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TD811.5
.5686
1987
      Solid and Hazardous
        Waste Report for
         Fiscal Year 1987
    Office of Solid Waste and Emergency Response
       U.S. Environmental Protection Agency
              November 1987

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  Solid and Hazardous
    Waste Report for
     Fiscal Year 1987
Office of Solid Waste and Emergency Response
    U.S. Environmental Protection Agency
           November 1987
            U S Environmental Protection Agcr
            Tiegion 5', Library t5^'1^ ,&r,n
            230 S. Dearborn Street, Room 16,«
            Chicago, IL  60604

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        Solid and Hazardous
          Waste Report for
          Fiscal Year 1987
      Office of Solid Waste and Emergency Response
         U.S. Environmental Protection Agency
                November 1987

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                               FOREWORD
This report provides a summary of the accomplishments of the Office of Solid Waste and
Emergency Response (OSWER) of the  U.S. Environmental Protection  Agency for  fiscal
year 1987. During this  period,  substantial progress was made in the  implementation of
both the Resource Conservation and Recovery Act  (RCRA) and the Superfund programs.

The  many accomplishments  described in  this report are the result  of  a team  effort
involving Headquarters,  Regional, and State personnel.  I, therefore, want  to pay special
tribute to the hard-working and  dedicated employees who manage and implement these
complex programs.

I  hope that this  report will provide  a  better understanding of the  many  positive
achievements within the  national solid and hazardous waste management programs.  Any
comments on the information  presented  herein will be greatly appreciated.
                                                               J. Winston Porter
                                                          Assistant Administrator

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                      TABLE OF CONTENTS
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 •        SECTION 4  CHEMICAL EMERGENCY PREPAREDNESS
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                                                                   Page
EXECUTIVE SUMMARY	 ES-1
      Superfund 	 ES-1
      Resource Conservation and Recovery Act 	 ES-1
      Underground Storage Tanks 	 ES-2
      Chemical Emergency Preparedness and Prevention Program	 ES-2
      Special Initiatives 	 ES-2

SECTION 1  SUPERFUND 	 1-1
      Response Activities	 1-1
      Enforcement Program	 1-6
      Regulations, Guidances, and Other Activities 	 1-7

SECTION 2  RESOURCE CONSERVATION & RECOVERY ACT 	 2-1
      Regulatory Activities and Reports to Congress 	 2-1
      Permitting Program	 2-3
      Corrective Action 	 2-4
      Enforcement 	 2-5
      Guidances, Training, and Other Activities 	 2-6

SECTION 3  UNDERGROUND STORAGE TANKS	 3-1
      Technical Standards	 3-1
      Financial Responsibility Requirements	 3-1
      State  and Local  Programs	 3-1
      LUST Trust Fund Implementation 	 3-2
      Outreach Activities	 3-4
           AND PREVENTION PROGRAM 	 4-1
     Regulatory Activities	 4-1
     Regional and State Activities	 4-2
     Emergency Planning	 4-2
     Outreach Activities	 4-3
     International Assistance	 4-3

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                       EXECUTIVE SUMMARY
The Office  of  Solid  Waste  and Emergency Response  (OSWER)  is responsible for
implementing the national solid and hazardous waste management program under the
Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous and
Solid  Waste Amendments  of  1984  (HSWA);  the  national  program to  respond  to
environmental emergencies and clean up uncontrolled hazardous  waste sites under the
Comprehensive Environmental Response,  Compensation and Liability Act (CERCLA), as
amended by the Superfund  Amendments and Reauthorization  Act (SARA);  the national
program to  manage hazards from underground storage tanks, also under RCRA; and the
Chemical Emergency Preparedness and Prevention Program under CERCLA.
This report summarizes the progress  made in FY 1987 by the OSWER offices and EPA
Regions in  meeting their program goals  and  priorities, and  implementing  their statutory
mandates.


SUPERFUND
During the first year after passage of the Superfund Amendments and Reauthorization Act
(SARA), OSWER focused on two key aspects  of the program — continuing site cleanups
and enforcement activities, and putting in  place many of the procedural aspects of SARA,
including the initiation  of numerous project management improvements. These objectives
were  met  and in some cases exceeded.  The  level of field  activities in the removal,
remedial and enforcement  programs equalled or exceeded pre-SARA levels,  in  most
cases.  Project management improvements were initiated, and  new contracts  were
awarded, thus  ensuring that the  pace of the  program will continue to accelerate,  while
maintaining a high degree of quality control.


RCRA
A number  of priorities drove the development,  implementation and enforcement of the
national hazardous waste management program in FY 1987.  These included meeting
permitting  and closure  deadlines,  requiring  corrective action, conducting  compliance
monitoring  and  enforcement  activities,  developing and  implementing regulations, and
providing  policy and  technical  guidance to  the  Regions  and States.   Ground-water
protection,  expansion  of treatment capacity, and improving information management were
also key priorities during this past year.
                                     ES-1

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 UNDERGROUND STORAGE TANKS
 The Office of Underground Storage Tanks (OUST) is a new office established to respond
 to the requirements of Subtitle I of RCRA.  The purpose of the UST program is to halt the
 installation of tanks that are most likely to leak from corrosion, help States identify the
 universe of tanks to be regulated, establish standards for tank design and leak detection,
 and clean up damage where leaks have occurred.

 In FY 1987, the priorities of the UST program were  to develop regulations that protect
 human health and  the environment; provide support and assistance to States to enable
 them to train staff and develop effective methods to deal with the problems of underground
 storage tanks; and evaluate alternative funding mechanisms and  provide  incentives for
 States to apply  for program approval.

 CHEMICAL EMERGENCY PREPAREDNESS AND PREVENTION
 FY 1987 was the second year of the Chemical Emergency Preparedness and Prevention
 (CEPP)  program.   The overall program goals are to promote community  awareness of
 chemical hazards;  assist in the development  of State and local preparedness programs
 and response capabilities;  and develop a chemical accident prevention  program.  In FY
 1986 and FY 1987 the program objectives were to develop the list of extremely hazardous
 substances and accompanying guidance;  build  program infrastructure  at the  Federal,
 State, and local levels; begin program  implementation; and establish data bases to  better
 understand the  causes of chemical accidents.

 In FY 1987 CEPP implementation was enhanced by the new requirements of Title III of
 SARA (October  1986), including a State and local emergency  planning structure, industry
 reporting requirements (community right-to-know)  and broad participation in the  planning
 process.  Throughout  most of the  year, the Preparedness Staff focused successfully on
 meeting the many statutory deadlines  imposed by Title III.


 SPECIAL INITIATIVES
 In order to meet evolving commitments in problem  areas, a number of initiatives were
 developed in FY 1987.  Several of the more significant ones are outlined below.

 Federal Facilities Compliance Initiative

OSWER recognized the importance  of Federal  facility compliance, and  established  a
special task force  within the Office of Waste Programs Enforcement.  The Task  Force
serves as a focal point for both RCRA  and CERCLA compliance issues, and is developing
an integrated strategy to solve the complex RCRA/CERCLA interaction at Federal facilities.
Since the task  force  was  established in June 1987, it  has made substantial progress,
including;
                                      ES-2

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             • With Region IX, negotiating the first RCRA corrective action order at a
               Federal facility, the Department of Energy Idaho National Engineering
               Laboratory (INEL)  facility.

             • With Region V and the State of Minnesota, negotiating with the Army
               the first agreement under section 120 of the  new Superfund law for the
               Twin Cities Army Ammunition Plant (TCAAP). The INEL and TCAAP
               agreements will serve as models for future agreements at Federal
               facilities, and should expedite future negotiations.

             • Developing an enforcement strategy for Federal facilities which
               describes EPA authorities under RCRA and CERCLA.

             • Developing guidance for pre-remedial activities at Federal facilities and
               strategies for identifying, assessing, evaluating, and listing Federal
               facilities on the National Priorities List.

             • Identifying the universe of potential hazardous waste sites at Federal
               facilities.

Improved Superfund Project Execution
The completion of current projects  in the pipeline has been a continuing high priority within
the Superfund program.  On August 19, we provided the Regions with guidance to assist in
the movement of  Superfund projects more expeditiously through the system. The goal is
to significantly increase the pace of Superfund remedial work through the implementation
of the  "project management approach".   This approach involves selection  of one
organization  to perform  the remedial investigation/feasibility study  at  a site,  provide
technical  support for  public hearings  and  remedy  selection,  conduct the  design
engineering  phase, and  serve as the construction manager.

Pro-Active  Memoranda on Kev RCRA-CERCLA Decisions
In FY 1987,  we began a process of providing the Regional Administrators at the  beginning
of each quarter with a list of key RCRA and CERCLA decisions due in that quarter.  This
pro-active approach is intended to keep the Regional Administrators apprised of some of
the significant commitments, by  project name in  most  cases, within  their  respective
Regions.  These  memoranda focused on RCRA permits, closure plans, and significant
noncompliers; and  Superfund Records of  Decision,  remedial  design  and construction
starts,  settlements, Section 107 referrals, site work completions and  expected deletions
from the National  Priorities List.
                                       ES-3

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Environmental Priorities Initiative
The Environmental  Priorities Initiative  (EPI) is an  integrated  approach to identifying and
addressing environmental problems. This initiative will lead to an integrated RCRA/CERCLA
management system designed to enable the Agency, and ultimately the States, to identify,
evaluate, prioritize and clean up first those sites which present or may present the greatest
threat to human health and  the  environment.   In FY 1987, an  EPA  Task Force  was
established  to  develop  an implementation plan to ensure  that the EPI principles are
integrated into our  program policies, regulations and guidance.

Municipal Solid Waste Activities
A rapidly developing issue in FY 1987 was heightened concern over municipal solid waste.
Many of the  concerns were related to municipal  waste combustion (MWC), as well as
increased interest  in source reduction and recycling.  During the year,  OSWER  began
development of a stronger EPA position in this area.  Included  were activities  related  to
MWC air pollution control and  ash characterization/disposal,  as  well as  review  of options
for source reduction and recycling. The municipal solid waste initiative will be continued in
FY  1988.
                                       ES-4

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                                  SECTION 1

                                SUPERFUND
 The Superfund program made considerable progress over the past year. The passage of
 the Superfund Amendments and Reauthorization  Act  of 1986  (SARA) provided us with
 even more challenges to  meet the broad directions  given by Congress.   While SARA
 required a number of significant mid-course corrections, substantial progress was made in
 terms of site activities over this past year.  Our use of  the Superfund response authorities
 — remedial, removal and enforcement — resulted in significant  accomplishments.   In
 parallel with these activities, we were also very active on the regulatory and policy fronts.
 This section discusses the specific progress made in these areas.
RESPONSE ACTIVITIES

Three types of response actions are possible under the Superfund site response program.
They include remedial  actions,  removal  actions and enforcement, progress in each  of
which is summarized below.


Remedial Actions

Remedial actions  are long-term actions that are generally undertaken at  more complex
sites.  These actions usually take a longer period of time than removal actions, require
extensive study to select the most effective clean-up option,  and may cost  millions  of
dollars to implement.  They may consist of removal and treatment (such as  incineration) of
contaminated materials,  pumping and  treating  of ground water, or other actions  to
permanently clean up a site.

Project accomplishments for the remedial program in FY 1987 were significant.  These
included  123  "first  start"   remedial investigation/feasibility  studies  (RI/FSs) and  60
subsequent  RI/FSs; 58  initial records  of decision  (RODs) and  17 subsequent RODs; 75
remedial design (RD) starts; 41 remedial action (RA) starts; 8 sites where remedial work
was completed; and 5 deletions from the National Priorities List  (NPL) (see Exhibit 1).  The
remedies  selected involve  a variety of  technologies  including  thermal  destruction,
solidification, stabilization, aeration, soil washing and flushing, and biodegradation.
                                       1-1

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                                     Exhibit 1
                                       123
                                  RI/FS First Starts

                                       60
                                 Subsequent RI/FSs
                                       58
                                    Initial RODs

                                       17
                                 Subsequent RODs
                                       75
                                     RD Starts
                                        41
                                     RA Starts
                                        8
                                   Remedial Site
                                 Work Completions

                                        5
                                   Deletions from
                                     the NPL
Of the total 75 RODs signed in FY 1987 (58 initial and 17 subsequent), 44 of these RODs
addressed final source control.  The other 30 RODs addressed temporary  storage (8),
ground-water action (16), and no further action (6). Over half (57%) of the final source
control RODs employed source treatment; 44% of the source  treatment remedies were
thermal destruction. The percentage of RODs addressing ground water where "pump and
treat" was selected to restore the aquifer was 69% (23/33). Many RODs contained both
source control and ground-water remedies and costs for the FY 1987 RODs (see Exhibit
2).

A key management initiative in  1987 was the  development   and implementation of a
strategy designed to expedite  the  pre-remedial process.  It focuses more  attention on
early decisions  to ensure that fewer low priority sites reach the more resource-intensive
parts of the pre-remedial process.

During FY 1987, the pre-remedial program completed Preliminary Assessments  (PAs) for
over 4,000 sites, Site Investigations  (Sis) for over 1,300 sites and 155 Hazard Ranking
System (MRS) scores (see Exhibits 3 and 4).  Ninety-nine sites were listed  as  final  NPL
sites, while an additional 64 sites (63 non-Federal,  1 Federal) were proposed for listing.
In addition, the pre-remedial program substantially completed development of Update 7 to
the  NPL that will propose approximately 200  new sites.
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       Exhibit 2
FY 1987 ROD Summary
Total RODs Completed
Final Source Control RODs
Total RODs Employing Source Treatment
Selected Remedies*
Treatment Technology
Incineration/Thermal
Solidification
Stabilization/Neutralization
Violatilization/Aeration
Soil Washing/Flushing
Biodegradation
Other
Total
Containment
On-Site Containment
Temporary Storage
Off-Site Disposal
Ground Water
Pump and Treat
Alternate Water
Supply



No Further Action


Program
47
26
18
9
5
2
3
1
2
22
10
8
1
13
7
3




















Enforcement
28
18
7


2
1
1
2
-
1
1
8

17
-
1

10
3

3

Total
75
44
25
11
6
1
4
3
2
3
30
27
8
2
23
10
6






—













—
* More than one remedy may be associated with a site
Remedy Costs

Program
Enforcement
Total

0-$2M
20
7
27

2-S5M
13
9
22

5-$10M

5
4
9

10-S20M
3
2
5

20-$50M $50M+
5
2
7
1
1
2

         1-3

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         PA's completed
             23,000
              (90%)
                                                           FY 1987
       Exhibit 4


7500  C"


6500  |O "."•;.' \


5500


4500


3500
 Total CERCLIS* = 27,000 (estimate)

   Percent of CERCLIS Sites with
Preliminary Assessments Completed
  Through FY 1987 (Cumulative)
 * (Inventory of potential Superfund sites)
                                                2500
1500
 500
                                                          \FY 1981-1986
                                              Number of Site Investigations
                                                      Completed
Two major project management support activities initiated in FY 1987 were the Alternative
Remedial  Contracts Strategy  (ARCS) and  the RI/FS Improvements Initiative.  The ARCS
concept was fully developed and procurement actions were initiated in two EPA Regions.
Key components of ARCS include promoting  continuity of performance from RI/FS to
construction management,  increasing the  level  of competition  for contract awards, and
facilitating contract management delegations to the Regions.  Contract awards under this
program in the two pilot Regions will begin in December 1987, and procurement actions
will be initiated in all remaining Regions during FY 1988.  The RI/FS Improvements Initiative
was forwarded to the Regions  on July 23, 1987.  The document includes suggested project
timelines and a series of project management recommendations.
Removal Actions

Since the inception of the Superfund program in  1980, the emergency removal program
has been highly successful. Removal actions are  relatively short-term actions designed to
protect  public health, welfare or the environment.   Removal actions  may  require an
immediate response to an emergency, such as a  fire, chemical leak, or explosion. Some
are quite extensive, involving significant engineering and requiring several million dollars to
complete.

In  FY 1987, 254 removal actions were initiated and 193  actions were completed using
Trust Fund resources.  This is, by far, the largest number of removals conducted in one
year since the program began in December 1980.  The total number  of removal actions
initiated  since the enactment of CERCLA  in 1980 is 1,051  (see Exhibit 5).
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 In FY 1987, the Office of Emergency and Remedial Response (OERR) implemented Phase
 I of an  Emergency Response Notification System.  This system  involves all ten Regions

 capturing and  sending release notification  reports to  a centralized data base to  be

 combined with National Records Center data.  This  information is used by the emergency
 response and preparedness programs, as well as other EPA offices and the States.



                                    Exhibit 5


                              1200


                              1000

                                        FY 1987
                              800


                              600  ^^^

                                   	   1981-1986
                              400


                              200
                            Number of Removal Actions
                                     Initiated
During the course of FY 1987, the removal program reissued all four zone contracts, two
Technical Assistance Team (TAT) contracts, four dioxin contracts, several 8(a) contracts
and  two  Regional Emergency Response Cleanup  Services  (ERGS) contracts.  These
contracts provide the technical assistance and cleanup  services that EPA  needs to
implement an effective removal program. In addition, OERR began working to implement
the recommendations of the On-Scene Coordinator (OSC)  Management  Support Task
Force, intended  to assist the OSCs in  meeting  current administrative requirements for
financial management, contract management, and documentation for cost recovery.  Five
Regions established Administrative Support Units to  implement the  recommendations,  and
the remaining five will establish  similar  units in FY 1988.   In addition, Headquarters is
providing training to  the OSCs on methods  of cost control and on the  new  Cost
Management Manual. A software program was developed  to aid  the OSCs in  improving
cost  management.   Revised  removal  contracts  and program   guidance  were  also
developed.
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 ENFORCEMENT PROGRAM

 EPA can use Superfund enforcement authorities to require a response action by a party
 responsible for the contamination.  EPA can obtain clean-up action by taking parties to
 court,  reaching an out-of-court settlement or issuing unilateral administrative orders where
 there is  a  threat to public health and the  environment.  If an immediate threat to public
 health develops,  or if a private party delays negotiations on  settlements for a  lengthy
 period, the Agency can use Fund money to address the hazard at once.

 Under the  enforcement program in FY 1987, 47 (out of 123) RI/FSs and 19 RD/RAs were
 conducted by  Potentially Responsible Parties (PRPs).  Exhibit 6 shows  total progress
 (remedial plus enforcement)  toward the SARA statutory goal of initiating 275 RI/FSs by
 October  1989.  Eighteen consent  decrees were lodged  to initiate remedial designs.
 Several others are in the final stages prior to issuance.
                                       Exhibit 6
                           300

                           270

                           240

                           210

                           180

                           150

                           120

                            90

                            60

                            30

                             0
I  1 FY 1989 Goal

HI FY 1988 Goal

EZ3 FY 1987 Goal

• FY 1987 Actual
                                Progress toward Meeting
                                   SARA RI/FS Goal
                                 (Remedial & Enforcement)
Cost Recovery and Settlements

During  FY 1987, the cost recovery program focused on prioritizing sites for cost recovery
based  on statutes of  limitations  and availability of PRPs, and  on revising cost recovery
revenue projections for the next five years.   In FY 1987, the Regions referred 37 sites for
cost recovery at a combined dollar value of approximately $81  million,  and completed 43
cost recovery settlements for a  total  value of almost  $36 million  (see Exhibit 7).   In
addition,  we  reached  17 settlements  in which  PRPs  will  conduct the  RD/RA and 50
settlements for RI/FSs.  The  value of the RD/RA settlements is in excess of $110 million.
                                        1-6

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                                     Exhibit 7
                                        FY 1987
                                        FY 1981-1986
80


70


60


50


40


30


20


10
                            Dollar Value of Cost Recovery
                                    Settlements
                                    ($ in millions)
 REGULATIONS, GUIDANCES, AND OTHER ACTIVITIES

 In parallel with  the  substantial site  activities,  OSWER was very active  in developing
 regulations and guidance.  Some of these activities were mandated by SARA, others were
 needed to improve  the pace  of  the Superfund  programs.  In particular, the  "project
 management approach"  was implemented to  assist the  Regions in moving  Superfund
 projects more expeditiously through the system (as discussed in the Executive Summary).

 Extensive guidance  was  also  drafted on  how  CERCLA  actions should  comply with
 applicable or relevant and appropriate requirements (ARARs)  of other  Federal laws,  as
 required  by SARA.  The  following sections outline additional  regulatory  and  guidance
 activities during the past year.
National Contingency Plan (NCP)

A  major effort over the past year  has been the mandated revision  of the NCP,  which
contains most of the Superfund regulatory program.  Key elements of the NCP will include
the selection of  remedy process, State involvement in cleanup activities, requirements
related to off-site disposal  of Superfund waste, and details of the administrative record to
be maintained.  We expect proposal of the revised NCP during  the first half of FY 1988.
Hazard Ranking System (MRS)

The revised MRS will be used to identify National Priorities List sites. We have compressed
the time schedule and expect to complete this rule before the end of FY  1988.
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1
 Guidance for Determining Selection of Remedy

 EPA decision makers were provided guidance to assist in making the selection of remedy
 at  Superfund  sites.   The  following  key  criteria should  be considered  in evaluating
 alternatives:

            •  Compliance with ARARs

            •  Reduction of toxicity, mobility, and volume

            •  Short-term effectiveness

            •  Long-term effectiveness and permanence

            •  Implementability

            •  Cost

            •  Community reaction

            •  State  acceptance

            •  Overall protection of human health and the environment


Technical Assistance Grants (TAGs)

Another SARA provision requires that  TAGs be made available to citizen groups to hire
their own  consultants  to review site activities.  We expect to publish an interim  final rule
this winter, and we will make grant awards under its provisions as we develop the final
rule.


Streamlining the Settlement Process

Key elements of this guidance document (issued February 12, 1987) are establishment of
criteria for settlement decisions; formation of two committees to expedite policy decisions
in Headquarters; and  setting of deadlines for settlement negotiations, for which only the
Regional Administrator or the Assistant Administrator can extend the period of negotiation.


Nonbindina Allocation of Resources (NBARs)

The NEAR guidance (issued May 28, 1987) discusses the preliminary allocation of costs of
cleanup among PRPs and  is based on such factors as volume, toxicity, mobility, and the
nature of the case against the parties.


Guidance on De  Minimis Settlements

This guidance  (issued June 19,  1987) provides that  EPA will  enter  into £le_ minimi's
settlements with small contributors who are minimally liable for the costs of cleanup.  This
settlement mechanism  removes the minor contributors from  the negotiation process so
EPA can concentrate its efforts on negotiating with the major responsible parties.
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 Guidance on Convenants not to Sue

 EPA issued guidance on covenants not to sue on July 10, 1987. A covenant not to sue is
 a third mechanism EPA may use to assist the settlement process.  A covenant would
 provide for PRPs to select a permanent remedy in return for a release from future liability.
 Guidance on Use of Mixed Funding

 SARA also authorized EPA to use mixed funding measures (mixed Fund/PRP financed
 cleanup) to  reach  settlement.   EPA  provided  guidance that  provides a  method  for
 evaluating mixed funding agreements on October 20, 1987.
 Special Notice Guidance

 Special notices will be used for RI/FS and RD/RA in  most cases.   Special notices will
 invoke moratoria on EPA conduct of RI/FSs under section 104(b), response actions under
 section 104(a)  and enforcement actions  under section 106.   Guidance was  issued in
 October 1987.
Reimbursement to Local Governments Rule

SARA  authorizes  reimbursement of local governments  for costs incurred in providing
temporary  emergency  measures  in  response to releases  of  hazardous substances.
Reimbursement can be granted for up to $25,000 per incident.  An  interim final rule was
recently published in the Federal Register.
Health Assessment Guidance

A close working relationship was maintained with  the Agency for Toxic Substances and
Disease Registry  (ATSDR)  throughout the  year.  A procedural  manual  on conducting
health assessments was jointly issued by EPA and ATSDR.  The manual is designed to
integrate health assessment provisions of SARA into the remedial program.


Suoerfund Innovative Technology Evaluation (SITE) Program

The  SITE  program  was established by SARA  to help develop  treatment  technologies
necessary to implement the new cleanup standards.   The  program's  objective  is to
develop, demonstrate, and subsequently encourage the use of such technologies as
alternatives to land  disposal.  Presently, 22 technologies have been accepted into the
program, and the  third Request for Proposals will be distributed in January 1988.  By the
end of the calendar year, we will have initiated field demonstrations of infrared incineration,
solidification, in-situ  vacuum extraction, and oxygen enhanced incineration technologies.
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Outreach and Training Activities

A  key element of reauthorization was  conducting  a variety of outreach  and training
activities designed to reach the Regional and State implementors.  Throughout the year,
OERR and the Office of Waste Programs Enforcement (OWPE)  staff visited  all ten EPA
Regions to provide hands-on  advice on incorporating new SARA  provisions in ongoing
projects and on developing RODs,

OSWER produced  a national  teleconference designed to introduce a  broad range of
Regional and  State personnel to the SARA provisions. This was followed by a series of
six, two-day conferences, sponsored by OERR and OWPE, reaching all ten Regions  and
numerous State personnel, to describe emerging SARA implementation policies.
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                                  SECTION 2

       RESOURCE CONSERVATION & RECOVERY ACT

 The RCRA program made substantial progress in addressing the priorities outlined for FY
 1987.  New regulations  were developed to fill gaps in environmental protection and to
 correct problems in the  existing regulations.  A foundation was  laid  to provide  a more
 workable program in the future by encouraging waste minimization, examining the criteria
 for disposal of municipal solid waste, continuing to study large volume wastes and working
 to establish and maintain reliable and useful databases.   Significant  progress was also
 made in implementing the RCRA  requirements: meeting the permitting deadlines, requiring
 corrective  action,  conducting compliance  monitoring  and enforcement activities, and
 providing guidance and assistance to the Regions and  States. This section reviews the
 specific progress made in these areas.

 REGULATORY ACTIVITIES AND REPORTS TO CONGRESS
 Regulations were developed in several areas in FY 1987, including land disposal, used oil,
 small quantity generators and closure.  The Office of Solid Waste (OSW) also prepared
 several Reports to Congress in  response to statutory requirements.  Summaries  of key
 activities are provided below.

 Strengthen and Improve Land Disposal Restrictions
 The  Hazardous  and Solid Waste  Amendments of 1984 (HSWA)  recognized that land
 disposal should  be the least favored method of managing hazardous waste because of the
 potential for ground-water contamination and other hazards associated with land disposal.
 The program for restricting land disposal of waste includes a series of deadlines for issuing
 regulations that  specify levels of  treatment needed before  the residues left after treatment
 are acceptable for land disposal.  During  FY 1987, the Agency issued a final rule to set the
 overall framework and to restrict dioxins and  solvents from land disposal (November 7,
 1986). In addition, we proposed  and  promulgated the regulation restricting the "California
 list"  of hazardous  wastes from  land disposal (December  11, 1986,  and July 8,  1987,
 respectively). HSWA also mandated the development of  new technological requirements
 to ensure that those land disposal  facilities continuing to  operate and those disposing of
 treated wastes provide the greatest  protection possible.  The Agency proposed regulations
 for containing liquid hazardous waste on December 24, 1986, and expanding requirements
 for leak detection systems on May  29, 1987.
 On July 7, 1987, EPA promulgated a rule containing a revised list of constituents for which
 there are reliable statistical tests  for assessing potential ground-water  contamination.  On
 August  24,  1987, the  Agency proposed a  new  statistical method for determining
 ground-water contamination.  Current  regulations do not  apply to certain methods of
 disposal now in  existence.  Examples include open burning  and open  detonation used by
the military.  On November 7, 1986, the Agency proposed  regulations covering  these
facilities.
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 Used Oil Standards
 HSWA required EPA to make a determination as to whether used car and truck crankcase
 oils  should  be listed  as  hazardous and managed  under  Subtitle C regulations.   In a
 November 1986 proposal, augmented in March 1987, the Agency announced that it will not
 list as a hazardous waste used oil that is recycled.  Used oil being disposed of may be
 listed as a hazardous waste in the future after study, or EPA may regulate such used oil
 under  the Toxic Substances  Control Act.   Burning hazardous wastes and used oils  in
 boilers and industrial furnaces, as well as storage and transportation of these wastes prior
 to burning,   can  result  in air  emissions  containing  toxic pollutants and carcinogenic
 substances.  EPA, therefore,  proposed a rule on May 6, 1987, that would place certain
 management standards on the burning of these wastes.

 Small  Quantity Generator Wastes
 Generators  of 1,000  kilograms or less per month of hazardous waste  (small quantity
 generators)  were not subject to  the hazardous  waste regulations prior to  HSWA.   In
 October 1987, the Agency proposed regulations  that would make the existing  rules  for
 storage of hazardous  waste now  affecting  large quantity generators also apply to small
 quantity  generators — those generating  from  100  - 1,000 kilograms per  month  of
 hazardous waste.  In addition, EPA proposed and  promulgated regulations requiring small
 quantity generators to file a modified manifest exception report with the Agency (May  1,
 1987, and September 23, 1987, respectively).  This report provides the generator with a
 record that the wastes have been received by the designated treatment or disposal facility.

 Closing Hazardous Waste Facilities

 The  current regulations provide two options for closing landfills,  surface impoundments,
 and waste piles.  There are circumstances where  a  combination of methods would be the
 most environmentally  protective.    Such methods were proposed  on March  19, 1987.
 Further, the  Agency issued a final rule on the same day to make consistent the closure
 requirements for interim status and permitted facilities.

 Reports to  Congress
 HSWA required study  of municipal solid waste facilities and,  if  necessary, revision of the
 solid waste disposal criteria.  The Agency  issued a nine volume Report to Congress on
 Municipal Waste Combustion  on  July 7,  1987.  In addition, two informational  documents
 were released in October 1986:  "A Survey of  Household Hazardous Wastes and Related
 Collection Programs"  and "Census of State  and Territorial  Subtitle  D Non-Hazardous
Waste Programs."
 RCRA exempted certain large volume wastes from regulation under Subtitle C  until further
 study and Reports  to Congress.   In FY  1987,  EPA  continued to  study oil,  gas  and
 geothermal energy  production wastes to determine whether they  should be regulated
 under Subtitle C, and  expects to issue a final report by December 31, 1987.   In addition.
the Agency  developed a  study on wastes from utilities for a Report to Congress, also due
in  December 1987.
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 The Agency issued a Report to Congress on Waste Minimization  in October  1986 that
 showed current waste generation and management practices. The report stated that there
 is a need to develop incentives for research into methods of waste  reduction and laid out
 the types of programs that are necessary over the next several years to move industry
 toward aggressive waste reduction.
 Subtitle D - Report to Congress.  RCRA established a cooperative framework for
 Federal,  State, and local governments to control the management of solid waste under
 Subtitle D.  HSWA required the Agency to  conduct a study of the extent to which the
 existing Subtitle D Land Disposal Criteria are adequate to  protect human health and the
 environment from ground-water contamination.  During 1987, work continued on a Report
 to Congress through the collection of data on Subtitle D waste  characteristics,  Subtitle D
 facility characteristics, and State Subtitle  D program characteristics.  In November  1986,
 Phase I of this Report to Congress was issued.  The final report will include the Agency's
 final conclusions about solid waste disposal  facilities  and practices, and will be issued in
 early 1988.
 Increased  attention has  also  been focused on working  more closely with  States and
 localities,  who will continue to have the basic solid waste management responsibility,  to
 ensure that their planning activities are improved and that the public is fully involved.


 PERMITTING PROGRAM

 The RCRA statutory deadlines for permitting provide an ambitious agenda for the Agency.
 Progress toward  meeting the November 1988 deadline for land disposal permits was
 significant in 1987.  EPA and the States issued 54  permits for land  disposal facilities and
 denied 37 permits for  land disposal facilities.  Closure plans for  332  land disposal facilities
 were approved during the same time period (see Exhibit 8). The Agency and the States
 also issued  14 permits for incinerators and denied two permits  for incinerators as well as
 approved  closure plans for 13 incinerators  in FY  1987 (see  Exhibit 9).  The  statutory
 deadline for incinerator permits is November 1989.
 To promote faster permitting and increase capacity  development,  EPA proposed, on June
 3, 1987, a  new system for permitting mobile treatment units; and on  August  14, 1987, it
 proposed simplified  procedures to allow changes at interim  status and permitted facilities
that are necessary  to comply with new regulations.  This  regulation will allow facilities  to
 avoid delays in,  or  termination of, treatment and  disposal  services as they  proceed  to
meet the new requirements.   On September 23, 1987, the Agency proposed  a revised
process  that  would  provide  a  more  flexible and  rapid  system  for  issuing permit
modifications.
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                          Exhibit 8
        540


        480


        420


        360


        300


        240


        180


        120


         60
                         '87
                         '82-'86
                Permits
                Issued
                            Permits
                            Denied
                        Closure Plans
                          Approved

Land Disposal Facility Final Determinations
                                          50
                                                    40
                                                    30


                                                                      Exhibit 9
                                                                                     ZJ'87
                                                                                     • '82-'86
                                                 Permits      Permits  Closure Plans
                                                  Issued       Denied    Approved
                                                     Incinerator Final Determinations


CORRECTIVE ACTION

HSWA called for the cleanup of releases from solid waste management units  at RCRA
facilities.  HSWA corrective action  covers releases  not only to  ground water, but to air,
surface water, and soil.  The development of this program is being coordinated closely
with the CERCLA cleanup program.  On October 24,  1986, EPA proposed a rule to require
facilities to demonstrate financial assurance for corrective action. The Agency published
the National Corrective Action Strategy in October 1986 and proposed and promulgated
regulations to allow the development of a corrective action program at regulated units  after
permitting a land  disposal facility (December 9, 1986,  and June 22. 1987).  In FY 1987,
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 the following corrective action initiatives were taken:  RCRA facility assessments (RFAs)
 were undertaken at 311 land disposal facilities, ten incinerators,  and 57 storage facilities.
 In addition, RCRA facility  investigations (RFIs)  were  undertaken  at  34 land  disposal
 facilities, two incinerators, and seven storage facilities.  In FY 1987, the Regions drafted 25
 corrective action administrative orders under RCRA sections  3008(h) and 3013; and seven
 judicial referrals for corrective action under RCRA sections 3008(h) and 7003.   In addition
 to the 25 orders, the Regions issued ten final section 3008(h) administrative orders.

 An intensive corrective action order training course was completed for all Regions  and
 Headquarters  in  June 1987.  Completion of this course  enabled EPA  Headquarters  and
 Regional staff  to effectively  develop  corrective action orders under 3008(h). The 3008(h)
 model order was developed and utilized in  draft form throughout most of the fiscal year.
 Final revisions are now under review and the final model order should be completed in
 early FY 1988.   The RCRA Corrective Action Plan was completed November 14, 1986.
 This plan provides detailed Scopes of Work for  conducting RFIs,  Corrective Measures
 Studies  (CMS),  and Corrective  Measures Implementation (CMI).   The  final  Interim
 Measures Guidance was issued June 10, 1987. This provides guidance in developing  and
 ordering  short term actions  in response  to immediate  threats or potential threats of
 exposure to hazardous wastes.
ENFORCEMENT

In FY  1987,  RCRA enforcement  focused its attention  on pursuing formal  enforcement
actions against RCRA land  disposal facilities with inadequate ground-water  monitoring
systems; assuring compliance with approved closure plans,  final  orders, decrees and
permit conditions; as well as enforcing major HSWA requirements, including land disposal
bans.  Emphasis was also placed on ensuring Federal facility compliance  and  supporting
criminal enforcement.

Inspections

All  of  the  approximately  1,500  land disposal  facilities  received  either  a compliance
evaluation inspection or a  comprehensive ground-water monitoring evaluation by either
EPA or the States in FY 1987, as required by HSWA.  In addition, all Federal, State and
local treatment, storage and  disposal facilities and a large majority of other treatment and
storage facilities were inspected.

Significant Non-Compilers (SNCs)

Particular emphasis  was placed on assuring enforcement against SNCs (i.e.,  facilities with
Class  I violations of the  ground-water  monitoring,  closure, post-closure or financial
responsibility  requirements).  At the  beginning of the year, there were 744 SNCs, 260 of
which had not been  addressed with formal enforcement action. At the end of FY 1987, all
but 7 of these had either been addressed by EPA or the States with enforcement  actions
or they had returned to compliance  (see  Exhibit 10).
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 Loss of Interim Status (LOIS)

 LOIS inspections were conducted  in  FY 1986 at  all of the  approximately  1,500 land
 disposal facilities in existence  on November 8, 1985.   Inspections  were conducted to
 determine  the  validity  of those  facilities certifying  compliance with the ground-water
 monitoring  and  financial responsibility requirements, and to ensure that those facilities who
 failed to certify  were not operating hazardous waste disposal units.  Many of the violations
 discovered  as  a result of these inspections were addressed with  formal enforcement
 actions in FY 1987.  For FY  1987, 994 facilities lost  interim status.  Of that number, 59
 facilities were  discovered  to  be  operating   without  interim status,  resulting   in 16
 administrative orders and  42  civil referrals. In addition,  of the 100 facilities that failed to
 submit closure  plans, the  Agency issued 55 administrative orders and processed 33 civil
 referrals.

                                     Exhibit  10
                               Tatar Begirtrting-of-year
                                 :   SNC* * 744

                                Beginning-of-year SNCs
                               with Formal Enforcement
                            Action or Returned to Compliance
GUIDANCES, TRAINING, AND OTHER ACTIVITIES

A  major  Headquarters implementation activity is  the development  and  issuance  of
guidance documents to interpret the requirements of technical regulations and explain how
those requirements can  be  met.   In  FY  1987,  OSW  issued  16 guidance documents
addressing the following areas:

            •  Incineration

            •  Ground-water alternate concentration limits

            •  Corrective action

            •  Closure

            •  State program development
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             • • Radioactive mixed waste

             •  Tank systems

             •  Minimum technology requirements

             •  Test methods

             •  Land disposal restrictions

Another  important  Headquarters activity  is  providing  training  and  direct  technical
assistance to the Regions and States.  The Permit Assistance Teams provide specialized
technical expertise to the Regions and States for particularly difficult  or precedent-setting
permit or closure issues.  In FY  1987, the  Permit Assistance  Teams conducted over 55
reviews of  such  issues.

In FY 1987 training courses were presented to Regional and State staff on:

             •  RCRA Facility Assessments

             •  RCRA Facility Investigations

             •  Risk Assessment Communication

             •  Land Disposal Restrictions

             •  Ground-water Technical  Enforcement Guidance Document

The  RCRA program  manages   large  and  ever-growing  amounts  of data  on facility
permitting and compliance status, hazardous waste generation, and from special surveys.
A major effort is  under way to develop  more reliable and useful data  bases, necessary to
manage the hazardous waste program. During FY 1987, the Agency determined the types
of data and data categories needed, and  designed methods of data entry suitable for easy
State-Federal interaction.  In January 1987,  EPA initiated a survey of treatment, storage,
disposal and recycling facilities.   In August 1987, the Agency began a new study of the
current waste generation rates.


Office of Ombudsman

In May 1986, OSWER established the Office of Ombudsman in Headquarters, as required
by section  2008 of RCRA.   Each  of  the ten  Regional Offices   also designated  a
representative to respond to hazardous waste complaints, grievances, and requests for
information. In its first year,  the  Office of Ombudsman received over 2.000 requests for
assistance.   The interaction with primarily  private citizens and small businessmen is  a
valuable tool in  EPA's management of the hazardous waste program.
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                                  SECTION 3

                UNDERGROUND STORAGE TANKS


 Major  accomplishments of the Office of Underground Storage Tanks (OUST) for FY 1987
 included the proposal  of regulations for tank technical standards,  corrective action and
 State program approval, as well as development of  policies and procedures to support
 implementation of the Leaking Underground Storage Tank (LUST) Trust Fund. OUST has
 placed significant emphasis on creating a program which will work and can realistically be
 carried  out in  50 States and  3,000 counties.  OUST Regional and Headquarters staff
 recognize that their role is to build effective State  programs rather than to be directly
 involved in implementing the program.

 TECHNICAL STANDARDS
 On April 17,  1987, OUST proposed  a  comprehensive set of  technical standards  for
 underground storage tanks. These included design, construction, installation, and release
 detection standards for new tanks, release  detection and upgrading  requirements  for
 existing tanks,  and corrective action requirements for tanks found to be leaking.  The
 objective of OUST in  drafting these  rules  was to fashion a regulatory  program that is
 practical, flexible, and easy to understand and implement.  During June, OUST conducted
 public hearings on  the proposed rule.  The hearings were attended by more than 1,000
 people and over 100  people testified.  OUST has since  received approximately 5,000
 comments from over 1,100 commenters. During the  public comment period, OUST took
 the opportunity to solicit comments more directly by conducting three separate series of
 expert  meetings  on different aspects of the rules and by  interviewing in person  over 50
 manufacturers, owners, installers,  tank testers, and State and local regulators.

 FINANCIAL RESPONSIBILITY REQUIREMENTS
 On April 17, 1987, EPA also proposed financial responsibility requirements for underground
 storage tank (UST) owners and operators.  Simultaneously, OUST launched a project
 aimed  at  developing  State funds or financial assurance mechanisms that could  be
 available when the financial  responsibility  requirements take effect.  OUST  has since
 worked  closely with the insurance industry,  tank owners and State officials to assure that
 the proposed regulations promote  OUST's objective to encourage the availability  and use
 of financial assurance  mechanisms in the future.

 STATE AND LOCAL PROGRAMS

 EPA  proposed requirements for the approval of State UST  programs to operate in lieu of
the Federal requirements.   This proposal established flexible  program elements and
 methods for judging the stringency and  enforcement adequacy of State programs.   In
drafting  these requirements, OUST's  primary  objective was to emphasize environmental
results  while being flexible in  the  means  various States  may choose  to obtain those
results.
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 Many States and local governments have started or accelerated development of their own
 UST programs.   In part,  this  stems from the work of EPA  Regional and  Headquarters
 programs.   By the end of the second year of the UST or preventive program,  48  States
 had their own notification systems, with 1.7 million tanks registered  with  the States.  Two
 notification systems are being  run by EPA Regional Offices,  with contractor help.  Many
 States have chosen to use the nationally  developed notification form and software.  Many
 States have or are developing fee systems to fund their State prevention programs.  The
 fee systems are frequently based on notifications or permits for tanks and this is providing
 an incentive for  States to update and complete their tank inventories. OUST's emphasis
 on flexibility and  letting States determine what is the best way  to run their UST programs is
 demonstrated by the  mix of agencies responsible for the program.  Five States have
 placed  the program  in the State Fire Marshall's Office, one in the State Corporation
 Commission, about eight in the water program and the remainder in the  hazardous waste
 program.

 LUST TRUST FUND  IMPLEMENTATION

 Following the passage of SARA,  OUST moved quickly to complete  the policy ingredients
 necessary  for implementing the LUST Trust Fund.  Essential elements of this effort include:

             •  OSWER guidelines for initial cooperative agreements

             •  Federal Register  notice for State clearinghouse review

            •  Delegations of key authorities to Regional Offices

            •  Mechanism for allocation  of funds  to Regions

            •  OSWER directive  for implementation of cost recovery provisions

 In  addition,  OUST worked closely  with other offices to ensure the timely production of other
 critical guidances pertaining to legal issues, accounting and financial policies, and Federal
 lead role in corrective actions.  These  products paved the way for rapid start-up of the
 Trust  Fund program,  consistent  with the goals  of environmental  protection  and State
 implementation.
States  are  taking the  lead in implementing the Trust Fund program.   Forty States and
three territories have  now signed cooperative agreements, and  several more  should  be
completed  early in  FY  1988 (Exhibit 11).    Many of these States are now  procuring
contractors and  will begin site assessments and cleanups  soon.  EPA has provided a
limited  backup role, taking a lead or supporting role in a few enforcement cases only  on
State request;  but most States  have moved ahead with existing or new authorities to take
the lead in  addressing UST leaks.   OUST has started to work through grant agreements
with several organizations such as the New England Interstate Water Pollution Association,
the Environmental Task Force, and the U.S. Conference of Mayors, on projects that will
help the regulated community and others understand,  carry out, or comply with the final
technical and financial responsibility regulations.
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OUTREACH ACTIVITIES

During FY 1987 OUST developed the following products to inform the regulated community
about the  UST program:

            •  A quarterly bulletin, "Lustline", aimed at State officials,  discusses the
               latest UST issues and developments

            •  A technical newsletter focuses on technical information  exchange

            •  A "plain English" brochure on designing and installing tanks  under the
               current laws, the Interim Prohibition

            •  Two "plain English" brochures ("What's in the Pipeline" and "Your
               Financial Responsibilities") summarize the proposed regulations to help
               the regulated community understand the EPA proposal

            •  A slide show,  "Tank Talk", on the proposed regulations, mainly for use
               by EPA Regional officials

            •  A fact sheet and Qs & As on the Trust Fund

            •  Public hearings,  which were not required by law, but  carried  out to
               receive as much helpful feedback as possible on the proposed rules
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                                SECTION 4

        CHEMICAL EMERGENCY PREPAREDNESS AND
                      PREVENTION PROGRAM
The  new  Superfund  also gave  us Title  III —  emergency planning  and community
right-to-know.   The overall  program  goals are to: promote community  awareness  of
chemical hazards, assist in the development of State and local preparedness programs
and response capabilities,  and develop a chemical accident prevention  program.  In FY
1986 and 1987 the program objectives were to: develop the list of extremely hazardous
substances and accompanying guidance;  build program infrastructure at the Federal,
State and local levels; begin program implementation; and establish data bases to better
understand  the  causes of chemical  accidents.   In FY 1987,  implementation  of the
Chemical Emergency Preparedness and Prevention (CEPP) program was enhanced by the
new requirements of Title  III  of SARA (October,  1986): a State  and local emergency
planning structure, industry reporting requirements (community right-to-know) and broad
participation in the planning process.

Throughout most of the year,  the  Preparedness Staff focused  on meeting the many
statutory deadlines imposed by Title III.  All major program objectives and deadlines were
met.

REGULATORY ACTIVITIES

On November 17, 1986, EPA promulgated the  SARA section 302/304  interim  final rule
establishing the  list of 406 extremely hazardous substances, their  threshold planning
quantities, and the emergency planning and release notification requirements—meeting the
30-day statutory deadline.  The final rule was promulgated on April 22, in advance of the
statutory reporting deadline of May 17.  The Preparedness Staff developed a proposed
rulemaking for the material  safety data sheet and hazardous chemical inventory reporting
requirements within 90 days as required by Title III.  The final rule was promulgated in
advance of the first SARA section  311  reports due October 17,  1987.  The Preparedness
Staff also supported development of the proposed rulemaking on trade secrets in advance
of the first  reporting  deadlines   for  which trade  secrets could  be  claimed. The
Preparedness Staff coordinated overall Title III  implementation with  the Office of Toxic
Substances (OTS), which  has the lead for the SARA section 313 emissions inventory.
OTS promulgated a proposed rule and accompanying technical guidance on section 313
reporting requirements on June 4.
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 REGIONAL AND STATE ACTIVITIES

 Regions  continued  to  work with  States  to develop  agreements  (State Implementation
 Memoranda) on State program implementation and designating priority areas for technical
 assistance.   Agreements have been developed with  about half of the States.  Regions
 provided assistance in conducting an exercise to test emergency plans in a priority area in
 each  State  and  provided other  technical  assistance  and  training to  States  and
 communities.  During FY 1987, State  Governors established State emergency response
 commissions, designated local  planning districts  (over 3,000 districts were established),
 and appointed local  emergency planning  committees  as required  by Title III.   The
 Preparedness Staff developed  a  program to gather  information  on  cases of chemical
 accidents, prevention policies and practices, and technologies in place at the time of the
 accident, and initiatives taken to prevent accidents from  recurring. This program, called
 the Accidental Release Information Program  (ARIP), was pilot tested in one Region early in
 the year.  The test was expanded to all Regions in the spring.

 EMERGENCY PLANNING

 EPA worked  with  the other 13 National Response Team  (NRT) agencies to  develop the
 guidance on  emergency planning required by section 303(f).  In addition to publishing the
 emergency planning guide,  the NRT completed a training strategy for coordinating Federal
 hazardous materials training with State, local and industry  training.  The NRT established a
 number of policies and procedures for managing the NRT/Regional Response Team (RRT)
 system, began work  on computer  applications for  preparedness and  response,  and
 initiated planning for the 1988 Hazardous Materials Spills  Conference.

 EPA worked  with  the Federal  Emergency Management  Agency  (FEMA)  and  the
 Department   of  Transportation  (DOT)  in   developing  draft  technical  guidance  on
 site-specific planning for releases of the 406 extremely hazardous substances. EPA also
 worked with FEMA to make  $5 million in grants available to States for Title III training.  EPA
 provided the funding to FEMA through an interagency agreement and developed a plan for
 use of  the funds with FEMA as required by Congress.  All  States (except Nebraska, which
 did not apply) were allocated funding through FEMA's existing comprehensive cooperative
 agreement with each State.  EPA and FEMA  developed  and  delivered a joint training
 course in contingency planning.
The Preparedness  Staff  initiated  the review  of  emergency  systems  for  detecting,
 monitoring, alerting the  public and preventing releases  of extremely hazardous  substances
and  developed an interim  Report to Congress,  as required by  Title III.  While led by
OSWER, the study involves a cooperative effort with several offices within the Agency as
well as with FEMA, which is providing its expertise for the  public alert section of the study.
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OUTREACH ACTIVITIES

Other  noteworthy  prevention-oriented  activities  completed  by the Preparedness Staff
include analysis of a proposed accident prevention section of the Air Toxics Bill; working
with the  Occupational Safety  and Health  Administration  (OSHA)  and  the Nuclear
Regulatory Commission  (NRC)  on a  joint  inspection  program directed at  improving
chemical safety, filling technological gaps and supporting the tort liability system; working
with OTS and the American  Institute  of  Chemical  Engineers (AlChE)  to conduct  an
International Symposium on Prevention of Chemical Accidents; and working with AlChE to
identify needs  for  chemical  process safety  guidelines.    The  Preparedness  Staff
participated   in  the  SARA  teleconference  in  March  and  conducted   an   additional
teleconference devoted to Title III in June.  EPA worked with almost 30 other organizations
(Federal agencies, State and local organizations, trade organizations, and  public interest
groups) in conducting six workshops on Title III implementation across the country in July
and August.  In addition, the Preparedness Staff developed and distributed thousands of
copies of a Fact Sheet on Title III, and has made many presentations to organizations and
groups affected by Title III.

INTERNATIONAL ASSISTANCE

The Preparedness  Staff is also active  in international emergency response  activities. In
bilateral relations, the Preparedness Staff co-chaired  Joint Response Teams with Canada
and Mexico and developed Joint  Contingency  Plans for responding to releases along U.S.
borders. In multilateral  efforts,  the Preparedness Staff initiated a preparedness/prevention
project with the Organization for  Economic Cooperation and Development  (OECD) as a
result of the  ministerial level meeting on chemicals;   is  working with the  United  Nations
Environment  Program (UNEP) on two  protocols  for  international notification of releases
and assistance in  response  actions; and is working with the International Program for
Chemical  Safety (IPCS) in developing  profile cards on toxic chemicals.
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I'.o. Environmental Protection Arc-
"!ogion 5, Library (5PL-16)
£30 S. Dearborn Street, Room  1670
Chicago, IL   60604

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