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Index to Guidance for Compliance Screening

Index to Guidance for Compliance Screening for Project XL

I. Introduction

II. Eligibility to participate in Project XL

A. Purposes of screening for eligibility to participate in Project XL:

B. Criteria for screening for eligibility to participate in Project XL:

1. XL participation should be deferred until the following problems are resolved, or sufficient time passes:
a. Criminal activity by project sponsor

b. Planned, pending or ongoing enforcement action at facility.

c. Currently debarred or suspended company
2. The following factors should be considered on a discretionary basis in determining eligibility:
a. Prior history of noncompliance at facility (violations now resolved)
b. Overall environmental compliance history of project applicant
c. Pending or ongoing citizen suits

III. Updating compliance status of XL project participants prior to high-visibility recognition events

A. Purposes of updating compliance status of XL project participants prior to high-visibility recognition events:
B. Criteria for updating compliance status of XL project participants prior to high-visibility recognition events:
1. Participation by Agency officials in a recognition event should be deferred until the following problems are resolved, or sufficient time passes:
a. Criminal activity by project sponsor
b. Planned, pending or ongoing enforcement action at facility.

IV. Process for compliance screening
A. Process for conducting Compliance screens:

1. Conduct of screen for eligibility to participate in Project XL
OR Lead
2. Conduct of screen for updating compliance status of Project XL participants prior to high-visibility recognition events
a. OR Lead
b. Regional Lead

B. Process for Decision making about the effect of screening findings:

1. Decision-making on eligibility to participate in Project XL
2. Decision-making on updating compliance status of Project XL participants prior to high-visibility recognition events
3. Procedure for deviating from this guidance

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