Compliance and Enforcement Annual Results:
National Enforcement Investigations Center and Homeland Security Highlights

FY2006 Annual Results Topics

National Enforcement Investigations Center

The National Enforcement Investigations Center, EPA's Forensics Science Division, is a state-of-the-art, fully accredited forensics center internationally recognized in forensic environmental chemistry. NEIC scientists, engineers, and environmental professionals provide expert support to both EPA's civil and criminal enforcement programs through compliance monitoring and engineering evaluations, forensic laboratory analysis, information management, computer forensics, and courtroom testimony.

Support for National Enforcement Priorities

During FY 2006, NEIC continued providing scientific forensic support to the Enforcement Program's National Enforcement Priorities. For example, NEIC provided technical expert support to the civil enforcement program for two important components of the national petroleum refinery priority -- benzene National Emission Standards for Hazardous Air Pollutants (NESHAPs) and Leak Detection and Repair. NEIC supported compliance monitoring investigations, case development, and development of injunctive relief and settlement negotiations, including those associated with the recent agreements with ConocoPhillips, Exxon Mobil, Sunoco, and Valero. NEIC also provided support for the wet weather national priorities, including settlement negotiations support for the Environmental Management System (EMS) provision of the City of Dallas storm water control settlement.

Application of Information Forensic Analysis Techniques to Compliance Investigations

Large-scale petrochemical manufacturing facilities can contain over 100,000 pieces of regulated process equipment which may leak air toxics and Volatile Organic Compounds (VOCs) to the atmosphere, thereby contributing to the formation of ground-level ozone. Leak detection and repair (LDAR) regulations affect almost all U.S. industry processes in which VOCs are used or manufactured. NEIC has expanded its investigation tools to include innovative information forensic techniques which allow previously-unexplored compliance areas to be evaluated in order to help identify noncompliance. For example, NEIC can model emissions from data collected onsite in order to evaluate the validity of company-reported emissions data.

NEIC innovation in leak detection and repair compliance investigations has encouraged several companies to enter global settlement negotiations to resolve both LDAR and other Clean Air Act compliance issues. As manufacturing facilities continue to rely more heavily on computerized processes for environmental monitoring and reporting, NEIC continues to develop specific techniques to collect and evaluate this detailed and often sizeable amount of data. As a result, NEIC has expanded these techniques into other media and manufacturing sectors, including pharmaceuticals, polyvinylchloride (PVC) plants, cement processors, and other chemical manufacturing facilities.

EPA Forum on Environmental Measurements

NEIC served on the EPA Forum on Environmental Measurements (FEM) Method Validation Team, which develops Agency-wide guidance for validating and peer reviewing EPA methods prior to publication for general use. During FY 2006, the Team produced the final document "Validation and Peer Review of U.S. Environmental Protection Agency Chemical Methods of Analysis" which was posted on EPA's website. The document provides Agency-wide guidance for EPA personnel who will evaluate the performance and suitability of new chemical methods of analysis before EPA publication. The method validation principles are based on current, international approaches and guidelines for intra-laboratory (single laboratory) and inter-laboratory (multiple-laboratory) method validation studies.

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Homeland Security Program

The Office of Enforcement and Compliance Assurance's Homeland Security Program (HSP) provides criminal investigative and scientific support, including forensic evidence collection at crime scenes involving hazardous materials and laboratory analysis, to other law enforcement agencies in response to suspected terrorist incidents. The HSP also provides intelligence gathering, analysis, and threat assessment assistance to the National Joint Terrorism Task Force and the Homeland Security Operations Center .

Homeland Security-related Training

The HSP provides training in environmental crime investigations emphasizing forensics evidence collection techniques for crime scenes involving hazardous materials and drinking and wastewater infrastructure protection. During FY 2006, the Homeland Security Program National Counter Terrorism Evidence Response Team conducted three training events to meet the requirements of the Homeland Security Cross-Goal Strategy of the EPA Strategic Plan. The training focused on critical drinking water and wastewater treatment facilities infrastructure protection; response and recovery; communication and information; and the protection of EPA personnel.

The HSP also trained 65 EPA special agents during the first two of six scheduled "Hot Zone Forensic Training" courses for EPA criminal enforcement investigators. This two-year training program is designed to enhance the basic forensic skills and sampling capabilities of criminal enforcement special agents. These enhanced skills are expected to increase the quality of scientific evidence collected during the course of a criminal environmental investigation.