United States      Solid Waste and
         Environmental Protection   Emergency Response   EPA530-R-95-037
         Agency        (5305W)         July 1995

SEPA   Community-based

         Environmental Protection

         OSWER Action Plan



  Community-based Environmental Protection (CBEP) brings the government closer to the
  people it is meant to serve.  Instead of addressing environmental problems piecemeal, statute
  by statute, and then applying a one-size-fits-all solution, CBEP addresses environmental
  problems in the context of the community in which they occur.

  Community-based Environmental Protection is not a new activity, isolated from the day-to-
  day work of the U.S Environmental Protection Agency (EPA). Instead, it is a new wav of
  accomplishing our traditional tasks in a more effective, more responsive manner.

  On February 15, 1995, the Deputy Administrator of EPA asked each Region and each
  natirtnal rwrwYfowi nffl^a. *. J,,~i__	A	_i_ _  *         .      .          * ~wu
  In response to this request, the Office of Solid Waste and Emergency Response (OSWER)

  SI^FP  IT*1 STC1V? ,detSmine hW to *TOVQ our Proce*ses * order to
  f * CBff   Wejf.ceiv^ useftil feedback, including suggestions to improve information
  access, increase flexibility of Regional commitments, and to encourage economic
  development by easing fears of Superfund liability.  Several OSWER activities already
  planned for the next few years will respond to these suggestions, and follow-up work to
  evaluate the success of these activities will ensure OSWER continues to be responsive.

  The goal or the OSWER action plan is to identify initiatives to reduce regulatory and policy
  barriers to CBEP, to make the information communities need more accessible, and to provide
 useful technical assistance and training in support of CBEP.                          .

 The following report details how OSWER will be supporting Regional, state tribal and  local

           baSed '0**' AfteF               Of *e att*butes of CBEP and  a
 nmi         -    ,
 or UbWER s role, the action plan presents current, short-term, and longer-term OSWER
 activities to support Community-based Environmental Protection.

 EPA has identified five attributes of Community-based Environmental Protection

 Five attributes of Community-based Environmental Protection are:

 Definable geographical area: This could include urban areas, ecosystems, neighborhoods
 counties, tribal lands, etc.                                                    ***,

 Involvement of stakeholders: A community-based effort should seek to involve those
 affected by the environmental problems being addressed.

 Multi-media, cross-program coordination.-  Community-based efforts should assess
 environmental problems across all relevant media, and coordinate implementation across
multiple environmental programs.                                           f*v

Collaboratively-developed environmental goals:  Specific, measurable environmental goals
are key to focusing and sustaining community-based efforts.

Monitoring, evaluating outcomes, and adapting management over time:  As most community-
based efforts are complex, flexibility must be built into the system in order to make changes
over time, based on monitoring and evaluation.

Most OSWER programs are implemented at the community level.

The Office of Solid Waste and Emergency Response (OSWER) provides policy, guidance,
and direction for the Agency's solid waste and emergency response programs.  OSWER
develops guidelines and standards for hazardous waste treatment, storage, and disposal, and
for underground storage tanks. OSWER funrshes technical assistance in the development,
management, and operation of solid waste activities.  OSWER also implements programs to
respond to active and abandoned hazardous waste sites and accidental releases (including
some oil spills)  and to encourage the use of innovative technologies in cleanup activities.
Finally, OSWER manages a program to oversee and assure stakeholder involvement in the
cleanup of Federal facilities.

All these programs can play a key role hi a community-based environmental protection
effort.  The environmental problems they address are almost always at the community level;
they  are by nature multi-media, potentially affecting the soil, air,  surface water and ground
water;  and they usually have a public outreach effort.

However, CBEP strategies go beyond traditional community involvement efforts.
Community-based efforts  must empower and equip the community to participate in
environmental decisions, taking into account not only the human but also the ecological and
socioeconomic health of a place.  CBEP strategies convert the  simple implementation of
statutorily driven programs into "tools" that communities can use to address multiple
environmental problems at once.  Increased efficiency, improved results;, and direct
community input are major goals of CBEP strategies.

OSWER programs are now looking to make that second leap to achieve community-based
environmental protection. For example, the Brownfields Economic Redevelopment Initiative
brings  communities into the decision process for cleanup of contaminated land.  Under this
initiative, cities  promote economic development of abandoned urban areas in ways that work
best for mem, by bringing together residents, businesses, lenders and developers.

The role of National Program Office is to provide the flexibility and technical assistance
needed to implement CBEP efforts.

The role of the  National Program Office (i.e. OSWER Headquarters) is not to actually
implement community-based efforts.  CBEP will be implemented at the local, state, tribal
and occasionally Regional levels. Instead, this action plan identifies areas in which OSWER
must provide the Regions, the states, tribes and the local governments with the flexibility and
technical assistance they need to implement the national programs in the: context of CBEP.

Flexibility will allow the best possible use of the OSWER programs' statutory authority as
tools to achieve community-based environmental protection. Some OSWER programs
already provide  considerable flexibility to the states in implementing national standards.
Further, the Underground Storage Tank (UST) program, the Chemical Emergency
Preparedness and Prevention (CEPP) program, the Resource Conservation and Recovery Act

                                        Page 2

  (RCRA) hazardous waste permitting program and the RCRA municipal solid waste landfill
  program are almost wholly delegated to the states.

  The UST program has built and relied on partnerships with state and local programs for
  implementation.  To make the UST regulatory program less burdensome, EPA based its
  regulations on performance standards, rather than on specific technologies, thereby providing
  states and owners/operators flexibility in meeting requirements. EPA also phased-in specific
  program requirements to allow states  and owners/operators time to develop programs and
  plan financial resources.  In addition, EPA has provided states with the flexibility to set their
  own clean-up level  for UST corrective actions, allowing site-specific  risk-based decisions.

  The CEPP program is tasked with facilitating local efforts to prepare  for aiid respond to
  emergencies. Operating as  a bottom-up,  community-based program,  OSWIER works in direct
  partnership with State Emergency Response Commissions (SERCS) and Local Emergency
  Planning Committees (LEPCs) to reduce  hazards and prevent accidents.  Current technical
  assistance, guidance, and grants to states  and LEPCs will maintain effective program
  implementation at the local level.  In a recent survey of LEPCs, 79% were found to be
  functioning and mostly compliant with key provisions of EPCRA.  Additional tools for
  successful emergency planning such as computer aided models, publications and peer
          programs have been developed by the CEPP program and are currently used by
 The RCRA Subtitle C hazardous waste management and permitting program has always been
 available for state implementation. Almost every state has been delegated the base RCRA
 hazardous waste program.  About half the states have also been delegated new portions of the
 hazardous waste program which resulted from changes in the RCRA statute in 1984   The
 states are very capable in implementing hazardous waste programs.  Because of the states'
 expertise and experience in the hazardous waste program area, OSWER is looking at wavs to
 delegate new RCRA rules to states in a more expedient manner than in the past.

 The RCRA Subtitle D municipal solid waste landfills (MSWLFs) program is entirely
 implemented by states.  OSWER published the "Solid Waste Disposal Facility Criteria" (Part
 258), a set of standards prescribing how MSWLFs are to be designed and operated OSWER
 also developed the State/Tribal Implementation Rule (STIR) that established criteria and
 procedures for review and approval of state landfill permit programs. The STIR also extends
 to Native American tribes the same opportunity available to states.  Most states have adopted
 and implemented MSWLF permitting programs.

 However, allowing flexibility goes beyond state authorizations or state program aDorovals
 To implement  CBEP,  OSWER must first ensure that its policies, regulations,, and planning
processes do not hinder community-based efforts.  In  the past, OSWER programs  have been
 seen as creating barriers  to community efforts in several ways. The OSWER planning and
budgeting process has  in the past stressed national program goals at the expense of local
environmental  goals.  Fixed clean-up standards can fail to take into account local conditions
In addition, the fear of RCRA and Superfund liability can shut down voluntary efforts  to   "
minimize waste and clean up contamination.
                                       Page 3

To help overcome these barriers, OSWER has begun to examine its current activities to see
if they allow adequate flexibility (while still ensuring minimum national standards necessary
to protect human health and the environment).

But simply allowing flexibility is not enough.  OSWER must also ensure that the tools it
provides support local, state, tribal and Regional CBEP efforts.  Several existing technical
assistance programs in OSWER are aimed at facilitating local environmental protection
programs.  OSWER programs offer assistance to communities in form of fact sheets,
newsletters, workshops, technical training, hotlines and other public outreach materials
explaining OSWER program requirements. Grants for technical assistance are awarded
directly to the states to address local priorities.  In addition, the Superfund Technical
Assistance Grants (TAGs) encourage community participation in the technical aspects of
Superfund clean-ups.

To further facilitate community-based efforts, OSWER is looking to improve its technical
assistance/training, information management, and grant programs to assist others in
implementing community-based efforts.  By receiving feedback from our customers (e.g.
Regional and state and tribal programs), OSWER can improve its processes to facilitate
community-based efforts.

The remainder of this Action Plan report discusses OSWER's current, near-term and longer-
term activities to overcome barriers and to promote and support Community-based
Environmental Protection.
                                       Page 4



 Brownfields Economic Redevelopment pilots will support creative demonstrations of local
 redevelopment solutions.

 At least fifty Brownfields pilots will be funded in 1995 and 1996, at up to $200,000 each.
 These pilots will help:

        1) test redevelopment models by directing special efforts toward removing regulatory
        barriers without sacrificing protectiveness;

        2) encourage community groups, investors,  lenders, developers and other affected
        parties to come together to clean up contaminated sites and return them to appropriate
        productive use;

        3) provide a series of redevelopment models for states and localities struggling with
        such efforts; and

       4) provide guidance to cities for cleaning up and returning contaminated, abandoned
       industrial Brownfields to productive use.

 To date, three pilots have been initiated, twenty-two more pilots will be announced by the
 fall of 1995, and twenty-five more will be selected in 1996. These two-year pilots will
 provide concrete data for a national policy discussion about what  works, along with a series
 of models for states and  localities faced with similar challenges.

 Expanded performance partnership agreements give states more flexibility in implementing
 environmental programs.

 Grant Flexibility Demonstration Projects in Regions 1 and 8 combine several grants
 [including UST and RCRA grants], thus allowing states to allocate according to highest
 environmental priority. OSWER is also participating in Agency efforts to draft language for
 authorizing legislation and develop implementation plans for more expanded performance
 partnership agreements.

Flexibility in setting Regional performance commitments will facilitate CBEP programs in
the Regions.

Regions will be encouraged to use the flexibility in  the RCRA Implementation Plan (RIP)
process and the Superfund Comprehensive Accomplishments Plan  (SCAP) to help meet the
Regional CBEP budget goal of 20 %.
                                       Page 5

EPA cooperative agreements encourage economic development and waste reduction through

       EPA has sponsored three cooperative agreements to address urban and rural
Municipal Solid Waste (MSW) recycling.  These initiatives seek to demonstrate regional and
local economic development and waste reduction through the use of recycled materials.
Specifically, the projects will develop new businesses and convert businesses to use
recovered materials; launch scrap-based and manufacturing enterprises; create jobs; create
markets for recovered materials; increase recycling-related investments; increase tax
revenues; reduce disposal costs; and examine the relationship among recycling programs,
market development, and community economic growth.

       The three cooperatives agreements include:  the EPA/Philadelphia Partnership,
Philadelphia, Pennsylvania; the Institute for Local Self-Reliance (ILSR) - National Capital
Area Project, Washington, D.C., Baltimore, Maryland, and Richmond, Virginia;  and the
Rural Jobs Through Recycling  and Integrated Waste Management Project- Land-of-Sky
Regional Council  (LOSRC), Ashville, North Carolina.

       As with many other OSWER community-based efforts, these projects are designed to
further the concept that communities' environmental protection and economic development
goals can both be addressed.
                                       Page 6

Technical Assistance/Training

Job training initiatives help build local workforce expertise to revitalize contaminated

EPA is working with the Hazardous Materials Training and Research Institute (HMTRI) to
expand training and curriculum development to at least twenty community colleges located
near Brownfields pilots.  Partnerships have already been established with many community
colleges, such as the Cuyahoga Community College in Cleveland and the Rio Hondo
Community College in Los Angeles, to foster workforce equity through environmental
education, vigorous recruitment of students of color, and high quality worker training.

EPA has also developed a Memorandum of Understanding (MOU) with the Department of
Labor to link the two agencies' respective local contacts at Brownfields pilot  sites to focus on
local workforce development. In addition, EPA and the National Institute of Environmental
Health (NIEHS) will be implementing a minority Superfund Worker Training Program,  a
pilot program for the recruitment and training of young persons who live in the inner city.

In addition, EPA has created the National Environmental Teacher's Institute at Morgan State
University and four Regional Institutes in Connecticut, Maryland, Ohio and Virginia.  The
U.S. Department of Energy also provide funding for this effort. The purpose of this effort is
to raise environmental awareness of teachers at communities impacted by hazardous waste
and environmental justice problems, in order to empower citizens through Mler participation
in environmental decision-making.

IP A's to states and municipalities help develop Brownfields programs.

Three EPA staff members have been assigned to cities, by inter-governmental personnel
assignment (IPA) to help develop Brownfields programs.  Two are assigned to the city of
Chicago, IL and one to the city of Detroit, MI.  This is a mutually beneficial arrangement,
providing cities with technical assistance  and EPA staff with practical experience. This will
be expanded to at least one IPA per Region during 1995.

Other OSWER technical assistance programs will continue to build state and local
environmental protection capacity.

Several existing technical assistance programs in OSWER aimed at facilitating local
environmental protection programs will continue. For example, RCRA technical assistance
and training will include workshops on enhancing public participation in the RCRA
permitting process.  Grants for technical  assistance are awarded directly to the states to
address local priorities.  In addition, Superfund Technical Assistance Grants (TAGs) will
continue  to be key in encourage community participation in the technical aspects of
Superfund clean-ups.
                                       Page 7

Information Management

"CERCL1S 3" recognizes the importance of easy information access in maicing decisions
for cleaning up sites.

CERCLIS 3, a modern, integrated information system, is being designed to support the
evolving needs of the Superfund program. CERCLIS 3 will offer its users a  "total site
picture11 support with conveniently integrated management tools. It will enable Superfund
staff to share comprehensive, reliable data across EPA Regions and Headquarters, and,
eventually, with other Federal Agencies and the public.

The Waste Information Needs (WIN) Initiative will determine the information and
technology needs of the future for the RCRA program.

The Waste Information Needs (WIN) Initiative has been established to reexamine the role of
information  and technology  in the ongoing business of regulating and overseeing hazardous
and solid waste management.  Information management has been identified as one of the key
tools needed for community-based environmental protection efforts.  OSWER will be
working in partnership with the states to evaluate waste information data and  technology
needs and to develop an Information Strategy Plan (ISP) to identify the needs of the future.
OSWER, working with the Regions and states, will coordinate national meetings (to be held
during the month of June), to develop the ISP.  The Association of State and Territorial
Solid Waste  Management Officials (ASTSWMO) will be coordinating the state support for
this project.

CAMEO and LandView Information Management Systems provide tools to local planners to
respond to chemical emergencies

A number of initiatives involve enhancing access to information to Local Emergency
Planning Committees (LEPCs), the 3,500 local entities established under Title ffi or EPCRA,
which join stakeholders at the community level in examining community risk.

LandView II, an innovative  "community right-to-know" software tool presents information
from five EPA databases, displayed on maps together with demographic and economic
information from the Bureau of the Census. LandView allows communities to evaluate
environmental risks and identify areas of concern for environmental justice.  This work grew
from CAMEO (Computer Aided Management of Emergency Operations), software developed
jointly by EPA and the National Oceanic and Atmospheric Administration to  assist the
management of information  now available to local communities through the Emergency
Planning and Community Right-to-Know Act.  In partnership with RTK Net, a non-profit
on-line information system,  CAMEO and LandView can enhance the community's access to
information and their use of that information to examine issues in their own neighborhoods.

In addition, the Risk Management Plans which certain facilities will be required to  prepare as
part of the Clean Air Act Amendments will be available to LEPCs and will provide
considerably more very specific information on risks of accidents in the community.  This
will require development of a system simply and easily accessible by LEPCs and others.
                                       Page 8

 Removing 24,000 sites from the CERCLIS inventory will help communities redevelop
 abandoned sites.

 Of the 39,000 sites in CERCLIS (EPA's inventory of known or potential Superfund sites),
 OSWER has determined that 24,000 sites do not currently warrant further Superfund
 involvement, based on available information, and have been screened out of the current

 Historically,  a negative stigma has often been attached to all sites hi CERCLIS, due to the
 potential for Superfund liability. However, the majority of sites that have been evaluated by
 OSWER have been found to not warrant further Superfund consideration. Thousands of
 these sites have been found to not be contaminated at all, while others are being cleaned up
 under state programs.    .

 As part of the Brownfields Action Agenda, OSWER is in the process of removing those sites
 which do not warrant further Superfund involvement from me CERCLIS inventory.  This
 removal will  help correct the market distortion that has made inclusion in CERCLIS an "
 impediment to redevelopment.   OSWER is also working to improve public access to site
 assessment data collected at these sites.

Increasing public access to information can provide the tools needed to conduct
community-based environmental protection.

Current and future efforts to increase access to OSWER information can provide the tools
needed to conduct environmental protection.  The latest efforts include placing a wide variety
of information about hazardous and non-hazardous solid waste on the Internet for access and
retrieval by the general public.   Examples of information available on the Internet include a
booklet  on safer disposal of solid waste, the universe of combustion facilities, and
information on hazardous waste storage, treatment  and disposal facilities.
                                       Page 9

Guidance/Regulations/Proposed Legislation

Developing and implementing tools to remove liability-based barriers to Superfund clean-
ups will encourage communities to clean up and reuse contaminated property.

OSWER will be supporting the Office of Enforcement and Compliance Assurance (OECA) in
identifying options and developing tools to remove liability-based barriers to clean-up of
contaminated sites.  For example, new guidance has been developed on Prospective
Purchaser Agreements in order to expand the circumstances under which EPA will enter into
agreements,  promising not to file a lawsuit against a prospective purchaser of contaminated
property for the contamination that existed before the purchase.  In addition, guidance will
also be developed to clarify the liability  of municipalities who acquire contaminated property
and of owners of property  located above contaminated aquifers.  Finally, EPA will issue
guidance to explain the policy that lenders who do not actively participate in the day-to-day
management of a facility will not be pursued for clean-up costs.

Issuing guidance on future land use in Superfund remedy selection process should result in
greater community involvement in and  support for remedies selected.

OSWER will issue a directive presenting information for considering laind use in making
remedy  selection decisions under CERCLA at National Priorities List (NPL) sites.  EPA
believes that early community involvement, with a particular focus on ithe community's
desired future uses of property associated with the CERCLA site, should result in a more
democratic decision making process; greater community support for remedies selected as a
result of this process; and more expedited, cost-effective cleanups.

Efforts to increase public participation  and stakeholder involvement give local communities
a greater voice in waste program activities.

OSWER has many efforts underway to increase public participation in waste program
activities.  For example, OSWER is encouraging Community Action Groups (CAGs) at
Superfund sites to promote early, direct, and meaningful public involvement in the Superfund
clean-up process.  CAG guidance is currently undergoing Regional review.  In a  similar
effort, EPA  and the Department of Defense (DOD) have issued joint guidelines and  are
conducting training sessions on establishing Restoration Advisory Boards (RABs) to enhance
community development at closing installations.  In addition, OSWER  proposed a public
participation rule on June 2, 1994, entitled RCRA Expanded Public Participation and
Revisions to Combustion Permitting Procedures to encourage earlier, more meaningful public
involvement in the RCRA  permitting process.
                                       Page 10

 The Siting Workgroup is looking at options to increase community involvement in siting

 The Siting Workgroup is evaluating current siting procedures in ten states and meeting with
 stakeholders involved in Environmental Justice issues in order to find ways to improve the
 siting of hazardous waste facilities.  In particular, the group  is looking at options to increase
 community involvement and awareness of siting actions early in the process, especially prior
 to the submittal of permit applications. The group is also exploring ways to consider the
 environmental impacts of proposed facilities on communities which already host more than
 one hazardous waste facility.

 Under the proposed  "Post-Closure Rule," authorized states  would have more flexibility in
 cleaning up regulated hazardous waste land disposal units.

 Current ground water monitoring and closure/post closure requirements are more stringent
 for regulated hazardous waste units than for other types of solid waste management units.
 This distinction is often purely administrative, as the two types of units  can contain similar
 types of wastes, and  in many cases are located in close proximity.   The proposed "Post-
 Closure Rule," if finalized, would allow regulators, on a case-by-case basis, to address clean-
 up of regulated units using the more flexible corrective action regulations for solid waste
 management units, which can take into account actual site conditions.

 Proposed rule would give states flexibility to allow the use of alternative monitoring
 methods at small municipal landfills.

 EPA is drafting a proposed rule that, if finalized, would provide approved states and Tribes
 with the flexibility to allow the use of  alternative monitoring  methods at small municipal
 landfills located hi dry/remote areas on a site-specific basis.   This would help alleviate the
 regulatory burden imposed by ground-water monitoring well requirements and free up
 resources to direct towards other  environmental efforts of higher priority to the community.

 Proposed Subtitle C Tribal Authorization  Rule will give Tribes flexibility \\n implementing
 hazardous waste programs.

 OSWER is currently drafting a proposed rule which will allow Tribes to apply for
 authorization of the Subtitle C hazardous waste program. The proposed rule provides Tribes
 the flexibility they need in order to  be able to obtain authorization by allowing authorization
 of partial hazardous waste programs. For example, Tribes which do not wish to be
 authorized  for permitting authorities may still obtain authorization for generators and
transporters.   This rule will allow Tribes to apply for funding to manage their own
hazardous waste program in lieu of the Federal government,  thereby enabling the Tribes to
participate  more in environmental decisions.
                                        Page 11

Tools for risk-based decision-making build flexibility into the VST corrective action

OSWER and the Regions will actively promote the development and implementation of risk-
based decision-making processes in state Underground Storage Tank (UST) programs through
information sharing and technical assistance.  Risk-based decision-making is a process that
state UST programs can use to make determinations about the extent and urgency of
corrective action and about the scope and intensity of their oversight of corrective action by
UST owners and operators.  This will provide a tool for states to build flexibility into their
UST corrective acaon programs, one which is conceptually and operationally compatible with
CERCLA remedial and RCRA corrective action programs.

Several uses of risk-based decision-making include but are not limited to: categorizing  or
classifying sites; aiding in the establishment of cleanup goals; and deciding on levels of
oversight in UST owners and operators. This will encourage the use of UST cleanup goals
that are compatible with broader community goals.

New OSWER exposure model can be used to assess lead exposure from several different

OSWER has developed a new model for evaluating lead exposures called the Integrated
Exposure Uptake Biokinetic Model (IEUBK).  This model allows the risk manager to assess
the contribution of different sources of environmental lead (e.g. lead from drinking water,
paint and household dust) to overall blood lead levels.  It allows a flexible approach to
considering risk reduction measures that would have the greatest impact on reducing blood
lead levels to people hi the community.

Superfund Reform Act emphasizes a CBEP approach.

In 1994, the Superfund Reform Act (SRA) was introduced to reauthorize Superfund with
provisions emphasizing economic redevelopment, community involvement and outreach, and
remedy  reform. These provisions  will help convert the Superfund program into a tool for
Community-Based Environmental Protection by fostering state program development,
promoting environmental justice, addressing worst sites first, and emphasizing construction

 Economic  Redevelopment Through Greater State Involvement
 An important focus of the Superfund program will be increased state involvement in the
 cleanup process.  The Agency intends to defer sites to the states and provide increased
 technical assistance as the states compel Potentially Responsible Party (PRP) response  under
 state authorities.  The Agency will enter into Core Program cooperative agreements with
 states to assist them in building and strengthening then-  own Superfund programs.  Providing
 the states with this assistance will enable states to address many of the sites that the Agency's
 Superfund program would otherwise have to delay while remediating higher risk National
 Priority List (NPL) sites.  In forging partnerships with the states, the Agency will increase
 the number of hazardous waste sites addressed and put to productive use, while enabling
 EPA to focus on the  most critical sites.
                                        Page 12

Outreach Activities/Environmental Justice
Hie goals of the program's environmental justice and community involvement and outreach
efforts are to address concerns pertaining to the societal equity of EPA's responses at
Superfund sites and enhance communities' access and input to site information. Over the
next five years, Superfund will enhance information access and outreach, increasing the
communities' understanding of site response plans and actions. The communities will then
have the additional information needed to take an active and informed role  in the  remediation

Remedy Reform/Worst Sites First/Construction Completions
While moving the program closer to a community-based approach, the SRA improves the
pace and quality of protection. By the year 2000, Superfund plans to reach 650 site cleanups
by completing an additional 372 construction completions. This cleanup goal will be reached
in part through the use of streamlined cleanup  techniques,  including presumptive remedies,
and the Superfund Accelerated Cleanup Model (SACM).  Through the SRA, the removal
authorities will expand and therefore increase the number of removals performed at both
NPL and non-NPL sites.  Utilizing removals over long term response actions will maximize
resources while minimizing the duration of cleanup activities.  Speeding up cleanups will
allow the community to more quickly put Superfund sites to  productive use.
                                       Page 13


Implementing Community-based Environmental Protection will be an iterative process, as we
learn from the early attempts to implement this new way of doing business.  A key part of
OSWER's long-term strategy will be to build on lessons learned.

For example, as the fifty Brownfields pilots progress through remedy selection and site
clean-up,  the information learned will be shared with other communities and possibly even
integrated into future Superfund reforms.  Similarly, knowledge on waste information
technology and data needs gained through current efforts can be applied to make the
information management systems more useful and accessible.  In addition, as OSWER
proceeds through the regulatory review process, additional possible changes to regulations to
provide more flexibility to state and local governments may be discovered.

Another key long-term activity will be to coordinate more closely with the other EPA
Program Offices. For example, OSWER will investigate the possibility of coordinating more
across headquarters on Regional commitments (i.e. Memoranda of Agreement or program
equivalent), on state grants, and on sharing environmental information.  In addition, there
may be other cross-program issues such as ground water protection that may require

Finally, the most important long-term strategy will be to respond to feedback on OSWER
efforts from its partners and customers.  Because OSWER does not directly implement
community-based efforts, the success of the strategy will be difficult to measure directly.  It
will only be by receiving feedback from the Regions, states and local communities that we
will know if regulatory and policy barriers to community programs have been lessened, if the
information needed is accessible, and if the technical assistance and training is useful.


This Action Plan was developed with direct Regional input and is the first step in responding
to their needs.  OSWER's role in Community-based Environmental Protection will be to
remove any barriers the national programs inadvertently introduced into the process, and to
provide guidance, technical assistance, training and information support where it is needed.
This role will not involve creating new activities, but rather performing current activities in
ways that are more supportive of Regional, state and local CBEP efforts;.

The next step in the process will be to solicit more customer feedback on the  activities
mentioned in the OSWER Action Plan.  As the Regional plans  are submitted, OSWER may
be better able to tailor this Plan to the Regions' specific needs.  In addition, feedback from
state and local governments will help determine if OSWER efforts are headed in the right

This Action Plan is a living document.  As the activities listed here are implemented,
adjustments may need to be made and new directions taken. However, the most important
objective will continue to be enhancing OSWER processes so they betteir promote and
support Community-based Environmental Protection.
                                       Page 14