EPA and enforcement discretion policy associated with COVID-19
April 13, 2020

In law, selective enforcement occurs when government officials such as regulators exercise enforcement discretion, which is the power to choose whether or how to punish a person who has violated the law. During this time with the COVID-19 Virus Pandemic, EPA has decided to apply enforcement discretion in certain cases.

This is not a policy to allow operators to pollute, but to allow some leniency/flexibility during the Pandemic to operate until a return to normal operations. As such, our customers should try to do their best to keep operating as normal and document any areas where they failed in compliance.

 

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What does “enforcement discretion” mean for my company?

The consequences of the pandemic may constrain the ability of regulated entities to perform routine

  • compliance monitoring,
  • integrity testing,
  • sampling,
  • laboratory analysis,
  • training,
  • reporting,
  • certification

 All enforcement discretion set forth in this temporary policy is conditioned on the following.

  1. Entities should make every effort to comply with their environmental compliance obligations.
  2. If compliance is not reasonably practicable, facilities with environmental compliance obligations should:
    1. Act responsibly under the circumstances in order to minimize the effects and duration of any noncompliance caused by COVID-19;
    2. Identify the specific nature and dates of the noncompliance;
    3. Identify how COVID-19 was the cause of the noncompliance, and the decisions and actions taken in response, including best efforts to comply and steps taken to come into compliance at the earliest opportunity;
    4. Return to compliance as soon as possible;
    5. Document the information, action, or condition specified in a. through d.

 

Why partnering with Cimarron?

Cimarron is a leading manufacturer of engineered production, process, and environmental equipment for the upstream and midstream energy industries. We bring decades of engineering, design, manufacturing and service experience to our customers with product capabilities that include separation, treating, conditioning, and environmental compliance. As a process systems specialist, Cimarron assists customers with producing oil and natural gas in a safe and environmentally responsible manner.

Our environmental products and services include the following:

  • BTEX combustor unit for glycol dehydrators
  • Mobile glycol reclamation system
  • Vapor Recovery Units (VRU)
  • Vapor Recovery Towers (VRT)
  • Flares
  • Enclosed Combustion Devices (ECD)
  • Leak Detection and Repair (LDAR) services
  • Vent gas measurement services
  • Field service
  • Parts

 

Contact Cimarron now to find out how we can assist your operations, at 1 (844) 746-1676 or q4!W=?rKfN~x}/L#7V]#[epl9.VV1T+qkmxUi%D for details.