Annual Self Audit Report Holly talked about her work with the State in reviewing, questioning and changing the report so that it could be understood by everyone involved. She also discussed the issues surrounding formal and informal enforcement actions and the need for policy decisions to be put in place. Focus needs to be made on looking at the model enforcement plan, making comments, and everyone here trying to reach agreement on it. There was a general discussion on data collection and reporting. What is appropriate for facilities with de minimus requirements.
Training Stated goal is to identify specific areas of training needed most by CUPAs.
Enforcement A discussion of administrative enforcement orders. OES was identified as responsible for elements of Chapter 6.95 and DTSC as hazardous waste enforcement. Discussion centered around DTSCs definitions of formal vs. informal enforcement actions, Class I, II, etc. for reporting purposes. A discussion of Villagarosa's actions to investigate and report on CUPA enforcement followed. The tape ran out at this point and the adjournment was missed.