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The water crisis in Flint highlights the challenge that cities face in order to provide clean drinking water: balancing the declining nature of our nation’s drinking water infrastructure and the funding needed to replace it. It is a difficult challenge that some cities handle better than others. Though the public outcry in Flint has been loud, it is thought-provoking to consider how the response might have been completely different a few years ago. Much has changed in the last 20 years to allow access to information that wasn’t available before. For example, Kentucky maintains the Drinking Water Watch, an online database where anyone can download information about their local drinking water systems, including sampling results and any violations.

Public access to information has resulted in greater pressure for violations to be punished. If there was any doubt as to increasing seriousness with which infractions of environmental regulations are enforced, the situation in Flint provides a clear example. Authorities have criminally charged one local official and two state officials in connection with the water crisis. Michael Glasgow, the city’s laboratory and water quality supervisor, recently pleaded no contest to a misdemeanor count of willful neglect of duty. By pleading guilty, a felony charge of tampering with evidence will be dismissed. Mr. Glasgow was charged with altering a July 2015 report to exclude data from two test sites. The change, which was made at the insistence of the two state officials, lowered the average lead levels below the threshold that required notification of affected residents.

Those with responsibility to certify and submit monitoring reports must be aware that we have entered an era of accountability. No longer are monitoring results sent off to pile up in the corner of a regulator’s office. Violations can easily be identified in almost real-time by anyone with an internet connection. But because 40 CFR 122.22, requires that all certifications are made “under penalty of law”, submitting false information may result in “significant penalties…including the possibility of fine and imprisonment for knowing violations”.

William Shane is an Environmental Engineer at Smith Management Group. William can be reached at williams@smithmanage.com.

May 24, 2016

Local Limits Allocation Methods and Duration

May 23, 2016


May 13, 2016

EPA Requires Energy Producers to Reduce Methane





A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.


SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.

SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.


SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.