NOV and Consent Order Resolution
Notice of Violation and Consent Order Resolution
You have a great compliance program; you are doing everything right, but…
In spite of your best efforts, you may find yourself with a Notice of Violation (NOV) or Consent Order that requires expert handling. Storage tank violations under the federal and many state UST programs carry penalties up to $11,000 per day per violation – that can add up fast.
While most companies may turn to their legal counsel for assistance, the help of a technical expert like the professionals at JD2 can be invaluable at mitigating the findings of the agency on your behalf. Some NOVs may not even require legal assistance depending on how the agency administers its program.
A thorough understanding of the regulations is required in order to evaluate the nature of the violations and interpret the agency’s position on the issue at hand. Proper resolution of an NOV may just require the right technical explanation of the circumstances at your facility.
By working with the technical and regulatory experts at JD2, you will be able to better understand the nature of the violations, be able to develop corrective action programs to address the regulatory needs and better yet, mitigate the penalty that may be associated with the NOV.
JD2 has developed relationships with regulators throughout the United States and has the experience to know how to address the sensitive issues that an NOV may represent.