The enforcement response plan (ERP) contained herein provides a framework for determining the appropriate response for violations of the Washington Suburban Sanitary Commission’s (WSSC’s) industrial and special waste regulations. This ERP is not intended to cover all violations or responses.

As a general rule, all noncompliances will be addressed through the issuance of a notice of violation (NOV). Repeat industrial user or single waste hauler violations may subject the violator to WSSC citations carrying fines of $250.00, $500.00, $750.00, or $1,000, increasing in cost with each violation until compliance has been demonstrated. Continued violations will result in escalated enforcement action.

Continuing violations, which cause the violator to be in significant noncompliance (SNC), or those violations which in any one instance constitute SNC, will subject the violator to a NOV, public notice in a newspaper(s) of general circulation that provides meaningful public notice within the jurisdiction(s) served by WSSC, and depending on the type of violation, increased self-monitoring.

In circumstances where an industrial user is in SNC for two consecutive evaluation periods, they will be subject to formal enforcement action in the form of an administrative order.

In those instances where standard enforcement responses are ineffective in compelling compliance, a referral will be made to the WSSC’s General Counsel’s Office or to the appropriate state or federal law enforcement agency for appropriate legal action.

This ERP will be reviewed and revised every five years, and the Maryland Department of the Environment’s (MDE’s) approval will be sought prior to implementation of the revised plan (Industrial discharge control program enforcement response plan, dated April 22, 2013)