220R83101
ASSESSING ERA'S LONG RANGE INFORMATION
SYSTEM NEEDS
FINAL REPORT
OF THE
LONG RANGE ADP USER REQUIREMENTS TASK FORCE
October 1983
Office of Information Resources Management,
Office of Administration and Resources Management
U.S. Environmental Protection Agency
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MEMBERS OF LONG RANGE ADP USER REQUIREMENTS
TASK FORCE
David Speights (Chairman)
Mike MacDougall
Irwin Auerbach
John Hidinger
Office of Administration
Region I, Administrative Services Division
Office of Policy and Resource Management
Office of Air, Noise and Radiation
Consultants:
Tim Matlack
Dennis Berg
Walter Spiegel
American Management Systems, Inc.
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TABLE OF CONTENTS
Page
Executive Summary i
I. Introduction 1-1
II. Summary of Findings II-l
III. Staff Offices to the Administrator III-l
IV. Associate Administrator for Policy and Resource Management IV-1
V. Associate Administrator for Legal and Enforcement Counsel V-l
VI. Assistant Administrator for Administration VI-1
VII. Assistant Administrator for Water VII-1
VIII. Assistant Administrator for Solid Waste and Emergency
Response VIII-l
IX. Assistant Administrator for Air, Noise and Radiation IX-1
X. Assistant Administrator for Pesticides and Toxic Substances X-l
XI. Assistant Administrator for Research and Development XI-1
APPENDIX A - Interview Guidelines A-l
APPENDIX B - Interviewees B-l
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EXECUTIVE SUMMARY
A. Study Objectives
Long term trends in program direction and management are among the most
significant factors in determining the ADP capabilities required by the Agen-
cy. This report presents the findings of a study conducted by a task force
within the Office of Administration and represents the first step in a long
term ADP planning process. The objectives of this study were to:
Identify long term trends in agency program direction, with an
emphasis on new initiatives, potential shifts in program direc-
tion or priorities, and potential changes in the roles of
program offices at headquarters, regional offices, ORD
laboratories and state agencies; and
Define the information management needs resulting from these
trends and their implications for ADP support.
The task force was not charged with providing technical recommendations
for the Agency's future hardware, software and telecommunications network.
Also, the study was not intended to document current ADP needs and
deficiencies of existing data bases, information systems and computerized
models.
B. Key Findings
1. Strategic planning and ADP evaluation functions are essential to
effective ADP support.
An enhanced strategic planning process for Agency programs
and better communication of program plans is needed to pro-
vide a foundation for long term ADP planning.
The Agency should conduct more audits of major ADP systems
to ensure that they are responsive to user needs.
2. Continued delegation of environmental programs to state agencies will
cause major growth in information exchange with states.
EPA will have an increasing need to obtain programmatic
information from state agencies.
EPA will increasingly be called on to provide technical and
research information to state agencies.
3. There is a critical need to improve the quality of and integrate
data.
Program managers need more complete, current and accurate
data to support analysis and decision-making.
Managers need much more integration or linkage of systems
and data bases across programs and functions.
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t The Agency will be handling confidential data for several
new programs (e.g., NESHAPS) and in supporting data systems
and must provide adequate security against unauthorized
access and disclosure.
4. There will likely be an explosion in demand for ADP services. The
components of this explosion will Include:
Development, enhancement and expansion of major applica-
tions:
Several major new and replacement systems for mature
and evolving programs
Significant growth for several existing data bases
Increasing size and complexity of environmental
models.
Increasing automation of office and laboratory functions:
Widespread growth in development and use of localized
applications
Continuing automation of laboratories
Need for expanded electronic mail network to include
state organizations.
High demand for user-friendly ADP "tools":
Retrieval software
Statistical analysis software
Automated graphics
Automated mapping
Optical character recognition
Software development tools.
High demand for general and technical ADP orientation and
training.
C. Next Steps
The Agency ADP organization will be coordinating the findings of this
study with the ADP network modernization program and with other ADP planning
activities, and will be working with other Agency offices and states to refine
and update the long term ADP plans reflected in this study.
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I. INTRODUCTION
A. Objectives
Long term trends in program direction and management are among the most
significant factors in determining the automated data processing (ADP) capa-
bilities required by the Agency. This report presents the findings of a study
conducted by a task force within the Office of Administration to help support
the design of the Agency's future ADP network and the acquisition of the need-
ed computer hardware, software and communications capabilities by the Agency's
ADP organization. This study represents the first step in a long term ADP
planning process and has two overall objectives:
To identify long term (i.e. 3-5 years) trends in program direc-
tion, with particular emphasis on new initiatives, potential
shifts in program direction or priorities, and potential changes
in the nature of program operations at headquarters, regional
offices, ORD laboratories, and state agencies;
To define the information and information management needs re-
sulting from these trends, and consequent implications for ADP
support.
The task force recognizes that ADP technology and costs are changing sig-
nificantly. However, this study is not designed to provide technical recom-
mendations for EPA's future computer hardware, software and telecommunications
network. The Agency's ADP organization, with the continuing cooperation of
the program offices, will be responsible for formulating specific technical
ADP plans for meeting these needs.
Of particular note, this study is not intended to document current ADP
requirements and deficiencies of existing data bases, information systems and
computerized models. However, the study does address current needs which will
require future ADP support as well, and which may lead to significant system
development or enhancement activities within a three to five year timeframe.
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B. Methodology
The findings of this report are based on a series of interviews conducted
with many of the senior managers at headquarters, regional offices and ORD
laboratories, and with representatives of state agencies. These interviews,
and the findings of the study, represent the perceptions of senior managers
regarding trends or potential changes in program direction and operations.
The interviews do not necessarily reflect firm commitments to program changes
or to specific information management or ADP projects. All interviews were
designed to be comprehensive, but were not intended to define program direc-
tions or ADP needs in great detail. Most interviews were 1 1/2 to 2 hours in
length and followed guidelines distributed in advance of the interview (see
Appendix A). In conducting this study, the Task Force found that many inter-
viewees were very tentative in projecting three to five year trends and tended
to focus on shorter term program directions and ADP needs.
Interviews were first conducted at headquarters with managers at the
office director level. Many managers consulted their staffs or included them
in the interviews. The interviews encompassed virtually all program offices.
(See Appendix B for a complete list of interviewees, including representatives
of regional offices, ORD laboratories, and state agencies.)
Following the interviews at headquarters, the Task Force prepared an in-
terim report for comment by the interviewees and to guide interviews with man-
agers in regional offices and ORD laboratories and with representatives of
state agencies.^ To obtain the perspective of the regions, three sets of
on-site interviews were conducted. The Task Force conducted in-depth
interviews with managers in Region I and their staffs. Interviews were also
conducted on-site with senior managers in Region II. In addition, group
interviews were conducted in Region VI for a cross section of managers from
"Long Range ADP User Requirements Study - Interim Report", June 7, 1983. All
comments regarding the interim report are reflected as appropriate in the cur-
rent version.
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all other regions, and several senior Regional managers were interviewed in
Washington. Regional representatives on the ADP Steering Committee were
included in these interviews.
The Task Force also interviewed many of the directors of ORD laboratories.
On-site interviews were frequently attended by senior laboratory staff. Sev-
eral directors were interviewed in Washington.
States are represented in the study by interviews conducted with the
directors of associations of state environmental agencies and two members of
the association of solid waste program administrators. Although individual
states were not contacted in conducting this study, state agencies will be
called on to participate in continuing ADP planning activities.
C. Next Steps
This report completes the initial phase of an ongoing long range ADP plan-
ning process. The Agency's ADP organization will assume responsibility for
extending the planning effort into the next phase, and for working with other
EPA offices on a continuing basis to assess their long range user require-
ments.
The ADP organization is now conducting two planning activities that will
be coordinated with the findings of this study:
A Computing and Telecommunications Acquisition Plan (3-6 years)
that addresses the central computing facility, the distributed
data processing network and the telecommunications network
requirements.
A Short Term ADP Plan (1-3 years) that addresses the ADP impli-
cations of the Agency's 1984 and 1985 program requirements and
management information needs. ADP plans will be developed first
at the program element level and will subsequently be developed
for individual systems and related types of services.
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The ADP organization is also working with representatives of other offices
to develop a policy for acquiring and using microcomputers.
D. Report Organization
Chapter II summarizes the findings of the study from a cross-cutting per-
spective and is structured to highlight overall information and information
management needs and implications for ADP support. The remaining chapters
focus on the program trends, information and information management needs, and
ADP support needs of individual programs. Each chapter addresses the programs
and functions attributed to a specific Associate or Assistant Administrator,
and is organized to highlight the views of headquarters, regions and states.
The views of regional organizations with no direct counterpart at headquarters
(e.g., Environmental Services Divisions, Deputy Regional Administrators) have
been included within the appropriate programs and in the study summary. The
views of ORD laboratories are reflected in the final chapter and in the
summary.
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II. SUMMARY OF FINDINGS
This chapter summarizes the most significant findings of the study with
respect to the Agency's needs for information management and related ADP sup-
port, and the trends in programs and management/administrative functions con-
tributing to these needs. Although the findings are directed toward a three
to five year time horizon, many of the findings are important in the short
term as well. Several of the most representative programs, functions and in-
formation systems (or applications) are noted in these overall findings.
A. Strategic Planning and ADP Evaluation Functions are Essential
To ensure that ADP activities adequately support programmatic activities
and efficiently use available resources, the Agency needs to improve the stra-
tegic program planning process and conduct more ADP audits.
1. Enhanced Strategic Program Planning Process Needed to Provide a Foun-
dation for Long Term ADP Planning
An analysis of the Agency's long term ADP needs, and subsequent plan-
ning for ADP support, should be based on an understanding of program goals and
objectives, the initiatives that will be undertaken to achieve them, and the
scientific and management decisions that will be faced and require information
support. In conducting this study, the Task Force became aware of a lack of
long-term Agency-wide or program specific plans for general guidance in ADP
planning. Consequently, strategic planning at the program and function level
is vital to the development of ADP plans that will in fact support future pro-
gram needs, and should be performed regularly.
2. Increasing Need to Audit Major Centralized Systems
A number of the Agency's centralized program management and adminis-
trative information systems no longer effectively support users' needs and
seem incapable of supporting future requirements. These systems were devel-
oped several years ago and have not kept pace with the changing information
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needs of management or with advances in ADP technology. However, the Agency
continues to devote considerable resources to maintaining both the software
and data for these systems. The Agency's evolving systems audit function
should expand the number of system audits for existing systems and post-
implementation audits for major new systems to ensure that major problems are
identified for action and that limited ADP resources are used cost-effective-
ly-
B. Strong Growth in Information Exchange with States
As EPA continues to delegate environmental programs to state agencies,
there will be an increasing need to obtain information from state agencies and
also to provide technical and other information to state (and local) agencies.
1. Increasing Requirement to Obtain Information from States
Most environmental programs will continue to be delegated to state
agencies, and EPA will need more and better quality information from states to
assess overall program effectiveness, identify major problems, and report to
the Congress. The Agency also must be sure that information of known quality,
especially for monitoring activities, is being collected. Effective manage-
ment of information obtained from states will require increasing ADP support.
State cooperation in the use of EPA data systems or forwarding of data from
state systems will be essential.
Cooperation will vary among states, among programs, and among differ-
ent types of data. State agencies are generally willing to report grants in-
formation, are less cooperative in reporting monitoring information, and
resist providing detailed compliance and enforcement information. States
which administer environmental programs through local agencies generally find
it more difficult to provide complete program information to EPA.
Program offices may adopt a variety of strategies to encourage states
to report information required by the Agency. A common strategy will be to
make an EPA information system available to support state (and local) program
managers. For this strategy to succeed, the Agency will need to address a
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number of characteristics of the state ADP environment and experience gained
to date:
States will seldom use systems that do not meet their
needs, and they should have a significant role in the
design of new and enhanced systems. Although no system
will be able to meet the needs of every state, the partici-
pation of several representative states will help build a
consensus on key requirements and encourage adoption of the
system by other states.
Agency systems should require the submission of only the
\ key data items that are needed and will be used by program
managers. The Agency should recognize the burden on states
of collecting and maintaining data and not require the sub-
mission of non-essential data.
Agency systems should provide some flexibility for states
to fine tune the system to address their unique require-
ments. Systems should provide a capability for user-
defined data items and an easy to use report writer to
enable states to develop custom reports and retrievals.
Some state agencies, like many organizations, experience
turnover among system users and frequently need to train
new users. Also, many agencies receive limited support
from state ADP staffs. To enable state agencies to
effectively use EPA systems, these systems should be well
documented and easy to use, especially for data entry
processing. Users must be able to easily enter new data
and correct errors, and will prefer interactive processing
for many applications.
State agencies have limited resources and are strongly dis-
couraged from purchasing ADP services outside the state
government. To encourage use of EPA systems, the Agency
should continue to provide timesharing to states through
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state grants, and incentives for using EPA's systems.
These incentives should include flexible report writers,
graphics capabilities, similar state-of-the-art ADP capa-
bilities, and other incentives for states to acquire and
use hardware, software and systems compatible with those of
EPA that may not be available through the state ADP
organization.
Providing standard software to state agencies for implemen-
tation on state computers is constrained by the diversity
of hardware and software utilized by states and the need to
design systems using common, and often less flexible, pro-
gramming languages (e.g. COBOL, FORTRAN). The Agency
should investigate the feasibility of providing micro-
computers or minicomputers to states (as government fur-
nished equipment owned by EPA) to provide interactive data
entry and manipulation capabilities and encourage state
use. This approach may prove to be more cost effective
than direct state use of EPA mainframe computers at the
National Computer Center or the use of regional minicom-
puters. Should this approach be taken, the Agency should
select a standard operating system for computers provided
to states by EPA programs to minimize the need for the
Agency to maintain information systems in several different
software environments.
Regardless of the Agency's efforts to improve ADP support, some state
agencies will not fully support EPA's data needs. Several managers believe
that the Agency should take a harder line in defining state reporting respon-
sibilities and establish a stronger link between reporting and program grants.
2. Increasing Need to Provide Information to States
As state agencies assume more responsibility for administering dele-
gated programs, they will request additional information and technical support
from EPA. An increasing awareness of toxic pollutants in all media will also
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generate a greater volume of state requests for scientific and technical in-
formation generated or compiled by EPA. Although much of the information
required by states may ultimately be retrieved directly from automated sys-
tems, many requests will require that EPA staff explain the source and accu-
racy of different types of data and constraints on its use to ensure that the
data is used properly. Specific requirements will include:
technical data on effluent guidelines and the performance
of control technologies to assist permit writers
health and environmental effects data for pesticides, chem-
icals and hazardous compounds, and physical and chemical
properties, to \ support state response to environmental
emergencies
t technical data on the control of hazardous waste
t . status information for enforcement actions referred to EPA
monitoring data maintained by states using EPA system.
In developing systems to support state agencies as well as EPA, it
will be essential to gain the participation of states in the design phase to
ensure that state needs are given full consideration.
C. Critical Need to Improve Quality of and Integrate Data
Program managers need more complete and accurate data than is currently
maintained in the Agency's information systems. To effectively use available
data, managers also need the capability to link data that is now maintained in
different systems to reflect the relationships between Agency programs and
functions. These needs are described below. The need to protect confidential
data from unauthorized access is also discussed in this section.
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1. Need to Improve Quality of Data Maintained by Agency Systems
A significant number of the Agency's major data systems maintain data
that is incomplete, inaccurate and/or not current, and thus do not meet the
quality control requirements of one or more current and potential users. Such
systems include monitoring, management and administrative systems. Two
problems frequently cited are data collection, entry and error correction pro-
cedures that do not reflect actual work flows, and inadequate automated con-
trols (i.e., edits) in data entry and update processes. For both new and
existing systems, providers of data will increasingly require interactive pro-
cessing for data entry, edit and error correction from terminals located in
users' offices (including headquarters, regions, laboratories and states).
Such processing must be "user-friendly" for individuals who enter data fairly
frequently but who do not have strong AOP skills. Examples of applications
likely to implement interactive data entry are the water permits compliance
system, hazardous waste compliance monitoring and enforcement systems, and
personnel system. For some systems, interactive data entry will be performed
by professional staff located outside of EPA facilities (e.g., at hazardous
waste sites) using portable terminals.
Another issue that will need to be addressed is the formulation of
standard definitions for data items that are used by or collected from two or
more different organizations. It will be especially important to define pro-
gram activities or accomplishments reported by state agencies (e.g., adminis-
trative enforcement actions), and develop with state assistance criteria for
denoting the "equivalence" of activities conducted by states with comparable
activities monitored by EPA.
An increasing emphasis on the multimedia measurement of toxic materi-
als will also affect the types of data stored in the Agency's systems. Con-
centrations of toxics in air and water are generally very small (e.g., parts
per billion, parts per trillion). Systems for maintaining ambient data must
be capable of accurately storing data for these materials at these small
concentrations in such a way that users know of the quality of the data (i.e.,
how precise, accurate and sensitive the monitoring system was that generated
the data).
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2. Need More Integration of, or Linkages Among, Systems and Data Bases
Across Programs and Functions
Many program offices indicate a specific need for the ability to link
logically related data which are or will be maintained in different files or
data bases. This capability is needed to perform analyses, data manipula-
tions, and simple retrievals, and should link data across systems within the
same media and across media and functions. Representative examples of this
need are:
t Obtaining current and consistent information on budgets,
status of funds, FTE counts, and contract commitments and
obligations. \
Identifying current water quality and trends, construction
progress, grants issued for designated waste water treat-
ment plants, and permit and discharge data for use by water
program staff at headquarters and in the regions.
Identifying for OPRM staff and regional environmental ser-
vices divisions the release of pollutants into all media
for designated facilities.
Obtaining the compliance status and enforcement history of
a facility or parent company for one or more statutes for
OLEC staff, regional counsel, regional top management, and
the staffs of enforcement offices at headquarters and in
the regions. (More complete data than that maintained by
existing systems is also required).
Identifying groundwater problems and the location of nearby
injection wells, Superfund sites, hazardous waste sites,
and other facilities for use by regional program staff.
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Comparing trends in program accomplishments for specific
organizations (including states) with budgets and perform-
ance commitments, to support the Comptroller's Off ice,
other offices within OPRM, and regional management and pro-
gram staff.
Identifying chemical properties, health and environmental
effects, and containment and removal technologies for sub-
stances found at hazardous waste sites for use by regional
environmental services divisions and state waste program
staff.
0 Identifying chemical properties and health and environ-
mental effects of chemicals with comparable structures as
part of the review of pre-manufacture notifications and
other notifications under TSCA.
Two major obstacles identified by users attempting to perform data
"cross-walks" are:
0 Inconsistent data definitions for common parameters, such
as facility/company identifier, chemical identifier, and
geographic location; and
t Differences in the software used by various applications,
the lack of a common language to access data, and limited
training and user support provided by ADP staffs respon-
sible for systems operated by another program office.
Although most programs at headquarters indicate a need for increased data
integration within media, OPRM, OLEC and regional program offices and environ-
mental services divisions have the greatest need for integration across media.
OA and regional administrative services staff have the greatest need for inte-
grating data across administrative functions. OPP, OTS and OSWER have the
greatest need for integrating health and environmental effects information
generated or collected by different program offices.
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3. Need to Protect Confidential Information in More Applications
With an increasing emphasis on toxics in several media, requirements
to safeguard confidential business information may be extended to several new
and existing systems. In addition to confidential information now maintained
in the OTS chemical inventory and in systems for pre-manufacture notifica-
tions, firms may submit confidentiality claims for information about toxics in
air emissions, water effluents, and solid wastes. Compliance and enforcement
data for hazardous waste sites may also be claimed confidential. Security for
systems which maintain these data will likely need to be improved to guard
against unauthorized data access and disclosure.
D. Likely Explosion in Demand for ADP Services
\
Program managers are becoming increasingly aware of ADP technology and the
benefits to be gained by making greater use of ADP to support program analysis
and operations. There will likely be an explosion in demand for ADP services
in four areas:
System development and enhancement support for major ADP
applications
Increasing automation of office and laboratory operations
Increasing use of ADP "tools" by end users
Increasing need for general and technical ADP orientation and
training
Each of these is described below.
1. System Development, Enhancement and Expansion Support for Major ADP
Applications
The growth in demand for ADP services represented by major applica-
tions will take three forms. Several programs and administrative functions
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will be developing new or replacement information systems. Second, several
existing systems will experience significant data base growth. Finally,
environmental models will be increasing in size and complexity. These trends
point toward an increasing demand for both computer and ADP staff support.
a. Development of New and Replacement Systems
Many of the systems the Agency requires to carry out both pro-
grammatic and administrative functions are currently in place. However,
several programs will likely develop major new or expanded applications.
These include:
pesticides and toxic substances research data bases/
bibliographies to. support chemical analyses and
research
underground injection control and permits system to
track injection sites
groundwater monitoring data base to identify national
and local problems and link data on groundwater qua-
lity with data for potential sources of contamination
t ocean monitoring data base to assess the effects of
ocean dumping of wastes
effluent guidelines research data bases/bibliographies
to assist NPDES permit writers in identifying appro-
priate technologies on a case by case basis
hazardous waste site permitting, compliance monitoring
and enforcement data bases to track program accom-
plishments
Superfund removal and remedial site management, moni-
toring and enforcement data bases
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Laboratory data management, and, in particular, sample
file control for some regional laboratories to perform
functions such as:
data acquisition and reduction
analytical quality control performance limits
checking
instrument calibration chart maintenance
automated instrument control
Several major system upgrades or replacements are anticipated,
including:
\
air quality monitoring and emissions system
water permits compliance system
t financial management and related systems
hazardous waste data systems
payroll system
personnel system
facilities management system
contracts information system.
b. Data Base Growth
Significant growth is expected in the volumes of several types
of data processed by existing data systems, including:
toxic emissions and monitoring data related to Nation-
al Emission Standards for Hazardous Air Pollutants
t water monitoring data for toxics
compliance monitoring and status information, espe-
cially for programs administered by state agencies
with incomplete reporting to EPA at the present time
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0 enforcement actions, including administrative and
other actions taken by state agencies.
c. Increasing Size and Complexity of Environmental Models
Environmental and health effects models developed by several
program offices and laboratories are expected to process larger volumes of
data and increase in computational complexity. Greater use will be made of
models of .local ecosystems within designated bodies of water. These models
process voluminous monitoring and other data. Complex long range transport
models for acid rain and regional (i.e., large area) models for ozone will
likely be developed. Models used to develop standards and regulations will
encompass more variables to more accurately reflect potential exposures,
environmental impacts and health effects, and to help ensure the proper degree
of control (e.g., air quality and pesticides). Overall, modelers will require
access to large computers to operate some of the more complex models.
2. Increasing Automation of Office and Laboratory Operations
Many functions now supported by manual information handling proce-
dures will substitute automated capabilities to make better use of limited
staff resources. Among the types of activities to be automated are local
office tracking systems and collection of data from laboratory equipment. In
addition, there will be much greater use of the electronic mail system and a
need to expand the system to users outside the Agency.
a. Widespread Growth in Development and Use of Localized
Applications
Several program offices at headquarters and virtually every
regional organization and ORD laboratory anticipate making greater use of ADP
to process numerical and text information that is principally of local inter-
est. A significant number of Agency staff are becoming computer literate and
will require that greater use be made of ADP to support program planning,
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management and office operations. Examples of the most common localized
applications include:
project scheduling and tracking
§ automated tickler files (e.g., follow-up on pesticide
registration filings, administrative orders, etc.)
t workload planning and modeling
word processing and automated document filing, includ-
ing correspondence, studies, reports, and policy
papers
Senior managers perceive that most of these applications will have relatively
small data bases, will be operated by end users, and will not be developed
unless they are inexpensive to operate and maintain. These applications
generally would not be implemented on the Agency's existing mainframe com-
puters, but may use data stored in the Agency's centralized data bases. Of
particular note, reasonable management controls should be placed on computer
use to ensure that data are protected from unauthorized changes and that users
do not waste resources on frivolous or personal applications.
b. Continuing Automation of Laboratories
Automated collection of experiment data and control of equipment
has made tremendous advances in the past several years and will continue to
increase significantly. Much of the laboratory equipment now used by the
Agency for analysis, and new equipment available to scientists, generates raw
data in a form suitable for collection, reduction and analysis by computers.
Some equipment generates large volumes of data quickly and requires the scien-
tist to use a computer to monitor the analysis and make adjustments. For
behavioral experiments that generate smaller volumes of data, small computers
(i.e., microcomputers) may be used to take periodic measurements and readings
of equipment and free scarce EPA laboratory staff to do other important tasks
that cannot be automated.
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A few ORD laboratories will require the capability to monitor
experiments being conducted off-site by contractor staff by examining data
submitted in real time to the Agency's computers by contractors' equipment.
Regional ESD laboratories may adopt a Sample File Control system to improve
data quality and management.
Overall, laboratories in ORD and in the regions will require
more dedicated small computers to support data collection and reduction, and
control of laboratory equipment, and improved processing capabilities to
support laboratory data management.
c. Growth in Use of Electronic Mail and Need to Add State Agencies
to the Network ,
Most offices at headquarters and in the regions with access to
electronic mail have found it extremely useful in communicating with regional
offices, laboratories and, to a lesser extent, other program offices at head-
quarters. Most remaining offices expect to- find it useful, and all but a few
anticipated at a least a doubling in their use of electronic mail within the
next two years. Most regional offices have found it to be especially useful
in communicating with headquarters, and would like a comparable capability
within a region to improve communications among program groups.
Several offices would like to add state agencies and other
organizations at the Federal, state and local level to the network to enhance
communications for environmental emergencies, streamline grants processing,
provide improved coordination on enforcement actions, and reduce the "paper
shuffling" and mailing delays for documents submitted by states (e.g., SIP
revisions) for EPA review. However, access priveleges for some new users may
need to be restricted if the network is expanded. In addition, confidential
information should not be entered into the mail system unless adequate securi-
ty can be provided.
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3. Widespread Need for User-Friendly APR "Tools"
Most offices have a current and long term requirement for a variety
of ADP tools to facilitate the use of information systems by program staff
with limited technical ADP expertise. Were the Agency to meet the requirement
for several of these tools, especially the capability to access and manipulate
data in Agency data bases, there would be explosive growth in the use of many
management, administrative, and technical information systems.
a. Data Retrieval and Statistical Analysis Software
Standard user-friendly software packages are needed that enable
users to retrieve data from Agency data bases by specifying their own record
selection criteria, and to manipulate the data (e.g., "what if" capability)
without changing the content of master files and data bases. One, or at most
a few, standard packages are desired which can be applied to virtually any
system or data base. User friendly retrieval tools will enable managers and
staff to quickly obtain information which might otherwise require contacting
several people or searching manual files. However, users must exercise
caution in interpreting data they are not familiar with to ensure that it is
not misused or misrepresented. (Similarly, caution should be exercised in
using automated graphics and mapping capabilities discussed below.)
A related requirement exists for statistical analysis software
which users can apply to the selected data to conduct a wide variety of analy-
ses. ORD laboratories and regional environmental services divisions now have
a pressing need for an easy-to-use statistical capability to analyze data
generated by laboratory tests.
Data dictionaries or similar capabilities are needed to enable
users to identify the data items maintained in different systems and the
relationships among those items.
-------
11-16
b. Automated Graphics
*
Standard user-friendly graphics packages are needed to make pre-
sentations of summary data in pictorial form and support comparisons of pro-
gram performance, easy identification of trends, etc. Most users require a
relatively simple graphics capability and the ability to print hardcopy graphs
locally. Users also emphasize that the cost of graphics software should be
lower than the costs of some software (e.g., TELEGRAF) currently used by the
Agency. Color graphics would be very useful to ORD laboratory staffs, but is
not essential to other users of automated graphics.
c. Automated Mapping
Much of the environmental data maintained by the Agency relates
to specific states, regions or other geographic locations. Software is needed
to support mapping of point sources and ambient data, including national maps
and highly detailed contour and point plot maps of individual regions, states,
river basins, etc. With the exception of laboratories, color mapping would be
useful, but is not essential.
d. Optical Character Recognition
Several offices would like to automate high volume routine data
collection and entry procedures to reduce staff resources needed for this
activity. Functions which are currently using or considering using optical
character recognition technology are document control in OTS, grants informa-
tion reporting, and printing of ORD research reports. In addition, several
offices expressed a need to convert printed materials prepared by contractors
into a format that is compatible with the Agency's word processing capabili-
ties.
e. Software Development Tools
Users in several program offices expressed a need for software
that will enable them to rapidly design and implement data bases to support
-------
11-17
local applications, and especially data management for scientific research and
individual projects or studies. However, these data bases may be of interest
to several offices and consequently should adhere to Agency data standards to
enable other users to link or integrate them in the future to support new
analytic efforts.
4. High Demand for General and Technical ADP Orientation and Training
Most managers throughout the Agency would like orientation and train-
ing for themselves and their staffs regarding the overall capabilities of ADP
and specific uses and capabilities of EPA information systems and data bases.
A significant number of senior managers desire hands-on training in the use of
the Agency's computer capabilities and specific applications. An orientation
for new appointees who may have minimal knowledge of ADP and of Agency systems
will be particularly useful.
Ongoing training and user support for state users of EPA systems will
be mandatory. Some state agencies experience turnover and also require
training to ensure the successful adoption of new 'system capabilities as well
as routine modifications.
E. Sources of Findings
Most of the findings of this study are not unique to individual offices,
but instead reflect common needs of managers in program offices at headquar-
ters, in regional offices, and in laboratories. Exhibit II-l identifies the
Agency (and state) organizations associated with each major finding.
F. Findings in Common with Previous ADP Studies
Several of the findings of the Task Force are consistent with those of
previous ADP studies, especially with the "Stage Assessment and Five Year Man-
agement Plan for ADP" conducted in 1979 by Nolan, Norton and Company.
-------
11-18
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11-20
Specific findings and recommendations of the Nolan, Norton study related to
the current study that are still relevant
Adopt a "top-down" ADP planning strategy, which links EPA's
overall mission plans (emphasis added) to plans for ADP
applications, data resource support, and computer equipment
acquisition phases. Develop an annual ADP plan within each AA
office, subject to central review and coordination.
Manage EPA's data resource as a key Agency asset distinct and
apart from the systems which currently use the data. Develop a
data resource plan for EPA which defines where data resides
within EPA and how it is to be managed and controlled on behalf
of all organizations that need it.
Learn to use technologies now emerging which will make extensive
data sharing and integration feasible and economical in the
future.
The following items are taken from "Stage Assessment and Five-Year Manage-
ment Plan for Automated Data Processing," Management Report, July 1979 by
Nolan, Norton and Company, Inc.
-------
III-l
III. STAFF OFFICES TO THE ADMINISTRATOR
A. Program Trends - Offices at Headquarters
The major functions of the staff offices to the administrator are not
likely to change significantly. However, the specific responsibilities, staff
size, and priorities among staff functions are highly dependent upon the
personal style of the Administrator and senior staff managers. Consequently,
there will be periodic realignments of staff and responsibility.
Specific functions addressed in our interviews with members of the Admin-
istrator's staff include:
review of decision documents
tracking of environmental impact statements
budgeting and financial management of the staff offices
public affairs, including contact with the public, Congress and
med i a.
B. Program Trends - Regional Staff Offices
The staff offices to the Regional Administrators were not covered
extensively in this study. Intergovernmental liaison functions are not
likely to change significantly. Specific functions addressed in our
interviews include:
interaction with state agencies and the Congress
public affairs
reviews of environmental impact statements required by NEPA.
C. Information Management Requirements and Related Applications
The information management needs of staff offices at headquarters and
in the regions are very similar.
-------
III-2
A large volume of controlled correspondence and other controlled
documents flows through the Office of the Administrator and the
Offices of the Regional Administrators. The existing document
tracking systems, many of which are manual, are inadequate, and
will have to be replaced.
t There will continue to be a high volume of communications be-
tween top EPA program officials and the staff offices of the
Administrator at headquarters, with a parallel flow in the
regions. To better support the volume of text data, the staff
offices wil1 require:
Continued extensive use of word processing capability,
and
Integration of word processing, electronic mail, and
document tracking.
The staff offices at headquarters and in the regions rarely use
the major program systems containing management or technical
data. Inquiries requiring program information are forwarded to
the respective program office. Inquiries by the Administrator's
staff for cross-cutting information may be sent to either the
program offices or to OPRM.
t Each program office has one or more constituency mailing lists.
There is a great deal of duplicate information among these
systems, as well as redundant effort in keeping the lists up to
date. There may be an effort to integrate these mailing lists.
A variety of requirements for information management and related
applications were identified as applying not only to the staff
offices to the Administrator, but also to managers throughout
the agency:
-------
III-3
On-going training and briefings to keep managers in-
formed of the information services available through-
out EPA.
Improved retrieval and data manipulation capabilities
for users to access information stored in Agency-wide
administrative information systems.
Personal data bases - an "automated filing cabinet"
for managers to index, store and retrieve text that
has already been keyed into word processing.
Graphics capability for use in presentations to senior
management is essential.
Flexibility in hardware installation, especially for
terminals connected to the EPA network or local mini-
computers, is necessary to support internal reorgani-
zations and office moves.
Improved system reliability and backup are required,
especially for management and administrative systems
currently implemented on DEC minicomputers at head-
quarters. Down time and data loss create major
problems in management and administrative systems that
are essential to program managers and budget staff.
D. ADP Tools
Electronic mail will be used increasingly for communications
with EPA managers in headquarters and in the regions. Regional
staff would like to add regional program managers and state
agencies to the network to provide more timely communication of
EPA actions, including policy decisions. However, state
agencies should have access to only pertinent mailboxes on the
network and not to all agency managers.
-------
III-4
Greater use of menu-driven systems to enable managers to re-
trieve data without requiring a great deal of system-specific
knowledge and training.
E. Other Remarks
t The new ADP organization should include program and management
analysts on its staff to ensure effective communications between
program staff and the technical ADP staff.
t Regional staffs require more information on ADP capabilities and
technology that may improve day-to-day office operations, and
improved means to identify the personal contacts for EPA's pro-
gram information systems.
Telephone capabilities in some regions are archaic. Regional
staff require telephone features (e.g., call forwarding and
potentially voice mail) that will improve the productivity of
the considerable time spent using the telephone.
-------
IV-1
IV. ASSOCIATE ADMINISTRATOR FOR POLICY AND RESOURCE MANAGEMENT
A. Overall Trends
The principal functions and responsibilities now conducted by the offices
within OPRM are not expected to change significantly over the next several
years, although the functions will likely be reorganized.^ 0PM will be
required to assess proposed regulatory decisions from an Agency wide
perspective, evaluate the effectiveness and efficiency of EPA program?, and
management, conduct analyses of program policy requested by the Administrator;
and manage the development and review of the Agency's budget. A continuing
emphasis will be placed on managing for environmental results. Specific
trends within individual OPRM offices are discussed in the following sections.
B. Program Trends - Office of the Comptroller
The overall budget process and functions performed by this office are not
expected to change significantly over the next several years. A potential
change to a two-year budget cycle is possible, but this would require Congres-
sional approval and is not likely to occur. The establishment of new offices
within EPA, or a major reorganization, would have a significant effect on the
budget structure but not on the budgeting process.
Several additional activities that may be undertaken include:
Increased automation of the budget process, especially narrative
text components of budget turnaround documents and program of-
fice submissions.
Redesign of the budget system or conversion to data base manage-
ment technology, but only in conjunction with an upgrade of
EPA's Financial Management System.
Pending Agency reorganization will likely shift the Office of the
Comptroller to what is now the Office of Administration.
-------
IV-2
Implementation of a program accountability system and linkage
with budget submissions.
C. Program Trends - Office of Policy Analysis
This office will continue to have a strong "project" orientation, conduct-
ing roughly 100 projects concurrently such as regulatory analysis for proposed
regulations, assessments of the economic impacts of alternative policies in
areas such as acid rain and NESHAPS permits, analysis of the economic benefits
of environmental improvement, and the large, multi-year Integrated Environ-
mental Management Project. IEMP is developing strategies and analytic methods
for assessing environmental problems and developing control strategies on a
multimedia basis as an alternative to traditional approaches which usually
focus on individual media. IEMP will develop and assess three strategies for
regulatory integration reflecting different baselines: the industrial
approach, geographic approach and chemical approach.
The industrial approach will ultimately develop complex models of the
operations of eleven industries and the impacts and interaction of
environmental regulation for all media. These models may be used to
forecast industry trends and support the design of new and revised
regulations, and will be maintained to reflect current data and
changes to the parameters of the model and their interrelationship.
The geographic approach will cut across industries and examine speci-
fic locations with respect to pollution sources, ambient conditions,
public exposure, and health effects to support the development of
localized regulatory strategies. Up to twenty cities/counties will
be examined.
The chemical approach will examine multi-media and cross-industry
control strategies for specific chemicals, and may assess alternative
data collection and analytic methods for monitoring toxic pollutants.
Its future evolution is uncertain.
-------
IV-3
Analyses by OPRM of energy issues related to the environment will probably
continue to be de-emphasized. Specific analyses to be conducted in the future
will be a function of the areas of interest to EPA top management.
D. Program Trends - Office of Standards and Regulations
This office will continue to address four major areas: regulatory reform,
regulation oversight and review, management of the regulations development and
review process, and implementation of the Paperwork Reduction Act.
Most new regulatory reforms now being considered are extensions
of the "bubble" principle -- water bubbles and bubbles for new
sources of air emissions subject to new source performance
standards. Ongoing programs resulting from these reforms will
be transferred to the appropriate program office. Current ef-
forts in environmental audit are oriented toward establishing an
information clearinghouse for use by firms wishing to establish
an audit function, and are not expected to result in new regu-
lation. Other reforms that may be initiated within the next two
to five years cannot be predicted at this time.
OSR anticipates a continuing significant role in reviewing pro-
posed regulations, although their degree of involvement in regu-
latory reviews may change under future Administrators.
OSR anticipates refining the regulation review process and im-
proving communications on the status of reviews to speed up the
review process, identify recurrent bottlenecks in the process,
and initiate action on bottlenecks in a more timely manner.
Increasing effort will be expended for providing information re-
sources management (IRM) direction and quality control on data
collection Agency-wide. OSR will review the statistical valid-
ity of proposed data collection efforts, and provide assistance
to other offices in obtaining data collection clearances from
-------
IV-4
OMB. Primary emphasis will be placed on quality control to en-
sure that the collection of poor quality data is either improved
or terminated. An IRM handbook will be prepared to assist pro-
gram offices in developing data management plans, and ongoing
analytic support will be provided by OSR.
A potential major growth area is the application of statistical
analysis to the development of neutral inspection strategies re-
quired by the Barlow decision. OSR will assist enforcement pro-
grams in developing legally non-discriminatory inspection tar-
geting algorithms which identify facilities most likely to be
out of compliance with applicable regulations.
E. Program Direction - Office of Management Systems and Evaluation
The principal mission of this office will be to support efforts by the
Agency's top managers to strengthen the management of EPA programs and to
improve relations between EPA and state environmental agencies. Specific
functions performed by OMSE will include operation of the Administrator's
Accountability System (which OMSE developed), development of other systems for
measuring program accomplishments and environmental results, and the conduct
of management studies to identify specific problems and potential solutions.
OMSE has played a major role in working with associations of State environ-
mental officials to find ways of removing barriers to EPA delegation of
authority to run environmental programs, and to develop improved methods for
EPA oversight of delegated programs. These efforts will continue. OMSE offi-
cials stress that EPA-State sharing of data can be mutually beneficial only if
it takes place within an agreed-upon framework for EPA oversight of program
effectiveness (as distinguished from review of individual State actions).
F. Information Management Requirements and Related Applications within OPRM
OPRM will be a significant user of information generated or collected by
other program offices as well as information generated internally by OPRM.
With respect to the latter category of information, OPRM will have the follow-
ing requirements:
-------
IV-5
An automated project tracking capability for use by the Asso-
ciate Administrator and deputies to identify the projects being
undertaken within OPRM and their current status.
A real-time capability to track the status of regulatory actions
and identify bottlenecks in the regulatory review process.
An automated capability to generate instructions for preparing
budget submissions and to integrate information about program
objectives and commitments with proposed funding levels.
Automated capabilities to manage and analyze data collected by
OMSE and OPA for specific projects.
Improved access to automated models developed and operated by
contractors and the capability to refine and rerun them to sup-
port comparable studies and analyses.
Access to commercial econometric models and private data bases,
and also to technical data bases maintained by the U.S. Geo-
logical Survey, National Weather Service, Bureau of the Census,
and Departments of Labor and Health and Human Services. Greater
use will likely be made of the Domestic Information Display Sys-
tem (DIDS) developed by several Federal agencies.
Improved flexibility for the Resources Management Information
System and greater integration with the Financial Management
System.
In-house implementation of IEMP models developed by contractors
on outside computer facilities to provide easier access and use
by other program offices and potentially by regions.
-------
IV-6
6. Information Management Requirements and Related Applications
Oriented toward Other Program Offices and Systems
OPRM will increasingly be a major user of management, technical, and ad-
ministrative information maintained by other program offices. Specific
requirements with respect to this information and related ADP systems include:
Improved data quality for many major systems, including monitor-
ing, permits, emissions/effluent, compliance and enforcement.
Significant deficiencies of existing systems include:
incomplete and old data, especially data collected
from State agencies
inaccurate data, poor quality control
lack of common data definitions and other standards,
and a data administration function.
Several other offices expressed the same problems with major
data systems.
Improved access to data maintained by other programs, including:
direct access to software and data, without the assis-
tance or intervention of ADP staffs
user-friendly software for retrievals, preferably
menu-driven; compatible software across systems to
minimize the need for training in different software;
and technical data base designs which are transparent
to users to the maximum extent practical
easy access to historical as well as current data to
assess trends.
-------
IV-7
Ability to retrieve logically related data now maintained in
different data bases using common attributes such as facility
identifier, chemical, location, etc. At present, this cannot be
done for most retrievals that cut across media (e.g. multimedia
studies for designated geographic locations or industries) or
across functions (e.g., trends in spending for designated pro-
grams, and related facility compliance rates and ambient condi-
data maintained by EPA programs with data maintained by other
agencies (e.g. population density). A related requirement is
the addition of geographic location data to several systems, al-
though less detail than latitude and longitude coordinates would
be sufficient.
H. APR Tools
A significant number of ADP tools are of particular interest to OPRM:
Automated graphics would be extremely useful in presenting pro-
gram management and accomplishment data to the Administrator and
the Congress, and would reduce current workloads for manually
preparing graphics. Color graphics would be useful, but not
essential.
Automated mapping to generate a clearer picture of environmental
conditions and facilitate multimedia comparisons for use by ana-
lysts and top management. A more accessible mapping capability
would be especially useful to the IEMP effort which currently
utilizes the capabilities of the ORD laboratory in Las Vegas.
User-friendly statistical analysis packages to manipulate data
collected by OPRM, other programs, and other agencies to sup-
ported a wide variety of analyses, ranging from budget analysis
to analysis of compliance and ambient conditions.
User-friendly software to access, manipulate and retrieve data
in support of specific OPRM studies.
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IV-8
Simple modeling or "simulation" software to support analyses of
alternate scenarios in the development of policy recommenda-
tions. Simple programming languages are required for comparable
uses.
t Text searching capability to aid in the development and review
of policy statements, budget instructions, etc.
In addition, OPRM anticipates much greater use of electronic mail by its
senior managers for communications with regional offices, laboratories, and
other program offices at headquarters. The Office of the Comptroller will
continue to be a significant user of electronic mail.
I. Other Comments
To ensure effective oversight of programs delegated to states,
and to provide information to support and justify policy deci-
sions, EPA should invest the resources required to improve the
accuracy, timeliness and completeness of monitoring data and
program accomplishment data collected from state agencies.
EPA should consider using third parties to collect and maintain
detailed data from state agencies about state program activities
and accomplishments that are needed to generate summaries essen-
tial to OPRM and other program offices. State agencies current-
ly perceive that EPA desires detailed data to "second guess"
state actions as well as to conduct higher level program analy-
ses, and they have been unwilling to provide much of the data
requested by EPA regarding compliance monitoring and enforcement
activities. Third party organizations would generate summary
reports requested by EPA, but would not provide access to indi-
vidual records. The use of certified public accounting or mar-
ket research firms represent two approaches to third-party data
collection.
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IV-9
OPRM and other offices in EPA will need the capability to
identify national environmental trends and compare the perform-
ance of states on a wide array of performance measures.
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V-l
V. ASSOCIATE ADMINISTRATOR FOR OFFICE OF LEGAL AND ENFORCEMENT COUNSEL
A. Program Trends - Office of the General Counsel
The General Counsel will continue to represent EPA when legal action is
taken against the agency. Management and control of litigation will continue
to be exercised on a case by case basis. No major program changes cr requests
for ADP support are anticipated.
B. Program Trends - Office of Enforcement Counsel
The role of enforcement staff in OLEC, headquarters program offices, and
the regions is not likely to change significantly with respect to program
operations. Overall there will be a trend at headquarters toward greater
monitoring of enforcement activities and lesser involvement in individual
cases. Also, the.recent decline in the number of enforcement actions is like-
ly to be reversed, with a significant increase in litigation. For most en-
forcement litigation, state agencies will have lead responsibility, with
regional offices providing technical support and oversight. OLEC will con-
tinue to perform the functions of: general program management; oversight of
regional enforcement programs, including quality control over judicial (civil
and criminal) cases; and coordination on criminal cases referred to the De-
partment of Justice. The Office of Waste Programs Enforcement, with the
assistance of OLEC, will handle litigation for Superfund.
The Office of Enforcement Counsel, together with the compliance groups
within program offices, may also take an active role in developing an overall
enforcement plan designed to improve the overall management of the enforcement
program and the current image of the program. Such a plan might include:
An inspection targeting strategy, utilizing statistical sampling
and other "neutral" inspection schemes *o focus compliance moni-
toring and enforcement resources on facilities that are most
likely to be out of compliance and have major violations of en-
vironmental statutes. For example, targeting of TSCA enforce-
ment resources for PCBs would direct resources to the types of
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V-2
facilities likely to be improperly using PCBs or non-responsive
to the potential for leaks and spills in electrical equipment.
An inspection targeting strategy geared to environmental re-
sults, focusing on facilities located in areas with significant
environmental problems that are likely to be contributing to
these problems.
t Giving consideration to the complete compliance history of a
facility/company, including administrative orders, in determ-
ining the appropriate enforcement action.
The thrust of these policies will be to "manage" the enforcement program
and move away from a more "reactive" mode of operations. The Office of Legal
and Enforcement Counsel will continue to utilize NEIC for high quality tech-
nical support.
1. Program Trends - National Enforcement Investigation Center
The NEIC anticipates several significant trends related to the com-
plexity of litigation, role of NEIC, and increase in enforcement for individ-
ual programs. Many of the trends have started within the past two years and
will continue over the next three to five years.
0 Enforcement litigation will continue to become increasingly
complex and require access to a wide variety of information
and analytic capabilities. The nature of enforcement liti-
gation is shifting from relatively simple issues (e.g., is
control equipment installed) to issues requiring substan-
tially different theories and evidence (e.g., intent of the
defendant, patterns of conduct, toxicity and risks for a
substance).
0 EPA will need to be more efficient in targeting its en-
forcement resources by identifying major environmental
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V-3
problems for individual facilities from a multimedia per-
spective.
State agencies will have lead enforcement responsibility
for many programs. However, delegation will probably not
increase dramatically in view of the lead time and re-
sources needed to implement a new state program. Substan-
tial EPA assistance to states will be required.
Regional offices will have lead responsibility for target-
ing EPA enforcement actions for violations not addressed by
state programs. However, mechanisms will be needed to pro-
vide Regional Counsels the information required to ensure
national consistency and respond to consistency issues
raised by defendants.
NEIC will continue to provide expert legal technical sup-
port in enforcement litigation and support the development
of overall enforcement stategies. In addition, NEIC will
provide information analysis on request to support litiga-
tion by Regional Counsels and U.S. Attorneys. NEIC will
not participate in enforcement actions that do not involve
1itigation.
t RCRA enforcement will likely experience major growth and
become EPA's largest enforcement program. Moreover, RCRA
litigation will be much more difficult than litigation of
other statutes due to the complexity of RCRA permits and
other considerations. State agencies may need considerable
EPA assistance, especially for evidentiary hearings. In-
creasing EPA experience will ultimately result in the
formulation of a routine Agency approach for RCRA litiga-
tion .
Superfund enforcement will increase significantly. How-
ever, CERCLA litigation is now becoming more orderly with
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V-4
the adoption of a new more routine approach for this activ-
ity.
Major growth is not anticipated for other EPA enforcement
programs.
t EPA compliance inspections conducted by Regional Environ-
mental Services Divisions will address multiple media to
more effectively use limited staff resources.
C. Program Trends - Offices of Regional Counsel
Regional counsels concur with OLEC's forecast that the roles of enforce-
ment groups at headquarters and in the regions will not change significantly.
State agencies will have lead responsibility for enforcement of most programs,
with regional counsel and program divisions providing technical support and
oversight, respectively. As delegation of EPA programs to states continues,
regional counsel anticipates that more stringent oversight by regional program
staff may take place to ensure that states are moving ahead diligently on in-
dividual cases and are following up on actions taken against violators (e.g.,
attaining compliance with administrative orders). Regional caseloads are not
expected to decrease with delegation.
RCRA and CERCLA enforcement activities, and to a lesser extent, TSCA en-
forcement, are projected to be major growth areas. OLEC and other compli-
ance/enforcement groups at headquarters are expected to manage for national
consistency. Some Regional Counsels do not want the front line responsibility
for coordinating enforcement consistency among regions.
D. Information Management Requirements and Related Applications - OLEC
Much stronger management of compliance information is needed to
help determine patterns of conduct and provide evidence in court
of recurrent noncompliance. Improved automated capabilities are
needed to manage evidentiary data. Of particular importance,
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V-5
evidentiary data should be treated as confidential and main-
tained under appropriate security.
0 OLEC needs to obtain more complete and accurate information on
the number and types of enforcement actions taken by state
agencies, as well as by EPA, for each environmental statute.
Existing incomplete information constrains EPA's ability to com-
pile evidence on prior violations, report overall rates of com-
pliance to the Congress and justify in detail its enforcement
budget requests for individual statutes. In collecting enforce-
ment information from states, it is essential to develop stand-
ard definitions of enforcement activities and ensure that the
nature of state actions is properly reflected in reports to EPA
and summary reports at the national level.
A capability to perform cross-media/statute research for desig-
nated facilities and companies is required for case development,
evidentiary 'hearings, and penalty selection. This capability
should include access to administrative actions, as well as
civil and criminal actions, at the Federal and state level.
This data is currently incomplete (especially for administrative
actions taken by states), and in some cases inconsistent. Com-
mon identifiers are needed (e.g., Dunn and Bradstreet codes) to
more easily access company information across media. Further,
OLEC has no control over the data and no collection mechanism to
secure data from the states. Enforcement data collection is
currently a responsibility of the regional offices and the com-
pliance offices under each assistant administrator.
Enforcement attorneys will need the capability to link EPA com-
pliance and enforcement information with pertinent information
maintained on external data bases, especially financial informa-
tion, and also including scientific information on regulated
substances and legal data bases.
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V-6
An automated tracking and "tickler" system is needed to ensure
compliance with administrative orders and consent decrees and to
support inspections. The current level of compliance with EPA
administrative orders and consent decrees is unknown.
The "Docket" system tracks key facts and textual information
about enforcement litigation. It has slow turnaround and is
cumbersome to use. Required enhancements include:
Interactive data entry at the source, rather than the cur-
rent procedure which routes new data and changes to a cen-
tral coordinator who sends the data to a contractor for
data entry.
Direct access to the data by OLEC staff members and other
users, including members of the various enforcement of-
fices, along with the capability to compile and manipulate
information to meet case-specific needs.
Ad-hoc query capabilities.
E. Information Management Requirements and Related Applications - Office of
Regional Counsel
The information management needs of regional counsels will be similar to
those of OLEC.
0 Regional counsels, and especially program divisions, require
more complete information about state enforcement activities to
effectively carry out program oversight and provide information
requested by headquarters offices and the Congress. It will be
important to identify the types of actions taken by states, and
to distinguish between actions taken under federal legislation
and actions that are unique to state statutes. Existing systems
are inadequate in that they do not contain information about
many state actions and do not enable EPA to assess how quickly a
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V-7
state is moving on major cases and determine whether EPA may
need to provide assistance or initiate a separate action.
It will be essential to develop nationally recognized defini-
tions of enforcement activities to enable regions to develop
reliable measures of program activities at the state level.
Since some states define various classes of actions using dif-
ferent terminology than EPA, and also have unique definitions
for terms also utilized within EPA (e.g., administrative action,
notice of violation), EPA should develop criteria for classify-
ing state actions to ensure that equivalent actions are classi-
fied similarly for reporting purposes. These criteria should be
defined by a collaborative effort involving EPA headquarters and
regional offices and state agencies.
An automated capability to obtain a complete compliance history
for designated firms or facilities across statutes will be use-
ful in developing enforcement actions. This history should
include state actions as well as those taken by EPA, and will be
especially useful in regions with a large number of enforcement
actions.
t Some regions have developed legal document cross-referencing
systems that should prove useful to all regions in supporting
enforcement case preparation.
F. ADP Tools
Most OLEC attorneys have excellent typing skills and will be
heavy direct users of word processors. Some regional attorneys
are also beginning to use word processing to streamline document
production and in some regions respond to a shortage of secre-
tarial support.
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V-8
OLEC and regional attorneys require the capability to iden-
tify and retrieve the current official copy of all consent
decrees and administrative orders for use in developing
similar new orders and decrees expeditiously. Regional
attorneys also require access to requests for evidence and
to motions for summary judgement.
A significant volume of electronic mail traffic between head-
quarters and the regions is anticipated. The capability to add
state agencies and other organizations to the network and rapid-
ly communicate consistent information regarding enforcement
cases to all participating government organizations would great-
ly improve coordination, especially for complex actions. Speci-
fic organizations that should be added to the network are:
U.S. Attorney in Washington
Assistant U.S. Attorney within the region
State regulatory agency
State Attorney General
Pertinent local environmental agencies and prosecutors.
Confidential information associated with enforcement actions
will require stringent safeguards, and probably should not be
entered into the network.
Teleconferencing, and any other tool that could improve communi-
cations between headquarters, regions, and outside agencies
(e.g. the Department of Justice), would expedite case handling
and reduce travel costs. Improvements in EPA's communications
network would especially be useful to support information ex-
change between NEIC and Regional Counsels.
Enforcement attorneys require better access to the Agency's com-
pliance and enforcement data bases, and the capability to manip-
ulate available data to meet unique requirements for individual
cases.
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V-9
6. Other Remarks
OEC suggested that other enforcement offices should make greater
use of NEIC legal research capabilities.
Improved ADP procurement processes are needed to enable regional
attorneys to acquire terminals and use information retrieval and
management routines developed by the NEIC.
Regional counsels require more information about the capabili-
ties of EPA's compliance and enforcement systems, support
capabilities available from the NEIC, and about ADP capabilities
and technology in general.
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VI-1
VI. ASSISTANT ADMINISTRATOR FOR ADMINISTRATION
The Office of Administration projects two broad trends cutting across all
functions within OA. First, OA activities will be viewed as services for
client organizations rather than as individual functions. OA will strive to
provide a wider range of services, and to consistently provide high quality
service. A major initiative will be to make administrative data systems more
accessible and reliable for program users by providing more accurate data and
improved capabilities. Second, OA will seek to improve the efficiency and
efficacy of its ADP systems in supporting Reform 88.
Emphasis will also be placed on developing mechanisms which equitably
identify the cost of services provided by OA to the other offices within
EPA that are using these services.
A. Program Trends - Financial Management
Recent legislation, such as the Federal Financial Managers' In-
tegrity and Prompt Payment Acts require tighter internal control
that will be implemented over the next several years. Internal
control reviews will be conducted on possible vulnerable areas.
Actions will be implemented to strengthen cash management pro-
cesses for both collections and disbursements to comply with
Treasury and OMB directives.
The Department of Interior Payroll System (DIPS) will no longer
be supported by DOI after September 1984. EPA will establish an
in-house payroll function and implement DIPS at the NCC.
Program offices will have greater participation in identifying
financial management needs and problems. A survey will be con-
ducted on the needs for better cost accounting information.
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VI-2
Under current development is an allocation methodology for dis-
tributing indirect costs to Superfund sites for purposes of bill-
ing the responsible parties. Additional enhancements related to
the Superfund program will be developed.
t Enhancements will be implemented to comply with the GAO require-
ments for approval of accounting systems in operations.
Efforts will be made to continue to improve the effectiveness and
efficiency within accounting operations offices.
t Agency-wide quality assurance and compliance program will be
instituted.
Accounting procedures, systems and controls will be standard-
ized by eliminating duplicative data entry systems.
Greater emphasis will be given to data integration with other
administrative functions.
B. Program Trends - Human Resources
The primary trend in human resources management will be to increase the
involvement of line managers throughout the agency in managing people require-
ments, and to encourage more structured planning of the Agency's training and
staff realignment needs. Line managers will have a more active role and/or
greater responsibility in developing training plans and processing personnel
actions.
C. Program Trends - Facilities Management
There will be two major program thrusts within the facilities management
area. The first priority will be to significantly increase the responsive-
ness, quality, and efficiency of existing services. EPA will exercise a
greater degree of control over facilities-related work (such as building main-
tenance) performed by contractors.
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VI-3
Second will be an effort to upgrade the quality of EPA facilities. As the
computer and the terminal become part of the office of the present, greater
consideration will be given to furniture, space, heating/cooling, lighting,
and wiring for ADP networks.
D. Program Trends - Procurement and Contracts
There will be no major change in direction for procurement and contracts
management. However, several factors will affect the work environment, in-
cluding:
New Federal procurement regulations, which in large part are re-
flected by existing EPA procedures
t Greater automation of routine activities
t In conjunction with increased automation, a shift in staff re-
sponsibility from clerical activities to policy, procedures, and
management activities.
E. Program Trends - Grants Administration
The grants administration function may experience several significant
changes over the next several years. Block grants would result in fewer
grants with larger dollar amounts. However, the total dollars granted through
EPA programs are not expected to decline. In addition, EPA will continue to
be accountable to the Congress for how program grant monies are spent by state
agencies, and for monitoring funding provided by state governments beyond the
Federal grant. EPA will also continue to monitor 12,000-14,000 active con-
struction grants.
RCRA may have a significant impact on the grants administration function,
with the potential evolution of a large grant program with some unique char-
acteristics (e.g., cost sharing). In the long term, EPA may also elect to
fund construction grants for resource recovery facilities.
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VI-4
F. Program Trends - Library Services
The library function will evolve from literature curatorial services to a
more comprehensive and centralized bibliographic reference service. The ob-
jective will be to provide equal access for all EPA organizations to library
collections and to a broad range of bibliographic data bases.
G. Program Trends - Regional Administrative Services and Management Organiza-
tions
Regional administrative services and management organizations anticipate
few substantive changes in the way they will perform administrative functions.
Most changes over the next three to five years will reflect new or improved
applications of ADP technology to administrative functions, and the impact of
ADP on specific functions such as facilities planning and maintenance. Great-
er use will be made of optical character recognition and other office automa-
tion tools to improve productivity at reasonable cost.
Regional organizations perceive a shift to more project oriented activi-
ties and an attendant need for improved accounting systems. Regions also are
beginning to experience an overall increase in "ADP literacy" of program staff
and increased demand for access to computer capabilities. Greater emphasis
will need to be given to space planning, furniture, lighting and especially to
wiring and local area networks to meet this demand. In addition, regional
libraries and "information centers" will shift from an initial heavy emphasis
on public access to information support of regional program staff.
H. Information Management Requirements and Related Applications - OA
Data entry for many administrative systems will be moved to the
point of transaction.
Data edit and validation will be performed at the time
of transaction input. Erroneous data will be cor-
rected by the person with the most knowledge of the
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VI-5
transaction. For some functions (e.g., grants admini-
stration) data will be entered by state agencies as
well as by EPA.
Written copies of many transactions will be unneces-
sary, and the cost of preparing, processing, and stor-
ing the transaction document will be eliminated.
Transactions need only be entered once, eliminating
redundant, and perhaps inconsistent, data.
Hardware to support geographically dispersed data en-
try, and real time access to data bases from the geo-
graphically dispersed data entry locations, will be
required.
With distributed data entry, it will be particularly
important to place accountability for data quality
with the individuals who enter data, and design the
proper approval controls and audit trails into each
application.
Data will be stored once, rather than in a number of different
places, within a data base environment.
There will be some cases where it is more expeditious
to store the same element more than once for ease of
access (i.e., access pathways).
Logical linkages between data structures that contain
the same element(s) will be required. For some pur-
poses, it may be valuable for a manager to view data
as having a different logical structure than the
structure actually used to store the data in automated
files.
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VI-6
Some systems, such as the Grants Information and Con-
trol System (GIGS), may utilize distributed regional
data bases. However, the Agency has not yet imple-
mented a significant application in this manner. For
these systems, the use of standard software and data
definitions across regional systems will be mandatory.
Systems that perform the same functions for different users,
will be merged or eliminated. This will improve the service
level and reduce the cost of maintenance for a number of appli-
cations (e.g., financial spending registers, FTE tracking). A
pilot study for a small purchases system may be expanded into an
Agency-wide system, encompassing the full cycle of procurement
actions from purchase requests through disbursement of funds by
the U.S. Treasury.
A wide variety of users require access to information held in
"corporate" data bases. For example, many line managers and
budget officers need access to financial data generated by FMD
(and currently stored in FMS) regarding their program. State
agencies and EPA program staff will continue to require access
to data maintained in GICS. However, widespread access will be
balanced against the "need to know" in designing data bases and
access privileges for individual offices, as well as for data
regulated by the Privacy Act.
Computers will be substituted for manual processing whenever
practical.
A number of reports that are currently compiled manu-
ally (by putting together outputs from several sys-
tems) will be automated.
Point of transaction data entry will eliminate prepa-
ration of many paper input documents and error list-
ings.
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VI-7
A number of other office paperwork functions will be
automated such as the preparation of procurement/con-
tracts documents.
t A major system replacement/integration effort is likely for the
budget/accounting/finance/procurement/contracts functions, poss-
ibly to include payroll. A pilot system is currently being
developed by the OA Budget and Control Staff to access selective
administrative data bases and integrate related data using an
office computer. This pilot may or may not be the basis for a
larger integration effort.
t Another likely candidate for system replacement/integration will
be the payroll/personnel/human resources functions.
A probable enhancement to the personnel system will
simplify and streamline processing and reduce the
paperwork burden, thus allowing personnel staff more
time to service program officials.
Tools are needed Agency-wide to support analysis and
projection of staff capabilities, requirements, and
potential staffing problems.
The Financial Management System may be brought in-house from the
Parklawn computer facility. The Department of Interior payroll
System (DIPS) will be brought in-house within the next year.
Major changes will be made to the Contracts Information System
to improve its accuracy, timeliness, efficiency and utility.
t Facilities management has a need for two types of integrated ap-
plications;
Job planning, status tracking, performance reporting,
and chargeback.
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VI-8
Facilities, property, and inventory tracking.
To respond to Congressional inquiries about the effects of dele-
gation and spending of grant monies, the grants administration
function will require more information abojjt how grant monies
are spent by states (e.g., monitoring, enforcement), and require
a link between GIGS and other programmatic systems such as com-
pliance and Superfund site tracking systems.
0 The Budget and Control Staff requires an automated budget devel-
opment and projection capability, and believes that this capabi-
lity would be useful to other EPA budget officers. BCS also
would like an enhancement to the budget system to support elec-
tronic transfer of the OA budget developed using automated tools
by OA into the budget system.
I. Information Management Requirements and Related Applications - Regional
Organizations
The information management needs of regional administrative organizations
are relatively consistent across regions and are comparable to those of OA.
Regions will reqire much better ADP support through agency-wide administrative
systems to improve program management, provide more efficient reporting to
program staff in the regions and headquarters, and eliminate the need to main-
tain redundant localized administrative systems. The current patchwork of OA
systems is not responsive to regional needs. The highest priorities of
regional organizations are improved access to data, more timely processing of
transactions, integration among administrative systems and with program man-
agement systems, project accounting, and expanded computer support for local
applications.
Regional administrative and program organizations will require
improved access to data maintained in official agency systems
(e.g., financial management, personnel) and more user-friendly
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VI-9
retrieval capabilities. These systems should be enhanced to
improve access but should incroporate adequate security to pro-
tect sensitive information,
Improved data quality will be essential. Financial trans-
actions, personnel actions and other transactions must be re-
corded accurately and processed in a timely fashion to support
management analysis and decisions. Corrections to erroneous
financial data, especially for payroll, must be made promptly
and the correction process will need to be less labor intensive.
Regions require integration of data now maintained in several
different administrative systems, and also integration with pro-
gram data. The most important linkages among administrative
data are finance/contracts, payroll/personnel, and personnel/
budget (to support planning for personnel operations). Linkages
with many program management systems (e.g., permits enforcement)
will be needed to compare state agency program commitments and
accomplishments with grants as part of EPA's oversight function
for delegated programs.
Virtually all regions will require an improved project account-
ing capability, especially for labor and contracts, to support
Superfund and other project work.
Virtually all regions will require additional computer support
for local applications such as work planning and project status
tracking. Many regional minicomputers are now operating at or
near capacity.
As OA enhances existing administrative systems, regions should
have an opportunity to participate in system designs to ensure
that potential impacts on regional program and administrative
operations are fully considered.
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VI-10
t To enhance EPA's oversight function, Regions require information
about the expenditure of state funds on environmental programs
in addition to EPA program grants.
t Regions will need the capability to track EPA property (e.g.,
ADP and laboratory equipment) made available to states as part
of delegation.
t Regional administrative organizations require an index of per-
tinent reference materials, such as OMB circulars, and access to
consolidated contracts information generated throughout EPA
(e.g., suspended and disbarred contractors).
Regional libraries will require the capability to link data for
local collections with reference information for other EPA
libraries and with other bibliographic systems (e.g., health
effects data bases for chemicals and pesticides).
0. ADP Tools
Improved tools are needed for end-user retrieval and manipula-
tion of financial, personnel and other administrative data to
support analyses of financial status, staff requirements, cur-
rent skills mix, and potential staffing problems.
An automated graphics capability would be very useful to head-
quarters and regional users to support analyses of grants and
other administrative data.
Electronic mail would be extremely useful to grants administra-
tion if state agencies were added to the network and EPA no
longer needed to r?type grant applications submitted by states.
Electronic mail capabilities linking regional program managers
and administrative organizations will be extremely useful.
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VI-11
The Financial Management Division will be exploring the
capability to transmit data directly, to the Treasury Dept. for
electronic transfer of funds (EFT) to recipients' commercial
bank accounts. Cryptographic codes will be developed by the FMD
to authorize the release of payments by Treasury.
Grants administration may utilize optical charcter recognition
(OCR) technology to facilitate progress reporting and data entry
for program and construction grants. The application of OCR
Agency-wide to timecard processing may also be cost effective.
Professional staff in several administrative offices and regions
will make considerable use of word processing and reduce the
typing workload for support staff.
Existing word processing equipment needs to be improved to
better support filling out pre-printed forms and the production
of long documents.
K. Other Remarks
Several regional administrative staff require additional infor-
mation on the operations and internal procedures for OA systems
and more information about ADP technology and capabilities in
general,
EPA should establish a group responsible for monitoring tech-
nology trends and their application to the Agency. Topics
should include ADP equipment, software and networks; telephone
industry; and document reproduction.
The existing PDP-11 minicomputers are fairly expensive to op-
erate (e.g., air conditioning, electric power) and should be
replaced with more efficient equipment.
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VI-12
Employees working at home is a new trend in the private sector
and may be addressed by the Office of Personnel Management with-
in the next five years. If at-home work is officially recog-
nized, EPA will need to modify its time reporting process and
payroll system.
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VII-1
VII. ASSISTANT ADMINISTRATOR FOR WATER
A. Program Trends - Office of Drinking Water
The Office of Drinking Water administers two major programs, drinking
water quality and underground injection control. The drinking water quality
program is mature and virtually totally delegated to state agencies. Individ-
ual utilities largely self-monitor water quality, with state agencies identi-
fying persistent non-compliance and initiating appropriate actions to encour-
age compliance. Regional offices will continue to have lead responsibility
for oversight of state agencies. Headquarters will continue to perform over-
all program management, establish and update water standards, monitor national
trends and the effectiveness of regional oversight efforts, and assist in
resolving major problems. No major changes are anticipated for this program.
The underground injection control (DIG) program is relatively new. Regu-
lations are currently being developed, and the program will ultimately be del-
egated to state agencies. Several types of wells will require permits, in-
cluding 40,000 salt water disposal wells in oil and gas fields. Deep wells
for hazardous waste disposal may also require permits in the future. Other
types of injection wells, such as solution mining, may be regulated in the fu-
ture.
B. Program Trends - Office of Water Program Operations
The major program within this office, construction grants, is largely del-
egated to state agencies, with 39 states having received partial or complete
delegation. The headquarters role is shifting from operations to management
overview, and EPA regional offices are becoming the focal point for data col-
lection. The current $2.4 billion annual funding level in construction grants
is not likely to change significantly within the next few years.
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VII-2
Performing scientific and economic analysis to support the rational expen-
diture of grants funds is becoming a major program priority. Key elements of
this strategy will include:
Use of management information systems to monitor progress
against program objectives.
Use of existing systems to assess relationships between grant
expenditures, facility construction, and water quality improve-
ments at specific locations and nationwide.
Use of models to predict the cost, results in effluent output,
and impact on water quality of different treatment plant de-
signs.
Program integration to produce a municipal water strategy. This
could include involvement with RCRA and TSCA programs as well as
the other water programs (e.g., drinking water, NPOES permitsj
enforcement).
C. Program Trends - Office of Water Regulations and Standards
With the exception of ocean waste disposal, no significant shifts in pro-
gram direction are anticipated.
There will continue to be substantial activity in the development of ef-
fluent guidelines through FY85. However, the issuance of revised guidelines
for additional industrial categories or chemicals is uncertain. There will be
an increasing number of requests from states for technical information for use
in applying the guidelines to write site-specific NPDES permits.
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VII-3
As land-based disposal of hazardous waste becomes less politically accept-
able, disposal in the oceans may increase and will receive greater EPA atten-
tion. Currently there is little information gathering or regulatory effort
oriented to the ocean environment. It is likely that there will be signifi-
cant growth in:
Study of the biological, chemical, and physical aspects (e.g.,
ocean currents) of the ocean environment.
Regulation of commerce at sea, including oil and gas drilling
and sea bed mining.
Permitting of sites, compliance monitoring, and enforcement for
ocean dumping and incineration at sea.
D. Program Trends - Office of Water Enforcement and Permits
Delegation of permitting, compliance monitoring, and enforcement activites
has accompanied delegation of the water programs. The role of the Office of
Water r Enforcement is shifting from efforts on individual cases to management
oversight and control, with regional offices having lead responsibility for
performing oversight of state agencies. The office will be more active in
day-to-day enforcement of newer programs that are not yet delegated, such as
UIC and oceans. There also will be an increased emphasis on enforcement of
pretreatment standards.
E. Program Trends - Regional Water Divisions
Regional water program managers are in general agreement on the future
direction of water programs and concur overall with the forecast by managers
at headquarters. The more significant program trends for each program are
noted below.
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VII-4
1. Drinking Hater and Underground Injection Control
State and local agencies will continue to have primacy for
the drinking water program, with regions retaining lead
oversight responsibility within EPA.
New drinking water standards will likely be issued for or-
ganic compounds. These compounds will require more complex
treatment than that now performed by public supply systems,
and EPA will be called on to provide technical assistance
and help state and local agencies identify knowledgeable
consultants for designing treatment programs.
There will be increasing interaction between the drinking
water program and RCRA and CERCLA. Contamination of pri-
vate supply systems is a growing problem and although EPA
has authorities for only public supplies, the Agency will
need to help state agencies address private supply
problems.
Groundwater issues will become more visible, with many
problems related to landfills and Superfund sites. States
have initiated groundwater monitoring on a case by case
basis, and will likely take the lead on collecting ground-
water monitoring data. Some states will continue to avail
themselves of matching grants for monitoring provided by
the U.S. Geological Survey, and will work with USGS for ADP
support. EPA's future role is unclear, but the Agency
should consider having USGS enter groundwater monitoring
data directly into any future EPA data system.
State agencies will take the lead on the UIC program, with
some states completely prohibiting injection wells. Future
amendments to the Safe Drinking Water Act represent the
greatest potential change to the UIC program.
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VII-5
2. Construction Grants
The construction grants program is highly delegated now and
will be nearly completely delegated to states within the
next few years. Regional offices will retain overview
responsibilities.
Future EPA activities will focus on the operations and
maintenance of treatment plants. Specific issues will be
projected versus actual costs, and ensuring compliance with
treatment standards.
A gradual reduction in the overall program is anticipated.
3. Water Quality and Permits
0 The most significant trend will be greater delegation of
permitting to states in the next few years. A heavy empha-
sis on state reporting and ADP will be the primary mecha-
nism for' oversight and tracking. Accountability and ADP
training for states will be key issues.
For permits issued by EPA, the regions anticipate a greater
regional role in decision-making on individual permits.
Increasing attention will be focused on organic and highly
toxic pollutants, and on minor dischargers. Many Superfund
and hazardous waste sites will not be major dischargers.
NPOES permits for toxics may need to reflect the local
biology of the receiving body of water.
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VII-6
4. Enforcement
In concert with delegation, the enforcement role of state
agencies will increase substantially. The role of EPA
headquarters will probably diminish and regional offices
will assume lead oversight responsibility. Audits of state
programs may become a key oversight activity.
Regional offices and states will make greater use .of ADP to
track NPDES permittee compliance and screen significant vi-
olations.
F. Program Trends - State Agencies
State agencies generally concur with the forecasts of EPA, but noted an
alternative trend for the drinking water program. Specific trends identified
are discussed below.
Although the drinking water program is relatively mature and
highly delegated, the potential adoption of much tougher drink-
ing water standards and limited Federal funding may force some
states to return the program to EPA. States are currently exam-
ining fees and other funding alternatives.
States will increasingly focus on toxic pollutants. Monitoring
strategies are currently being developed (e.g. biomonitoring,
microcosm studies) and state agencies are establishing a tech-
nology exchange program. Assistance now being provided by the
EPA laboratory in Athens should be expanded to increase tech-
nology exchange between the states and EPA.
States will require EPA assistance in responding to spills and
emergencies at waste sites, and would like to see EPA establish
a central information center to provide information and analytic
support.
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VII-7
Groundwater contamination will be the hot issue of the late
1980's. States initially considered groundwater a state issue,
but are shifting to the view that groundwater problems cross
state lines.
Consolidation of state environmental agencies within a "state
EPA" will gradually increase. There will be an attendant slight
increase in multimedia coordination and integrated permitting
across programs.
G. Information Management Requirements and Related Applications - OW
t The states are legally obligated to report drinking water stan-
dards compliance and enforcement information to EPA. The Model
State Information System (MSIS) will continue to be used by a
number of states to support this activity. EPA will continue to
make a considerable effort to provide orientation and training
to state agencies for MSIS and make it a valuable tool for man-
agers at the state level. This is a high priority since the
quality of data in MSIS has been suspect. States are more like-
ly to exercise quality control over the data if they also use
the data within their program.
The Federal Reporting Data System (FRDS) will continue to obtain
information from the states for national level reporting. Some
states will report more frequently than the current annual re-
porting requirement.
An EPA information system will probably be developed to support
the UIC program. It would include:
A lite inventory
Permit tracking, including applications and dispositions
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VII-8
Compliance monitoring data, including groundwater monitor-
ing data and the results of mechanical integrity tests
Enforcement actions.
Some of the above functions may be monitored at the headquarters
(rather than regional) level by the water enforcement program.
The capacity to maintain historical water quality data is needed
to demonstrate improvements in water quality as a result of
treatment plants.
STORE! will continue to be used to monitor ambient water qua-
lity. With the exception of the potential addition of biota
data to the BIO-STORET component of STORET, no major enhance-
ments are anticipated. STORET will continue to maintain one of
EPA's largest data bases, with flexible state reporting
procedures.
COGENT will continue to be used by OWPO to perform modeling of
river reaches and the effects of point source effluent controls
on ambient water quality.
There is an increasing need to collect accurate and complete
data on state activities. OW's overall strategy will be to make
systems provided to states by OW easier to use and more respon-
sive to the needs of state program managers. Significant ele-
ments of this strategy include the following:
Potential enhancement to GICS to make it easier to use by
state agencies (and by EPA) include:
On-line data entry and validation, and
On-line retrival and ad-hoc inquire.
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VII-9
Enhancement of MSIS to improve edits on water quality data
and provide better data analysis capabilities for state
users.
Enhancement of PCS to collect additional data items to sup-
port regional and state use for tracking inspections, com-
pliance status against permitted effluent, and enforcement
actions. Technical enhancements include on-line screen
data entry and retrieval capabilities, and automated
graphics and mapping.
The capability to integrate data or perform crosswalks among wa-
ter data bases and with data bases for other media is needed to:
Link information about the same facility or municipality
held throughout the agency.
Verify that municipal facilities receiving grants meet
NPDES permit requirements.
Compare ambient conditions and trends with grants, permit-
ting, and enforcement activities in order to manage for en-
vironmental results by targeting resources to the areas
that produce results.
Analyze water program activities and activities of programs
for other media to identify locations with related problems
for designated chemicals/pollutants.
Program managers within OW (and throughout the Agency and in
states) require orientation and training in the capabilities and
use of existing ADP systems.
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VII-10
To improve access to effluent guidelines information, existing
manual research and technical data may be automated, or auto-
mated indexes to hardcopy files of research documents may be de-
veloped. A study currently is being conducted by OWPO.
All water program offices are currently conducting an analysis
of program activities, related decisions, and information needs
for the next several years. Regional water program staff and
state agencies are participating in this effort. Findings will
be available in early FY84.
H. Information Management Requirements and Related Applications - Regional
Water Divisions
Regional offices generally concur with the headquarters forecast of over-
all information needs within the regions. Effective collection of a wide
variety of data from states and improved ADP support will be essential to pro-
gram oversight. In the future, program offices at headquarters should stress
collection of only key items of data that will be used regularly, avoid col-
lecting excessively detailed information which imposes a significant reporting
burden, provide stronger incentives (positive and negative) to states to
report data, and strive to minimize software changes and consequent retraining
for systems used directly by states. Without improved data collection and ADP
support, regional offices will be unable to perform their oversight function.
Section K of this chapter presents several suggestions for improved data
collection from states.
Integration or crosswalks for different types of water program
data and integration of water data with data for other programs
will be a major need of water program managers. Specific cross-
walks needed include:
Permit and effluent data with grants data for treatment
plants
Permit and effluent data with water quality data
Data for injection wells, waste sites, and NPDES permittees
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VII-11
Enforcement actions and plant outfall identifiers
Grants information with changes in water quality.
t Regions and states will require improved access to profiles on
chemicals (e.g., history, sources, transport, distributors, ex-
posure levels) to assist in "significant no adverse response
level" (SNARL) determinations.
Regions and states require improved data entry (preferably in-
teractive) and more timely updating of data bases for central-
ized information systems such as PCS and STORET. Current pro-
cessing lags frustrate users and inhibit use of these and other
systems.
Regional and state permit writers will require much better ac-
cess to technical effluent guidelines information developed by
OWRS in order to apply the guidelines to specific facilities and
more effectively address water quality conditions at the plant
site. State requirements will increase significantly with con-
tinued delegation. An automated bibliography or index of perti--
nent documents, with reasonably prompt access to actual hard-
copy, would probably be adequate.
Much of the data that will be maintained by an UIC information
system currently being developed by EPA to support well inven-
tories, permit and compliance tracking, and enforcement will be
collected by states. This system should be compatible with
state agency systems, provide the flexibility to address
region-specific needs, and interface with systems for NPDES per-
mits and RCRA functions.
Regional staff will require more information about the health
and environmental effects of water toxics, especially heavy
metals and organic compounds. Regional staff also require that
analytic methods used to generate STORET data be included in
this system.
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VII-12
Use of EPA monitoring systems (e.g. STORE!) and management in-
formation systems (e.g. PCS, MSIS) by states will continue to
vary from state to state. State agencies with responsive in-
house ADP functions will tend to use state systems and provide
the minimum information requested by EPA. State agencies with
limited ADP resources will tend to use EPA systems or rely on
manual processing systems. Training of state agencies in the
use of EPA's water systems will be a continuing requirement to
respond to turnover of state staff and support modifications to
EPA's systems.
Many states will continue to use GIGS to provide grants infor-
mation to EPA.
I. Information Management Requirements and Related Applications - State
Agencies
State water agencies will differ markedly in the level of ADP support re-
quested from EPA. Many states will have little in-house ADP support and will
use EPA systems made available to them if adequate-training is provided and if
the systems do not require more staff than alternative manual procedures.
States with strong ADP support will tend to use their own systems to support
program operations and management. Most states have the following re-
quirements of EPA:
More consistent reporting requirements from year to year.
Elimination of simple "bean counting" to measure program activi-
ties, and collection of redundant, irrelevant or extraneous
information. States would be willing to assist in the
development of new reporting standards, but caution that the
standards should not limit regulatory flexibility.
More timely turnaround for updating data submitted by states and
providing feedback to state agencies.
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VII-13
Access for permit writers to "best available technology" infor-
mation and other information developed by EPA in formulating ef-
fluent guide!ines.
Also, the use of new procedures and technology to process construction
grant applications, review and reporting, should be reviewed carefully to
assure maximum effectiveness at all levels. Specific actions should be fully
discussed with the states to determine optimum operational efficiency.
J. ADP Tools
0 There is a major requirement for "user friendly" access to data,
especially for software tools to support user retrieval and ma-
nipulation of program and administrative data.
The Office of Water Program Operations has a specific need
to do large scale data analysis, such as in the development
of effluent guidelines, on a one-time basis. APL and SPSS
would be useful tools.
Several managers at headquarters and in the regions require
the capability to down-load data and perform analyses using
local computers in order to provide ready access to the
necessary processing capability and to control costs.
Several program offices anticipated increased usage of electron-
ic mail in headquarters as well as between regions and head-
quarters. One director specifically suggested that electronic
mail be limited to use between managers at the office director
level and above to control the volume of traffic through the
system and avoid an overload of mail messages sent to senior
managers. Others suggested that state agencies be added to the
network-.
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VII-14
There is a pressing need for simple automated graphics to sup-
port presentations and data analysis. A few regional program
users require color graphics. Some managers consider existing
graphics packages too complex and/or expensive to be beneficial.
Regions require an automated mapping capability. Site mapping
for bodies of water, treatment plants, NPDES permittees, waste
sites and injection wells is particularly important. Few reg-
ions seem to use the existing river reach models.
Automated scheduling and calendars with general access would be
useful to some regions.
K. Other Comments
Program managers at EPA headquarters and regions, and represent-
atives of state agencies, have numerous suggestions for improv-
ing the collection of data from states. Several suggestions are
not addressed directly at ADP, but emphasize a better definition
of information needs prior to system development and the use of
program audits as a surrogate for collecting voluminous program
management data from state agencies. Most suggestions, however,
relate to ADP, and should be considered by all programs with
state delegation.
States should have a significant role in system design to
ensure that a system is useful to the states as well as to
EPA. Systems that do not meet state needs seldom succeed.
Although no system can meet all state needs, participation
by several states will help choose the most needed capabil-
ities and gain the acceptance of other states.
Software designed by EPA should be flexible to meet unique
state and local needs. In addition to standard data items
and processing routines, a system should provide data
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VII-15
fields that can be defined by states. Flexible report
writers should also be available to facilitate unique state
retrieval s.
Since some state agencies, like many organizations,
experience high turnover and limited training support is
available from state ADP organizations, EPA systems should
be easy to use, especially for data entry processing. Data
entry and edit should be interactive and enable users to
quickly and easily correct errors. Retrievals should also
be interactive where possible.
State resources are extremely limited for many programs,
and ADP often is funded at a minimal level. State agenices
are frequently prohibited from purchasing ADP services that
could be provided in-house. EPA should consider providing
states free timesharing resources and should not charge
timesharing use against grant monies. Timesharing costs
for state users should be considered a necessary EPA
business expense.
Interactive processing using centralized data bases for
multi-user systems may be quite slow and very expensive.
EPA should consider developing applications for states on
minicomputers or microcomputers and giving or lending them
to states.
EPA should provide intensive training to state staff on the
use of systems developed by EPA, including ongoing training
for new state agency staff. Establishing user groups and
user support functions is also helpful. Failure to provide
adequate ongoing training and support will cause even the
best designed system to fail.
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VII-16
For systems maintained and operated on state computers, EPA
should provide program maintenance or support for the core
system, and encourage state ADP staffs to address the more
challenging and state-of-the-art issues -- use of data base
management systems, graphics, etc.
These recommendations are not mutually exclusive and should be
used in combination to address the particular needs for each
program application.
To avoid unreasonable expectations of new systems, managers need
to have a realistic perception of:
The elements of system development and associated duration
and costs. Testing and debugging costs are frequently un-
derestimated.
The total cost of operating a system, especially data col-
lection and input.
A common problem in system development has been "shooting at a
moving target". Requirements for future years must be better
defined prior to system development to avoid the need for fre-
quent system modification.
A number of systems were developed several years ago and may no
longer meet program needs. Systems should be audited more fre-
quently to identify needed improvements and assess the cost-
effectiveness of continued system operation.
Collection of data from states using external third parties is
unnecessary and wasteful in the opinion of state agencies. EPA
and states should work together to establish mutually acceptable
frameworks for information exchange.
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VII-17
There is a data quality problem throughout EPA. ADP staffs have
been pathological about not taking responsibility for data, and
to date program staff have not assumed responsibility for data
quality.
There is a need to demystify ADP through orientation and train-
ing of senior managers.
Additional resources will be needed by regions to maintain the
information in centralized water systems (e.g., PCS, STORET).
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VIII-1
VIII. ASSISTANT ADMINISTRATOR FOR SOLID
WASTE AND EMERGENCY RESPONSE
A. Program Trends - Office of Solid Waste
There has been a radical revision in the RCRA program direction in the
last several months. The hazardous waste program had been viewed as a matur-
ing program; state delegation was increasing, and the Federal EPA role was
concentrated on program oversight and monitoring, plus making policy decisions
for relatively few new regulatory issues. It now appears that EPA's role will
be much more significant, both in terms of formulating new regulations and
maintaining an active involvement in RCRA program operations.
Regulatory action will occur in two areas. EPA will regulate several pre-
viously unregulated activities, including burning waste in boilers, under-
ground storage tanks, and air emmissions from land disposal sites. In addi-
tion, EPA will identify additional substances as hazardous wastes.
An area of uncertainty is the regulation of land disposal of hazardous
waste. To date the emphasis has been on effective containment of land-based
disposal of hazardous waste. Due to the problems associated with Superfund
sites, as well as evidence of the failure of liners, land disposal of
hazardous waste may be prohibited or severely limited in the future.
Delegating RCRA permit issuance, inspection, compliance, and enforcement
to the states has been on a fast track; 36 states have at least partial
authorization. However, it appears that the two year deadline for complete
delegation will not be met, for various reasons:
There continue to be a wide variety of unresolved technical
and legal issues requiring EPA involvement.
Permit issuance has been moving slowly, and EPA attention is
needed for improving the permit review and approval process.
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VIII-2
There appears to be widespread non-compliance with existing
interim status standards. In addition, many states are not
doing an effective job of monitoring compliance.
In some states, enforcement action has been virtually non-
existent.
The net result is that substantial EPA headquarters and regional office in-
volvement in RCRA operations will continue for an extended period of time.
B. Program Trends - Office of Emergency and Remedial Response
Considering the progress of the Superfund program so far, and the size and
impact of the program, reauthorization of the CERCLA legislation is likely.
There are currently 419 Superfund sites with remedial action underway at ap-
proximately 170 sites. The major limitation to the program is funding and
staffing for site and program management. In the future it is likely that
OERR will handle at least an additional 150-200 sites;
Program activities are evolving from an emphasis on overall program plan-
ning to more operational functions, including:
Emergency removals
Remedial construction
Monitoring of contained sites.
There is a possibility that Congress will include victim compensation in a
reauthorization of CERCLA. The resulting actions required of EPA, and the re-
sources necessary to perform them are unknown at this time.
C. Program Trends - Office of Waste Programs Enforcement
Day to day enforcement for the RCRA program is performed either by the
delegated states or by the regional offices (for undelegated states). The
headquarters role is one of overall management and program direction. However,
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VIII-3
because the RCRA program was relatively new at the time of delegation, there
have been a number of problems;
Lack of resources in regions and contract support.
A large number of unresolved legal and technical issues that
must be assessed and coordinated to avoid possibly inconsis-
tent decisions on specific issues arising at different waste
sites.
No standard reports of measurable activities and no complete
data base addressing compliance monitoring and enforcement
activities nationwide.
Some state authorizations, inspections, and enforcement ac-
tions falling behind schedule.
Consequently, it is likely that EPA regional offices will perform more direct
enforcement and provide substantially more program aid and direction to states
than was anticipated. The RCRA program will revert back to EPA from at least
some of the states.
The CERCLA (Superfund) inventory currently contains 419 of the possible
15,000 sites, and the priority list will likely expand to 800-1200 sites.
There are currently at 50-60 active enforcement cases in the Superfund pro-
gram. These cases are very complex, with some cases involving upwards of 500
responsible parties. It is anticipated that the case load will double to 100
or more cases within the next 1-2 years.
D. Program Trends - Regional Organizations^
Regional offices anticipate several significant trends for the Superfund
and hazardous waste programs.
This section includes the RCRA and CERCLA programs within Regional Waste,
Air and Waste, and Environmental Services Divisions.
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VI11-4
1. Superfund Program Trends
t For many of the highest priority sites Superfund activities
will shift from site surveys to site cleanup, with signifi-
cant construction and removal efforts.
The number of enforcement actions taken by EPA and atten-
dant litigation will increase substantially. Cost recovery
will likely be a major issue. EPA may accept partial reim-
bursement by firms which cannot afford to pay the full cost
of site cleanup.
EPA will undertake more detailed tracking of costs for in-
dividual sites to support cost recovery. In addition to
direct cleanup costs, EPA will likely include an overhead
allocation as part of total reimburseable costs, and may
seek to include unrecovered costs at some sites as part of
the overhead to be allocated to other sites.
The present funding will not address all designated Super-
fund sites. Over the next ten years, less than half of the
expended funds will likely be recovered. The Congress will
likely enact new legislation providing substantial addi-
tional funding.
t EPA will probably designate additional sites for cleanup
under Superfund.
EPA will continue to rely heavily on contractors to perform
site surveys and cleanups.
States will receive limited delegations of authority but
will have an increasing role for some sites.
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VIII-5
2. Hazardous Waste Program Trends
t The hazardous waste program will be growing rapidly in most
regions, and will likely become the single largest program
in each region.
The hazardous waste program will continue to be delegated
to state agencies. Several regions now report complete
delegation. Most states will implement the RCRA program
successfully with EPA technical assistance and federal
funding. Congress will likely extend RCRA compliance
deadlines for states if necessary. EPA may need to pull
back the program in a few states, and some states will
return the program if funding is cut significantly.
Some states now have an active enforcement program. RCRA
enforcement and litigation will increase substantially over
the next few years. However, for sites likely to require
government funds for cleanup, states may be reluctant to
initiate action and subsequently seek reimbursement.
State agencies will look to EPA to establish a RCRA clear-
inghouse or information center to make available informa-
tion about cleanup/containment strategies and risks associ-
ated with specific substances.
The number of regulated waste sites will increase by a fac-
tor of 15 to 20 if the cutoff for regulated facilities is
lowered to 100kg.
Present as well as future goals are very unclear. Regions
expect OSW to articulate specific goals and objectives fcr
the Agency's RCRA program.
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VIII-6
E. Program Trends - State Agencies
State agencies forecast that the emphasis for both RCRA and CERCLA will
shift to construction, removal, and permitting. Additional resources will be
needed to support state workloads. In addition, groundwater contamination may
prove to be a major problem. Some states will integrate the DIG and RCRA
programs.
F. Information Management Requirements and Related Applications - QSWER
The Hazardous Waste Data Management System (HWDMS) serves the
basic RCRA program information needs, including inventory, per-
mits, .inspections, and compliance data. However, the complete-
ness and accuracy of HWDMS data is suspect.
t There is a pressing need to collect information regarding state
RCRA activities. The strategy taken by other EPA offices of de-
veloping standard software tools for the states will likely be
followed. There is a potential for a major software development
project to;
-- Support the state program management functions now ad-
dressed by HWDMS for EPA.
Collect monitoring and inspection data, including fa-
cility, hazardous waste type or group, discharge compo-
sition as compared to permit amounts, other pollution
source, waste manager, and geographical location.
-- Provide EPA headquarters the ability to summarize the
above information and perform analyses of:
The number and type of inspections performed,
The number and percentages of violations, and
some detail regarding each violation,
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VIII-7
The time between findings of non-compliance
and the return of facilities to compliance,
and
Enforcement actions taken in cases of non-
compliance.
t Several states have developed systems to track manifests of
hazardous waste and follow up on discrepancies in the manifests
to detect disposal violations. It would be very useful to be
able to provide such software to other states on request.
The Emergency and Remedial Response Information System (ERRIS)
maintains an inventory of Superfund sites. The enforcement pro-
gram has a need to track site specific technical information and
may want to link this information to ERRIS. In addition, use of
ERRIS may be extended to states, in order to improve and expand
the inventory with state data.
The Site Enforcement Status System (SESS) is now being imple-
mented. It will identify all Superfund sites for which enforce-
ment actions have been taken or are in progress, and will sum-
marize the actions for each site.
The Program Management System (PMS) is being developed to sup-
port CERCLA management needs. The system contains three com-
ponents:
-- A Project Tracking System, which contains the summary
status of all projects, has been implemented, but OERR
is concerned with its ability to provide up-to-date in-
formation.
-- A Site Coordination System, which will support on-site
management, is currently in the planning stage.
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VIII-8
-- An Enforcement System will be developed in the future.
There is a requirement for a system to store and classify Super-
fund technical information and support dissemination to regional
and state on-site coordinators and other personnel involved in
technical aspects of site management.
A need exists for systems to support budgeting/planning efforts
for both the overall CERCLA budget process and for project man-
agement .
0 An ADP training or orientation effort is needed to make managers
more aware of the ADP tools and applications currently available
throughout EPA.
G. Information Management Requirements and Related Applications -
Regional Organizations
Overall data management for Superfund and hazardous waste sites needs to
be improved substantially to support regional and state program operations.
Designation of a data administrator for RCRA at EPA headquarters will be
especially helpful. Specific requirements for regional organizations are
identified below:
EPA will need more reliable site-specific accounting information
for staff and contract resources to support enforcement actions
for cost recovery and enable site managers to more effectively
control costs. Existing accounting procedures and systems,
especially error correction processing, must be improved.
Regional offices and states require the capability to maintain
cost information for many types of on-site contractor activities
to support a more informed evaluation of proposed prices. Con-
tractor prices vary widely for materials, labor and transporta-
tion in different areas, and seem to also vary greatly within
designated areas. This requirement will become more important
as remedial actions increase at RCRA and Superfund sites.
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VIII-9
Regional offices will need automated capability to manage RCRA
enforcement information for an increasing number of actions.
Existing manual systems will not be adequate. Since most sites
have at least one potential violation it will be especially im-
portant to denote specific types of violations to ascertain the
magnitude of non-compliance of a site, and include information
for enforcement actions taken by states (and their equivalence
to EPA actions). Access to a central data base of administra-
tive orders and consent decrees will be very useful to regional
staff in preparing new orders and decrees and to EPA head-
quarters for technical review.
Regional and state RCRA site and program managers will need au-
tomated tickler files to manage site activities. This capa-
bility must be sufficiently flexible to support common and
unique tracking points. Some sites may have as many as 70+
tracking points. However, it may be difficult to replace
interim manual tracking systems used by many managers.
Regional offices need the capability to integrate air, water and
waste data for specific facilities now, and this requirement
will be imperative in the future.
EPA must initiate a major effort to manage groundwater data that
is now being collected by several programs, and an anticipated
major increase in monitoring data to be collected in the future.
Many states and EPA contractors collect some monitoring data,
but most of the data is stored in manual form. No standard
coding conventions exist for many common data items. Several
regions are currently trying to use STORE! to store some of the
available data, but STORET may not be able to fully accommodate
groundwater data requirements. Requirements for a groundwater
data base are critical.
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VIII-10
Many states have developed or will be developing RCRA site man-
agement systems. EPA should provide software capabilities which
will enable states to use these systems to automatically feed
data to EPA which meets RCRA reporting requirements. However,
some state systems will not maintain adequate data, and data
definitions across systems will vary. Regions will require im-
proved data support analyses of compliance rates and permit
processing turnaround.
Proposed regulations for manifest tracking will impose a sub-
stantial data collection and management burden on state agen-
cies. Several states have developed manifest systems which will
meet EPA's requirements and may prove useful to other states.
EPA may need to develop standard software for use by states.
Some states will maintain data in parallel EPA/State systems.
Regional (and state) RCRA and Superfund program and site
managers will require access to a clearinghouse that can provide
detailed information about physical and chemical properties of
wastes, cleanup and containment technology, and the health and
environmental effects of compounds discovered at waste sites.
Access to a data base containing both acute and chronic exposure
toxicity data for rapid response risk assessments is considered
a vital need. A clearinghouse will be vital to maintaining
national consistency for RCRA and CERCLA.
H. Information Management Requirements and Related Applications -
State Agencies
Many state agencies will resist providing detailed RCRA site in-
formation to EPA. EPA reporting requirements are becoming in-
creasingly detailed, change frequently, represent a significant
drain on program resources. State agencies are more willing to
submit summary information quarterly to EPA.
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VIII-11
Many states will use an automated site tracking capability, in-
cluding state systems. However some states, such as Nebraska
will have relatively few hazardous waste sites and will be able
to support site tracking needs with manual systems.
State agencies require the technical support of a RCRA clearing-
house. Associations of state waste program administrators
(i.e., ASTSWMO) are now beginning to establish a clearinghouse
function and encourage a cooperative effort with EPA.
I. ADP Tools
Regional offices require more user friendly software to access
and retrieve information from centralized data bases and sys-
tems.
Electronic mail has been very useful. It will have increasing
utility for communications with regions.
0 There is a need for statistical packages to perform analysis and
"what if" manipulations on existing data. However, some doubt
exists as to how useful these tools will be if there is not a
significant effort to clean up existing and new data.
A flexible graphics package and site mapping capabilities would
be very useful to EPA regional and headquarters staff (and state
agencies) for data summary and analysis, and for management
briefings.
t
A PERT-type site planning and management capability would be
especially useful to site managers in managing large sites which
will probably involve EPA, state, and contractor parallel
ac t i v i t i e s.
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VIII-12
Voice mail and teleconferencing are potential tools to expedite
enforcement actions which require a high degree of coordination
among different organizations. A great deal of time is lost
playing "telephone tag".
J. Other Remarks
Audits should be conducted of major Superfund and RCRA informa-
tion systems to ensure that they meet the needs of their
intended users.
OSWER will need to make a substantial commitment to training re-
gional and state users of Superfund and hazardous waste systems
developed centrally to ensure that the data bases are kept cur-
rent and used effectively.
t The collection of detailed site tracking and technical informa-
tion by EPA has become a major burden for regional and state
site managers. In view of limited resources and the other
responsibilities of site managers, EPA should carefully consider
its reporting requirements to balance information needs with
available resources for data collection and maintenance.
The collection of information from states about state activities
at Superfund sites will not take place until Superfund monies
are authorized for this purpose. Reporting of state activity at
Superfund sites is not covered by RCRA reporting requirements.
The NEIC Financial Assessment System will be a potentially use-
ful tool in assessing a firm's "ability to pay" when selecting
enforcement actions. Regional RCRA and CERCLA program staff
will need to learn more about this and other NEIC capabilities.
The NEIC literature search and research capabilities should be
used more effectively by headquarters and regional staff in pre-
paring litigation.
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IX-1
IX. ASSISTANT ADMINISTRATOR FOR AIR, NOISE, RADIATION
A. Program Trends - Office of Air Quality and Planning Standards
The air program is relatively mature with most day-to-day activities con-
ducted by state and local agencies. Regions perform program oversight func-
tions as well as handle program operations where required for states with in-
complete state implementation plans (SIPs). Headquarters operations include
development of standards; establishing policy and procedures; evaluating
program effectiveness; assessing air quality, emissions, and compliance status
and trends, and program representation in the public forum. No major changes
in program operations are anticipated unless there are major changes in the
reauthorization of the Clean Air Act. These changes may include expanded
programs to address acid rain and air toxics.
National ambient air quality standards (NAAQS) have been established for
the criteria pollutants and will be reviewed on staggered five year cycles.
New source performance standards were to be completed for 68 source categories
by 1982, with reviews on a staggered four year cycle. It now appears that one
round of the NSPS effort will be completed between 1985 and 1988.
National emissions standards for hazardous pollutants (NESHAPS) are being
developed for particularly hazardous pollutants. Seven pollutants have been
examined to date, with NESHAPS established for four pollutants. Thirty-seven
additional pollutants are currently under study, and there is potential for
substantial growth in this program area.
The prevention of significant deterioration (PSD) program is designed to
control the degradation of air quality in areas that currently meet NAAQS.
This program has been delegated to most states, and many of the states have
delegated the PSD program to local regulatory authorities.
Compliance monitoring and enforcement activities have largely been dele-
gated to state agencies (and, in turn, to local agencies) with EPA's role fo-
cused largely on program oversight and ensuring that state actions comply with
state implementation plans (SIPS). Regional offices currently administer
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IX-2
these activities in states that have not implemented a compliance monitoring
and enforcement program, and conduct inspections to assist states in devel-
oping enforcement actions. EPA will be completing delegation wherever possi-
ble and carry out oversight to ensure that state programs are working proper-
ly. Audits of state programs have been initiated recently, and will increase
in number over the next few years to include annual audits of most states.
There will be a push for more frequent monitoring and/or reporting of
compliance status. There are approximately 28,000 sources subject to inspec-
tion. The 17,000 NSPS, NESHAPs, and Class Al SIP sources are subject to annu-
al inspection, while the 11,000 Class A2 SIP sources are inspected biennially.
Currently, EPA collects from states and regional offices quarterly data pro-
viding a snapshot of facility compliance, but few states provide details re-
garding the number of days a facility is out of compliance. The technology
now exists to support continuous emissions monitoring (CEM). EPA will require
continuous emissions monitoring where it is cost effective and presently re-
quires CEM for certain classes of sources. However, EPA is unlikely to re-
quire CEM for the large majority of sources.1
B. Program Trends - Office of Mobile Sources
Mobile sources is a fairly mature and stable program. Research and regu-
lations development are performed at the national level, while the inspection
and maintenance program is administered by state and local agencies. There is
only a minor regional office role. Although program emphasis may shift from
year to year, no major shifts in program direction are anticipated.
The national program to test cars for emissions violations has recently
placed greater emphasis on testing in-use vehicles (but will also continue to
test new vehicles). This trend may accelerate if programs that place greater
emphasis on determining compliance on the basis of in-use emissions are
adopted in the future.
NOTE: Environmental Sciences Research Laboratory in ORD believes that CEM is
especially important to provide an accurate emissions inventory and
eliminate a major source of error in air models.
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IX-3
EPA collects summary data from state inspection programs but does not
request detailed records from states. Data for tampering and fuel switching
programs, aw well as for emissions violations, are obtained by other QMS
activities and are not obtained by the state inspection and maintenance
programs.
There are several regulatory efforts currently underway regarding;
t Heavy duty vehicles (trucks, heavy equipment, etc.)
Diesel powered vehicles
0 Fuels - especially for additives other than lead, blended fuels,
and liquid fuels other than gasoline, notably methanol and
ethanol.
No major additional regulations are expected to be promulgated.
C. Program Trends - Office of Radiation Programs
The Office of Radiation Programs is relatively small and differs substan-
tially from most EPA programs. It specializes in one hazard, addressing radi-
ation across media and across legislation. Legislative authority is contained
in virtually all major authorizing legislation for EPA programs including
RCRA, CERCLA, CWA, CAA, and TSCA. Coverage includes discharges into air and
water, waste disposal of radioactive effluents, and naturally occuring radio-
active materials. ORP also derives authority from other laws including the
Atomic Energy Act and Uranium Mill Tailings Act.
Current regulatory activities of the radiation program are aimed largely
at completing regulations started in previous years. Virtually no new regula-
tory actions have been started during the past two years.
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IX-4
The non-regulatory functions include:
Identifying, locating, and measuring radiation sources and re-
sultant exposures.
t Technical assistance to other agencies, state government and
other groups to facilitate protection and determine appropriate
remedial actions.
Emergency preparedness - including response to radiation acci-
dents by measuring releases into the environment and suggesting
solutions. This activity includes a continuing presence at
Three Mile Island.
Research - including keeping up with existing scientific infor-
mation and in rare cases conducting or sponsoring validation
studies.
The office conducts no enforcement program. Enforcement activities will
continue to be conducted by other offices in EPA and offices in other federal
agencies (e.g., NRC). There is a small regional role in the radiation
program.
The future directions of the radiation program are uncertain. There are
few new regulatory activities in progress. On the other hand, the need for
the four non-regulatory functions listed above has not changed significantly.
Further, several Superfund sites have been identified as having hazardous ra-
dioactive material. While the Office of Radiation Programs has not yet been
involved in Superfund activities, the office may have a future role in the
cleanup of radioactive hazardous materials.
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IX-5
D. Programs Trends - Regional Organizations2
Regional air program staff concur with the headquarters forecast of
continued state delegation, but believe that many elements of the air program
will continue to evolve over the next several years. The following trends are
anticipated:
Air pollution control strategies for criteria pollutants may
shift from an emphasis on ambient concentrations to performance
based standards.
Control of air toxics will likewise reflect a performance based
strategy, as evidenced by NESHAPS.
Continuous emissions monitoring may be adopted for certain types
of facilities. EPA would not collect CEM data from firms, but
would likely require reports of non-compliance events and/or
period reports of compliance rates.
Emissions trading activity may increase in some parts of the
country. The reopening of plants that are now shut down as the
economy gears up and new VOC regulations may encourage increas-
ing bubble activity. However, several regions anticipate no
significant emissions trading activity.
Modeling for criteria pollutants may increase in some regions
and decrease in others. Dispersion and diffusion modeling may
increase to check on industry modeling for proposed emission
trades, and to predict the impact on air quality of Superfund
site cleanup efforts. More complex models will be developed for
long range acid deposition and ozone.
State agencies will continue to need technical assistnce and
training on the use of air quality models.
p
This section include the air and radiation programs within Air, Air and
Waste, and Environmental Services Divisions.
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IX-6
Regional offices will have continuing role in the mobile source programs.
Regional activities will address fuel switching, tampering, state inspection
and maintenance, and local transportation control management plans. TCM plans
will be needed in more localities if the current CO standard is not relaxed.
Complex models for CO diffusion will be needed to support TCM planning.
Regional offices also will have a continuing role in supporting the radia-
tion program. Radiation issues will arise for a number of Superfund sites,
and regions will also assist states in preparing and reviewing radiological
emergency response plans developed to address potential accidents.
E. Programs Trends - State Agencies
EPA has addressed many tough problems for controlling air pollution for
criteria pollutants, and will in the future address more difficult problems
for controlling air toxics. In the short term, state and local agencies seem
to be more aggressive than EPA in controlling toxic emissions. EPA is ex-
pected to speed up the NESHAPS program to quickly develop an effective federal
program and obtain more national consistency.
State agencies would like to see more continuous emissions moni-
toring. CEM will make enforcement easier and will be essential
to effectively enforce bubbles. Several EPA new source perfor-
mance standards will require CEM.
States anticipate limited growth in emissions trading. Shifting
EPA policies and limited state funds will inhibit growth.
Delegation of air programs to states will continue and will be
successful if EPA provides technical assistance, and if suffi-
cient federal state and local resources are available for pro-
gram operations. If funds are cut significantly, delegation of
some programs will not be completed and several states may re-
turn the air program to EPA.
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IX-7
EPA audits of state air programs will commence in FY84, and may
become more detailed and address a larger number of program
areas in future years. Many state agencies support audits as a
means to ensure national consistency and a strengthening of pro-
grams in some states. Audits will probably be conducted annual-
ly in each state.
Mobile source programs will not change significantly at the
state level, although some states or localities may implement
tampering and fuel switching programs as an alternative to in-
spections and maintenance programs now required by EPA.
Congress may authorize a major new acid rain control program
within the next five years.
F. Information Management Requirements and Related Applications - QANR
There will be a continued effort to collect and maintain a large
volume of air quality, emissions and compliance data. Much of
the data required is currently collected by state or local agen-
cies. Both the Congress and EPA staff will be raising questions
that require access to large volumes of raw data, such as:
Time series of emissions data for NSPS and best avail-
able control technology (BACT) development and review.
Compliance status of a facility or industrial classi-
fication, including identification of specific pollu-
tants and quantitative measures of non-compliance.
The potential exists for a significant increase in the amount of
data maintained by EPA information systems and data bases:
The number of monitoring stations is increasing.
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IX-8
The number of pollutants, especially toxics, that will
be monitored and regulated is expected to increase,
and in turn will require more monitoring.
PSD provides for continuous monitoring in many cases
(although EPA will probably not collect continuous
monitoring data for all sources).
While EPA might like to have the states maintain the
data, and provide EPA access to the data, many states
do not have automated systems to maintain the data,
and access to data maintained in some state level sys-
tems would be extremely difficult.
EPA wants improved access and more efficient maintenance of air
quality data for criteria pollutants. The AIRS system is ex-
pected to be operational for air quality data by 1985, and for
emissions and compliance data in 1986. AIRS will provide direct
access to states and regions. Approximately 2/3 of the states
will eventually use the AIRS system exclusively for maintaining
ambient data, while the remaining states are expected to main-
tain their existing systems and submit monitoring data to AIRS
in automated form. Functions now performed by CDS will
ultimately be incorporated in AIRS, but not in the initial AIRS
implementation.
EPA needs organized access to state and local air program regu-
lations through a "clearinghouse". Obtaining specific regula-
tions can be difficult, time consuming and costly. However, no
specific initiatives to address this problem are contemplated at
this time.
There will be a moderate increase in air quality modeling activ-
ities, and more accurate models will be required. Computer
based models will process larger volumes of data and increase
significantly in computational complexity to improve on the im-
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IX-9
precision of existing models. Some new models will encompass
large regions, such as models for ozone and for acid deposition.
In general, models will require increasing computing power.
A shift away from an air quality based regulatory
strategy would result in a reduction in modeling.
This shift is considered unlikely within the next
three to five years.
The amount of paper shuffling of SIP revisions between state
agencies, regions, and several headquarters offices should de-
cline as EPA makes greater use of word processing and electronic
mail. However, no decline in the number of SIP revisions is
anticipated.
Overall state use of the Compliance Data System (CDS) will in-
crease. More states will begin using CDS, and state input of
compliance data will expand.
An enhancement to provide on-line input and retrieval
may entice increased state use of the system. In ad-
dition, states will require in an improved management
reporting capability.
EPA will continue an effort to standardize definitions
of compliance monitoring and enforcement activities.
Until data definitions are standardized, summary in-
formation can be meaningless and even misleading.
0 The Office of Radiation Programs previously initiated a compre-
hensive Population Dose Assessment Program, utilizing an auto-
mated system to track total exposures to radiation throughout
the entire country. The system was never completed, but may be
revived.
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t There has been a substantial amount of dumping of radioactive
materials into the ocean. Little knowledge exists of how dumped
materials are transported by ocean currents, and there may be
significant benefit in developing a model of radiation transport
in ocean environments.
Existing administrative systems (e.g., finance, personnel) fail
to meet program office requirements. An off the shelf automated
document control register would be useful to program offices
that do not have the resources to develop a custom ADCR system.
G. Information Management Requirements and Related Applications - Regional
Organizations
Regional offices share many of the information management needs of OANR
and have several unique requirements.
Regions and state will require more sophisticated information to
support compliance monitoring and enforcement of increasingly
complex stationery source programs. Examples include emissions
trading, and potential seasonal variation of VOC emission stand-
ards.
Regional offices and many states will use the new AIRS system to
maintain and retrieve air quality and emissions data. However,
some states are skeptical about the actual capabilities of AIRS
and its ease of use. AIRS will need to improve on existing in-
terfaces to state systems that feed data to EPA. In addition,
the integration of compliance and enforcement data with emis-
sions data within AIRS should be given a higher priority and im-
plemented soon.
Regional offices require the capability to examine air quality
data over specified time periods and perform trend analyses.
Access to only current data is inadequate.
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A major acid rain program would likely require the integration
or linkage of large data bases for least four types of data:
emissions, precipitation, ecological effects, and air quality.
Adoption of CEM will generate a requirement for systems to main-
tain compliance information submitted by firms and help EPA
staff identify facilities with major recurring incidents of non-
compliance.
Greater emphasis on toxics will be accompanied in the regions by
a more multi-media perspective. Regional staff will require the
linkage of compliance data across media. Regional staff also
will focus more on the health risks of toxics across media.
Direct access to CSIN may be useful.
t Emissions and enforcement data related toxics will be claimed
confidential by some firms and will require that appropriate
safeguards be built into ADP systems.
Radiological emergency response plans will be developed for many
facilities and may be required of several counties for a single
nuclear facility. Regional radiation staff will require ADP
support to monitor the status of RERPs.
Air quality models for criteria and other pollutants may change
significantly over the next 3-5 years. The next generation of
models will be more complex, utilize actual meterological data
to reflect local conditions, and generally process larger vol-
umes of data than present models. Models for CO will be espe-
cially complex. States with limited ADP support will seek to
use EPA computers for modeling capabilities.
t A new ADP system may be needed to support the evolving air pro-
gram audit function.
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IX-12
t There should be a stronger link between automated emissions, air
monitoring, and compliance data and the Administrator's account-
ability system. Improved collection of data from states will be
essential to making this link useful.
H. Information Management Requirements and Related Applications - State
Agencies
Many state agencies will continue to use EPA data systems to
maintain large volumes of monitoring data, including data for
monitors not included in the national monitoring network. Agen-
cies with limited ADP capabilities will also maintain emissions
and compliance data on EPA systems. However, states require im-
proved access to EPA air data systems and will require continued
ADP training support.
State agencies would like EPA to establish a central clearing-
house for air toxics information related to control technolo-
gies, emission limitations, and health studies conducted by EPA
and other organizations. Information about the range of toxic
emissions for specific industries would also be useful.
Automation of the SIP revision process should help speed up pro-
cessing of these actions. Significant improvements have been
realized in the past two years as a result of parallel process-
ing by state agencies and EPA, and "direct to final" approval of
non-controversial actions.
I. ADP Tools
Graphics have appeared to be useful in the past, but the cost of
using existing graphics packages has proved to be too great.
Inexpensive graphics would be very useful for management presen-
tations and to help interpret the output of air quality models.
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Electronic mail has already proven useful to OAQPS and the re-
gions and could be used to speed up communications for SIP pro-
cessing and the review of proposed policy and standards. Elec-
tronic mail connections between the states and the regions would
also be valuable to improve SIP processing.
Regional offices and state agencies require an automated mapping
capability to help track the significant number of changes in
designations of attainment and non-attainment areas of specific
pollutants. An isopleth mapping capability is needed to help
interpret the output of air quality models.
0 Regional offices and state agencies need an improved capability
to access and retrieve data stored in national data bases.
There is an increasing awareness that effective communication of
large volumes of information to end users is frequently as much
or more of a problem than collecting data. OAQPS is currently
studying alternatives to the voluminous printouts of existing
systems for communicating information to program managers and
staff.
J. Other Remarks
OAQPS is currently unaware of specific directions in office au-
tomation, but would be interested in obtaining information on
current and planned capabilities to assess potential
applicat ions.
Senior managers should receive mandatory training on the capa-
bilities, uses, and limitations of EPA's information systems.
Some state agencies prefer to use EPA software but do not want
to store all air program data on EPA's computers. The Agency
should investigate providing minicomputers to state agencies.
Several states have already purchased minicomputers from a
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variety of manufacturers. If EPA finds it cost-effective to
provide minicomputers to state agencies, the funding of
computers by different programs within EPA should be coordinated
to ensure the acquisition of compatible hardware and software
across programs.
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X. ASSISTANT ADMINISTRATOR FOR PESTICIDES AND TOXIC SUBSTANCES
A. Program Trends - Office of Pesticides Programs
The pesticides program is relatively mature and stable, with few major
changes anticipated during the next several years. EPA will continue to de-
termine potential health and environmental effects of pesticides, focusing on
both new and existing formulations. Many studies will be performed by indus-
try and contract laboratories. These studies are expected to increase in com-
plexity (e.g., stochastic processes) to more accurately assess the potential
risks of exposure to pesticides, and reflect a variety of exposure path-
ways -- water, groundwater, food chain, etc. OPP will be working with ORD to
determine the feasibility of developing standard models to assess specific
risks (e.g., runoff in streams, leaching into, groundwater) and may make these
models available to industry to obtain more consistent and rigorous analyses
of these risks. OPP also will be placing particular emphasis on making the
results of studies reviewed by OPP available to state agencies and the public.
Two initiatives may result from a reauthorization of FIFRA. First, EPA
may be authorized to collect fees for registering pesticides, with fees fully
loaded to reflect direct costs and a proportionate share of overhead expenses.
Second, EPA may be directed to increase monitoring for pesticides in the envi-
ronment .
The overall responsibilities of state agencies and OPP are not expected to
change significantly. OPP will continue to provide technical assistance to
state agencies and review state agency registrations of pesticides and exemp-
tions.
OPP will also continue present efforts to monitor staffing requirements
for activities within each of its major functions and for different types of
studies to develop improved models for workload forecasting and management.
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X-2
B. Program Trends - Office of Toxic Substances
Overall, there will be no significant changes in the responsibilities of
OTS, regions and state agencies, with most program development and management
functions centralized within OTS. There will likely be substantial growth in
the volume of chemical information collected by OTS under Section 8 of TSCA
and other EPA program offices may use the TSCA authority to collect informa-
tion on toxic pollutants (e.g., OAQPS for toxic emissions). Other non-EPA
regulatory programs may also collect information under TSCA authority. Pro-
mulgation of a substantial number of new test rules is anticipated, which also
will result in the collection of large volumes of data. The number of test
rule studies conducted is expected to increase from 200 in 1983 to 600 in
1986.
Premanufacture notifications for new chemicals have not leveled off as an-
ticipated and are expected to grow over the next few years. OTS anticipates
collecting increasing volumes of data for each PMN, with a significant number
of PMN submissions containing confidential business information (CBI). OTS
may also initiate a major effort to update the information maintained in the
existing chemicals inventory (i.e., CICIS).
OTS anticipates that states will increasingly want access to much of the
information collected by OTS, especially exposure and monitoring data. How-
ever, access will of necessity be constrained by OTS' requirement to safeguard
confidential information. OTS is developing an information sharing plan with
EPA regions, state agencies, other Federal agencies, and international
organizations that will address this issue. OTS also has recently proposed a
regional and state support program.
C. Program Trends - Pesticides and Toxic Substances Enforcement Division
Compliance monitoring and enforcement trends for FIFRA and TSCA differ
significantly, with the most significant changes related to TSCA. Enforcement
authority for FIFRA has been delegated to 52 of the 57 jurisdictions. Most of
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X-3
the 59,000 annual inspections of pesticide producers, distributors and appli-
cators are now performed by state agencies. Certification of pesticide appli-
cators has been delegated to 51 of the 57 jurisdictions. Regional offices
provide oversight of state programs and conduct inspections and take enforce-
ment actions in non-delegated states. Headquarters functions include:
Providing policy and guidance to regional and state enforcement
programs, including guidance on neutral inspection strategies
and assistance to regions in setting targets for state enforce-
ment activities;
t Conducting laboratory audits;
Processing annual pesticide production reports;
Providing assistance to regions and coordination with the De-
partment of Justice on criminal enforcement actions; and
Serving as liaison with OPP for issuing "stop sale" and other
emergency orders.
The TSCA compliance monitoring and enforcement program is still in the
early stages of implementation. As more regulations and sections of the laws
become enforceable, the size of the program is anticipated to grow rapidly. A
TSCA enforcement program is currently in place for PMS', dioxin, CFCs and
PCBs. The compliance monitoring and enforcement programs for asbestos, sec-
tion 8, and sections 12 and 13 will begin this year. There is currently no
authority in TSCA to delegate enforcement to states, although EPA may issue
grants to states and contracts to private firms to conduct TSCA inspections.
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D. Program Trends - Regional Organizations^-
The regional FIFRA role will consist largely of program oversight, with
most emphasis on enforcement. For states that do not have a pesticides pro-
gram, regional environmental services divisions or contractors will conduct
inspections of facilities. Over the next few years, regional ESDs anticipate
an increasing emphasis on multimedia inspections.
Regional pesticides staff also forecast increasing analysis by OPP and ORD
of pesticide fate in soil and water. The Congress and state agencies have a
great interest in potential exposures to pesticide residues.
Regional offices feel that the future regional role with respect to TSCA
is less certain, and will be determined largely by the TSCA budget. Regions
will concentrate on inspection and enforcement, utilizing contractors for
field studies and ESDs for analysis of samples. Grants may be issued to some
states for inspection support, but TSCA is not a delegatable program and will
be managed by EPA.
E. Information Management Requirements and Related Applications - OPTS
OPP, OTS and PTSED share a number of requirements for improved information
management capabilities, and also have several unique needs. Common
requirements include the following:
Both OPP and OTS require improved access to large volumes of
technical information on chemicals and references to health and
environmental studies. Each office anticipates developing or
enhancing major systems which will automate large volumes of
bibliographic data.
A new Pesticides Document Management System will control
bibliographic data for the approximately 250,000 existing
studies regarding pesticides as well as the thousands of
This section includes the pesticides and toxic chemicals programs within
Air and Waste Management Divisions and Environmental Services Divisions.
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X-5
new studies conducted by EPA and other organizations each
year. Copies of these studies will be indexed and main-
tained on microfiche.
The OTS Global Index of documents will be enhanced to main-
tain additional reference information. Voluminous paper
copies of studies will be reduced to microfiche.
Joint efforts between OTS and ORD laboratories will con-
tinue to address the extraction of technical information
from published and unpublished sources.
Resource constraints will require increased sharing of technical
data between OPP and OTS, and with other EPA offices. Moreover,
OTS anticipates a significant increase in use by other Federal
agencies, EPA regional offices, and state agencies. OTS intends
to make the physical and chemical properties data, health and
environmental effects data, and environmental effects data main-
tained in SPHERE system widely accessible to other users.
Both OPP and OTS require the capability to identify chemicals
included in technical data bases that have similar chemical
structures. A related requirement is the capability to identify
apparently new chemicals as being the same or similar to known
chemicals, and to determine if the information regarding the
known chemical is applicable.
Additional OPP needs are as follows:
OPP may develop a very large system to maintain raw and
summarized technical data on chemicals and pesticides.
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X-6
Automated transmission of pesticide test results from regis-
trants or independent laboratories to EPA is a distinct possi-
bility. Several laboratories utilize automated data capture and
appear to be willing to work with EPA to develop the required
data conversion and communication software.
OPP currently tracks 20,000 to 30,000 registration actions an-
nually, and requires an improved capability to:
Track deadlines for firms to submit requested technical in-
formation and generate notifications
Use expected submissions to EPA to plan work loads and
schedules.
Within OTS there is a need to be able to provide the public, industry, and
Congress with access to the data that is used for decision making. This is
balanced by the requirement to protect confidential business information in
both hardcopy and in automated systems. There will be an increasing volume of
confidential business information collected, with stringent access restric-
tions effectively requiring dual systems.
To handle OTS' increasing workload and integrate roughly 25 existing
information that support the assessment of chemical risks under TSCA, OTS will
be converting its existing DEC 2020 applications to an IBM-compatible
processing environment. This effort will be dependent on the use of common
data elements.
The new FIFRA and TSCA and Enforcement System will be used to by PTSED
support both FIFRA and TSCA enforcement requirements. PTSED intends to
provide direct access to states for entry and retrieval of FIFRA data, and a
significant increase in data volume is anticipated. Another likely
enhancement will be the capability to automatically generate "custom" letters
based on specific criteria (e.g., key ingredients of pesticides).
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X-7
F. Information Management Requirements and Related Applications -
Regional Organizations
Much of the ADP support required for FIFRA oversight and re-
gional FIFRA and TSCA operations will be provided by the FIFRA
and TSCA Enforcement System. However, regions must obtain more
complete information from state agencies and ensure that states
use consistent data definitions in reporting to EPA.
t Regions will require improved access to current information
about pesticides health effects to respond to public information
requests. The existing microfiche-based retrieval system is not
sufficiently current.
A multimedia inspection initiative would require integration or
stronger linkages among permit, registration, and other facil-
ity-oriented systems. A data base of inspections conducted to
date and findings would be especially useful.
G. ADP Tools
Software development tools are needed which will enable OTS to
quickly develop data bases to support one-time data collection
efforts for new test rules, for Section 8 studies, and for other
information-gathering efforts.
OPP will increase its use of electronic mail to communicate with
regional offices, and requires the addition of state agencies to
the mail network to support:
EPA issuance of emergency exemptions to allow uses of pes-
ticides that are normally prohibited or restricted. Cur-
rent use of special mailings takes up to 15 days to get
through both the internal EPA mail system and postal ser-
vice, and is unacceptable.
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X-8
Prompt notice to OPP for proposed state pesticide registra-
tions. State registrations become de facto federal regis-
tration unless EPA disapproves them within 90 days. Prompt
notification would enable OPP to conduct a more in-depth
review within the allotted timeframe.
t A graphics capability is needed, especially by PTSED, to support
presentations and briefings for senior managers.
t An automated mapping capability is needed to target inspection
sites based on proximity to other inspection sites, and to sup-
port analyses of patterns for chemical spills or disposal in de-
veloping enforcement cases under TSCA.
Automated data capture in the form of light pens and bar codes
is needed to assist in managing documents containing TSCA CBI
and the TSCA 1ibrary.
OTS requires local processing capability (e.g., minicomputers or
microcomputers) to improve record-keeping and analysis by indi-
vidual staff, reduce the current overload of batch data entry
and processing, and will be examining the use of micropro-
cessors/microcomputers to support scientific applications. OTS
is now conducting a study on the integration of terminals, word
processors, and microcomputers, and on the feasibility of using
microcomputers both as data entry devices and as analytical
tools.
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XI-1
XI. ASSISTANT ADMINISTRATOR FOR RESEARCH AND DEVELOPMENT
A. Program Trends - Office of Research Program Management
ORPM anticipates that the principal mission and functions of ORD are not
expected to change significantly over the next three to five years. ORD will
continue to provide environmental research and development services to other
EPA programs, although priorities among different types of R&D (e.g., health
effects, environmental effects, control technologies) may change over time.
From a financial management perspective, ORD will continue to have a very
complex budget structure and to monitor funds at many levels of detail, in-
cluding crosswalks to many decision units and program elements.
B. Program Trends - Environmental Monitoring Systems Laboratories
EMSLs forecast many significant trends for environmental monitoring. The
following trends are anticipated:
Much more monitoring at landfills and Superfund and hazard-
ous waste sites, including both quick response and rela-
tively sophisticated monitoring for toxics.
0 Less emphasis on fixed station monitors and greater focus
on monitoring human exposure using portable monitors and
microcomputers to record data, and including monitoring of
indoor air.
Development of a monitoring network for organic toxic air
pollutants, expanding from a three station pilot to a fifty
station network in two years.
Increasing analysis of the interaction of multiple com-
pounds (i.e., multivariate analysis) in the air.
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XI-2
Growth in monitoring related to acid deposition, with rapid
growth if Congress authorizes a major new acid rain pro-
gram.
Increasing automation of monitoring equipment, with many
functions now performed by software or people handled by
computer chips.
Continuing strong emphasis on quality assurance/qua!ity
control for monitoring data, and utilization of sample file
control systems within EPA laboratories.
Continuing development of standard test procedures (i.e.,
methods research) for all media.
Close working relationship between EMSL and state water
programs to improve QA/QC for water monitoring data gen-
erated by states.
C. Program Trends - Industrial and Municipal Environmental Research
Laboratories
lERLs and MERL may be consolidated in a proposed reorganization of
ORD. However, consolidation will likely have a minimal impact on actual work
requirements of these laboratories. Specific program and research trends
anticipated by MERL include:
Greater emphasis on quality assurance/quality control over
laboratory data, with real-time QA/QC of data as it is gen-
erated for some studies.
Increasing modeling of the operations of waste water treat-
ment plants to'assess their ability to treat toxic wastes
and to project equipment maintenance needs.
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XI-3
Implementation of new approaches for operating small remote
treatment plants from a central location using micro-
computers and minicomputers.
Development of new modeling capabilities to assess the
impact of upstream discharges on downstream municipal
drinking water supplies, and continued assessments of
effluent on water quality even though water standards will
be oriented to control technologies.
0 Much greater MERL role in responding to spills and cleanup
of Superfund sites, and a potential increase in Superfund
research.
Increasing automation of laboratory activities to improve
overall productivity. (MERL is currently heavily auto-
mated .)
Establishment of an Innovative Technology Clearinghouse for
use by other EPA offices.
Specific trends anticipated by lERLs include:
Greater use of computers as feedback/control devices on
laboratory processes.
Continued strong emphasis on quality assurance/quality con-
trol for laboratory data.
t Development of new automated models for control technolo-
gies, such as incineration of hazardous waste.
Use by permit writers in regional offices and states of a
new effluent guidelines design and costing model.
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XI-4
Development of new data bases and growth of existing data
bases for organic chemicals production, hazardous waste
destruction, and other research data.
t Potential shift to more in-house work, less extramural
(i.e., contractors).
Development of internal inventories of chemicals and de-
tailed "cradle to grave" tracking systems for chemicals
handled by EPA laboratories to meet Agency-wide chemical
handling rules.
Delegation of programs to states will have no major impact on lERLs.
Little direct interaction with state agencies is anticipated.
D. Program Trends - Environmental Research Laboratories
ERLs anticipate many research trends with important implications for ADP
support. Specific trends include:
t Development of complex models to conduct analyses of
smaller particles and secondary materials found in the air
that are produced by conversion of gases to particles.
Continued shift from short distance to more complex long
range air transport and regional models from both a
standards setting and R&D perspective.
Potential adjustment of air quality standards to shorter
intervals (e.g., one hour standard).
Generation of large volumes of data by laboratory and field
experiments.
Development of multimedia models oriented to idividual
chemicals.
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XI-5
t Development of very complex estuarine models to assess the
resiliance of estuaries and biota to various pollutants.
t Increasing automated collection of salinity, dissolved
oxygen, and PH data, and automated tracking of water clean-
up acitvities within marine laboratories.
Overall much greater emphasis on real world ecosystems and
potential shift away from purely technology-based standards
for water effluent (e.g., "use potential" of streams con-
sidered in writing permits).
Increasing application of office automation within labora-
tories.
E. Program Trends - Environmental Criteria and Assessment
Environmental Criteria and Assessment Offices will continue to support
other program offices by furnishing the best possible scientific information
to those responsible for making regulatory decisions regarding pollution
control. This information, in the form of assessment documents, criteria
documents, and special reports, must be the most comprehensive and current
evaluation of relevant literature possible. The ECAOs will therefore continue
to seek improvements in timely research data acquisition, retrieval, and
presentation. Specific areas of information needs are identified in several
trends:
0 EPA will face increasing pressure from the Congress and
from within to establish standard protocols and guidelines
for conducting risk assessments and standardize analytic
methodologies where practical.
ECAO's will be investigating theories of toxicity to enable
EPA to more easily and reliably predict the toxicity of new
chemicals and substances.
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XI-6
ECAOs are unique within ORD in that they do not generate research data,
but collect and evaluate the scientific literature produced by national and
international researchers. Access to the most current and comprehensive
information on pollutants under study is crucial to document quality.
Integration of the reference data base resulting from literature search and
review with text and graphic components of the documents must occur
expeditiously, as successive drafts of the 300 to 1200 page documents are
typically produced against very stringent schedule requirements.
ECAOs also anticipate an increasing emphasis on air toxics beyond the
forty pollutants targeted to date. As many as 500 to 1,000 toxic pollutants
may need to be regulated. ECAOs also will participate in ongoing review of
existing pollution standards, and anticipate providing more support in the
future to OTS and OPP for chemical assessments, and to regional offices for
Superfund site assessments. ECAOs may also establish information exchange
programs with the Center for Disease Control and other Federal agencies who
require access to EPA health research information.
F. Programs Trends - Center for Enviromental Research Information
CERI will continue to perform three major functions - technology transfer
among EPA labortories, with state organizations, and to a lesser extent with
industry; production of research reports produced by all components of ORD;
and general office administration functions. CERI is uncertian of the future
mix of these functions. Report production activities could decrease signifi-
cantly if EPA's research role is diminished by state delegation (but
delegation of research is not anticipated). However, CERI would continue to
perform a clearinghouse function.
CERI intends to automated more of the document production process by
utilizing automated transmission capabilities between ORD laboratories, CERI
editors, and typeset operations to avoid rekeying of documents.
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XI-7
G. Program Trends - Health Effects Research Laboratories
HERL research related to water health effects will continue to include a
large proportion of toxicology studies. Epidemiology studies may also be
conducted for all media and would be performed largely by contractors. For
air and other media, HERL research will continue to emphasize human clinical
studies, animal studies, genetic toxicology, nonionizing radiation, and
neurotoxicology with increased emphasis on teratology (i.e., birth defects),
neuropathology, and neurochemistry.
There will also be a strong emphasis on determining the contribution of
air and water pollution to cancer using bioassays and potency analysis. For
animal studies the goal is to provide better models to quantitatively
extrapolate animal data to humans. Other emphasis will be to produce
dose-response data on the toxic effects of pollutants and develop models to
improve our ability to use toxicological data in risk assessments.
HERL anticipates no significant increase over the limited technical
support it now provides directly to states.
H. Information Management Requirements and Related Applications - Office
of Research Program Management
ORD's requirements for scientific information are specific to
individual studies and laboratories. It is ORPM's view that
there is a limited need to share data across studies; however,
some studies require scientific and technical data (e.g.,
monitoring) maintained in systems operated by other program
offices. This requirement will continue.
In ORPM's view, it is extremely difficult to predict overall ADP
support requirements for scientific work. However, current
trends indicate that laboratories will require the capability to
support the automated collection of greater volumes of data
being generated by laboratory experiments.
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XI-8
To support headquarters' requirements for management informa-
tion, ORPM will continue to develop and enhance the ORDIS
system, a comprehensive system encompassing many administrative
functions and implemented on a network of microcomputers.
Future enhancements of ORDIS include establishing an automated
interface with EPA's Financial Management System and Resources
Management Information System, and adding contract plans to the
ORDIS data base.
ORD will likely standardize the management systems used by the
laboratories and establish a communications link between these
laboratory systems and ORDIS.
t ORD budget staff require a more current (possibly real time)
obligations register within EPA's Financial Management System to
support control of spending, especially for monitoring end-of-
year obligations balances.
I. Information Management Requirements and Related Applications - Field
Organizations
The program and research trends projected by ORD laboratories and other
field organizations will have significant implications for information manage-
ment and ADP support.
There is a strong need to share research data and its
derivatives across project and program lines. The demands
for quality assurance, engineering design and economic
recommendations, exploration of program interfaces, and the
maintenance of organizational technical "memories" all
require broadly-based data management strategies. It will
be especially important to develop standards for common
data items to ensure compatability of data across projects.
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XI-9
ECAOs, EMSLs and other users require the addition of QA
indicators to air monitoring data bases and the submission
of QA data for other monitoring data bases that now have
indicators.
Most laboratories require improved access to the Agency's
major central data bases, including technical, biblio-
graphic and administrative data. ORD headquarters and
laboratories should have an opportunity to participate in
the redesign of Agency-wide administrative systems now
operated by the Office of Administration.
Many laboratories will need an automated capability to
track chemicals handled in the laboratory. A standard
application would be appropriate to conform to Agency-wide
guidelines.
t ECAO and other laboratories require access to additional
outside bibliographies and literature search capabilities.
ORD has a very complex budget structure due to the large
number of program areas served, and types of accounting
information required by AAORD. ORDIS will probably not
meet all information needs of laboratory managers. Supple-
mentary information management systems will remain neces-
sary to monitor lower levels of data for day-to-day opera-
tions.
0 Virtually all ORD field organizations require atuomated
support of local applications - project tracking, document
management, equipment and supplies monitoring, and others.
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XI-10
J. ADP Tools
ORD laboratory functions will require access to a number of ADP tools.
t Many laboratories (e.g., EMSLs, ERLs, HERLs, lERLs) will be
using minicomputers and microcomputers to collet data
directly from laboratory and field equipment. Examples
include:
strip chart recorders
brain stem analysis
salinity monitors for estuarine field studies
Automated sensors will also be used increasingly for
behavioral studies to reduce staffing needs for observation
and recording data.
Many laboratories, especially ERLs and HERLs, will be using
computers to operate laboratory equipment and provide data
in real time to staff scientists and technicians to monitor
and control experiments. Examples include:
control human exposure chambers
electroencephalograms
Most laboratories require the capability to access and
manipulate research and financial data. User-friendly
statistical software packages are a major requirement of
ECAOs and HERLs, and these organizations also require much
greater participation from applied statisticians in the
design and analysis of health research experiments.
Many scientists require a user-friendly capability to inte-
grate word processing, data processing, and model outputs
to more efficiently prepare research reports. This capa-
bility is especially important to ECAOs in reducing the
time needed to produce and review criteria and assessment
documents.
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XI-11
Most laboratories and headquarters staff require an easy-
to-use automated graphics capability. Graphics capabili-
ties are especially useful in displaying model results.
HERL has a high priority to produce high quality hardcopy
graphs and ECAO requires a three-dimensional graphics capa-
bility. Most laboratories require scientific and color
graphics. ORDIS now provides a graphics capability for
management and financial data.
Electronic mail capabilities are quite useful in communi-
cating between headquarters and laboratories. A small
increase in use is anticipated. Several laboratories do
not yet have access to the mail network.
CERI requires a capability to transmit large documents from
other laboratories to CERI for editing and production. The
ability to transmit engineering sketches and graphs in
addition to text is needed by lERLs and CERI.
K. Other Remarks
0 HERLs, EMSLs and other laboratories will continue to
require access to big computers to operate models, perform
complex analyses, and process the large volumes of data
associated with many experiments.
t HERLs requires improved local computer capabilities to sup-
port more rapid collection of data generated by some equip-
ment used in a single experiment.
Many laboratories anticipate significant use of word pro-
cessing by scientists. Several laboratories need to re-
place old equipment that is not reliable. CERI requires a
spelling checking capability that can support many tech-
nical terms and check spelling for documents quickly.
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XI-12
0 Several laboratories require improved ADP training for
technical and administrative staff.
EPA needs to improve its ADP procurement process to enable
ORD laboratories 'to acquire relatively inexpensive ADP
equipment (e.g., microcomputers) needed to support labora-
tory operations.
HERL Cincinnati identified a need to increase the number of
on-site scientific ADP support staff.
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A-l
APPENDIX A
Interview Guidelines
The purpose of the interviews is to identify how EPA's key program-
matic functions are likely to operate in the long-term (e.g., five years
fron now) and what this implies for ADP support.
1. Whaf trends do you foresee for your program's goals and operations and
related ADP support needs over the next five years?
2. What are the main forces within and external to EPA which will affect
your program over the next five years?
3. In response to these trends, how do you-expect"the functions of EPA
headquarters and regional offices, and of state and local agencies,
. to evolve? What are the implications for related ADP support?
4. What new information needs do you expect to have? Are you aware of
any existing sources for this information?
5. Which of your current functions require improved automated support?
What major changes or enhancements to current ADP systems would allow
you to do your job more efficiently or effectively?
6. What other needs or uses of ADP support can you envision?
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APPENDIX B - INTERVIEWEES
1. Staff Offices to the Administrator
Joseph Foran
Clayton Jones
Grace Moe
2. Associate Administrator for Legal and Enforcement Counsel
Office of Enforcement Counsel
Michael A. Brown
Richard H. Mays
National Enforcement Investigation Center
Thomas Gallagher
3. Associate Administrator for Policy and Resource Management
Ronald Brand
Office of Policy Analysis
Richard D. Morgenstern
Fredrick W. Allen
Michael Alford
0 Office of Standards and Regulations
C. Ronald Smith
N. Philip Ross
t Office of the Controller
John C. Chamber!in
Edward Callahan
Judy Lum
Office of Management Systems and Evaluation
Lewis Crampton
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B-2
4. Office of Water
t Office of Water Enforcement
Bruce R. Barrett
James Elder
Office of Water Regulations and Standards
Steven Schatzow
Edmund M. Notzen
Office of Water Program Operations
Henry I. Longest, II
Office of Drinking Water
Victor Kimm
Avrum Marks
5. Office of Solid Waste and Emergency Response
Office of Waste Programs Enforcement
Gene A. Lucero
Office of Sol id Waste
Michael B. Cook
Office of Emergency and Remedial Response
James Lounsbury
Elaine Stanley
6. Office of Air, Noise, and Radiation
0 Office of Mobile Sources
Richard Wilson
Laszlo Bockh
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B-3
Office of Air Quality, Planning, and Standards
Sheldon Meyers
Richard Rhoads
Bernard J. Steigerwald
George Bonina
Edward E. Reich
Office of Radiation Programs
Raymond Brandwe in
7. Office of Research and Development
t Office of Research Program Management
Samuel Rondberg
Thomas DeMoss
Environmental Monitoring Systems Laboratory - RTF
Thomas Hauser
Gerald Akland
Jon Clark
Environmental Monitoring and Support Laboratory - Cincinnati
Robert Booth
Terri Firestone
Ann Alford
0 Industrial Environmental Research Laboratory - RTP
David Stephan
Clyde Dempsey
William Candy
Albert Klee
Thelma Johnson
Industrial Environmental Research Laboratory - Cincinnati
Jim Dorsey
Municipal Environmental Research Laboratory
Francis Mayo
Fred Bishop
Jon Herrman
Diana Bakhaus
Warren Schwartz
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B-4
Environmental Research Laboratory - Athens
David Cline
Environmental Research Laboratory - Gulf Breeze
Henry Enos
Environmental Research Laboratory - Corvallis
Thomas Murphy
Environmental Sciences Research Laboratory - RTP
Alfred Ellison
Robert Browning
Health Effects Research Laboratory - RTP
F. Gordon Hueter
Gerald Nehls
Health Effects Research Laboratory - Cincinnati
Richard Bull
Judy Stover
Environmental Criteria and Assessment Office - RTP
Michael Berry
Environmental Criteria and Assessment Office - Cincinnati
Steven Lutkenhoff
Richard Hertzberg
Center for Environmental Research Information
Robert Edgar
Office of Pesticides and Toxic Substances
Pesticides, and Toxic Substances Enforcement Division
A. E. Conroy, II
John S. Seitz
Ken Shiroishi
Office of Pesticide Programs
Edwin L. Johnson
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B-5
Office of Toxic Substances
Marcia Williams
Linda A. Travers
9. Office of Administration
Immediate Office of the Assistant Administrator
John P. Horton
Samuel A. Schulhof
Martha McDonald
Susan Gordon
Office of Administration - Cincinnati
William Benoit
Office of Administration - RTP
John DeFord
John Knight
Office of Personnel and Organization
Kenneth F. Dawsey
Clarence Hardy
Robert Magor
Victoria W. Pierce
Don Webb
Office of Fiscal and Contracts Management
Clarence E. Mahan
Harvey Pippin
Steve All bee
Paul A. Martin
Tom Me Intyre
Gordon R. Takeshita
John Sandy
Office of Management Information and Support Services
Edward Hanley
Carol Alexander
Stormy Friday
Jack Sweeney
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B-6
10. Region I
Office of Intergovernmental Liaison
Stephen Ells
t Office of Regional Counsel
Sam Silverman
Administrative Services Division
Louis Gitto
Robert Goetzl
Wayne Wirtanen
Nancy Lewis
Daniel Regan
Phillip Cincotta
Michael MacDougall
Air Management Division
Harley Laing
Harold Kazmaier
Marvin Rosenstein
John Hanisch
Waste Management Division
Dennis Huebner
Mary Grealish
Robin Lind
Ruth Leabman
Dennis Gagne
Water Management Division
Jerome Healey
Charles Bishop
Clyde Shufelt
Al Ikalainen
Larry Brill
Carol Wood
Anthony DePalma
t Environmental Services Division
William Walsh
Donald Porteous
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B-7
11. Region II
Deputy Regional Administrator
Richard Dewling
Assistant Regional Administrator for Policy and Management
Herbert Barrack
Robert Messina
Air and Waste Management Division
Conrad Simon
0 Environmental Services Division
Barbara Metzger
12. Region III
0 Uater Program Division
Leonard Mangiaracina
0 Air and Waste Management Division
Stephen Wassersug
13. Region IV
0 Deputy Regional Administrator
John A. Little
0 Air and Waste Management Division
Thomas Devine
0 Environmental Services Division
James Finger
14. Region V
0 Air Management Division
Steve Rothblatt
0 Environmental Services Division
William Sanders
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B-8
15. Region VI
Deputy Regional Administrator
Frances Phillips
Assistant Regional Administrator for Management
John Fleeter
Water Management Division
Kenton Kirkpatrick
James Graham
Air and Water Management Division
Robert S. Jorgensen
Environmental Services Division
William Librizzi
16. Region VII
Assistant Regional Administrator for Planning and Management
John Arend ale
Water Management Division
Alan Abramson
17. Region IX
Administrative Services Division
James Thompson
Office of Regional Counsel
Robert Thompson
18. Region X
0 Deputy Regional Administrator
R. Edwin Coate
Environmental Services Division
Gary O'Neal
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B-9
19. State and Territorial Air Pollution Program Administrators and Asso-
ciation of Local Air Pollution Control Officials
S. William Becker
20. Association of State and Interstate Water Pollution Control
Administrators
Robbi Savage
21. Association of State and Territorial Solid Waste Management Officials
Sue Markland Morel and
22. State Agencies (through ASTSWMO)
Oklahoma State Department of Health, Waste Management Service
H.A. Caves
Nebraska Department of Environmental Control, Water and Waste
Management Division
Maurice W. Sheil
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