June 1, 2026
3:00PM - 4:00PM

Environmental Hot Topics Track

Compliance Audits, Ratings, and Penalties

Speaker: Aaron Hebert

In this session we will discuss the Audit Privilege and how to ensure you are preparing your disclosure properly:

·       The citation related to the violation is critical because it will be used to determine repeat violators even if the violation is not really a repeat issue for the same EPN.

o   The importance of the citation identified on the disclosed violation. Examples of best practices.

·       The use of Audit Privilege disclosures on the site’s compliance history ratings.

·       Pros and cons of grouping disclosure items.

The compliance history review period will be discussed:

·       This is the period when companies can review their information before it is published.

·       Review the site’s complexity score because it will impact their compliance rating.

o   Facilities are seeing lots of errors. The higher the complexity the less each violation will impact their compliance rating.

·       Did you know you get “credit” for reporting violations (found and reported under the Audit Privilege) in your score?

·       Don’t assume someone else is reviewing the compliance history…

The calculation of penalties using TCEQ’s guidance will be discussed:

·       How the TCEQ estimates penalties, with examples.

·       The effect of repeat violations on penalties.

·       How much of the penalty estimate is subjective?