United States       Office of Planning      April 1979
  5814       Environmental Protection    and Management
           Agency         Washington DC 20460
&ER&     EPA Policy Guidance
           for FY 1980/1981

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         EPA POLICY GUIDANCE
          FOR FY 1980/1981
U,S,  ENVIRONMENTAL PROTECTION AGENCY
           WASHINGTON,  D,C,
             APRIL 1979
                             Co a

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 ADMINISTRATOR'S POLICY GUIDANCE



             1980/1981
DOUGLAS M, COSTLE, ADMINISTRATOR





BARBARA BLUM, DEPUTY ADMINISTRATOR

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                  EPA POLICY GUIDANCE
                   FOR FY 1980/1981
TABLE OF
CONTENTS

ADMINISTRATOR'S/DEPUTY ADMINISTRATOR'S
      POLICY GUIDANCE  	  ,    3

ASSISTANT ADMINISTRATORS' OVERVIEWS

     AIR, NOISE AND RADIATION	11

     WATER AND WASTE MANAGEMENT	16

     TOXIC SUBSTANCES	  .  .  .   20

     ENFORCEMENT	35

     RESEARCH AND DEVELOPMENT   	   42

     PLANNING AND MANAGEMENT    	   48
                         ill

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             ADMINISTRATOR'S POLICY GUIDANCE
     EPA and State and local agencies can be proud of what
they have accomplished over the last two years.  We have
won strong legislative mandates, and we are making good
progress in implementing them.  EPA is better  integrated,
and we have begun the process of strengthening our State
and local relationships.  We are making good progress in
developing effective controls for toxics.  In  area after
area we are recognized front-runners in the Administration's
reform efforts.  The air and the water are getting cleaner.
The people, the President, and the Congress support our
work: they respect both our professionalism and our
ability to get a tough job done.

     This Guidance addresses the future.  But  before we
go on to define what lies ahead, we wanted to  note how far
EPA has come.  The Agency has been working hard and well.
Congratulations and our thanks.

     In this Agency Policy Guidance we identify what we
feel the Agency's priorities should be for the next
several years.  Our Assistant Administrators follow with
more detailed guidance for each of their areas of respon-
sibility.  We have worked closely with them in developing
these program guidances.

     Broadly stated, the Agency's priorities are as
follows:

     o  To reduce public exposure to dangerous
        pollutants;

     o  To protect sensitive ecological systems;
        and

     o  To improve management of our environmental
        programs.
REDUCE PUBLIC EXPOSURE TO DANGEROUS POLLUTANTS

     Over the last several years we have come to understand
more of the connections between the thousands of chemicals
our society has put into our environment and a great many
of the diseases that afflict modern man.  EPA has been
given lead responsibility for identifying, evaluating,
and controlling environmental pollutants.  Doing so is one

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                           - 4 -

of our chief objectives.  We are approaching the problem at
every point -- when a chemical is produced, shipped, used,
or ultimately disposed of.  Our Toxics, Air, Water,
Pesticides, Drinking Water, Radiation, Hazardous Waste,
and spills programs must all give the toxics problem
greater priority.  In doing so we expect that all action
on individual pollutants should generally be governed by
the principle of addressing first those that present the
greatest health risks.  A major part of that effort has
been the development of an integrated strategy for toxic
substances, a strategy which we will continue to develop
and refine throughout 1980 and 1981 through vigorous
implementation of the Toxic Substances Control Act.

     As another element of an Agency-wide toxics strategy,
we will develop an Agency cancer policy.  The policy
will provide a framework for continuing decision-making
in our pesticides, toxics, and drinking water programs
and for emerging carcinogen regulations under the Agency's
air, water, and hazardous waste programs.

     Finally, our urban strategy is a key part of this
effort because it is based on attacking the unhealthy
environmental conditions of cities.  We expect the
Assistant Administrators and you to continue to implement
our existing urban initiatives and to develop innovative
solutions for urban problems.

PROTECT SENSITIVE ECOLOGICAL SYSTEMS

     Increasingly during the past two years, we have
focused the Agency's efforts on dealing with pollutants
as they affect public health.  Ultimately, however, we
must protect the environment that supports us and all
other life.  While continuing to clean up our air and
water, we need to give much more attention to particularly
sensitive environmental systems such as wetlands.  Though
natural systems like wetlands and fisheries are usually
described as renewable -- on the assumption that they can
regenerate themselves when depleted or damaged -- we are
beginning to learn how fragile they truly are as we begin
to understand sensitive ecological relationships.  Once a
groundwater supply is contaminated with toxics, for
example, it may take centuries for natural restoration
(or millions of dollars for clean-up) if it is ever to
support healthy natural life or to be used for drinking
water.

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                           - 5 -

IMPROVE MANAGEMENT OF OUR ENVIRONMENTAL PROGRAMS

     We have made a major commitment to finding better,
more effective ways of regulating.  There are almost fifty
reform efforts in progress across the Agency now.  We are
beginning to see the results of this commitment, and we
expect a great many more initiatives to move into
implementation stages over the next several years.  We
will continue to look for complements to traditional
regulation, such as offsets and the bubble, our reporting
requirements, sunset, and procedural simplifications.  We
want your active help in finding better ways to carry out
our responsibilities.  Specifically, we want to continue
to:

     o  Integrate EPA programs — We have made a good
        start in our efforts to consolidate our grant
        and permit programs.  The integration of programs
        in water quality, drinking water, solid waste,
        hazardous wastes, and underground injection can
        serve as a good model for other program areas.

     o  Strengthen Federal/State/local partnerships --
        Establishing the State/EPA Agreements and
        encouraging appropriate delegation should streng-
        then and improve environmental programs at all
        levels.  We also need to retain and improve our
        ability to assess performance at all levels.  We
        want to work for passage of an Integrated Environ-
        mental Assistance Act as a legislative base for
        increasing management flexibility between us and
        the States as well as in State programs.

     o  Improve coordination with other Federal agencies —
        We must make greater use of the IRLG and Regulatory
        Council mechanism to assure coordinated and
        concerted action among all Federal agencies.  We
        must work particularly closely with the Department
        of Energy in developing environmentally and health
        sensitive energy policies.

     o  Reform and refine our management practices --
        In this area we are emphasizing the completion of
        Civil Service reforms recently enacted.  We must
        also put in place the planning, zero-based
        budgeting accountability system for the Agency.

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        In addition, we are reassessing our monitoring
        with an eye to the quality, utility and compati-
        bility of our information systems.

     o  Improve regulatory reform -- We are giving major
        emphasis to the development of more flexible, less
        costly alternatives to our traditional regulatory
        approaches, such as the "bubble" concept and
        "banking" of offsets in nonattainment areas.  We
        want to continue improving the quality of our
        regulations.  One of the most important elements
        to the latter is continued strengthening of the
        Steering Committee; we want to enlarge the role
        of the Regions in this process.

     o  Strengthen the Agency's research capacity and
        programs -- We want to improve our ability to
        forecast environmental problems and solutions,
        particularly in the long term.  We need to expand
        the data base for our regulatory decision-making.

     Finally, there are a number of cross-cutting issues
we want to flag.  We expect:

     o  a strong commitment to improving public partici-
        pation;

     o  a determined affirmative action program; and

     o  continued attention to the Administration's
        urban programs.
     The 1980-1981 planning years present a great challenge
to us as managers.  We must continue to move this Agency
toward protecting public health and the environment more
fully.   We expect that each participant in this planning
will consider how his or her program can contribute to
these initiatives.

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     The following sections of this Guidance set forth our
priorities in greater detail.  They serve as the basis for
FY 1980 Federal and State program implementation and as
the policy framework for program and resource recommen-
dations to the President for FY 1981.
                                  DoJuglSTs M. Costle
                                  Administrator
                                  Barbara Blum
                                  Deputy Administrator

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ASSISTANT ADMINISTRATORS' OVERVIEWS
      AIR, NOISE, AND RADIATION



      WATER AND WASTE MANAGEMENT



      TOXIC SUBSTANCES



      ENFORCEMENT



      RESEARCH AND DEVELOPMENT



      PLANNING AND MANAGEMENT

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         OFFICE OF AIR, NOISE, AND RADIATION

     Overview Statement of Priorities and Goals

      David G. Hawkins, Assistant Administrator


PUBLIC PARTICIPATION AND INFORMATION

     Each OANR program plan should include resources and
should plan for effective participation.  Limited resources
should also be available for case-by-case assistance to
participants in a small number of major rulemaking and/or
permit proceedings.

     I would also like OANR offices to work with Regional
Offices to develop effective public participation programs
for their activities.

     Finally, each office should review existing public
information materials in its area of responsibility.
Program plans should provide for major improvements in
our information base and should include a system for
keeping our public information materials current.  Please
work with our Office of Public Awareness representative
in this effort.  Our laws, particularly the Clean Air
Act, are complex but their purposes and effects can be
simply explained.  We must make more of an effort to do
so.

AIR

     High priority must be given in 1980 to completing all
actions required as a result of State implemention plan
submissions in 1979.  Most plan approvals, disapprovals,
and promulgations should be completed in 1979, as should
the schedules for implementing the plans.  However, some
such actions may not occur until 1980.  We must have in
place systems for tracking State progress in implement-
ing their approved plans.  We need to emphasize and
develop ways of assuring that the States assume their
responsibilities under the plans including all new source
review responsibilities.  It is especially important that
we encourage States to implement the program for Prevention
of Significant Deterioration.

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                        - 12 -

     During 1980 programs for visibility protection and
Prevention of Significant Deterioration for pollutants
other than TSP and SO  should be ready for implementation.
States should be urged to assume responsibility for these
programs as well.

     The next major round of SIP revisions will be in 1982
for those areas where EPA has granted extensions beyond
the 1982 deadline.  Our guidance requires that for ozone
these areas base their revised plans on an air quality
model.  It appears that the most appropriate technique for
protecting future air quality in this round of SIPs will
be the relatively complex dispersion models which account
for photochemical reactions.  We should give high priority
in 1980 to the acquisition of data required for these
models and to validating them.   The 1981 program plan
should provide for the use of these models in all areas
where required in a time frame that permits technical
review and public participation on development of control
strategy to assure meeting the Clean Air requirements.

     The general problem of lack of confidence in air
quality data also must be addressed in 1980.  Emphasis
must be given to the establishment of technically sound
sites and procedures for National Air Monitoring Stations
(NAMS) and State Local Air Monitoring Stations (SLAMS) as
required by our monitoring regulations.  Participation by
State/local laboratories in quality assurance programs
should be mandatory.  If the programs require additional
resources, this should receive a high priority in the
1981 budget request.

     At Headquarters, by December 31, 1890, we must have
completed our review and appropriate revision of all
existing ambient air quality standards.  The plan for
1980 should clearly recognize this requirement and, given
the need for a better quantification of benefits, provide
for the development of such a data base and analyses as
may be required.

     The budget for 1980 provides funding to complete the
development of new source performance standards for all
major stationary sources by 1982.  The program plans for
1980 and 1981 must demonstrate that we are on a schedule
which will meet that statutory deadline.

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                        - 13 -

     No large increment  in  resources is being provided in
1980 for activities related to hazardous air pollutants.
I expect that, before the next fiscal year begins, we will
have in place a policy on air carcinogens providing a
systematic approach to substantially reduce risks from air-
borne carcinogens.  Our plan  in 1980 should provide for
the orderly implementation  of that policy with a major
intensification of actions  in 1981.  This program should
take into account and be coordinated with other programs
regulating risks from toxic or hazardous pollutants.

     In Mobile Sources we should have completed all vehicle
rulemaking specifically required by the Clean Air Act in
1980.  Our future 'standard-setting program should address
the need to regulate presently unregulated pollutants, and
resources to address the light-duty diesel should be
available in 1980 in the event that research establishes
the need for additional action.  Our 1980 program should
focus on such assessment activities as may be necessary if
standards are to be proposed  in FY 1981 or subsequent
fiscal years.

     Given commitments to inspection/maintenance programs
in the SIP's, we must be in a position of being able to
provide expert guidance to  State and local I/M programs.
The 1980 plans should address, as a matter of priority,
such data gathering and assessment as may be necessary to
assure that we can assist I/M programs to achieve their
maximum potential.

     We should give major attention to other activities
which will help assure that vehicles in use perform as
intended, and the 1980/81 plans should specifically address
this concern.  In particular, we should continue to examine
test procedures to improve  their relation to real-world
problems.
NOISE

     In FY 1980 I thiAk that every effort should be made
to become current with our previous commitments to regulate
new products.  New commitments should be limited until we
are assured that the backlog of previous identifications
and/or proposals can be eliminated.  If we take on new
efforts, they should focus on transportation-related
concerns.

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                         -  14  -

To the extent the 1980 budget is not adequate to complete
the required pre-regulatory work for light duty vehicles
and tires, the Agency should not make formal commitments.
These sources would then be a major initiative in the
1981 budget.

     Although I am attracted by the idea of using noise
labeling as a method of enhancing consumer choice, I
believe we should complete promulgation of the general
labelling and hearing protector regulations first.  Any
proposal for additional work in the labeling area in
1980 must be carefully tailored to fit within available
resources and my desire for us to complete pending
actions.  An expanded program may be considered in 1981,
but it should have a lesser priority than work related to
transportation sources.

     I am anxious that we show material progress in
implementing the Quiet Communities Act.  To the extent
that our stated goals of 400 communities and 40 States
with effective noise programs provide a real basis for
program planning, our program plans for both 1980 and
1981 should clearly indicate projected progress against
these goals.

     We should likewise display our actions to undertake
investigations and studies on a more complete health
base for noise control against a specified objective.  I
think it important that we develop an outline which
indicated the areas in which new information should be
produced on a priority basis and that our proposed
research-related plans in both 1980 and 1981 indicate how
they will meet our needs as outlined.
RADIATION

     In radiation the mission of EPA is now reasonably
well defined as a result of the IRG Report, Libassi
Committee deliberations, NRC Agreements, and our own
actions in developing criteria for waste disposal.  The
IRG Report indicating the multi-agency nature of the
Federal government's nuclear waste management program
should be used as a blueprint for defining the scope of
and timing required for EPA standard-setting in this
area.  The program focus in 1980 should be on actions
delineated in that report.

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                         -  15  -

     The priority we give to actions under the Clean Air
Act must be a product of the reduction in radiation risk
which such actions can accomplish compared to reduction
achieved in other radiation programs.  To the extent that
priority must be given to the issue of radioactive waste,
and/or to the completion of standards required under the
Uranium Mill Tailings Act, I am willing to accept a slower
rate of progress on Clean Air Act-related problems in 1980.
Nevertheless, the program plan for 1981 should present a
full range of actions to effectively implement our deter-
minations on the nature of radioactive air pollution
problems, we should assign them high priority.

     Given the acknowledged limitations of our resources,
I would expect only limited EPA resources devoted in 1980
to implement EPA's general authorities to provide Federal
radiation guidance.  I would much prefer that we take time
to establish an interagency committee to review the poten-
tial scope of the guidance function and assess priorities
as our major program action in the guidance area in 1980.
Implementation of the committee's recommendations would
follow in 1980 and 1981.  Additional resources for EPA in
1981 could be sought where necessary to supplement the
resources of other agencies.

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             OFFICE OF WATER AND WASTE MANAGEMENT

          Overview Statement of Priorities and Goals

          Thomas C. Jorling, Assistant Administrator
     The priority objectives of EPA's Water and Wastewater
Management programs are to implement statutory mandates
providing for:

     o  Achievement and maintenance of the physical,
        chemical, and biological integrity of the Nation's
        ground and surface waters, with special emphasis
        on protection of public health and sensitive
        aquatic ecosystems;

     o  Treatment, containment, and control of toxic and
        hazardous materials in solid waste;

     o  Protection of an adequate supply of high quality
        drinking water for public consumption; and

     o  Federal, State, and local development of integrated
        environmental management systems which minimize
        transfers of pollutants between media and which
        identify optimal ultimate disposal strategies for
        pollutants.

     The objectives described above can be achieved most
efficiently in terms of both dollars and manpower through:

     o  Effective use of State planning and program funds
        to implement water quality management, water supply,
        and solid waste management goals through State/EPA
        Agreements;

     o  Management of the $4 billion/year construction grants
        program to meet the treatment needs of publicly owned
        treatment works (POTW's) effectively at least cost to
        all levels of government;

     o  Application of alternative, innovative, and cost-
        effective technologies and management practices
        to solve water and solid waste pollution problems;
        and

     o  Emphasis on resource recovery, reuse, and recycling
        to conserve energy, materials, and water.

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                          - 17 -
     The objectives and management tools  to achieve  them will
be delivered within a context of program  integration and
consolidation.  An integrated focus  for the Agency and  for
OWWM in particular arises because the Resource Conservation
and Recovery Act  (RCRA) closed the gaps in the waste disposal
cycle left by previous air and water legislation by providing
control for the disposal of pollutants in or on the land.
Since there is no "free dumping ground",  an integrated
approach is necessary to determine the best mix of environ-
mental controls to minimize the adverse effects of pollution.
These integrative efforts will be manifest in the way we
deal with identifiable areas of control or regulation.  For
example; many programs within OWWM act on specific chemicals.
When one program  is dealing with a chemical, it is imperative
that all programs regulating that chemical share knowledge,
experience, and implementation.

     Integration of water quality, water  supply, and solid
waste programs will generally occur at the State level  via
the State/EPA Agreement process.  EPA will encourage States
to conduct integrated problem assessments, develop long-term
strategies to solve their water and waste management problems,
and commit to one-year work programs to implement their
strategies.  In return, EPA will supply program and planning
grants from the Clean Water Act (CWA), Safe Drinking Water
Act (SDWA), and RCRA to assist the States that undertake
integrated approaches.

     An integrated State/EPA agreement process is a logical
outgrowth of the Water Quality Management (WQM) program,
which is a key focus of the Office of Water and Waste
Management.  The major goal of WQM is the development of a
State and local decision-making process to control point and
nonpoint sources of pollution.  Current WQM efforts are
concentrated on plan implementation to achieve water quality
improvements.  Continuing WQM grants will only be made  to
State and areawide agencies who can show evidence of imple-
mentation.

     In managing the $4 billion/year construction grant
program, the Agency will consider publicly-owned treatment
work systems as a structural and functional component of
human community.  This should enable questions relating to
levels of performance and technology, operations and
maintenance, sludge management, pretreatment,  toxics,
combined storm water overflow and urban drainage to be
viewed as parts of a single system.

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                          - 18 -
     EPA's strategy for 1980-81, then, is to orient funding
toward meeting environmental requirements through stringent
cost-effectiveness review and to stress innovative and
alternative approaches to waste treatment, including water
and energy conservation, reuse and recycling of pollutants,
and small systems.  Funds earmarked for State delegation
under Section 205(g) of the CWA will be directed toward
State assumption of program activities with high pro-
fessional quality consistent with Congressional policy and
requirements.  In addition, the construction grant program
will move rapidly toward reinforcing other Agency actions
such as the control of toxics and enforcement objectives
through implementation of the municipal enforcement strategy.

     Industry is a key focal point for the application of
technology and management practices to control environmental
pollution.   The multiple controls on industry must be
applied in a coherent way to a single facility or industry
category to control toxic and hazardous pollutants effectively.
The available control mechanisms include spill prevention
control plans; best management practices for toxics; BAT,
pretreatment, new source performance standards, and BCT;
RCRA hazardous waste controls; and underground injection
control (UIC).

     This arsenal of controls will be implemented coherently
through consolidated permitting of NPDES, RCRA Section 3005,
and UIC permits.  Permit consolidation will enable concen-
tration on programmatic, environmental, and procedural
permitting elements which allow technical and legal talents
to be applied effectively and efficiently to achieve environ-
mental objectives.

     All OWWM programs will emphasize conservation of our
precious natural resources:  energy, water, minerals and
other materials.  The resource recovery program will strive
to maximize the use of energy and materials which are
currently disposed of as solid wastes.  Municipal and
industrial point source control programs will stress
reuse of wastewater and recycling of pollutants through
standards, permits, and financial assistance.  In parti-
cular, the construction grants program will focus attention
on multi-purpose projects which recover energy and materials
and reuse wastewater.

     Four final OWWM priority areas are:  attention to
specific ecosystems; development of criteria and standards;
implementation of new OWWM public participation regulations;
and emergency response.

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                   - 19 -
An important focus is on specific ecosystems or
subsets of ecosystems, such as:  ground water as it
is influenced by the programs of OWWM; wetlands
protection as it is specifically achieved by the
regulatory program under section 404, and wetlands
as influenced by such other factors as solid waste
facility siting, treatment systems siting, and
others.  The oceans represent another ecosystem
which is high priority and can only be protected
by the integrated application of OWWM programs.

Another integration of OWWM activity ranging across
all programs is in development of criteria and
standards.  Water quality criteria, 404 criteria,
403 criteria, safe drinking water standards, and
hazardous substance criteria all will be looked at
as they are developed, issued and applied.

Overall public participation regulations for water
quality, water supply and solid waste programs,
which were promulgated in February 1979, will be
implemented in 1980.  These regulations support
program integration objectives by standardizing
certain public participation requirements for OWWM
programs.  They should foster more effective and
constructive public involvement across these
programs.

1980 must see the emergency response capabilities
of OWWM integrated so that the various authorities
under the Safe Drinking Water Act, Resource
Conservation and Recovery Act, and the Clean Water
Act are carried out in a coherent way by adequately
trained people.  We must build on the emergency
response capabilities already in place under
section 311 and expand them to recognize that the
response is attentive not just to surface waters
but also to ground waters and to the landscape
and atmosphere.

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            OFFICE OF TOXIC SUBSTANCES

    Overview Statement of Priorities and Goals

    Steven D. Jellinek, Assistant Administrator
     This Overview Statement lays out what I believe
to be the important priorities for achievement by the
pesticides and toxics programs for the years 1980
and 1981.  As such, it represents my "guidance" to
the managers and staff of the two programs and infor-
mation of interest to our colleagues throughout the
Agency.

     I have arranged the objectives for each into
"general" and "specific" categories.  The specific
objectives are subdivided further into "highest"
priority, "high" priority, and "other."  We have no
low priority objectives.

     The general objectives are provided to give a
sense of what I believe are the thrust and tone of
the programs.  The specific objectives are more in
the nature of outputs I expect to be delivered.

TOXICS —1979

General Objectives

     o    Continue the thrust toward institution-
          building.  From the organizational per-
          spective:

               Secure adequate space.

               Staff up to budgeted levels with
               qualified professional and support
               personnel, with special efforts on
               increasing the number of women
               and minorities.

               Organize to the branch level.

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                      - 21 -
     From the regulatory perspective:

               Place more emphasis on premanufacture
               review, test standards, and test rules.

               Give less emphasis to existing chemical
               regulation.

     o    Complete the development of a priority
          setting system for choosing chemicals for
          testing and regulation under TSCA and
          other statutes; clarify and establish the
          role of the Toxic Substances Priorities
          Committee in this system.

     o    Develop a detailed program planning system
          for each DAA-ship.

     o    Clarify the regional role in TSCA implementation,

Specific Objectives

     Highest Priority

     o    Publish the Chemical Substances Inventory.

     o    Promulgate the final regulations on premanu-
          facture notification;  establish and operate
          a system for screening and assessing notices;
          and take actions under TSCA sections 5("e)
          and 5(f)  to prevent or control the manufacture
          of new chemicals, as required.

     o    Promulgate a final regulation establishing
          test standards for oncogenicity, chronic
          toxicity, combined oncogenicity and chronic
          toxicity, and good laboratory practices.

     o    Propose the first section 4 test rule
          requiring industry to  test 20-30 chemical
          substances and categories of substances.

     o    Propose a rule under section 8(a)  to develop
          basic use/exposure information on approximately
          2-3,000 chemicals to aid in setting priorities
          for regulation.

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                       - 22  -
          Propose a regulation under section 6 banning
          or limiting the use of one existing chemical
          that poses an unreasonable risk to public
          health.

          Fully implement the program to help States
          and school districts identify and control
          asbestos in school buildings.
High Priority
          Propose testing guidelines for premanufacture
          notification.

          Propose remaining test standards for health
          effects and several fate and ecological
          effects test standards; resolve inconsis-
          tencies with pesticides testing guidelines.

          Conduct health and environmental effects
          assessments, monitoring, and economic impact
          analyses to support regulation of new and
          existing chemicals.

          Follow premanufacture notices with individual
          "significant new use rules" and/or individual
          section 8(a) information rules for a few
          selected new chemicals, as required.

          Begin the development of generic follow-up
          systems for "significant new use rules" and
          section 8(a) information rules for new
          chemicals.

          Begin developing proposed regulations banning
          or limiting the use of an additional 2-4
          existing chemicals that pose an unreasonable
          risk to health or the environment.

          Complete an analysis of the issues concerning
          the impact of testing costs on small volume
          chemicals and, if appropriate, develop
          proposed legislative solutions.

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Other
                       - 23 -
          Continue the development of TSCA and inter-
          agency chemical information systems and data
          bases.

          Complete the development of responsive and
          effective document control data services,
          and FOI procedures.

          Develop model rules for information gathering
          under section 8(a).
     o    Develop a process to review and act expedi-
          tiously on carcinogens, mutagens, and terato-
          gens under section 4(f).

     o    Initiate the development of generic approaches
          to banning or controlling the use of chemicals
          under section 6.

     o    Promulgate the PCB ban rule.

     o    Provide industry assistance on TSCA require-
          ments .

     o    Distribute State grants.

     o    Continue development of public participation
          programs.

     o    Support OECD and other planned international
          harmonization programs.

     o    Propose model regulations under section 8(c)
          and 8(d) to require recordkeeping and submission
          of health and safety studies concerning signifi-
          cant effects of chemicals.
TOXICS—1980
General Objectives
          Continue the thrust toward institution-
          building.  From the organizational perspective:

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                      - 24  -
               Staff up to budgeted levels with
               qualified professional and support
               personnel, with special efforts on
               increasing the number of women and
               minorities.

               Build effective staff teams through
               management actions and training.

     From the regulatory perspective:

               Fully operate premanufacture review
               and test rule development.

               Increase emphasis on existing chemical
               regulation, both individual and generic
               approaches.

     o    Operate a priority-setting system for choosing
          chemicals for testing and regulation under TSCA
          and other statutes, in conjunction with the
          Toxic Substances Priorities Committee.

     o    Operate a detailed planning system for the
          toxic substances program; initiate formal
          evaluation;  modify program design, as needed,
          to increase quality and quantity of output;
          develop, jointly with the R&D community,
          specific program requirements for high
          priority research; examine the need for
          major legislative changes in 1981.

Specific Objectives

     Highest Priority

     o    Fully operate the premanufacture notification
          review process; take actions under sections
          5(e)  and 5(f) to prevent or control the
          manufacture of new chemicals, as required.

     o    Promulgate the section 4 test rule proposed
          in 1979; propose and promulgate additional
          test rules.

     o    Conduct health and environmental effects
          assessments, monitoring, and economic
          impact analyses to support regulation of
          new and existing chemicals.

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                  -  25  -
o    Promulgate the section 6 regulations proposed
     in  1979 banning or limiting the use of one
     chemical; propose section 6 regulations for
     several additional existing chemicals.

o    Promulgate the section 8(a) information rule
     on  2-3,000 chemicals proposed in 1979.

High Priority

o    Promulgate final testing guidelines for premanu-
     facture notification.

o    Propose and promulgate model rules under
     section 8 (a); promulgate model rules for
     sections  8(c) and 8(d).

o    Promulgate the full set of health effects test
     standards and the fate and ecological effects
     test standards proposed in 1979; propose
     additional fate and ecological effects test
     standards.

o    Father develop and begin to use generic
     follow-up systems for "significant new use
     rules" and section 8(a) information rules for
     new chemicals.

o    Publish the revised chemical substances
     inventory; maintain the integrity of the
     inventory.

o    Develop proposed regulations implementing
     generic approaches to regulation under
     section 6.

o    Begin partial operation of TSCA and inter-
     agency chemical information systems and data
     bases;  continue systems development.

o    Review and act expeditiously on carcinogens,
     mutagens,  and teratogens under section 4(f).
Other
     Begin reviewing existing test standards as
     required by section 4.

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                       - 26 -
     o    Begin review of overall economic and
          innovation effects of TSCA.

     o    Provide industry assistance on TSCA require-
          ments.

     o    Continue to develop public participation
          programs.

     o    Support OECD and other planned international
          harmonization programs.

TOXICS—1981

General Objectives

     o    Achieve institutional maturity.  From the
          organizational perspective:

               Have  a stable organization in place with
               technically and managerially qualified
               staff.

     From the regulatory perspective:

               Fully operate all major program com-
               ponents.

               Balance emphasis on regulation of new
               and existing chemicals.

     o    Operate an integrated priority-setting system
          for choosing chemicals for testing and regu-
          lation for TSCA and other statutes, in con-
          junction with the Toxic Substances Priorities
          Committee.

     o    Operate a  detailed planning and evaluation
          system for the toxic substances program;
          explore alternatives to established regu-
          latory approaches.

     o    If appropriate, develop and support pro-
          posals for major legislative changes.

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                     - 27 -
Specific Objectives

     Highest Priority
          Fully operate the premanufacture notification
          review process at an improved level;  take
          actions under sections 5(e)  and 5(f)  to pre-
          vent or control the manufacture of new chemicals,
          as required.

          Promulgate and propose regulations under section
          6 with greater emphasis on generic approaches,
          banning or limiting the use of a significantly
          greater number of existing chemicals  that pose
          unreasonable risks to public health.

          Conduct health and environmental effects
          assessments, monitoring, and economic impact
          analyses to support regulations of new and
          existing chemicals.

          Continue promulgating rules under sections 4
          and 8 to obtain data to support assessment
          and regulation.
     High Priority
     o    Revise testing guidelines for premanufacture
          notification to provide more specific guidance,

     o    Complete fate and ecological effects test
          standards; review existing test standards
          as required by section 4.

     o    Use routine, generic follow-up systems for
          "significant new use rules" and section 8(a)
          information rules for new chemicals.

     o    Complete chemical information systems
          development; operate systems, services, and
          data bases at full scale.

     Other

     o    Continue actions under 4(f).

     o    Maintain industry assistance.

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                       - 28 -
     o    Continue to develop public participation
          programs.

     o    Support international harmonization programs.

     o    Continue TSCA overall economic and innovation
          impact studies.

     o    Evaluate and refine operating programs.

PESTICIDES—1979

General Objectives

     o    Continue the thrust toward institution-building.
          From the organizational perspective:

               Secure adequate space.

               Staff up to budgeted levels with qualified
               professional and support personnel, with
               special efforts on increasing the number
               of women and minorities.

               Complete the reorganization; fill senior
               line  positions.

     From the regulatory perspective:

               Place more emphasis on completing major
               RPAR actions, initiating conditional
               registration, establishing the registra-
               tion  standards process, and making
               registration decisions on new chemicals
               with  adequate hazard data.

               Give  less emphasis to large-scale
               operation of the registration standards
               process.

     o    Develop management systems for expediting
          decisionmaking on high volume operations,
          such as registration and registration
          standards.

     o    Develop a  detailed program planning system.

     o    Clarify the regional role in FIFRA implementation,

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                       -  29  -
Specific Objectives

     Highest Priority
          Review benefits and risks of 15-20 RPAR com-
          pounds identified as posing potentially
          unreasonable adverse effects.

          Reach 17-23 final risk/benefit determinations
          on RPAR compounds.

          Implement the conditional registration program.

          Process 25-30 new registrations, 5,000-5,600
          administrative/technical amendments and 2,000-
          2,500 routine/intrastate registrations in an
          efficient,  effective manner.

          Give registration priority to new chemicals
          for which complete hazard data are submitted.

          Inititate the preparation of 42-47 generic
          standards,  including the reassessment of
          associated  tolerances.

          Evaluate the scientific basis of the system
          for establishing tolerances, including con-
          sideration  of inert ingredients in order to
          revise tolerance regulations.
     High Priority
          Provide timely and responsive guidance to the
          States relative to their FIFRA section 5(f)
          experimental use permits and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

          Review 1,000-1,500 section 24(c)  special local
          needs registrations and conduct overview
          activities on their final actions.

          Review 170-220 section 18 emergency exemptions
          in a median turnaround time of 4  weeks,  including
          full scientific review of pertinent data.

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                       - 30 -
     o    Develop proposed guidelines for biological
          pesticides.

     o    Establish 80-120 pesticide residue tolerances
          and review 75-100 amendments for food and
          animal feed crops after review of data and
          risk/benefit analyses in a median turnaround
          time of 105 days.

     o    Accelerate the program to classify pesticides
          for restricted use.  Aim for completion in
          1980.

     o    Develop and initiate procedures to require
          early testing to fill data gaps on existing
          compounds instead of waiting until such gaps
          are identified in the development of generic
          standards.

     o    Integrate IPM into the RPAR process and into
          regulatory actions (e.g., section 18 emergency
          exemptions)  when technically appropriate.

     Other

     o    Audit 50-70 testing laboratories.

     o    Develop more precise procedures for handling
          confidential business data.

     o    Conduct training program.

     o    Improve FOI response procedures, so that all
          requests are given an initial response
          within 10 days and a final response as
          quickly as possible.

     o    Monitor for hazard prediction and significance
          of potential problems.

PESTICIDES—1980

General Objectives

     o    Continue the thrust toward institution-
          building.  From the organizational perspective:

               Build effective staff teams through
               management actions and training.

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                       -  31  -
     From the regulatory perspective:

          -    Emphasize completion of the remaining
               RPAR reviews, increasing production of
               registration standards, and registration
               decisions on new pesticide chemicals.

          -    Initiate reregistration of existing
               pesticides.

     o    Operate priority-setting systems for selection
          of chemicals for the registration standard
          process and for priority registration decisions,

     o    Operate a detailed planning system; initiate
          formal evaluation; modify program design, as
          needed, to increase quantity and quality of
          output; develop, jointly with the R&D
          community, specific program requirements for
          high priority research.

Specific Objectives

     Highest Priority

     o    Review benefits and risks of 12-17 RPAR com-
          pounds identified as posing potentially un-
          reasonable adverse effects.

     o    Reach 15-20 final risk/benefit determinations
          on RPAR compounds.

     o    Implement the conditional registration
          program.

     o    Give registration priority to new chemicals
          for which complete hazard data are submitted.

     o    Reregister 1,000-1,400 products from available
          generic standards.

     o    Complete the generic standards initiated last
          year, and initiate the preparation of 40-50
          generic standards, including the reassessment
          of associated tolerances.

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                       - 32 -
     High Priority
          Provide timely and responsive guidance to the
          States relative to their section 5(f)  experi-
          mental use permits, and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

          Review 1,000-1,500 section 24 (c)  special local
          needs registrations and conduct overview
          activities on their final actions.

          Review 170-220 section 18 emergency exemptions
          in a median turnaround time of 4  weeks, in-
          cluding full scientific review of pertinent
          data.

          Promulgate guidelines for biological pesticides

          Establish 80-120 pesticide residue tolerances,
          and review 75-100 amendments for  food and
          animal feed crops after review of data and
          risk/benefit analyses, in a median turnaround
          time of 105 days.
     Other
          Audit 50-70 laboratories.

          Improve FOI response procedures, so that all
          requests are given an initial response within
          10 days and a final response as quickly as
          possible.

          Monitor for hazard prediction and significance
          of potential problems.
PESTICIDES—1981
General Objectives
          Achieve institutional maturity.  From the
          organizational perspective:

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                       - 33  -
               Have a stable organization in place,
               with technically and managerially
               qualified staff.

     From the regulatory perspective:

               Fully operate all major program com-
               ponents.

               Substantially complete RPAR.

     o    Operate an integrated priority setting system.

     o    Operate a detailed planning and evaluation
          system.

     o    Intensify strategy for replacement of older
          pesticides with unknown or hazardous effects
          with new, safer pesticides and alternative
          pest control actions.

Specific Objectives

     Highest Priority

     o    Integrate the RPAR process into the generic
          standards production process.

     o    Give registration priority to innovative,
          environmentally protective compounds.

     o    Reregister 1,000-1,400 products from available
          generic standards.

     o    Complete the generic standards intiated last
          year, and initiate the preparation of 40-50
          generic standards, including the reassessment
          of associated tolerances, with attention to
          detail and quality.

     High Priority

     o    Provide timely and responsive guidance to
          the States relative to their section 5(f)
          experimental use permits, and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

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                  -  34 -
     Review 1,000-1,500 section 24(c)  special
     local needs registrations, and conduct
     overview activities on their final actions.

     Review 170-220 section 18 emergency
     exemptions in a median turnaround time of
     4 weeks.

     Establish 80-120 pesticide residue tolerances,
     and review 75-100 amendments for food and
     animal feed crops after review of data
     and risk/benefit analyses, in a median turn-
     around time of 105 days.
Other
     Audit 50-70 laboratories.

     Improve FOI response procedures, so that all
     requests are given an initial response within
     10 days and a final response as quickly as
     possible.

     Monitor for hazard prediction and significance
     of potential problems.

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                    OFFICE OF ENFORCEMENT

          Overview Statement of Priorities and Goals

          Marvin B. Burning, Assistant Administrator
     This guidance builds upon the top priority activities
set out for enforcement in the EPA Policy Guidance for
FY 1979/80.  The activities described are our top enforce-
ment priorities, not a complete list of all enforcement
activities.  These priorities are stated as programmatic
priorities and as management-institutional priorities, but
the two are obviously interrelated.

PROGRAMMATIC PRIORITIES

Enforcement in Emergencies

     All EPA, State, and local enforcement personnel should
give top priority to any true emergencies involving sub-
stantial threats to public health and safety.  Containment
and removal of the dangers is, of course, the top priority.
Follow-up on penalties for violations can be undertaken in
the course of other enforcement, rather than as an emergency,
This guidance applies, of course, to emergency enforcement
response to hazardous spills.

     At this time in FY 1979, EPA personnel have as their
top priority the investigation and prevention of substantial
and imminent hazards created by existing or abandoned
chemical waste sites.  Those efforts will continue as facts
may dictate.  We expect a large number of civil actions of
this nature in FY 1980 and 1981.

Major Source Enforcement Effort

     The major source enforcement effort against violators
of the Air Act and Water Act is our next highest priority
after emergency situations.  Enforcement against these major
sources is critically important to accomplishing our environ-
mental goals.  It is directed against that small minority of
major sources which failed to meet the requirements of the
Air and Water Acts by the statutory deadlines.  It includes
many of the most serious and most recalcitrant sources of
pollution in the country.  By bringing these sources into
compliance, with penalties where appropriate, we will keep

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                         - 36 -
faith with the great majority of firms and public bodies
which met their responsibilities and will build the
confidence necessary to continue voluntary compliance
with all the environmental laws.

     In FY 1980, Regions and States will bring the major
source enforcement actions to decision by settlement,
administrative process, or court trial, including
appropriate penalties, and make or defend appeals.  By
the end of FY 1980, the major source drive should be
nearly completed, with only a few actions and appeals
still pending in trial or appellate courts.  In FY 1981,
actions and appeals still pending should be completed as
rapidly as possible.

Enforcement against Automobile and Truck Pollution

     Because of the great public health and environmental
significance of air pollution from automobiles and trucks,
especially in urban areas, enforcement against mobile
sources of pollution will continue to be a top enforcement
priority in FY 80/81.

     EPA enforcement will continue to ensure that new
vehicles meet emission standards.  We will increase our
emphasis on maintaining the effectiveness of emission
control systems throughout the period of their use.  To
achieve this, EPA's main emphasis will be on inspection
and maintenance systems in the major nonattainment areas
for auto-related pollutants, supplemented with Head-
quarters audits and I/M programs.

     o   To ensure that new vehicles meet standards, EPA
         enforcement will continue our assembly line
         audits, recall and warranty efforts.

     o   To ensure that cars in use meet standards and to
         support introduction of inspection and maintenance
         systems where needed, EPA will continue to focus
         investigations and enforcement actions (a) on
         national or regional fleets, chains, dealership or
         repair facilities, or "pattern" violations and (b)
         in major metropolitan areas where auto pollution
         is high and I&M will be introduced.  EPA will
         encourage State and local anti-fuel switching and
         anti-tampering efforts.

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                          - 37 -
     We will use private, State, or local contracts to
carry out inspections to ensure the availability and purity
of unleaded gasoline, and the installation and operation of
vapor recovery systems on fuel delivery trucks and at
gasoline outlets.

     EPA and the States, in cooperation with other agencies,
will implement any programs authorized to control the
leaded-unleaded gas price differential and other 'authorized
environmental/energy programs.

Consolidated and Simplified Permitting

     EPA is consolidating its permit programs, both to
simplify administrative steps and to get all important
environmental problems addressed in a single process.  By
October 1, 1979, companies will be able to submit just
one application for all water, solid and hazardous waste
permits, go through one review, and be issued one permit.
We expect application forms for air quality permits to be
consolidated in late FY 1980  (or early FY 1981).  NPDES
second round permits under the Clean Water Act will be
issued throughout FY 1980/81.  We will begin to issue
hazardous waste permits in late FY 1980, accelerating in
FY 1981.  We will also start  issuing Underground Injection
permits in FY 1981.

     In all permitting activities, we will give first
priority to large or major sources with serious adverse
health effects, including those with significant toxic
discharges.

Full Federal Compliance

     President Carter has directed all Federal facilities
to come quickly into compliance with Federal, State, and
local environmental requirements.

     By the end of 1980, we expect all, or almost all,
Federal facilities both major and minor sources will be
in compliance.   Regions should see to it that all Federal
facilities do indeed come into compliance as soon as
possible.   EPA will ensure that Federal agencies request
necessary funds for compliance by reviewing the agencies
plans included in the annual A-106 report.

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                          -  38  -
     EPA is encouraging the States to assume these respon-
sibilities for Federal facilities.  The States should
find the managers of Federal facilities cooperative.  EPA
will assist the States in getting any disputes resolved.

Stationary Sources

     Completing the Major Source Enforcement Effort contin-
ues to be of highest priority in FY 1980/81, including the
monitoring of compliance orders to ensure that sources comply
with the terms of the orders.  We also want to ensure that
major sources comply with new requirements placed on them
by SIP revisions and by the ambient standards for lead, and
to enforce new source performance standards and national
emission standards for hazardous air pollutants.

     As the Major Source Enforcement Effort is completed in
FY 1979/80, EPA will design and implement an improved program
of compliance monitoring and enforcement to ensure continuous
compliance.

     During FY 1979, regulations will be promulgated for
administrative assessment of noncompliance penalties under
Section 120 of the Clean Air Act.  This program should be
fully implemented during the second half of FY 1979 and
throughout FY 1980/81.  Prompt implementation of these
penalties should assist in obtaining and maintaining
compliance with the Air Act.

Water Enforcement

     Completion of the Major Source Enforcement Effort,
including actions against publicly owned treatment works
(POTW's), continues to be of highest priority in FY 1980/81.
As this effort is completed, EPA will design and implement
an improved program of compliance monitoring and enforcement
to ensure continuous compliance.

     Beginning in FY 1979 and growing in importance in
FY 1980/81 will be advice and assistance to delegated States
so that State pretreatment programs can be established and
the conditions of those programs enforced.  During FY 1981
the activities of assisting and advising States and POTW's,
modifying permits to incorporate pretreatment requirements,
approving POTW treatment programs, notifying affected
indirect dischargers, and determining treatment levels
should be at their peak level and of prime importance if we
are to achieve compliance by all affected POTW's and indirect
dischargers by FY 1983 or FY 1984.  NPDES permits will be
issued as part of the consolidated permits program.

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                          - 39 -
Strategies for New Programs  (TSCA, RCRA, SDWA, FIFRA)

     In recent years, Congress has provided new programs
and has amended existing statutes to respond to the threats
of chemical poisons, hazardous wastes, and pesticides, and
to protect drinking water supplies.  We must carefully
devise or revise enforcement strategies under the additional
provisions of the Toxic Substances Control Act (TSCA), the
amended provisions of the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA), the hazardous waste provisions
of the Resource Conservation and Recovery Act (RCRA), and
the Safe Drinking Water Act  (SDWA).

     Under RCRA, our priority enforcement activities in
FY 1980/81, in addition to responding to emergencies,
include monitoring and enforcing the notification program
(Section 3010); reviewing proposed State programs for
enforceability and adequacy; issuing permits, monitoring
permitted sites, and ensuring that Compliance Schedules
are met; and monitoring and enforcing the manifest
systems.

     Under TSCA, our compliance monitoring and enforcement
will initially focus on PCBs, chlorofluorocarbons, inventory
requirements and to premanufacturing notice requirements.
We will continue our special investigative efforts regarding
the accuracy and truthfulness of laboratory test data in
the toxics and pesticides programs.

     Under FIFRA, during FY 1980/81 EPA will attempt to
develop cooperative enforcement grant programs with the
remaining seven States (for a total of 50) and will
continue to enforce regulations on pesticide use until
States assume this responsibility.

     Under SDWA, EPA will respond to emergency situations
threatening public health and will concentrate on enforce-
ment of primary drinking water standards, particularly in
non-primary States.

Noise Control

     The noise enforcement program will continue to ensure
compliance with standards and requirements for products and
procedural labeling as its top priority.  Although urban
noise can often be controlled through State and local efforts,
it continues to be a Federal responsibility to ensure that
products meet the standards established under the Noise Act.
EPA Headquarters will carry out this function.

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                          -  40  -
MANAGEMENT AND INSTITUTIONAL PRIORITIES

     In addition to the preceding programmatic priorities,
we have a number of management and institutional improve-
ments as top priorities.  These improvements have to some
degree already been described in the programmatic priorities
and they obviously interrelate with them.

     o  Consolidated Permitting -- EPA will consolidate
        and simplify its permitting activities, mostly
        during FY 1979 and totally by the end of FY 1980.
        It will assist and encourage States to do so as
        well.

     o  Industry Enforcement Strategies — During FY 1979
        and FY 1980 EPA will develop and implement industry
        enforcement strategies for selected industries.

     o  Continuous Compliance -- We will develop programs
        for ensuring continuous compliance by regulated
        sources, including compliance monitoring (and
        information systems for recording and tracking
        compliance), penalties to remove the economic
        benefit of non-compliance and remote sensing
        techniques.

     o  Improved Oversight of State Enforcement -- During
        FY 1979 and thereafter, Headquarters and Regional
        personnel will begin to apply standards of perfor-
        mance to State enforcement activities under all
        Federal grants or contracts for enforcement.

     o  Management and Management Information Systems —
        During FY 1979 and FY 1980 as needed, we will
        review our management, reporting, and information
        systems (including ADP systems).  Our emphasis will
        be on improved accuracy, usefulness, simplicity,
        and compatability.

     o  Improved Cooperation with Other Agencies —
        During FY 1979, 1980, and 1981, we will improve
        our cooperation with other agencies, such as the
        Department of Justice, the other members of the
        IRLG (OSHA, FDA, and CPSC), the Securities Exchange
        Commission (SEC), and the Departments of Energy and
        Interior.

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                  -  41  -
Innovative Methods — Throughout FY 1979, 1980,
and 1981 the Office of Enforcement will explore
innovations such as widened use of penalties to
remove economic benefits of delay, environmental
auditing, and contracts or grants with citizen
groups.

Investigating Criminal Violations — During
FY 1980/81 EPA enforcement will improve its
ability to investigate criminal violations of
environmental laws by recruiting and training
EPA investigative personnel.

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             OFFICE OF RESEARCH AND DEVELOPMENT

        Overview Statement of Priorities and Goals

         Stephen J. Gage, Assistant Administrator
     During the next two years, three major objectives will
be driving the Environmental Protection Agency's research
and development program: (1) continuing the integration of
the Office of Research and Development into the mainstream
of the Agency's activities, (2) enhancing the Office's
capability to provide the scientific and technological data
the Agency will use for future regulatory and enforcement
actions, and (3) improving that data through scientific peer
review of research procedures and results, quality control
of risk assessments, and quality assurance of monitoring
data.

     Much of the groundwork for achieving these objectives
has been laid during the past year.  The Research Committees
have been quite successful in planning research in five
critical areas jointly with the Program Offices.  A signifi-
cant Public Health Research Initiative ($37 million, 46
positions) was developed and successfully defended with
OMB through the cross-agency zero-based budgeting for toxics.
A new Office of Health and Environmental Assessment, building
on the successful experiences in scientific assessments by
the Carcinogen Assessment Group and the Environmental
Criteria and Assessment Office, has been proposed.  Other
developments have also built a good foundation for future
action.

INTEGRATING ORD INTO THE AGENCY'S MAINSTREAM

     Joint planning of the Agency's research and development
activities through the five pilot Research Committees already
provides a very valuable linkage between the regulatory
program offices responsible for developing regulations and
the ORD scientists and engineers supporting the regulatory
efforts.  During early 1979, we will establish seven new
Research Committees to cover the joint planning of sub-
stantially all of the research in support of regulation and
enforcement.  Each of the 12 committees will be specifically
oriented to the users of the research information, typically
Program Office Deputy Assistant Administrators or, in some
instances, Division Directors (see Attachment A).

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                         -  43  -
     The new Research Committees will develop multi-year
research strategies oriented toward supporting regulatory
needs; identify research outputs required within the next
budget year (now beginning the FY 1981 cycle); seek the
required resources through the Agency's ZBB process; and
monitor and evaluate ongoing and completed research.  We
must make special efforts during this formative period
to bring more fully the Agency's enforcement and Regional
programs into the joint planning process.  In the  interest
of cost-effectiveness, it will be necessary for the Regional
Offices to coordinate their participation and share respon-
sibility for representing Regional interests in the Research
Committee; ORD will support the Regional Offices in this
effort.

     We will continue to experiment cautiously with matrix
management approaches as a means of improving the  coordi-
nation and delivery of high-visibility, short-term research
outputs.  Matrix management of the diesel emissions program
will continue, and we will consider establishing a limited
number of similar programs, such as in Acid Precipitation.

     Closely related to the evolution of the joint research
plannng approach is the long-overdue simplification of
ORD'S planning and reporting systems.  We must take this
step to bring ORD's planning and management approaches into
synchronization with (1) the five-year plan developed in the
preparation of the Agency's Research Outlook, (2)  the multi-
year plans developed by the Research Committees, and (3) the
Agency's ZBB review and decisions.  We must also eliminate
the redundant paperwork that absorbs too much ORD staff time.

     In order to improve accountability for the research
and development efforts, we must bring into operation a
reliable tracking system for the critical outputs required
by the Program Offices as identified by the Research
Committees.  As a corollary, we must also reduce to a
manageable number the outputs to be tracked.  While we must
have adequate information to monitor progress of the key
outputs, we must vigorously resist spending too much time
and effort reporting preliminary and fragmented data.  Good
research management means monitoring the right indicators,
not all of the possible indicators, of orderly progress
toward objectives.  Too much reporting together with
overspecification of research investments will counterpro-
ductively tie the hands of the research managers and stifle
innovative research.  Management flexibility must, of
course, be coupled with accountability.

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                         - 44 -
     With the increased pressure for higher quality manage-
ment of several key research areas, we will be realigning
the laboratory reporting relationships to consolidate
functional or discipline groupings.  These changes, which
should improve morale and productivity, will allow us to
improve the implementation of the Agency's research efforts.
Specifically, the realignment will establish an office for
health effects research management; an office to integrate
environmental transport, fate, and effects research; and an
office to integrate control technology and hazardous waste
research.

BUILDING A RESEARCH FOUNDATION FOR AN IMPROVED DATA BASE

     We made important progress in the past year in starting
the long-term process of building a foundation for a signifi-
cantly improved scientific and technological data base for
the future regulatory and enforcement actions of the Agency.
Planning and budgeting the Public Health Research Initiative
was a critical first step, but it was only a beginning.

     We must now commit ourselves to the de.tailed planning
and implementation of the Initiative.  Since the Initiative
represents the first significant expansion of the Agency's
basic environmental health sciences, we must wisely dedicate
it to achieving a solid understanding of human health effects
caused by both direct and indirect environmental exposures.
Because we will be drawing heavily on scientific talent in
the private sector to assist us in this effort, we must
begin immediately to seek the best scientific advice
available to help us in this planning effort.

     The second critical step, a broad environmental
research initiative, must be taken immediately.  Because
of the heightened awareness in the Administration of
EPA's requirements for the best scientific and techno-
logical data that can be developed for the Agency's
comprehensive environmental regulations, we now have an
excellent opportunity to seek a government-wide review of
environmental research.  This review will focus on how
existing and future Federal resources can support broader
based, longer term environmental research to build an
improved data base.  We must assume the leadership in
developing the conceptual framework for such efforts,
bringing to bear on the program design the best scientific
advice available.  We must look to the Agency's Science
Advisory Board, the President's Office of Science and

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                           - 45 -
Technology Policy, and the National Academy of Sciences as
well as numerous  individual scientists  in this comprehensive
planning and review effort.  We are now  in the process of
developing a select set of initiatives  for 1981 and beyond,
focusing on protecting humans from environmentally mitigated
pollutants; identifying and protecting  critical components
of ecosystems from injury; and addressing the more global
problems of protecting our life support  systems.

     In parallel  with these activities,  we must 'carefully
review the longer-term research already  underway  in ORD to
assure ourselves  that we are directing our attentions to
the most important future problems and  are using  the best
scientific talent we can attract to work on these problems.
We must determine if we are obtaining high quality, well-
documented results from our research grants -- the primary
mechanism we have for supporting innovative ideas.  We must
make the scientific community more widely aware of our
research grants,  encourage much greater  competition for
those grants, and ensure that they are awarded strictly on
the basis of merit through enhanced peer review.  We should
also see if alternative approaches for handling these longer
term grants can relieve the burdensome monitoring loads
placed on the individual laboratory researchers.

     An invigorated, competitive grant program for longer-
term research in  each research area, coupled with an expanded
Anticipatory Research Program, will provide the Agency with
an important new  base of exploratory research.  It is
essential that, with the significant infusion of new funding
associated with the Public Health Research Initiative, we do
not waste this opportunity to build a firmer foundation with
the help of the best scientific talent available  in the
country.

IMPROVING THE QUALITY OF DATA USED IN DECISION MAKING

     Scientific and technological data come in many forms
and in varying quality.  The credibility and integrity of
all data used in  Agency decisions is a prerequisite for
any analyses.  The evaluation and synthesis of the data is
an essential step in informing the many  far-reaching
regulatory decisions.  We have made significant progress
during the last year in providing carcinogenic risk
assessments for the Program Offices and  in improving the
capability of ORD to prepare Air and Water Quality criteria
documents by establishing the new Environmental Criteria and
Assessment Offices in Research Triangle Park and Cincinnati.

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                         - 46 -
     We have not yet, however, undertaken the special
responsibility assigned by the Administrator to provide
quality control of the Agency's risk assessments.  With
approval of ORD's new Office of Health and Environmental
Assessment (OHEA), we must now move ahead, first to quickly
develop guidelines for the several types of risk assessments
required for the Agency's regulation development, and then
to exercise oversight to ensure that the asssessments
prepared by the Program Offices conform reasonably to the
guidelines.  We must also proceed to staff OHEA with the
best qualified people we can attract from the scientific
community, significantly upgrading in this process ORD's
capability to provide consultation to the Program Offices
and, upon request, assessments of specific chemicals.

     Although we in ORD have discussed the role of peer
review extensively during the past year, we must now
act in the coming year to build into all of the Agency's
scientific and technological efforts appropriate review
mechanisms.  We must begin with enhanced peer review for
individual research projects.  The ORD senior laboratory
management must convey to the professional staff strong
support for and assistance in periodic external peer
review of individual projects.  Whenever feasible, the
results of individual projects should be subjected to
rigorous scientific or technological scruntiny through
publication in referred journals.  We should also see
that the results of our grants and contracts are published
in peer-reviewed journals, slowing the growth of that body
of EPA-published "gray literature" which now constitutes
the only publication channel for too much of our work.
Publication of research results in the peer-reviewed
literature must become an important criterion for advance-
ment in all of our laboratories.

     In addition to peer review of individual research
efforts, we must systematically review our research programs,
While such reviews may begin at the laboratory level, it is
usually more appropriate to conduct them at the level of the
Deputy Assistant Administrators or even of the Assistant
Administrator.  Since the Research Committees will be
providing the primary focus for the bulk of our research
activities, it is logical that we direct our attention
increasingly to programmatic reviews along the lines of the
committees.  We should also be mindful of other mutually
supporting programmatic areas which may provide results for
several committees, such as biological screening tests,
analytical methodologies, etc.

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                         - 47 -
     Finally, we have been expanding in the past year our
efforts to provide support to Agency laboratories for
quality assurance of environmental monitoring data.  We must
now assume the lead for improving the quality assurance of
all of the environmental monitoring data used in the Agency's
decisions.  We must first make sure our house is in order
by requiring adequate quality assurance practices for all
environmental quality monitoring, sampling, and analytical
activities conducted in the ORD laboratories or by our
contractors or grantees.  This policy should become effective
immediately.  We must also require, through the Blue Ribbon
Monitoring Task Force, similar quality assurance practices
for all of the Agency's laboratories, contractors, and
grantees.  Lastly, we must work closely with the Regional
Offices to bring quality assurance practices into uniform
use in all of the State and local laboratories, which
provide the bulk of the environmental quality data available
to the Agency.

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            OFFICE OF PLANNING AND MANAGEMENT

       Overview Statement of Priorities and Goals

     William Drayton, Jr., Assistant Administrator
     The Agency's central management objective remains that
of creating a national environmental program that derives
strength and initiative from decentralization and purposive-
ness and environmental coherence from effective integration.
Toward these and other ends we must strengthen our analytic
and common services in a number of areas.  This guidance
deals first with that central objective, then with other
objectives connected with our analytic and common services.

AN INTEGRATED,
DECENTRALIZED PROGRAM

     From its inception EPA rejected the top-down, over-
centralized, untrusting Louis XIV/Herbert Hoover form of
management common to most government organizations, a form
that has failed.  Instead we are building on the philosophy
of the Federalist Papers:  decentralize and democratize
within a realistic set of incentives designed to ensure
organizationally responsible results.

     Not only are we doing what makes sense for EPA, but
we're setting the pace for others.  That's why others in
the government have quickly recognized so many of our
reforms as models.

     No matter how satisfying being out front is, however,
it doesn't make ground breaking any easier.  Although
we've come a long way, we still have several years of
intense work ahead of us:

     (1)  We should continue to strengthen our regulation
          development and zero-base budgeting.  They
          provide the structure that makes possible broad
          involvement in the Agency's two principal cross-
          cutting areas for decision making:  respectively,
          (a) regulation and policy development and (b)
          priority setting, management, and resource allo-
          cation.  Regulation development is mature, and
          ZBB is over the worst of its start-up pains.
          Both need continuing adjustment and strong support,

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                    - 49 -
     The Regions should contribute more heavily to
     regulation development and review, especially
     regarding operational and resource issues.

     Last year ZBB focused heavily on process;
     henceforth it should focus more on substantive
     analysis: getting workload analysis fully
     implemented,  finding efficiencies, developing
     new program initiatives, and re-examining older
     programs carefully.  We must also continue to
     help Office of Management and Budget develop
     cross-agency ZBB.

(2)   We need both stronger State programs and
     stronger State/EPA collaboration.  State and
     local officials now staff 85 percent of the
     national environmental regulatory effort,  and
     we are seeking to delegate even more.   We must
     strengthen our joint environmental management
     effort, especially in the following areas:

        We have more than doubled the Federal grant
        support to State and local units since 1977
        (including the addition of the Clean Water
        Act, Section 205(g) funds).

     -  Our new State/EPA agreements should become
        more than contracts:  they should induce
        joint planning and they should press
        decision making up to the senior policy
        officials on both sides.  This should make
        it easier to refocus programs as our needs
        change and to innovate and integrate.  By
        1981 the agreements should cover all our
        programs.

     -  We must win passage for and then implement
        our Integrated Environmental Assistance
        legislation to give the States the  flexibility
        and added  resources for such refocusing,
        innovation, and integration.

        We should  encourage personnel interchange
        and training,  e.g., through group IPA's.

(3)   Our Regional  Administrators must strengthen
     their management/analytic capacity so  that
     they can better manage their Regions,  lead
     and evaluate  the State and local agencies  in

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                         - 50 -
          their areas more effectively, and participate
          equally in Agency-wide policy and management
          decision making.  Unless the Regions'  ability
          to think and manage is strong, both Regional
          decentralization and EPA's linkage with State
          and local government are at risk.  Headquarters
          analytic units must help the Regions develop
          this capacity, and both sides should build
          strong, continuing ties.

     (4)   Our managers should adopt Agency-wide career
          paths.  True independence, based ultimately
          on the real ability to move if frustrated,
          will flow from the professional breadth,
          self-confidence, and reputation such mobility
          will foster.  It will also give the Agency a
          management team with Agency-wide environmental
          perspective and loyalty, a critical step in our
          successful integration.

     (5)   The Agency's grantees, programs, and managers
          should be held accountable for their perfor-
          mance .  We do not do this core management task
          at all well now.  Our new personnel performance
          evaluation and reward program -- probably our
          most demanding management reform for the next
          12 to 18 months -- will make major difference.
          Our review of monitoring and the new Regional
          Profiles may help.  OUr fundamental scrutiny
          and rationalization of our many computer-based
          information systems will help.  A systematic
          regiment of evaluations beginning at the local
          and State levels and working up is critical.
          Such evaluations should be backed by a reformed
          reporting system and tied to the promises made
          in ZBB.  Designing and implementing a practical,
          integrated, limited-cost way of holding the
          States' and our own decentralized managers
          accountable is a difficult, missing part of our
          management construction.

RESPONSIVE,
EFFICIENT SERVICES

     We will continue implementing a number of fundamental
improvements in the Agency's services in 1980-81:

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                         - 51 -
     (1)  We must begin to manage EPA's personnel.  The
          new Civil Service Reform Act only makes this
          possible:  we will have to make it happen by
          changing the way each of our managers does his
          or her most important job.

     (2)  We will begin pilot tests of contracting reform
          in 1979 to improve responsiveness and cut
          processing time.

     (3)  The Agency will commit to new computers after
          a thorough management review of our data needs
          and of our existing and planned programs.

A SMART AGENCY

     Our analytic services — directly supporting our top
managers, helping prepare regulations, checking budget
pricing, providing legal or economic analyses, negotiating
with other agencies, and the like -- must keep up with a
growing workload and maintain a superior level of pro-
fessional quality.  Compromise here is foolish.

     We must continue our leadership in regulatory reform.
Finding more effective, equitable, and economical ways of
doing our work is one of the most useful, highly leveraged
opportunities open to us.  (Further, as America's largest
regulatory agency, we have a responsibility to lead.  Our
two most important reforms are controlled trading and tools
for regulatory decision making, including benefits analysis,

     Once we set a standard for controlled trading of
clean-up requirements, we can allow those we regulate to
find more efficient ways of achieving the same (or better)
environmental result.  These alternatives must also be as
administrable and enforceable as our initial approach.
Offsets (in both non-attainment and PSD areas), the bubble,
banking, brokerage, and perhaps marketable rights should
gradually all fit together into an increasingly important
complement to traditional "command and control" regulation.
If we can make this approach work on a wide scale, we will
provide our first positive incentive for control technology
innovation and significantly reduce clean-up costs (and
therefore resistance to clean-up).

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                          -  52  -
     To strengthen both performance and accountability
we should strengthen our program evaluation capacity at
all levels.  We should also play a stronger leadership
role in Administration debates on both economic and energy
policies; the best defense is a more sensible alternative.
                                               GPO 938 887

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