Standardized Reporting Requirements and Operating Procedures for Environmental Notices of Violation and Regulatory Agency Site Visits

It is Postal Service™ policy to comply with all applicable local, state, and federal environmental regulations. A notice of violation (NOV), or similarly entitled actions, such as a warning letter or a notice of noncompliance, is issued to the Postal Service for failure to comply with an environmental regulation. These actions can be issued from a local, state, or federal agency and may occur as the result of a site visit or inspection by the respective agency.

Examples of noncompliance actions include, but are not limited to, the following:

n The issuance of an NOV from a state environmental protection agency for a Vehicle Maintenance Facil­ity’s noncompliance with the state’s underground storage tank regulations.

n The issuance of a notice of noncompliance from a state environmental agency for the improper disposal of hazardous waste generated by a postal worker or contractor working at a postal facility.

n A warning letter issued by a state department of envi­ronmental protection for storm water violations.

Environmental Notices of Violation and Similarly Entitled Actions

The Office of Environmental Compliance and Risk Man­agement, Office of Sustainability, is standardizing the tracking and reporting of all NOVs within the Postal Ser­vice. Tracking NOVs will ensure that timely and necessary actions are taken to respond to NOVs and that certain crit­ical NOVs are referred to the Law Department, and it will assist in trend analysis to determine internal compliance-focused activities.

When an installation head or a facility department project manager becomes aware of an NOV, or similarly entitled action, issued by a local, state, or federal agency, he or she must send an electronic copy of the NOV to the respective regional manager of Environmental Compliance and Sustainability within 5 days of receipt.

Environmental Agency Inspections and Site Visits

The installation head or his/her designee must follow the Postal Service’s “Standard Operating Procedure for Envi­ronmental Agency Inspections and Site Visits” to ensure appropriate authorization and facility compliance during environmental agency inspections at postal facilities. For more information on this procedure, visit the “Compliance at My Facility” page on the Office of Sustainability website at http://blue.usps.gov/sustainability/environmental/compliance_requirements.htm

Similarly, the installation head must report visits and site inspections by a local, state, or federal environmental reg­ulatory agency to the respective regional manager of Envi­ronmental Compliance and Sustainability immediately, regardless of whether the site visit is announced (pre-scheduled) or unannounced.

Office of Sustainability Points of Contact

For environmental regulatory agency visits and NOVs generated in the Northeast, Eastern, and Capital Metro areas, and Headquarters-related facilities, send an email notification and/or electronic copy to Nick DeCarlo, Regional Manager Environmental Compliance and Sustain­ability at Nicholas.Decarlo@usps.gov

For environmental regulatory agency visits and NOVs generated in the Great Lakes, Western, Southern, and Pacific areas, send an email notification and/or electronic copy to Larry Hanna, Regional Manager Environmental Compliance and Sustainability at Larry.J.Hanna@usps.gov

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