their elementary 

school. These children would otherwise not have 

routine access to effective asthma care. 

Studies suggest that children who remain in the 

program for three visits experience improvement in 

their asthma health, therefore, the mobile asthma 

clinic will provide each child with at least three visits. 

This settlement resolves violations of FIFRA for 

allegedly selling and distributing an unregistered 

pesticide, which was marketed to allergy sufferers, and 

addresses both environmental justice and children’s 

health concerns involving allergies. The settlement 

supports the mobile asthma clinic for a full year of 

diagnosis and treatment. After one year of treating 

children, the S.C. Johnson &Son settlement 

anticipates that the mobile asthma clinic will be 

continued through the University of Maryland. 

Page 23 
“Citizens now have more information 

about releases of toxic emissions in their 

communities, which provides incentives for 

facilities to drive emissions down.” 

Innovation at the Environmental Protection Agency: 

A Decade of Progress, U.S. EPA, April 2000 
Beyond Compliance: Supplemental Environmental Projects 

ASHLAND OIL COMPANY SEPS 

REDUCE POLLUTION, EDUCATE, 

AND PRESERVE NATURE 

Through combined efforts involving EPA, Ashland Oil 

Company (Ashland), and state and local agencies, 

Ashland agreed to perform six SEPs to settle an 

enforcement action for environmental violations. These 

SEPs involve pollution reduction, environmental 

restoration, assessments and audits, and environmental 

compliance promotion. The SEPs are part of an unusual 

1999 settlement which involved three of Ashland’s 

geographically-dispersed petroleum refineries located in 

St. Paul Park, Minnesota; Canton, Ohio; and 

Catlettsburg, Kentucky. 

Reducing Local Environmental Impacts 

In two separate SEPs, Ashland agreed to provide for the 

installation of hydrofluoric acid detection and mitigation 

systems. Ashland agreed to these additional pollution 

reduction measures at both the St. Paul Park, Minnesota 

and Canton, Ohio facilities. Hydrofluoric acid is an 

extremely toxic compound that can cause severe burns of 

human tissue. The detection and mitigation devices 

provide additional protection for the surrounding 

communities, and go far beyond what is currently 

required by law. 

In a separate SEP, Ashland agreed to install upgrades on 

its Canton Refinery oil/water separator tanks. This will 

substantially reduce emissions of volatile organic 

hydrocarbons to the atmosphere, and thus reduce the 

smog in the area. 

Restoring Minnesota Prairie Lands 

The Grey Cloud Dunes area incorporates high terraces, 

sandy soil, prairie grasslands, and distinct species of plants 

growing on dunes on high banks above the Mississippi 

River. Ashland held ownership of 274 acres of this 

prairie, and local groups were concerned about the 

potential for industrial development which could destroy 

this unique ecosystem. As one of its SEPs, Ashland 

renovated the Grey Cloud Dune Prairie and donated it to 

the State of Minnesota. The state has dedicated the 

land, located near Cottage Grove, Minnesota, as a 

permanent scientific and natural preservation and study 

area. 

Promoting Environmental Compliance and 

Education 

Ashland teamed with the Salato Center in Frankfort, 

Kentucky, for an environmental compliance promotion 

and education program that provides training and 

technical support to small businesses, developers, 

industry, and the agricultural community. The program is 

designed to provide education on how to achieve and 

maintain compliance with the Clean Water Act and Clean 

Air Act, and about the potential benefits of pollution 

prevention or other measures which enable businesses to 

exceed environmental compliance requirements. 

Air Monitoring and Assessment 

In conjunction with the Commonwealth of Kentucky, 

Ashland agreed to conduct ambient air monitoring and 

analysis as part of a tri-state geographic environmental 

initiative involving Kentucky, Ohio, and West Virginia. 

Page 25 
Maintain the chemical, physical, 

and biological integrity of the 

Nation’s water supply. 
Beyond Compliance: Supplemental Environmental Projects 

ASARCO'S SEPS PROTECT 

PUBLIC HEALTH AND RESTORE 

WETLANDS 

ASARCO's lead refinery in Omaha, Nebraska, began 

operations during the end of the 19th century. 

Although this facility is now closed, over a century of 

operations resulted in contamination of the surrounding 

area by airborne lead particulates. As part of a 

settlement agreement for Clean Water Act violations, 

ASARCO agreed to implement SEPs to: (1) create, 

restore, or improve the ecosystem of the Missouri River 

into which the plant discharged; and (2) explore and 

mitigate potential public health problems related to its 

past operations. 

Improving the Ecosystem of the Missouri 

River Watershed 

The first SEP focused on reversing wetland losses in the 

Missouri River corridor. Protecting and restoring the 

nation's wetlands have been a major EPA goal during 

the last decade. Because the Missouri River corridor 

had substantial wetland losses which afflicted many 

river basins, this SEP contributed to the on-going effort 

to reverse those losses, partially through the 

development and implementation of a wetland 

restoration plan for sites along the river corridor. 

To implement this SEP, ASARCO assisted the PapioMissouri Natural Resources District (District) with the 

purchase of approximately 475 acres adjacent to 

property the District already owned. The new land was 

used to restore, enhance, or create wetlands in the river 

corridor, and to expand an existing protected wildlife 

area. The District carried out restoration and sampling 

activities to assess the effectiveness of restoration 

efforts at four sites along the Missouri River. 

Assessing and Protecting Public Health 

ASARCO’s second SEP focused on assessing public 

health risks due to the long-term airborne lead 

contamination problem. The Omaha/Douglas County 

Health Department was selected to measure both 

current blood lead levels in children and evaluate 

possible health impacts. The blood level sampling was 

completed, and the results led to further sampling. The 

additional sampling included both blood levels in 

vulnerable children and measures of lead levels in soils, 

homes, and at daycare facilities. Superfund cleanup 

actions have been initiated to remove contaminated 

soils from the yards at some daycare facilities that were 

particularly impacted. 

Page 27 
Beyond Compliance: Supplemental Environmental Projects 

BROWNFIELDS CLEANUP BY 

SHERWIN-WILLIAMS 

As part of its 1997 consent decree to resolve 

environmental violations, the Sherwin-Williams resin 

and paint facility in southeast Chicago agreed to 

perform two SEPs to improve the environment in the 

surrounding community. Sherwin-Williams chose to 

clean up a Brownfields site on Chicago's southeast side 

and to restore a wetland in the southeast area near 

Lake Calumet. The combined environmental benefits 

to the community came from not only the SEPs but 

also from the changes in facility operations (e.g., 

reduced VOC emissions due to changes in the paint 

production process) required to ensure future 

environmental compliance. 

Cleaning Up a Brownfields Site 

Sherwin-Williams contracted with the City of Chicago 

to redevelop a Brownfields site in the Victory 

Heights/West Pullman section of the city. The 130-

acre site, which is about a mile from the SherwinWilliams plant, contains vacant, partially demolished 

factories and is crisscrossed with active and inactive 

railroad tracks. The surrounding neighborhoods are 

primarily minority. There are community groups 

dedicated to the restoration of this area. Of particular 

interest in this case is that the SEP addresses 

improving the quality of life for people who have been 

and will be affected by any pollution generated by the 

Sherwin-Williams facility. 

"SEPs are an innovative way of leveraging a 

community's resources to successfully address 

environmental issues by complementing their 

Brownfields program." 

Department of Environment. 

"We believe such projects can be effective tools in 

addressing issues of environmental justice in lowincome and minority communities." 

attorney for Citizens for a Better Environment. 

Using SEPs at Brownfields: 

Dave Reynolds, City of Chicago 

Stefan Noe, 

Wetlands Restoration 

The second SEP involves wetlands restoration in the 

Indian Creek marsh near Lake Calumet, which is also 

near the Sherwin-Williams facility. The company 

contracted with Open Lands, a local environmental 

group completing the marsh restoration. The project 

includes cleanup and protection of the existing 

habitat, planting, maintenance, and upkeep. 

Page 28 
Beyond Compliance: Supplemental Environmental Projects 

SIMPSON PAPER COMPANY 

RESTORES SALMON HABITAT 

After declining for many years, the salmon population 

in three creeks in Humboldt County, California, is 

recovering due to the positive results of SEPs 

performed by the Simpson Paper Company. On 

January 6, 1995, EPA and Simpson entered into an 

Administrative Order which ended an EPA 

enforcement action for Clean Water Act violations at 

Simpson's Humboldt pulp mill located on the Pacific 

Ocean in Humboldt Bay, California. As part of the 

settlement, Simpson agreed to perform three SEPs to 

restore the salmon spawning habitat in three creeks: 

Salmon Creek, Long Prairie Creek, and Terwer Creek. 

With mutual interest in restoring the migratory fish 

habitat, EPA and Simpson easily agreed to use the SEP 

policy, making the negotiation process relatively simple 

and straightforward. These SEPs complemented EPA's 

ongoing efforts to protect water quality and habitat of 

northern California watersheds. 

Enhancing Salmon Creek’s Riparian 

Corridor 

To enhance the survivability of salmonids in Salmon 

Creek, Simpson successfully planted an estimated 500 

conifers in riparian zones along the stream. It is 

anticipated that as the cover matures, branches and 

trees will eventually fall into the stream providing 

good salmon recruitment areas and hiding areas as 

pools with adequate cover are formed. 

Creating Quality Spawning Habitat in 

Long Prairie Creek 

Once suffering from limited pool depth and a lack of 

escape cover, the Long Prairie Creek is again becoming 

quality spawning habitat. By implementing this SEP, 

Simpson increased pool depth and the rearing habitat 

in existing pools by appropriately placing large logs or 

rootwads within the channel. Where possible, only 

natural anchoring techniques were used to place the 

logs. 

Improving Rearing Habitat in Terwer Creek 

After witnessing little spawning and a lack of riparian 

vegetation, edgewater cover, and stream channel 

stability within the Terwer Creek canyon, Simpson 

used this project to improve the juvenile rearing 

habitat in this stream. The project involved placing 

logs in areas that would provide ideal spawning 

habitats for the salmon. Habitat restoration projects 

along these streams are expected to yield immediate 

short term and long term improvements in habitat for 

relatively small capital outlays. 

Page 29 
Reduce global and 

cross-border 

environmental risks. 
Beyond Compliance: Supplemental Environmental Projects 

I

NTERNATIONAL COOPERATION ON 

A POLLUTION PREVENTION SEP 

This SEP, involving General Instruments’ facility in El 

Paso, Texas, and Transportation Electronics’ facility in 

Juarez, Mexico, is the first example of a cooperative 

effort between EPA and PROFEPA, the enforcement 

arm of Mexico's environmental protection agency. 

Wastes from the Mexican maquiladora plant were 

shipped to the staging facility in El Paso, Texas. From 

there, wastes were shipped to treatment, storage, and 

disposal facilities in the United States. General 

Instruments and Transportation Electronics violated the 

Resource Conservation and Recovery Act by using an 

unlicensed transporter to take wastes from Juarez to El 

Paso. When EPA took enforcement action against 

both General Instruments and Transportation 

Electronics, the companies agreed to perform a 

pollution prevention SEP at the Juarez facility. 

The SEP addresses a manufacturing process at the 

maquiladora plant where the facility purchased and 

placed into operation three Inert Gas (Nitrogen) Wave 

Solder machines to replace the existing solvent-based 

machines. By using solvent-free flux, no process 

water is necessary, resulting in a 100% reduction of 

the plant's wastewater discharge from solder 

operations. Use of the new machinery and the 

solvent-free flux greatly reduces the risk of employee 

exposure during solder operations, as well as 

optimizing the use of the solder, and reduces the byproduct solder dross, which is a hazardous waste. 

Because the Juarez facility was not in violation of any 

Mexican law, the SEP provided a means of bringing 

about a significant voluntary environmental 

improvement. 

Page 31 
Reduce or eliminate 

the generation of 

hazardous wastes. 
Beyond Compliance: Supplemental Environmental Projects 

SAFE DRINKING WATER FOR THE 

CITY OF SANDPOINT, IDAHO 

After two years of work, the City of Sandpoint, Idaho 

can now offer its residents clean, safe drinking water. 

Prompted by EPA in 1998, Sandpoint began to take 

appropriate actions to address public concerns about 

unsafe water quality caused by the city's ineffective 

water pretreatment program. In the same year, 

Sandpoint proposed an environmental restoration and 

protection SEP as part of resolving an EPA 

enforcement action for SDWA violations. The SEP 

would protect and improve the quality of Sandpoint’s 

public drinking water supply. 

Protecting Drinking Water Through Land 

Acquisition 

To both improve the quality of its drinking water and 

help protect it from potential contamination, 

Sandpoint purchased 60 acres of land that lies within 

the city's watershed. Two sources of the city's 

drinking water, Little Sand Creek and Lake Pend 

Oreille, are located within this newly-acquired land. 

To preserve the land and protect these drinking water 

sources, Sandpoint put all the necessary easements 

and covenants in place. These actions and the 

continued success of this project will provide safe 

drinking water to the residents of Sandpoint for years 

to come. 

REDUCING WASTES AT 

SPECTRUM GLASS 

On April 25, 2000, the Spectrum Glass company 

located in Woodinville, Washington, agreed to 

perform a pollution prevention/pollution reduction 

SEP as part of resolving an EPA enforcement action 

for environmental violations. This SEP requires 

Spectrum Glass to conduct a two-year pilot project to 

determine the feasability of directly reusing glass 

cullet, currently a waste product containing 

chromium, manganese, and zinc. The company 

intends to reuse approximately 986,000 pounds of 

cullet each year, which is at least 8% of the cullet 

currently generated. Thus, by reusing the cullet, less 

waste containing these metals will be disposed. 

To evaluate the effectiveness of the SEP, Spectrum 

Glass will report on costs of the SEP and any lost 

profit margin; percent reduction in use of sodium 

bichromate, manganese dioxide, and zinc oxide; 

percent reduction in hazardous materials landfilled; 

and percent cullet reused each year. 

While this project is expected to result in some lost 

profit margin for Spectrum Glass, the pollution 

reduction gains benefitting the environment and 

public health will be significant. 

Page 33 
Beyond Compliance: Supplemental Environmental Projects 

PSC PRESERVES AN ECOSYSTEM 

AND REDUCES AIR POLLUTION 

In 1992, Public Service Company (PSC) purchased the 

Hayden Station. This 440-megawatt power plant, 

which sits in the Yampa Valley of Colorado, is located 

19 miles upwind of the Mount Zirkel Wilderness Area. 

At the time of the purchase, Hayden Station operated 

with no controls for nitrogen oxides or sulfur dioxide, 

and emitted extremely high levels of both pollutants. 

In 1993, the local Sierra Club sued PSC over opacity 

violations caused by the Hayden plant and the adverse 

effects of the plant's emissions on the wilderness area. 

EPA subsequently sued PSC for additional violations of 

the Clean Air Act at the Hayden Station. 

In negotiations with EPA and the Sierra Club, PSC 

agreed that it would conduct two environmentallybeneficial projects in the Yampa Valley. While PSC 

suggested the idea of the SEPs, which all parties feel 

helped to resolve the litigation, the Sierra Club 

suggested the specific elements of the SEPs. The 

parties reached agreement on the SEPs in May 1996. 

PSC placed funds for the projects in escrow accounts 

managed by the Sierra Club. Both SEPs have now 

been completed. 

Preventing Ecosystem Damage 

This SEP focused on the preservation of the Yampa 

Valley ecosystem. The Sierra Club used the escrowed 

funds to purchase land in the Yampa Valley for 

conservation easements to prevent development 

which would damage the Valley ecosystem and the 

nearby wilderness area. Initially, the Sierra Club 

focused on the possibility of purchasing key parcels of 

land to prevent the development of a planned ski 

resort, which could have brought an additional 20,000 

visitors to the Valley. However, this purchase was not 

necessary because, after extended negotiations, the 

developer chose to build 20-30 high-end private 

houses rather than the ski resort. This decision was 

spurred by local opposition in the Valley, the expiration 

of the developer's permits with the Forest Service, and 

tax incentives for the developer. 

Consequently, the Sierra Club was able to use the 

escrowed funds to purchase a large ranch located next 

to the Yampa River. The land, approximately 1,000 

acres, was deeded to the Yampa Valley Trust. Because 

this land is at the base of a national forest, its 

purchase is critical to preservation of the ecosystem. 

“The parties saved themselves and taxpayers money 

by negotiating rather than continuing to litigate. 

sides compromised and reached a settlement that 

ensures improved air quality in the Yampa Valley and 

nearby Mount Zirkel Wilderness Area." 

Former EPA Regional Administrator, May 22, 1996. 

This agreement makes sense because ... 

All 

Patricia Hull, 

Page 34 
Beyond Compliance: Supplemental Environmental Projects 

Reducing Air Pollution 

Under the second SEP, PSC placed funds into an 

escrow fund to promote conversion of wood-burning 

stoves to natural gas or propane. In this case, the 

Sierra Club used the escrowed funds to assist the 

county health department, which administered the 

conversion of almost 400 wood-burning stoves to 

either propane or natural gas. For low-income 

families, the full cost of the conversion was covered; 

for others, there were subsidies. The SEP helped the 

county resolve the nonattainment problems for 

particulate matter, and it has recently been redesignated as attaining the air quality standard. The 

health department has been extremely pleased with 

the results. This SEP demonstrates that pollution 

prevention SEPs are not restricted to cutting edge 

technology. 

Page 35 
Beyond Compliance: Supplemental Environmental Projects 

RESTORING FISH HABITAT IN 

MONTANA 

In March of 1999, CONOCO Pipeline Company and 

the Yellowstone Pipeline System, which is operated by 

CONOCO, came to an agreement with EPA on 

penalties resulting from a 1992-93 oil spill into Camas 

Creek on the Flathead Indian Reservation in Montana. 

As a SEP, CONOCO agreed to construct fish 

passageways on the Jocko River, which is located 

within the same watershed as Camas Creek. The goal 

of the passageways is to enhance the growth of the 

threatened bull trout population and to preserve a 

genetically pure population of westslope cutthroat 

trout, which is Montana's state fish. When 

completed, the passageways will be owned and 

operated by the Confederated Salish and Kootenai 

Tribes. 

This SEP involved several parties, including EPA, the 

Department of Justice, the companies, the Fish and 

Wildlife Service, and the Tribes. From discussions 

among the parties, one positive outcome was the 

groundbreaking progress made in Tribal relationships. 

The design of the SEP was largely due to input from 

the Tribes during the SEP negotiations. While others 

will also benefit from this SEP, the Tribes will receive 

substantial rewards from the fish passageways. 

PROTECTING ALASKAN 

WETLANDS 

As part of the settlement for violating the Clean 

Water Act, the Quality Asphalt Paving, Inc. will 

transfer affected wetland property to the state parks 

department for protection and management. Barriers 

will be built to limit access and promote natural 

restoration of the site. 

Page 36 
Beyond Compliance: Supplemental Environmental Projects 

CONCLUSION 

The SEPs described in this booklet are but a small 

sampling of the projects undertaken as part of EPA’s 

environmental enforcement settlements. While these 

projects have significant monetary value, the true 

value of these projects lies in the impacts that they 

have on public health and/or the environment actually 

or potentially affected by the violation. SEPs offer a 

unique opportunity to achieve additional 

environmental improvements that are in addition to 

what is required for violators to return to compliance 

with environmental regulations. 

In going beyond what is required to settle an 

enforcement action, SEPs help the Agency meet its 

long-term, Congressionally-mandated goals. For 

example, projects that reduce emissions of pollutants 

or eliminate their production have a positive effect on 

the local community’s air quality. SEPs that involve 

health screening and treatment for children affected 

by the pollution can improve public health 

dramatically. Restoration projects that return 

wetlands to their natural state not only provide habitat 

for endangered and other species, but allow for 

natural filtration of pollutants and flood control. 

Because the benefits to the community and the 

environment that can be obtained through SEPs can 

be significant, the Agency encourages their use in 

settlement agreements. Additional information on 

SEPs and the SEP policy may be found at 

www.epa.gov/oeca/sep. 

Page 37 
United States

Environmental Protection Agency

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Washington, DC 20460

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