SMALL BUSINESS OMBUDSMAN
UPDATE OOON00001
United States Environmental Protection Agency
Washington, DC 20460
MEMORANDUM
Home Page www.epa.gov/sbo
SUBJECT:
FROM:
TO:
DATE:
Update on Recent Small Business
Activities at the U.S. EPA
Karen V. Brown
Small Business Ombudsman
Persons Interested in Small Business
Environmental Issues
July, 2000
SMALL BUSINESS OMBUDSMAN STAFF
Robert C. Rose, Deputy Small Business Ombudsman
The Clean Air Act & General Assistance
Delane Anderson, Special Assistant
Andrew Teplitzky, Environmental Scientist
Eileen McGovern, Program Analyst
Angela Suber, Special Assistant
SENIOR ENVIRONMENTAL EMPLOYEES
James E. Malcolm, P.E., Chemical Engineer
Toxic Substances & Hazardous Materials
Larry 0. Tessier, P.E., Civil Engineer
Asbestos, Radon and Lead
Arnold Medbery, P.E., Mechanical Engineer
The Clean Air Act, Asbestos, Water
Thomas J. Naklej, Civil Engineer
The Clean Water Act, Safe Drinking Water Act and
General Assistance
CONTENTS
Page
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Deputy Adm Memo
Small Bus. Strategy
Small Biz Env. Home Page
Web pages/Hotlines
SB Regional Contacts
Clean Air Act (CAA)
Clean Water Act (CWA)
Pesticides (F1FRA)
Hazardous Waste (RCRA)
Superfund (CERCLA)
Right-to-Know (EPCRA)
Toxic Chemicals (TSCA)
Six Key Aspects/SBREHA
SBA Fairness Board
Stats on EPA Innovation
Update on Environ Info
Performance Track
State Success Stories
30
31
32
34
36
38
39
40
42
43
44
45
47
51
53
55
58
59
Ten Innovative Projects
Superior Asst Tools
New Publications
Risk Management
HPV Challenge
S.B. Sector Programs
Design for Environment
Innov. in Compliance Asst
Audit Protocols
SBIR
Coating Alt Guide
Compliance Asst Centers
Penalty Reduction
State Sm. Bus Asst. Prog.
State Sm. Bus Contact
P2 Program Contacts
Procurement Contacts
Order Form
\
Toll Free Hotline
800-368-5888
202-260-0490
HELP ME; HELP YOU, NOW!
Our Small Business Ombudsman function is
changing. We are soon to be the Small Business
Division within the new EPA Office of Policy,
Economics and Innovations. In our new role, we will
expand to further serve as the Agency-wide focal point
to hear from you, serve, and assist small businesses. We
are now in the process of revising and updating the
Agency's Small Business Strategy...that is to say, we are
improving our recognition and addressing of small
business issues, problems, and needs, and determining
how best to carry out such initiatives across the Agency.
As your needs change, so should our Strategy.
Now, you can help me with our new Strategy by
identifying problems, issues and assistance deficiencies
of which you are aware and advise me, with your
suggestions on how we can better serve you. Do it now.
Call and ask for me on our Toll Free Hotline at 1-800-
368-5888, call me directly on (202) 260-1390, e-mail
me via brown.karen@epa.gov. or write to me at: Karen
V. Brown, Director, Small Business Ombudsman
Division (2131), Ariel Rios Building, 1200
Pennsylvania Avenue, NW, Washington, DC 20460.
LET ME HEAR FROM YOU, WE NEED YOUR INPUT!
Karen V. Brown
ONE-STOP-RELIEF
SMALL BUSINESS OMBUDSMAN FUNCTIONS
EPA's Office of the Small Business Ombudsman
(OSBO) performs the following functions:
Provides a convenient way for small businesses to access
EPA;
Facilitates communications between the small business
community and EPA;
Investigates and resolves disputes with EPA; and
Works with EPA personnel to increase their
understanding of small businesses in the development and
enforcement of environmental regulations.
Call (800) 368-5888
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 1 200Q
MEMORANDUM
SUBJECT. Revising EPA's Small Business Strategy
OFFICE OF
THE ADMINISTRATOR
TO. Assistant Administrators
General Counsel
Inspector General
Chief Financial Officer
Associate Administrators
Regional Administrators
Staff Office Directors
In 1984, the Agency unveiled its first Small Business Strategy-, entitled EPA Small Business
Initiatives: Strategy for Improved Regulation and Compliance. The focus of this strategy was to
improve both the Agency's regulation of small business entities and their level of compliance with
environmental regulations. Now, 16 years later, with small businesses dominating the U.S. economic
landscape, it makes sense for us to revisit the 1984 Strategy- and update it to highlight policies and
approaches that can help us achieve our goals in a way that is relevant to the small business community.
This memo announces our intent to revise the Small Business Strategy- and to ask for your
interest and cooperation in this important effort. The Administrator and I have asked the Small Business
Division in the soon-to-be-finalized Office of Policy, Economics, and Innovation (OPEI) to serve as the
Agency's focal point for small business-related activities and, in that capacity, to coordinate the revision
of the Small Business Strategy. Rick Farrell, Associate Administrator for OPEI, will soon send a follow-
up memo transmitting further details about your involvement in the Strategy revision process.
The Administrator and I would like the revised Strategy to consider several major points of
emphasis. First, we must integrate an awareness of small businesses into all of our core functions, paying
special attention to the potential impact that our regulatory activities may have on small businesses and, if
possible, find new ways to help small businesses meet and even exceed the requirements of our
regulations. Second, we must continue to address improvements in our collection and delivery of
information and assistance in a way that makes sense for small businesses. Finally, we must, as an
Agency, and in conjunction with our co-regulators, improve the coordination of program activities that
may potentially impact small businesses.
The small business community is an important customer for EPA and I am excited about acting
on this much-needed opportunity to update our strategy to address their needs.
W. Michael McCabe
Acting Deputy Administrator
cc: Deputy Assistant Administrators
Deputy Regional Administrators
Recycled/Recyclable
Printed with Soy/Canolซ InK on paper
contains at least 50% recycled fiber
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U.S. EPA Updating Its Small Business Strategy
You probably didn't know that back in 1984, the Environmental Protection Agency issued its first
small business strategy, entitled EPA Small Business Initiatives: Strategy for Improved Regulation and
Compliance (to view a copy of the 1984 strategy, go to www.epa.gov/sbo/stratl984.pdf). While the
Agency has worked to address many of the issues highlighted in the strategy over the past 16 years, it
recognizes that not all issues have been fully resolved and a number of new ones have emerged. This is
why the Agency is now working on an update to its Small Business Strategy. The goals of the revised
strategy are threefold: enhance the environmental performance of small business, unify EPA's approach
to small business, and seek workable policies and approaches that are most effective in addressing small
business environmental issues and needs. The Agency began the revision process earlier this Spring and
has held a series of meetings both in-house and with external stakeholders to help identify issues and
recommendations. The issues and recommended actions generally can be arranged in four categories:
providing the information and assistance that small businesses need to meet or exceed regulations;
seeking easier, more efficient ways to regulate/permit small businesses; providing opportunities for non-
regulatory, voluntary approaches to "green" small businesses; and addressing a number of internal
Agency cross-cutting issues such as enforcement concerns, coordination amongst Agency program
offices and regions, and adjustment of program budgets and resources. The Agency anticipates
finalizing the revised strategy in August of this year. For more information, please contact Andy
Teplitzky at U.S EPA (202) 260-4088 or via e-mail at Teplitzkv.Andy@epa.gov.
Survey Of EPA'S Small Business Customers
Last summer, the Agency published Aiming for Excellence to document our commitments to
encouraging stewardship and accelerating environmental progress. One commitment specified in Aiming
for Excellence is to assess the value and accessibility of the many hotlines, clearinghouses, and other
EPA support functions that are intended to benefit small businesses. To assist us in making this
assessment, we are using a survey which will be administered through telephone conversations that
should take no longer than eight minutes. We have developed and tested questions and are currently
awaiting final survey approval, expected in July. Then we will begin calling you to ask your opinion of
how we're doing and what worksand what doesn'tfor you. We will complete the survey calls and
report back on the results later this summer. So if you hear us on the other end of your telephone line,
please take a few moments to help us get better at helping you! For more information, please contact:
Eileen McGovern at: U.S. EPA, (202) 260-5352
"Cataloging" EPA's Products and Services For the Small Businesses
The senior managers in our new home, the Office of Policy, Economics, and Innovation, recognize
that the small business community is an important customer for EPA. In the process of integrating the
Small Business Ombudsman into the Office of Policy and the Office of Reinvention, Agency leaders
have made it clear that EPA must expand its outreach and assistance to small businesses and deal with
regulatory issues in a friendly and cooperative basis. In keeping with this concern, we are developing a
"catalog" of the products and services that EPA makes available to small businesses. We are currently
reviewing all the information sources within EPA and working to ensure that our product is complete and
accurate. The catalog will include all Agency efforts, whether targeted specifically for small businesses
or to a broader audience that includes them. Staff is working to have the document ready for publication
and available for our customers this summer. For further information contact: Eileen McGovern at
USA EPA (202) 260-5352 or via e-mail at: mcgovern.eileen@epa gov
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SMALL BUSINESS ENVIRONMENTAL HOME PAGE
http://www.smallbiz-enviroweb.org
The Small Business Environmental Home Page (Home Page) continues to benefit the small
business community and the Section 507 programs. This Home Page was developed and is
being maintained by Concurrent Technologies Corporation (Pittsburgh Office) under
cooperative agreement funding provided by U.S. EPA SBO.
Developed in response to requests from the State's Section 507 programs and the Small
Business Community for assistance in centrally distributing and exchanging information
about their program activities, the Home Page provides efficient access to EPA, state, and
other environmental and pollution prevention information focused on small business.
For those who have not visited the Small Business Environmental Home Page lately, please
check it out again! The links and resources on the Home Page are continuously updated. For
example, contacts are updated weekly, monthly regulatory updates are provided, state and
federal news briefs are posted on the State News-Share and Find! subpage, and the
publications searchable database now includes over 3,500 directly linked publications and
fact sheets! You can always find out what's been added/revised on the Home Page by
clicking on the What's New button.
NEW! The Small Btautau C*wi>uuune*Ual Web &oa*A is now up and running! The
BoGAd is a forum for you to share environmental information focused on small business.
There are eight conference categories available for you to post your questions,
information to be shared, and replies. There is also a chat room available for users who
are on line at the same time.
Don't forget the performance measurement tools and success stories searchable database
(http://w\vw. smallbiz-enviroweb.org/perfmeas. asp) still needs your tools and stories to add!
The database enables tools from states and EPA to be reviewed and directly downloaded,
revised, and used.
The Home Page continues to include: links to state environmental agencies and small
business assistance program web sites, SBO update newsletters, key Compliance Advisory
Panel (CAP) contacts and meeting information, links to state environmental newsletters and
funding information subpages, the National Small Business Financial Assistance (SBFA)
Work Group web page, Mid-Atlantic Region Small Business Assistance web page,
compliance information (including monthly regulatory updates, environmental reporting
calendar and requirements checklist, law summaries, links), EPA and small business
assistance program contact lists, links to trade associations and listing of trade association
contacts, summaries and links to new small business initiatives and policies, industry sector
links, funding help, and links to environmental and other helpful sites.
Users are encouraged to provide information on events, news, contacts, publications/fact
sheets, videos, CAP information, performance measurement tools and success stories, and
corrected/new links to include on the Home Page, and any comments and suggestions about
the Home Page to Audrey G. Zelanko (zelanko@smallbiz-enviroweb.org ; 412/577-2649).
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WHERE TO CALL FOR MORE INFORMATION AND HELP
EPA SMALL BUSINESS OMBUDSMAN
Toll Free Local and DC Area T.D.D. Fax
(800)368-5888 (202)260-1211 (202)260-1258 (202)401-2302
smallbiz.ombudsman@epa.gov Homepage www.epa.gov/sbo asbestos.ombudsman@epa.gov
EPA Web Pages and Hotlines Phone Number
National Center for Environmental Publications 800-490-9198
(www.epa.gov/ncepihom/index.htmn 513-489-8190
Indoor Air Quality Information Clearinghouse 800-438-4318
(www.epa.gov/iaq)
Radon 800-767-7236
(www.epa.gov/iaq/radon)
EPA Energy Star 888-782-7937
(www.epa.gov/smallbiz)
Clean Air Technology Center 919-541-0800 (English)
(www.epa.gov/ttn/catc) 919-541-1800 (Spanish)
Mobile Sources (Emissions) 734-214-4333
(www.epa.gov/omswww)
Emission Measurement Center 919-541-0200
(www.epa.gov/ttn/emc)
Stratospheric Ozone Information 800-296-1996
(www.epa.gov/ozone)
Acid Rain (emission trading, auctions, Information) 202-564-9620
(www.epa.gov/acidrain)
Safe Drinking Water Hotline 800-426-4791
(www.epa.gov/safewater)
National Small Flows Clearinghouse (WV Univ) 800-624-8301
(www.nsfc.wvu.edu)
Storm Water Phase II Information 202-260-5816
(www.epa.gov/owm/sw2.htm)
Water Resource Center 202-260-7786
Pollution Prevention Information Clearinghouse 202-260-1023
(www.epa.gov/opptintr/librarv/libppic.htm)
National Solid & Hazardous Waste Ombudsman 800-262-7937
Washington Metro Area 202-260-9361
Wetlands Information 800-832-7828
(www.epa.gov/owow/wetlands)
U.S. EPA RCRA, Superfund & Underground Storage Tanks Hotline 800-424-9346
Washington Metro Area 703-412-9810
(www.epa.gov/epaoswer/hotline) or www.epa.gov/ceppo
Emergency Planning & Community Right to Know Title III (EPCRA) 800-424-9346
Washington Metro Area 703-412-9877
Toxic Substance Control Act (TSCA) Information Service 202-554-1404
Office of Pesticide Program Registration Division (Ombudsman) 703-305-5446
(www.epa.gov/pesticides)
Bio-Pesticide Staff Assistance 703-308-8098
www.epa.gov/pesticides/biopesticides)
National Pesticide Telecommunications Network 800-858-7378
(http://ace.orst.edu/info/nptn)
EPA Waste Wise/Waste Reduction 800-372-9473
(www.epa.gov/wastewise)
Office of Environmental Justice 800-962-6215
Office of Pollution Prevention & Toxics 202-260-1772
(www.epa.gov/opptintr)
Chemical Emergency Preparedness & Prevention Office 202-260-7938
(CEPPO) Small Business Liaison
(www.epa.gov/ceppo)
Small Business Innovation Research (SBIR) 800-490-9194
(http://es.epa.gov/ncerqa/sbir)
EPA Inspector General (IG) 202-260-4977
(www.epa.gov/oigearth/index.htm) 800-546-8740
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OTHER WEBSITES & HOTLINES Phone Number
Small Business Environmental Home Page (412) 577-2649
(www.smallbiz-enviroweb.org
Recycling Hotline (800) 253-2687
(www. recycle, net/recycle)
National Technical Information Service (NTIS) (800) 553-6847
(www.ntis.gov) (703) 605-6000
National Response Center for reporting oil spills and hazardous (800) 424-8802
substance releases
Washington Metro Area (202) 261-2675
(www.nrc.uscg.mil)
Department of Energy (DOE)-National Alternative Fuels Hotline (800) 423-1363
(www.afdc.nrel.gov)
Energy-efficiency & Renewable Energy.Clearinghouse (800) 363-3732
(Operated by the DOE)
(www.eren.doe.gov)
DOT-Transportation of Hazardous Materials (800) 467-4922
(http://hazmat.dot.gov)
CHEMTREC Chemical Transportation Emergency Line, operated by (800) 262-8200
Chemical Manufacturers Association
(www.cmahq.com/cmawebsite.nsf/pages/chemtrec)
Center for Management Courses on ISO 9000/14000 (703) 250-5900
www.ceem.com
National Lead Technical Information Center (800) 424-5323
(www.epa.gov/lead/nlic.htm)
Small Business Administration (800) 827-5722
(www.sba.gov)
Regulatory Fairness Boards (SBA) (888) 734-3247
(www.sba.gov/regfair)
Occupational Safety & Health Administration (OSHA) (800) 321-6742
(Worker Safety Referral Services)
(www.osha.gov)
American Lung Association (800) 586-4872
(www.lungusa.org)
Consumer Product Safety Commission (800) 638-2772
(www.cpsc.gov)
Radon Auto Emission & Sun Safety(National Safety Council) (800) 557-2366
(www.nsc.org/ehc/indoor/radon.htm)
INFOTERRA/USA (202) 260-5917
(www.epa.gov/INFOTERRA)
Government Printing Office (202) 512-1800
(www.gpo.gov/ffinfo)
National Institute of Occupational Safety and Health (800) 356-4674
(www.cdc.gov/niosh/homepage.html)
National Environmental Training Center for Small Communities (800) 624-8301
(www.estd.wvu.edu/netc/netcsc homepage.html)
EPA REGIONAL REGULATORY SMALL BUSINESS LIAISONS
REGION 1 CT, ME, MA, NH, RI, VT Dwight Peavey (617)918-1829
2 NJ, NY, PR, VI JohnD.Wilk (212)637-3918
3 DE, DC, MD, PA, VA, WV David Byro (800) 228-8711/(215) 814-5563
4 AL, FL, GA, KY, MS, NC, SC, TN Annette V. Hill (404)562-8287
5 IL, IN, MI, MN, OH, Glynis Zywicki (312)886-4571
6 AR, LA, NM, OK, TX David Gray (800) 887-6063/(214) 665-2200
7 IA, KS, MO, NE Janette Lambert (913)551-7768
8 CO, MT, ND, SD, UT, WY Rob Laidlaw (303)312-7064
9 AZ, CA, HI, NV, GU Mark Samolis (415)744-2331
10 AK,ID, OR,WA BillDunbar (206)553-1203
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STATUS OF HIGH VISIBILITY ACTIONS
OBTAINING ADDITIONAL INFORMATION
FOR SMALL BUSINESS
Some articles in this newsletter cite certain reference publications by Item Number that provide additional information on the topic. These
publications can be ordered by completing the Publication Order form on page 59. In addition, the Ombudsman's Office maintains an inventory of over
300 EPA and related publications containing useful environmental information for small business. A complete listing of these publications can be obtained
by calling the Ombudsman's Office at 1-800-368-5888 or 202-260-1211.
Recent Initiatives to Better Serve You
Our efforts to assist the Small Business Community over the
past year continue at a high level. Here are some more things we
have done or are currently doing to help you
Hosted seventh National Small Business Ombudsman and
Technical Assistance Program Conference in Missoula, MT
attended by 44 States, 2 Territories, and the District of
Columbia (191 participants), and have set plans through a
grant to the state of Texas's National Resource Conservation
Commission for an eighth Conference in Austin, Texas during
the Spring of 2001.
Implemented external stakeholder guidance and acted as a
principal participant in the Agency's Regulatory Tiering
(prioritizing) Process.
Coordinated individual meetings and follow-up meetings
between major small business trade associations and the EPA
Deputy Administrator, Assistant Administrators, and Agency
Small Business Program Office Representatives on January
27, and June 14, 2000, to discuss small business initiatives and
issues.
Finalized EPA's 1998 Small Business Ombudsman Report to
Congress under Section 507 of the 1990 Clean Air Act
Amendments.
Cooperatively participating in managing Small Business
Regulatory Enforcement Fairness Act of 1996 small business
entity outreach activities in order to implement Act
requirements.
Planning annual Small Business Liaison Conference for EPA
Regional Small Business Representatives from August 2-3,
2000, which will also be attended by over a dozen state small
business program representatives.
Upgraded EPA Small Business Ombudsman Home Page on
http:/www. epa. go v/sbo.
Participated in 40 to 50 EPA Regulatory work groups as
formal reviewers to represent Small Business concerns.
Conducted fifth State Compliance Advisory Panel (CAP)
Training in June for CAPs utilizing a newly completed
Compliance Advisory Panel Management Manual to assist
State CAPS with their Clean Air Act responsibilities.
Issued revised (improved) Environmental Management Guide
for Small Laboratories.
Upgraded a Source Book on Environmental Auditing for
Small Business.
Developed a new booklet titled: Little Known But Allowable
Ways To Deal With Hazardous Waste.
In the process of implementing Cooperative Agreement
projects with 10 states to improve small business technical
assistance and outreach and to measure their effectiveness.
Conducted two-days specialized training to awardees on
March 16-17, 2000.
Started an initiative to revise EPA's Small Business Strategy.
Initiated a project to assess EPA current suite of environmental
services for small business.
Clean Air Act (CAA)
Implementation Strategy Update
EPA's Office of Air and Radiation has prepared an
Implementation Strategy publication. It outlines the schedule, by
industry, for issuing regulations required by the Clean Air Act. It is
included in our Item 1-11 package.
Final Integrated Urban Air Toxics Strategy
This Strategy is a framework for addressing air toxics in urban
areas. Although existing programs have already achieved substantial
emission reductions, more needs to be done to reduce toxics air
pollutants, particularly in the urban areas. The Strategy outlines
actions to reduce emissions of air toxics and assessment activities to
improve EPA's understanding of the health and environmental risks
posed by air toxics in urban areas. The Strategy includes a list of 33
air toxics that pose the greatest potential health threat in urban areas,
and also provides a list of area sources responsible for a substantial
portion of the emissions of these air toxics. For more information
about the Strategy, visit EPA's web site at:
www.epa.gov/ttn/uatw/l 12k/urbanpg.html or call EPA's Office of Air
Quality, Planning and Standards at 919-541-4487.
Amendment And Changes to The Operating Permit
Program Final Rule
In 1992, EPA issued regulations providing for the establishment
of comprehensive state air quality permitting systems consistent with
the requirements of Title V of the Clean Air Act. The Rule allows
States to issue a general permit covering numerous similar small
sources, each of which need only submit information covering its
eligibility. The Rule was revised and expanded in 1994, including the
provision of more flexibility in the revision of permits, with more
flexibility provided in 1995. Amendments were published on June 3,
1996, providing non-major source emission exemptions. See 7/1/96
Code of Federal Regulations (CFR), Part 70. On February 14, and
May 22, 2000, the Agency extended state operating permit programs
interim approvals. For detailed history, see our Item 1-25.
A Guide for Small Businesses
A booklet entitled The Clean Air Act Amendments of 1990: A
Guidefor Small Businesses was published in 1992, Item 1-36. This
guide provides small businesses a broad overview of the Act's
complex requirements and the effects they are likely to have, in
general, on a small business. The guide provides contacts for
EPA SMALL BUSINESS OMBUDSMAN
JULY 2000
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obtaining additional information. Accompanying the booklet is a
four-page summary entitled What A Small Business Should Know
About the New Clean Air Act
Court of Appeals for the District of Columbia
Decision on New National Ambient Air Quality
Standards Revisions for Particulate Matter and
Ozone
American Trucking Associations, Inc. v. USEPA,
Nos. 97-1440 and 97-1441
(D.C. Cir. May 14, 1999
Summary of Decision
In July 1997, EPA issued health-based air quality standards for
ozone and particulate matter. In response to challenges filed
by industry and others, a 3-judge panel of the Court of
Appeals for the District of Columbia Circuit issued a split
opinion on May 14, 1999.
The Court held (2 to 1) that the Act, as applied and absent
further clarification, is unconstitutional because it "effects an
unconstitutional delegation of legislative power."
Contrary to the claims made by petitioners and other critics,
nothing in the court's opinion undercuts or criticizes the
science on which EPA relied.
The Court rejected petitioners' claims that EPA should take
cost into account in setting the air quality standards.
Contrary to the claims made by petitioners, nothing in the
Court's opinion undercuts or criticizes the process EPA used.
The Court held paradoxically that the Clean Air Act allows
EPA to revise the primary ozone standard, but stated that
revised ozone standard "cannot be enforced."
In addressing whether EPA should have considered alleged
benefits of ozone as a shield in blocking UVb radiation, the
Court held that EPA must consider whether ozone has a
beneficial effect, and if so, consider such effects in assessing
ozone's net effects on health.
The Court found "ample support" for EPA's decision to
regulate coarse particulate pollution below the 1987 levels, but
also found that PM10 was "a poorly matched indicator for
coarse particulate pollution" because PM10 includes fine
particles.
The Court rejected petitioners' claim that EPA should have
considered any detrimental health effects relating to
unemployment that allegedly would be caused by the NAAQS.
The Court upheld EPA's decision to rely on the regional haze
program to mitigate some of the adverse visibility effects
caused by PM2.5.
The opinion remanded the cases to EPA for further
consideration.
The Court left the new ozone standard in place based on its
determination that it "cannot be enforced."
The Court vacated the revised coarse particle (PM 10)
standards.
The Court prepared a briefing schedule to determine whether
the PM2.5 standards should be vacated or remain in place
while the case is remanded to the agency.
Update on Ozone and Particulate Matter Air
Quality Standards and Recent Court Decisions
On May 14, 1999, the U.S. Court of Appeals for the District
of Columbia Circuit issued an opinion regarding the final
national ambient air quality standards for ozone and
particulate matter that EPA issued in July 1997.
On June 28, 1999, the Federal government filed a petition for
rehearing key aspects of the case in the U.S. Court of Appeals
for the D.C. Circuit.
The court responded to EPA's petition on October 29, 1999.
Rehearing was denied, because the Court's rules require a
majority vote of the active judges, rather than of the voting
judges. Two judges did not participate for unspecified reasons.
On January 28, 2000, the Department of Justice filed a petition
seeking Supreme Court review of the decision
On May 22, 2000, the Supreme Court announced it will hear the
appeal this Fall.
We will continue to keep you up to date on any new
development.
CAA Medical Waste Incinerator Rule
This final rule applies to incinerators that are used to bum
hospital waste and/or medical/infectious waste (MIW). The rule
encompasses incineration at hospitals, other health care type facilities,
and commercial waste disposal incinerators that burn these wastes.
For both new and existing sources, the regulation provides incinerator
operators with a number of compliance options, i.e., pollution control
technologies to meet the new air emission standards depending on the
size of the MIW. We have worked closely with small community
hospitals to provide them with the most affordable way to meet the
new requirements. Rural incineration facilities are required to meet
less stringent emission limits, but must still make changes. See
OSBO, Item 1-46.
In addition, we have added a recent direct final rule on waste
combustors constructed on or before September 20, 1994, clarifying
units affected by Federal Plans.
National Emission Standards for Hazardous Air
Pollutants (NESHAP) Rules Available for Some
Industries
In 1994, a General Provisions Rule was issued to establish a consistent
set of requirements for NESHAPs under the air toxics provisions of
the Clean Air Act, Item 1-20. Since then, EPA has finalized rules
which affect many small businesses, including various types of
"Halogenated Solvent Cleaning Processes, Item 1-21; (See new
revised Direct Final Rule w/Amendments), *Chromium Electroplating
and Anodizing Operationsrevision of compliance deadlines for
California: Federal Register (FR) 1/30/97 and area source deferrals
FR 8/18/99, Item 1-22; *Ethylene Oxide Emissions from Commercial
Sterilization and Fumigation Operations, Item 1-23 (IMPORTANT
NOTE: Certain portions of the Rule have been SUSPENDED until
December 6, 2000, and December 6, 2001); *Dry Cleaners-rule
amended relative to certain transfer machines, Item 1-27; Aerospace
Manufacturing and Reworkamendments and control techniques
guidelines finalized 9/1/98, Proposed amendments, 1/24/00 FR 3642-
48, Item 40; Wood Furniture Manufacturing and control techniques ,
Item 1-41; Printing and Publishing, Item 1-42 which includes proposed
amendments; and Hospital/ Medical/ Infectious Waste Incinerators,
Item 1-46. Rules have also been finalized for Consumer
Products-9/11/98, Item 1-43; Automotive Refinish Coatings-9/11/98,
Item 1-44; and Architectural Coatings-9/11/98, Item I- 45. All these
rules include a schedule for various product regulation.
The NESHAP for Hazardous Organic Compounds (HON) in
production operations, primarily in Synthetic Organic Chemical
Manufacturing, was issued in 1994. Amendments and/or revisions
have been issued in the Federal Registers, and since then in almost
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every year. Several of the amendments exclude some volatile
organic compounds and ease implementation plan requirements.
Equipment leaks have also been addressed. Item 1-24.
IMPORTANT NOTE:
*Discretionary deferment of Title V Operating Permit requirements
for area sources has been extended to 12/09/04 for: Halogenated
Solvent Cleaning, Chromium Electroplating and Anodizing,
Ethylene Oxide Sterilization and Fumigation, Dry Cleaning, and
Secondary Lead Smelting. Final rule was published in 12/12/99
FR, pp. 69637-643.
CAA List of Source Categories and Schedule for
Regulating Hazardous Air Pollutants
On November 18, 1999, EPA published a new revision to the
Initial List of Categories of Sources, as required under Section 112
(c)(l) of the Clean Air Act of 1990; and a revised schedule for the
Promulgation of Emission Standards for the above categories. Item
1-28.
State Motor Vehicle Inspection Maintenance
Programs Provided More Flexibility
In 1992, EPA published a Final Rulemaking the subject
programs tougher, including a requirement for "test only"
stations. Our Office raised strong objections to that rule, because of
the adverse impact on many small businesses. In 1995, EPA
published a Final Rule allowing the states flexibility in designing
their enhanced auto inspection programs. This rule was amended
on 9/23/96 and 1/9/98 and a new proposal issued on 8/20/99 will
soon be finalized. Item 1-29.
Perchloroethylene (PCE) Health Effect Studies
EPA's National Center for Environmental Assessment in The
Office of Research and Development (ORD) has started a health
assessment to update the Agency's data base on possible health
hazards associated with chronic exposure to perchloroethylene. The
assessment will characterize hazard and dose-response for cancer
and general noncancer toxicity; in addition to conclusions about
cancer hazards, if any, a reference concentration (RfC) for
inhalation exposure and a reference dose (RfD) for ingestion
exposure will be recommended. The assessment began in the
Spring of 1999, and completion is expected in calendar year 2001.
The Agency's plan is to develop the assessment, with a full peer and
public review process, and then provide a data file for insertion into
the EPA Integrated Risk Information System (IRIS) which records
the Agency-wide viewpoint on health assessment issues.
Stratospheric Ozone Protection CFC Phaseout
Rules
An accelerated phase-out of the production of
Chlorofluorocarbons (CFC), Halons, Carbon Tetrachloride, Methyl
Chloroform, and Hydrochlorofluorocarbons (HCFC) was mandated
and internationally endorsed in 1992 with reconsideration of
petition criteria and incorporation of Montreal Protocol Decisions:
Final rule, 6/1/998 FR 29240-245. Item 1-5. A final rule detailing
the above phase-out, with Methyl Bromide added, was issued, Item
1-15. Final rules also have been issued which control recovery and
recycling of all refrigerants during the servicing of on-road motor
vehicle air conditioners, Item 1-14; emissions reduction, and use of
certified personnel during servicing and disposal of all other air
conditioning and refrigeration equipment which use ozone depleting
substances,. Item I- 16. Rules were also issued banning the use of
CFCs and HCFCs in non-essential products, 2000 essential-use
allowances, 1/6/00 FR 716-28, Item 1-17, Labeling of products
containing ozone depleting substances and their packaging, Item 1-18,
and significant new alternative refrigerants, last update 4/26/00 FR
24387-392xItem-J9.
CAA Field Citation Program And Monetary Award
Final Rules
The proposed Field Citations Rule allowing EPA field inspectors
to levy immediate, on-the-spot fines is on hold. EPA issued a
proposed Monetary Awards Rule outlining eligibility criteria and
general program implementation for making awards to citizens upon
the conclusion of civil or criminal cases. EPA is presently making
awards under its existing statutory authority. A final rule outlining
additional eligibility criteria is also on hold. No date has been set for
issuance of either final rule. See Item 1-12 for both.
Accidental Release Prevention Requirements: Risk
Management Programs Under Clean Air Act Section
EPA has taken direct final action to amend the Chemical
Accident Prevention Provisions, also known as the Risk Management
Program (RMP) regulations, codified in 40 CFR part 68.
This action is set forth in the Federal Register (5/26/99 FR
28695-7041).
The revisions concern the worst-case release scenario analysis for
regulated flammable substances in 40 CFR 68.25. EPA is issuing
these revisions so that the regulated community can treat regulated
flammable substances in the same manner as regulated toxic
substances for determining the quantity released when conducting a
worst-case release scenario analysis. EPA is taking this direct final
action pursuant to a settlement agreement with the American
Petroleum Institute (API).
EPA clarified its interpretation of Clean Air Act sections 1 12(1)
and 1 12(r)(l 1), as they relate to Department of Transportation (DOT)
requirements under the Federal Hazardous Materials Transportation
Law under a settlement agreement with the Chlorine Institute (CI),
(5/26/99 FR p. 28705). Item 1-30.
Chemical Safety Information, Site Security
and Fuels Regulatory Act
The Chemical Safety Information, Site Security and Fuels
Regulatory Relief Act (August 5, 1999) establishes new provisions for
reporting and disseminating information under Section 1 12(r) of the
Clean Air Act. The law has two distinct parts that pertain to:
Flammable fuels; and
Public Access to OCA (also known as: "worst-case scenarion")
data.
Flammable Fuels
Flammable fuels used as fuel or held for sale as fuel at a retain
facility are removed from coverage by the RMP program. However,
flammable fuels used as a feedstock or held for sale as fuel at a
wholesale facility are still covered. A retain facility is a facility "at
which more than one-half of the income is obtained from direct sales
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to end users or at which more than one half of the fuel sold, by
volume, is sold through a cylinder exchange program.
EPA published the Final Rule on the Flammable Fuels on
March 13, 2000.
Public Access to OCA Data
The law exempts OCA data from disclosure under the Freedom
of Information Act (FOIA) and limits its public availability for at
least one year. By August 5, 2000, the federal government is to (1)
assess the risks of Internet posting of OCA data and the benefits of
public access to that data, and (2) based on that assessment, EPA
did publish proposed regulations governing public access to OCA
data in the Federal Register on April 22, 2000. A final Rule is now
in process These items are also in Item 1-30.
Guidance from EPA on Potential to Emit (PTE)
In 1995 and 1996, in part to response to several court
decisions, EPA issued transitional guidance relative to the definition
of PTE under the Clean Air Act. PTE is important because of a
source's PTE determines its need for a State Operating Permit under
Title V. This Office has advocated that concerns of small
businesses regarding clarity, realistic definitional parameters, and
alternatives be considered. EPA issued a second extension of the
1995 "transition" policy on 7/10/98, good until 12/31/99. In 1966
EPA issued a clarification of methods for calculating PTEs in Batch
Chemical Manufacturing. Guidance to assist States in creating
minor source status for low-emitting sources in 8 industries
(gasoline service stations, gasoline bulk plants, boilers, cotton gins,
coating sources, printing, degreasers using volatile organic solvents,
hot mix asphalt plants) was issued on April 19, 1998. Guidance
regarding the PTE of some sources located on tribal lands was
issued on March 7, 1999. Finally, a new booklet has been
developed as a Guide to Small Businesses, Item 1-31.
Clean Air Act Compliance Assistance Enforcement
Policy for Small Businesses
In 1994, EPA's Office of Enforcement and Compliance
Assurance issued a policy giving small businesses a limited grace
period. This policy provided them with additional time to correct
violations revealed during requested assistance from a State Small
Business Assistance Program established under Section 507 of the
CAAA, Item 1-13.
New Source Performance Standards and Emission
Guidelines for Several Categories of Industrial
Combustion Sources
The Clean Air Act (CAA) requires regulation of toxic air
pollutant emissions under Sections 112 and 129, from several
categories of industrial combustion sources, including boilers.
process heaters, waste incinerators, stationary combustion turbines.
and stationary internal combustion engines. These combustion
devices are used primarily for energy generation and waste disposal
in a wide variety of industries and commercial and institutional
establishments. They burn a variety of materials, including fossil
fuels (e.g., oil, coal, and natural gas) and various commercial and
industrial wastes. The industrial combustion regulations could
affect thousands of sources nationwide and have significant
environmental, health, and cost impacts. Regulations for
commercial and industrial waste incinerators (solid waste) were
proposed on November 30, 1999. (See below). Regulations for the
other industrial combustion source categories will be proposed after
this date.
Commercial and Industrial Solid Waste Incineration
Units; Proposed Standards and Guidelines (40 CFR
Part 60, Subparts CCCC and DDDD)
The EPA has proposed air pollution emission limits for
incineration units that burn commercial and industrial waste materials
The proposal, which was publishedjn the Federal Register on
November 30, 1999 (vol. 64, no. 229, pages 67091-67127, OSBO
Item 1-46), would require wet scrubbing on most new and existing
units. Additionally, there are proposed requirements for operator
training and qualification, preparation of a waste management plan,
and new unit siting. Nine pollutants are addressed by the proposed
rule, including dioxins/furans, lead, and mercury. The public
comment period ended on January 31, 2000, and promulgation of the
final rule is expected by November 15, 2000.
National Radon Proficiency Program
EPA ceased operations of its National Radon Proficiency
Program on 9/30/98. Contact your State Radon Contact, (Item J-4) to
determine what are the, or whether there are, requirements associated
with providing radon measurement and or radon mitigation/reductions
in your state. Some states have proficiency programs or requirements
of their own, Item J-1.
Clean Water Act (CWA)
Wetlands Helpline
The EPA Wetlands Helpline is operated by SC&A, Inc. under
contract to EPA. The Helpline is a toll-free telephone service and
e-mail service staffed by contractors who respond to requests for
information about wetlands regulations, legislation and policy
pursuant to Section 404 of the Clean Water Act, wetlands values and
functions, and wetlands agricultural issues. The Helpline provides
EPA-approved information and documents about EPA programs, and
the wetlands programs of other Federal, State and non-governmental
organizations. The Helpline information on wetlands protection
efforts and wetlands values includes an extensive contacts list to direcl
callers to regulatory agencies or to other appropriate referrals for
information. You can reach the Helpline by calling 1-800-832-7828
or by sending an email to wetlands.hotline@epa.gov. Wetlands
information is also on the Internet at www.epa.gov/owow/wetlands.
Effluent Guidelines Program
Effluent guidelines are regulations for industrial discharges to
surface waters and to publicly-owned treatment systems. EPA's
Office of Water is working on effluent guidelines for the following
industries: centralized waste treatment, feedlots (swine, poultry, beef,
and dairy cattle), iron and steel, construction and development, metal
products and machinery, oil and gas extraction (focused on synthetic-
based drilling fluids), coal mining, meat products, and aquatic animal
production (often called aquaculture).
For two of the rules under developmentfeedlots and metal
products and machineryEPA convened a Small Business Advocacy
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Review Panel in December of 1999. Both Panels completed their
reviews earlier this year and sent their report, with
recommendations for the upcoming proposed rules, to EPA's
Administrator.
Since the last edition of the newsletter, EPA completed two
effluent guidelines actions. First, EPA proposed effluent guidelines
for coal mining in April. The Administrator certified that the coal
mining proposal would not have a significant impact on a
substantial number of small entities. The comment period for the
Coal Mining proposal will close on July 10, 2000. EPA also
completed the effluent guidelines for Transportation Equipment
Cleaning, when the Administrator signed the final rule in June. The
final rule for Transportation Equipment Cleaning excludes some
low-flow facilities from needing to comply with the national
regulations. That exclusion, along with other changes since
proposal, led to less costly and less burdensome requirements than
had been proposed; EPA projects much lower impacts for small
businesses in this industry.
You can check for updates on all of the effluent guidelines on
the Internet at http://www.epa.gov/OST/guide/.
Confined Animal Feeding Operations (CAFOs):
Revisions to Effluent Guidelines And NPDES
Permit Regulations
EPA is revising the 1974 regulations for Confined Animal
Feeding Operations (CAFOs) as part of its settlement agreement
with the Natural Resources Defense Council. The revisions cover
three areas, which have been combined in a single rulemaking:
ป The effluent limitation guidelines for swine and poultry, which
are the technology-based standards for discharges of pollutants
from feedlots;
ป The effluent limitation guidelines for beef and dairy, which are
the technology-based standards for discharges of pollutants
from feedlots; and
> The NPDES permit program regulations, which define the
universe of facilities that need to apply for a permit and the
permit conditions.
These revisions are needed because of the changes in the
industry over the past 25 years, including: concentration of animals
in fewer, larger operations; vertical integration within the industry;
and changes in the relationship between herd size and available land
(e.g. more manure than can be properly applied to available land).
EPA is considering a number of changes to update the regulations
to reflect current industry characteristics and practices, and to make
the rules simpler and easier to understand. Changes under
consideration include: covering dry poultry operations, permit
requirements to develop Comprehensive Nutrient Management
Plans for the proper application of manure, and increased public
involvement in general permits for CAFOs.
EPA conducted a SBREFA panel for these regulations, and
will factor the findings into its options selection process later this
year. EPA plans to propose all three rules for public comment in
December 2000.
Reissuance of the NPDES Industrial Storm Water
General Permit (Multi-sector General Permit)
The current and (in nearly all instances) only general permit
available to industrial storm water dischargers is the Multi-Sector
General Permit (MSGP). This permit was originally published in the
Federal Register in 1995 and was subsequently modified in 1998. As
with all NPDES permits, the maximum length of time the MSGP is
effective is five years, which occurs in September, 2000. EPA has
revised the original / modified MSGP and published the draft permit
(known as the MSGP-2000) in the Federal Register on March 30,
2000. The comment period closed on May 30. The Agency expects
to reissue the permit by September 30. The draft permit is posted on
the internet at www.epa.gov/ownVsw web site.
All permittees currently coveted by the MSGP will need to
obtain a copy of the MSGP-2000 after it becomes final, to ensure that
any new requirements are met and then submit a new Notice of Intent
(NOI) form to obtain coverage or a Notice of Termination (NOT)
form to indicate coverage is no longer needed. A new "no-exposure"
permitting exemption is also available to all industrial dischargers as
of February 8, 2000. This new exemption, as part of the Phase II storm
water regulations, provides incentives for industrial facilities to protect
their operations from storm water exposure. If this is a viable option
for a facility, the operator would not need an NOI or NOT, just the
submission of the No Exposure Certification form. At least 70,000
industrial facilities will be able to take advantage of this new
permitting exemption by protecting their operations from storm water,
such as covering operations under a storm resistant shelter. Guidance
on the "no exposure" permitting exemption will be available by early
July, 2000.
Revision of Pretreatment Requirements
On July 22, 1999, EPA published a proposed rule to streamline
the General Pretreatment Regulations (40 CFR Part 403) in the
Federal Register [64 FR 39563]. The purpose of the proposed
rulemaking is to reduce the burden to publicly-owned treatment works
(POTWs) and industrial users. The proposed revisions would allow
POTWs : more flexibility in regulating low pH wastes, the option to
establish either mass or concentration based limits, to better tailor
oversight of and sampling by significant industrial users, and to allow
the granting of removal credits for certain pollutants. The proposed
rulemaking also clarifies how management practices and general
permits can best be used, provide for use of electronic reporting, and
address other important program issues. EPA worked with
stakeholders (State approval authorities, trade associations, industrial
users, environmental organizations and individual POTWs) prior to
drafting the proposal by asking for their review and comment on brief
discussions of the issues. The public comment period on the proposed
rulemaking closed on November 19, 1999. EPA received 216
comments from a variety of interested stakeholders. EPA is currently
reviewing and preparing a response to comments for inclusion in the
preamble to the final rulemaking. EPA anticipates promulgation of a
final rule in early 2001.
Establishment of Electronic Reporting for NPDES
Permittees
USEPA expects to propose a rule to allow NPDES reports and
other information to be submitted electronically. The proposed rule
would establish criteria for electronic reporting and a specific process
and conditions for electronic reporting of discharge monitoring
reports. The proposal addresses electronic signature, certification, and
record keeping requirements that permittees would follow when
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submitting forms to USEPA electronically. The proposal is
planned for winter 2000.
Safe Drinking Water Act (SDWA)
The Safe Drinking Water Act (SDWA) has several provisions
that will benefit small water systems. EPA is seeking input from
small water systems and other stakeholders as it develops the
regulations, guidances, and assistance documents needed to help
states and water suppliers implement these provisions. EPA has
formed several working groups through the National Drinking
Water Advisory Council (NDWAC) that will provide input and
recommendations on EPA activities in SDWA implementation.
Each of these working groups has representatives of small water
systems. All of these meetings are open to the public, and small
businesses are invited to participate. Meeting information can be
found on the Office of Ground Water and Drinking Water's Internet
Website at www.epa.eov/OGWDW/in the calendar section
Drinking Water State Revolving Fund
The reauthorized SDWA of 1996 included the establishment of
a Drinking Water State Revolving Loan Fund (DWSRF). States
receive capitalization grants which they use to fund eligible water
system drinking water infrastructure projects needed to address
problems in public health and improvements needed to comply with
drinking water standards. Under the DWSRF, States are required to
provide a minimum of 15% of available funds to small systems
serving fewer than 10,000 persons. Also, under the DWSRF set-
aside programs, States are allowed to take up to 2% of their
DWSRF allotment to provide technical assistance to small systems.
Through other set-aside categories, States can also provide technical
assistance to water systems in the areas of capacity development,
operator training, and source water protection. To date, 800 loans
for $1.6 billion have been made to water systems for eligible
projects. Of these 800 loans, 75% went to small water systems.
Drinking Water State Revolving Fund information is on the internet
at www.epa.gov/ogwdw/dwsrf.hrml.
Small System Capacity Development
The SDWA Amendments create a focus on enhancing and
ensuring the technical, financial, and managerial capacity of water
systems to comply with National Primary Drinking Water
Regulations (NPDWRs). The Amendments provide states with a
number of new or improved tools for helping small systems,
especially systems which cannot afford to comply with NPDWRs
through conventional approaches.
In August 1998, EPA released guidance documents to assist
states with ensuring new water system capacity and to develop a
capacity development strategy for systems already in existence. A
subgroup of NDWAC provided formal input to EPA as it developed
these guidances. Recently, the subgroup also finished producing
two documents concerning small systems to assist them in their
deliberations: Small System Regulatory Requirements Under the
Safe Drinking Water Act as Amended in 1996 and National
Characteristics of Drinking Water Systems Serving Populations
Under 10,000. Copies of all these documents can be requested
through the Safe Drinking Water Hotline on 1-800-426-4791.
Over the past year, states submitted to EPA programs to ensure
that any new system commencing operation after October 1, 1999
will demonstrate technical, managerial, and financial capacity. Every
state met the September 30, 1999 deadline for the new systems
capacity development program. States are now developing and
enhancing strategy programs to help existing water systems achieve
and maintain capacity. States must be developing and implementing
their existing systems strategies by October 1, 2000 or else lose a
portion of their DWSRF funds.
Capacity Development for Tribal Systems
EPA has begun development of several resource documents to
assist those working with Tribal water systems. These documents will
focus on the development of technical, managerial, and financial
capacity of systems serving Tribal lands, which often face unique
situations and challenges. The documents include a Tribal capacity
development resource handbook, a brochure of existing EPA efforts to
ensure drinking water for Tribes, a preventative maintenance tool for
Tribal systems, and a brochure on building water system capacity for
Tribal Administrators. EPA will finalize these products during the
coming year.
Other Technical Assistance for Small Water Systems
EPA supports a network of nine Small Water System Technology
Assistance Centers that provide technical assistance to small water
systems in several areas. These include the evaluation of treatment
options, education and training programs for operators and managers,
source water protection, and information management. These Centers
are located at the University of Alaska Southeast at Sitka, Western
Kentucky University, the University of Missouri at Columbia,
Montana State University, the University of New Hampshire,
California State University at Sacramento, Charles County
Community College (Maryland), the University of Illinois at
Urbana-Champagne, and Pennsylvania State University.
Source Water Protection
States are currently conducting assessments of the sources of
drinking water for all public water supplies in the United States.
States have until 2003 to complete these assessments. Each
assessment will define source waters to be protected, identify potential
sources of contamination, and determine the relative vulnerability of
the water supply to contamination. The information in these
assessments will help water suppliers and local governments develop
any necessary measures to protect their water supplies.
Consumer Confidence Reports
All 55,000 community drinking water systems were required to
provide their first annual water quality report to their customers by
October 19, 1999. The next report was due to customers by July 1,
2000, and July 1 for each year thereafter. These short reports provide
consumers of public drinking water supplies with information on the
source of their drinking water, levels of any contaminants found in the
water, and potential health effects of any contaminants that exceed
federal or state public health standards, as well as give them
information on how to participate in drinking water protection. EPA
has developed a series of materials to help water systems create these
reports. You can find this information on EPA's website at
www.epa.gov/safewater/ccrl .html.
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Class V Underground Injection Control (UIC)
Control Wells
On December 7, 1999, EPA published its final Class V UIC
rule in the Federal Register (64 FR 68546). Class V injection wells
are typically shallow disposal systems that are used to place a
variety of fluids below the land surface, into or above underground
sources of drinking water. The fluids released by certain types of
these wells have a high potential to contain elevated concentrations
of contaminants that may endanger drinking water.
The Class V rule focuses on two categories of Class V
injection wells, that are known to pose a threat to underground
sources of drinking water: motor vehicle waste disposal wells and
large-capacity cesspools. New large capacity (serving 20 or more
people per day) cesspools are banned nationwide as of April 5,
2000. Existing large capacity cesspools will be closed nationwide
by April 5, 2005. New motor vehicle waste disposal wells are
banned nationwide as of April 5, 2000. Existing motor vehicle
waste disposal wells will be regulated in areas identified by States
as sensitive to protecting existing and future drinking water
supplies. EPA has extended the deadline for States to identify
regulated water areas and fully believes that all States will meet the
deadline. A fact sheet is available on the EPA website at
www.epa.gov/safewater/uic.htmlffclassv.
Upcoming Drinking Water Rules Affecting
Small Water Systems
In the Federal Register on May 10, 2000 (vol. 65, no. 91,
pages 30194-30274), EPA proposed rules to protect consumers of
public drinking water supplies from certain high-risk contaminants.
EPA is required under the Safe Drinking Water Act to promulgate
the Ground Water Rule (GWR) to require disinfection "as
necessary" for drinking water systems using ground water.
Drinking water systems using surface water have been required to
disinfect since 1989. The GWR establishes a multi-barrier strategy
designed to identify high-risk water systems, and will require
corrective action only where contamination or significant
deficiencies have been identified. Thus, only a subset of the ground
water systems will be required to disinfect.
The Long Term Surface Water Treatment Rule will establish
protections against Cryptosporidium and other microbial
contaminants for water systems using surface water sources. In the
Federal Register on April 10, 2000 (vol. 65, no. 69, pages 19046-
19150) EPA proposed this rule. Finally, EPA proposed (in the
Federal Register on June 22, 2000, vol. 65, no. 121, pages 38888-
38890) the Arsenic rule, to tighten standards against arsenic in
drinking water. A March 1999 National Academy of Sciences
report concluded that the current drinking water standard of 50 ppm
be lowered as soon as possible based on the risks of lung, bladder
and other internal cancers. Further information on these rules can
be found at www.epa.gov/safewater/standards.html. or by calling
the Safe Drinking Water Hotline at 1-800-426-4791.
Pesticide-Federal Insecticide,
Fungicide & Rodenticide Act (FIFRA)
Agricultural Pesticide Worker Protection Standards
(WPS) Update
The Code of Federal Regulations, 40 CFR, Parts 156 and 170 are
set to protect pesticide workers. These rules and regulations have been
revised as late as 6/26/96. A Proposed Rule Change covering glove
requirements was published in September, 1997. A Final Rule
amendment is anticipated in mid 2000.
EPA has available many items"to assist in compliance with the
Worker Protection Standards, including bilingual training manuals for
pesticide applicators, videos and leaflets for pesticide handlers, a
pesticide safety poster for workers, a slide presentation covering the
"Standard," a heat stress guide, and other items. A copy of the
publication "Worker Protection Standard: Materials Developed by
EPA, States, and Other Organizations, " which describes Worker
Protection Standard materials and how to obtain them, may be
obtained from the EPA Certification and Worker Protection Branch
(http://www.epa.gov/pesticides/safety), (7506-C) U.S. Environmental
Protection Agency, Ariel Rios Building, 1200 Pennsylvania Avenue,
N.W.,Washington, DC . 20460, or by calling 1-703-305-7666. These
WPS materials addressing pesticide safety and training may also be
obtained through EPA Regional Offices
(http://www.epa.gov/epahome/locate2.htm), States Agencies
(http://ace.ace.orst.edu/info/nptn/-statel.htm) the Cooperative
Extension Service (http://www.reeusda.gov/), the Government
Printing Office, and private agricultural supply businesses.
The EPA Office of Pesticide Programs recently began a
comprehensive review of the WPS rule and its implementation. The
first in a series of work shop meetings was held in Autsin, TX in June
2000. The WPS stakeholders are welcome to participate in the
assessments. For further information and to be notified of future
meetings, contact the Certification and Worker Protection Branch
referenced above.
Restricted Use Criteria for Pesticides
In Ground Water Policy Statement
The agency plans to publish a policy statement in the Federal
Register by the Fall of 2000, which will establish criteria for
determining whether a pesticide should be considered for restricted
use due to its potential to reach ground water. Pesticide products
classified for restricted use may be purchased and used only by
certified pesticide applicators or individuals under their supervision.
This policy does not directly change the classification of any pesticide
products. EPA will propose restricted use classification for specific
pesticide products only after further evaluation of products which
meet the criteria.
This policy will lay some of the ground work for the Ground
Water Pesticide Management Plan Rule and will be published prior to
promulgation of the rule.
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Ground Water and Pesticide Management Plan
This regulation would establish Pesticide Management Plans
(PMPs) as a new regulatory requirement. When issued, the rule
will prohibit use of certain pesticides unless they are managed in
accordance with an EPA approved State or tribal plan. The rule
would also specify procedures and deadlines for development,
approval and modification of plans by States and tribal authorities.
The Policy Statement on Restricted Use Criteria for Pesticides
in Ground Water (noted in our "Update elsewhere) will lay some of
the ground work for this regulation.
Final action on this rule is anticipated in the Fall of this year.
Hazardous Waste Management Resource
Conservation & Recovery Act (RCRA)
Revised Standards for Hazardous Waste
Combustion Facilities
Under the Clean Air Act (CAA) Amendment of 1990, EPA is
required to establish National Emission Standards for Hazardous
Air Pollutants (NESHAPs) for most hazardous waste combustors
(HWCs) (i.e., incinerators, cement kilns, boilers, and some types of
smelting furnaces). In addition, under the Resource Conservation
and Recovery Act (RCRA), EPA is required to establish standards
for all HWCs as necessary to ensure protection of human health and
the environment.
Consequently, the Agency established new emissions
standards for HWCs, for cement kilns, Light Weight Aggregate
Kilns (LWAKs), and incinerators under joint CAA and RCRA
authority.
Final action on cement kilns, LWAKs, and incinerators (Phase
I) has been completed (Sept. 30, 1999 FR p 52828) and included in
Item C-92.
The Agency is in the process of developing a proposal to
address boilers and other industrial furnaces that burn hazardous
waste.
Mercury-containing And Rechargeable
Battery Management Act: Codification of
Waste Management Provisions
The purpose of this would be to codify into the Code of
Federal Regulations certain provisions of the Mercury-Containing
and Rechargeable Battery Management Act the impact the May 11,
1995 Universal Waste Rule (40 CFR Part 273). The Act was signed
by the President on May 13, 1996.
Action on this specific rulemakmg has now been suspended,
but will be revisited once resources are available.
RCRA Reporting And Recordkeeping Burden
Reduction
To meet the goals of the Paperwork Reduction Act of 1995,
the Office of Solid Waste (OSW) plans to reduce its Subtitle C
reporting and recordkeeping burden on the regulated community,
states, and the public. On June 18, 1999, OSW published for
review and comment a Notice of Data Availability (NODA) with
EPA's burden reduction ideas, and their associated burden
reduction estimates. This notice may be found at the web site
www.epa.gov/epaoswer/hazwaste/data/burdendreduction. After
reviewing the comments OSW received on the NODA, OSW will
publish a proposed rule to implement as many of these ideas as
warranted.
The EPA Office of Solid Waste (OSW) is committed to reducing
its paperwork burden by 40%, the goal established by the Paperwork
Reduction Act, and has already reduced its paperwork burden
substantially (by 1.6 million hours or 18%) through such reductions a;
eliminating regulatory requirements for the Land Disposal Restriction:
Program and ending the requirement for states to prepare Capacity
Assurance Plans.
There are ongoing burden reduction efforts in OSW, such as
streamlining the Hazardous Waste Manifest, development of a
standardized permitting system, and a major overhaul of the Biennial
Report and the Hazardous Waste Notification system.
The Office of Solid Waste has undertaken the Burden Reduction
Initiative, a major project that will further reduce paperwork burden.
Some of the ideas the initiative is working on are:
(1) OSW requires 334 notices and reports from facilities to show
compliance with its regulations. Approximately 100 of these notices
and reports that may be streamlined or eliminated;
(2) Changing regulations to specifically allow facilities to
electronically report and record all documents required is being
considered;
(3) Streamlining facility self-inspection requirements; and
(4) Reducing requirements of the Land Disposal Restrictions
Program, which regulates the disposal of hazardous wastes.
Now it is planned to issue a proposed rule by December 2000.
Solvent-contaminated Shop Towels And Wipes
EPA's Office of Solid Waste is considering a rulemaking that
would change the regulations affecting solvent-contaminated shop
towels, wipes, and rags. Currently, a disposable wipe or rag may be
regulated as a hazardous waste if that wipe or rag comes in contact
with a solvent that, when spent, is a listed hazardous waste or exhibits
a characteristic of hazardous waste.
Regulatory requirements for hazardous waste found in 40 CFR
261-265, 268 and 270 apply to these wastes. Reusable towels are
provided a conditional exemption from regulation as hazardous waste
under most state programs. As a condition of the exemption,
however, the towels may not contain any free liquids when they are
sent offsite to a laundering facility. Otherwise, there are few
regulations applicable to reusable shop towels.
Current rulemaking effort is directed to both clarifying and
streamlining requirements for disposable and reusable solvent-
contaminated shop towels, wipes and rags, such as record-keeping and
reporting, manifesting, etc., so long as specified conditions are met;
i.e., "no free liquids," and transported off-site in closed containers.
Standardized Permit For RCRA Hazardous Waste
Management Facilities
This rulemaking will allow a type of general permit, called a
standardized permit, for facilities that generate waste on-site in tanks,
containers, and containment buildings. Under the standardized permit,
facility owners and operators would certify compliance with generic
design and operating conditions set on a national basis. The
permitting agency would review the certifications submitted by the
facility owners or operators. The permitting agency would also be
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able to impose additional site specific terms and conditions for
corrective action or other purposes, as called for by RCRA.
Ensuring compliance with the standardized permit's terms and
conditions would occur during inspection of the facility after the
permit has been issued.
A Notice of Proposed Rulemaking (NPMR) is anticipated for
the Fall of this year (2000).
Hazardous Waste Recycling Regulations
EPA has promulgated streamlined, hazardous waste
management regulations governing the collection and transportation
of certain wastes which are frequently recycled, such as batteries,
recalled pesticides, and mercury thermostats, termed "Universal
Wastes " This Final rule (5/11/95 FR pp. 25491-551) and
Amendment (12/24/98 FR pp 71225-30) are included in the Item C-
51.
Modifications to the Definitions of Solid Waste and
Regulations of Hazardous Waste Recycling
Recycling of hazardous waste is governed by the resource
Conservation and Recovery Act (RCRA) hazardous waste
regulations. The portion of these regulations known as the
Definition of Solid Waste specifies whether hazardous materials
that are recycled are subject to RCRA regulatory jurisdiction or not.
Other parts of the regulations set forth requirements for managing
recycled hazardous waste. Previously, the Agency was developing
a broad revision to the recycling regulations. However, the Agency
has since determined that narrower sector-specific and waste-
specific changes are more appropriate. Thus, this general action has
been withdrawn. The sector-specific and waste-specific changes are
described elsewhere in this Update.
Glass-to-glass Recycling of Cathode Ray Tubes
(CRTs): Changes to Hazardous Waste Regulations
This rulemaking is part of the Reinventing Government effort.
It will revise text in the CFR to reduce burden or duplication, or
streamline requirements.
This action will revise the existing Federal hazardous waste
regulations to remove unnecessary regulatory barriers to glass-to-
glass recycling of cathode ray tubes (CRTs). A CRT is the main
component of a television or computer monitor. A CRT is made
largely of specialized glasses, some of which contain lead to protect
the user from X-rays inside the CRT. Due to the lead, when they
are disposed of or reclaimed, some CRTs are hazardous wastes
under the Federal Resource Conservation and Recovery Act
(RCRA) regulations. Glass-to-glass recycling involves the return of
used CRT glass to manufacturing of new CRTs.
This action is planned in response to a June 9, 1998
recommendation on CRT recycling from the Common Sense
Initiative (CSI) Council to The Environmental Protection Agency
(EPA). CSI is a consensus-based process for developing cleaner,
cheaper, smarter environmental improvements. The Council
includes representatives of industry; environmental groups;
community groups; environmental justice groups; labor; and,
Federal, State, local, and tribal governments. The recommendation
involves minimizing RCRA requirements for glass-to-glass
recycling while retaining appropriate controls to ensure protection of
human health and the environment. The goal of the recommendation
is to facilitate an increase in glass-to-glass recycling, thereby
minimizing disposal of lead, increasing resource recovery, and
enhancing protection of human health and the environment.
A Notice of Proposed RuleMaking (NPRM) is anticipated to be
published in October 2000.
Hazardous Waste Management: Spent Lamps
Rulemaking Status
EPA has published a final rule for the management of spent
hazardous waste lamps. The final rule was published on July 6, 1999
(64 FRpp. 36541), and a copy is included in ItemC-51. This rule
adds spent hazardous waste lamps to the RCRA Universal Waste
Program, which contains streamlined requirements for record keeping,
storage, and transportation on the part of generators, collectors, and
transporters. Final disposal or recycling remains subject to applicable
RCRA Subtitle C regulations.
Identification And Listing of Hazardous Waste;
Inorganic Chemical Industry Wastes; And
Designation And Reportable Quantities
EPA, under an Environmental Defense Fund settlement
agreement, will amend, if necessary, the regulations for hazardous
waste management under the Resource Conservation and Recovery
Act (RCRA) to reduce hazards to human health and the environment
for inorganic chemical industry wastes. The wastes covered under this
listing determination include: sodium dichromate production wastes,
wastes from the dry process for manufacturing phosphoric acid,
phosphorus trichloride production wastes, phosphorus pentasulfide
production wastes, wastes from the production of sodium phosphate
from wet process phosphoric acid, sodium chlorate production wastes,
antimony oxide production wastes, cadmium pigments production
wastes, barium carbonate production wastes, potassium dichromate
production wastes, phenyl mercuric acetate production wastes, boric
acid production wastes, inorganic hydrogen cyanide production
wastes, and titanium dioxide production wastes (except for chloride
process waste solids). This action is proposed under the authority of
section 3001(e)(2) of RCRA which directs EPA to make a hazardous
waste listing determination for inorganic chemical wastes. After an
extensive study of the waste streams of the above chemical industry
processes, including characterization of the wastes generated and a
risk assessment evaluating plausible mismanagement scenarios, EPA
will propose which of the above wastes, if any, should be listed as a
hazardous waste under 40 CFR part 261.
A Notice of Proposed RuleMaking (NPRM) is anticipated for late
this summer.
Reinventing the Land Disposal Restrictions Program
The Land Disposal Restrictions (LDR) program was established
to minimize threats posed by the land disposal of untreated hazardous
wastes. The program has been in place for a number of years and now
regulates all but the most recently listed hazardous wastes. The
Agency is now examining the LDR program, exploring past
accomplishments, current issues, and future possibilities. The goals of
the examination are to make the LDR program more cost-effective,
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clearer, more enforceable, and, more flexible while continuing to be
environmentally protective. The Agency will develop an advance
Notice of Proposed Rulemaking (ANPRM) to present initial
thinking and the results of some activities taken as part of the
ongoing LDR Reinvention Project so that the public will have an
opportunity to comment. The ANPRM was published June 19,
2000 (FR 6/19/00 pp. 37932-56).
Land Disposal Restrictions; Potential Revisions for
Mercury Listed and Characteristic Wastes
The Advanced Notice of Proposed Rulemaking (ANPRM),
published in the Federal Register, May 28, 1999, pages 28949-63,
solicited information and comments on EPA's data on Mercury-
bearing hazardous waste, technical and policy issues regarding
mercury hazardous waste treatment and potential avenues by which
current mercury treatment standards might be revised. Some forms
of mercury wastes are now required to be treated by either
incineration or retorting. Both of these forms of treatment have the;
potential to emit mercury via air emissions. Also, some information
suggests that certain waste types which are required to be retorted
may not be amenable to that form of treatment. There also is a
shrinking demand for mercury, which brings up concerns about
requiring recovery of mercury wastes. The information items
gathered by this ANPRM process are to be used to propose revised
treatment standards for some forms of mercury hazardous wastes in
a future rulemaking.
EPA is currently conducting mercury treatability tests with
ORE), University of Cincinnati and DOE to obtain the data needed
in order to revise the current mercury LDR treatment standards.
Until these tests have been completed, a date for publishing a
Notice of Proposed Rulemaking (NPRM) cab not be set. In the
meantime, more information on the NPRM may be obtained from
the RCRA Hotline at 1-800 424-9346 (DC area at 703-412-9810).
The notice is also available from the World Wide Web site address
www.epa.gov/fedrgstr.
Uniform Hazardous Waste Manifest Update
Further Rulemaking actions under consideration which address
management of hazardous wastes include a revision of the Uniform
Hazardous Waste Manifest to reduce the paperwork burden
associated with the manifest, consistent with the current Agency
objectives for burden reduction. Currently, many states collect
manifests, and they may require additional information to be
supplied on the manifest in the optional blocks provided on the
form. This can become burdensome when waste must be
transported to several different states and each state has slightly
different requirements or requires its own form. Also, some states
require paying a fee to obtain their manifest. The Agency seeks to
reduce the burden of the manifest by streamlining the form by
prescribing one universal form, and, where feasible, by utilizing
automated information technologies which facilitate the electronic
completion, signing, transmission, and storage of manifest data. A
notice of proposed rulemaking is scheduled for about September,
2000.
Hazardous Waste Identification Rule (HWIR)
On November 19, 1999, the Environmental Protection Agency
published in the Federal Register a proposal retaining and revising
the mixture and derived-from rules under RCRA's hazardous waste
management program (64 FR 63381). The mixture and derived-
from rules ensure that hazardous wastes that are mixed with other
wastes or treated in some fashion do not escape regulation as long
as they are reasonably likely to continue to pose threats to human
health and the environment. This proposal also includes a discussion
of two regulatory options for concentration-based exemptions, (i.e., a
"generic" exemption and a "landfill-only" exemption). In addition,
this notice discusses the possibility of revising the Land Disposal
Restrictions (LDRs) by replacing technology-based treatment
standards in 40 CFR 268.40 and 268.48 with risk-based treatment
standards.
The original mixture and derived-from rules were promulgated in
1980 but were vacated by the D.C. Circuit Court of Appeals in 1991
based on the court's belief that these rules had been promulgated
without adequate public notice and opportunity for comments The
court recommended that EPA reinstate these rules on an emergency
basis to ensure the continued protec_tion of human health and the
environment. Shortly after these rules were reinstated, Congress
enacted a mandate to revise the mixture and derived-from rules by the
deadline of October 1, 1994. That deadline was not met by the
Agency and thus EPA is subject to the consent decree dated April
1997 (Environmental Technology Council v. Browner, C.A. No. 94-
2119, 94-2346). This consent decree required this recently published
proposal, and final action on revisions to the mixture and derived-
from rules by April 30, 2001.
Information related to this proposal is available in electronic
format on the Internet at:
.
Other information may be obtained by contacting the RCRA Hotline
at (800) 424-9346 or in the Washington, D.C. metropolitan area at
(703)412-9810.
Hazardous Waste Storage and Disposal Regulation
Related to Low Level Mixed Waste
The Environmental Protection Agency (EPA) seeks to amend its
regulations under Subtitle C of the Resource Conservation and
Recovery Act (RCRA) to provide a conditional exemption from
certain requirements for eligible mixed waste. The "Storage,
Treatment, Transportation, and Disposal of Mixed Waste; Proposed
Rule" was published in the Federal Register on November 19, 1999.
Mixed waste is a radioactive RCRA hazardous waste. It is
regulated under two authorities: 1) the Resource Conservation and
Recovery Act (RCRA), as implemented by EPA or authorized states
for the hazardous waste component; and 2) the Atomic Energy Act of
1954, as amended (AEA), for the radiological component as
implemented by either the Department of Energy (DOE), or the
Nuclear Regulatory Commission (NRC) or Agreement States.
The focus of the proposed rule is to provide flexibility under
RCRA Subtitle C to generators of eligible mixed waste. EPA is
proposing a conditional exemption from the definition of hazardous
waste applicable to: low-level mixed waste (LLMW) for storage; and
LLMW, or hazardous waste contaminated by Naturally Occurring
and/or Accelerator-produced Radioactive Material (NARM) for
transportation and disposal. The proposal is expected to reduce dual
regulation for generators in the management and disposal of their
wastes. This flexibility will enable generators of LLMW who are
licensed by the Nuclear Regulatory Commission (NRC) to claim an
exemption for storing and treating these wastes in tanks or containers
(using solidification, neutralization, or other stabilization processes)
without a RCRA permit. The proposal will also provide flexibility for
the manifesting, transportation and disposal of eligible mixed waste.
Waste meeting the proposed conditions will be exempted from certain
RCRA Subtitle C hazardous waste requirements and managed as
radioactive waste in accordance with NRC or Agreement State
regulations.
The Federal Register Notice is available in electronic format on
the Internet at . EPA
requested public comment on the proposal. The comment period
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ended February 17,2000.
Small Quantity Generator Handbook
A handbook has been published, "Understanding the
Hazardous Waste Rules--A Handbook for Small Business1996
Update" [EPA-530-K-95-001], June 1996, which is available in
Item C-10. Also, included with the handbook in Item C-10 is an
Addendum, which provides information on Department of
Transportation regulated waste transport requirements and domestic
sewage requirements for hazardous wastes. In addition, in an
"Appendix A," the Regional and State contacts for the regulated
waste program are "updated," and notations are made on which
states require fees for obtaining copies of the Waste Manifests for
transport of the waste generated. Other appendices in the
Addendum provide sources of information and guidance on waste
minimization and pollution prevention.
Used Oil Management Standards
On May 6, 1998, EPA issued a Direct Final Rule (5/6/98 FR
pp 24963-9) which included eight amendments clarifying various
parts of the used oil management standards and provisions of the
hazardous waste regulations concerning used oil. EPA also issued a
notice of proposed rulemaking on May 6, 1998 (63 FR 25006), in
which the Agency proposed and solicited public comment on the
same eight amendments. EPA received relevant adverse comments
on three of the amendments in this rulemaking: the amendments to
40 CFR 261.5(j) (mixtures of conditionally exempt small quantity
generator waste and used oil) 40 CFR 279.10(1) (applicability of the
used oil management standards to used oil contaminated with
polychlorinated biphenyls (PCBs), and 40 CFR 279.74(b) (record-
keeping requirements for marketers of used oil that meets the used
oil fuel specification). Accordingly, on July 14, 1998 (7/14/1998
FR pp 37780-3), the Agency withdrew these three amendments and
reinstated the regulatory text that existed prior to the May 6,1998
Direct Final Rule. These Federal Register Notices are included in
the OSBO Item C-36. EPA will promulgate a final rule in the near
future (pending review and approval by EPA's office of general
counsel) finalizing the three amendments, as appropriate, and
addressing the comments received. The five amendments that did
not receive relevant adverse comment became effective on July 6,
1998 as provided in the May 6, 1998 Direct Final Rule.
EPA also received supportive comments on the three
amendments being withdrawn, as well as, the other amendments
issued in the May 6, 1998 Direct Final Rule. All of the comments
received on the May 6, 1998 Direct Final Rule are available on the
Internet: hrtp: //www.epa-
gov/epaoswer/hazwaste/usedoil/index.htm and at the RCRA
Information Center, at 1-703-603-9230. EPA pamphlet 530-SW-
89-039A "How to Setup a Local Program to Recycle Used Oil"
May 1989 is included in OSBO Item C-68.
Above-ground Storage Tanks (Ast)/spill Prevention
Control and Counter-measures Update
The EPA has promulgated the Oil Pollution Prevention rules
under Title 40 CFR Part 112 included in Item C-77 requiring that
facilities prevent oil spills and ensure preparedness in the event of
spills. This rulemaking is commonly known as the Spill Prevention
Control and Countermeasure (SPCC) regulation. The rulemaking
deals with spill prevention. The SPCC program concerns regulation
of non-transportation related facilities with above-ground storage
capacity in excess of 1,320 gallons or 660 gallons in a single tank, or
buried tanks of greater than 42,000 gallons capacity. Proposed Rules
were published (FR 10/22/91, pages 54611-41), and (FR 2/17/93,
pages 8841-4 and pages 8846-8) which are included in Item C-77.
The Clinton Administration is committed to reducing the burden that
EPA regulations place on facilities without jeopardizing the level of
environmental protection. In support of this objective, the EPA has
completed a study of a cross-section of facilities which store oil to
determine the level of risk the various facilities pose to neighboring
populations and the environment. Proposed rule was published (FR
12/2/97, pages 63812-20), which is included in Item C-77.
The rule 40 CFR Part 112, included in Item C-77, also concerns
facility preparedness and development of response plans under the Oil
Pollution Act (the Act of 1990) which requires that EPA issue
regulations to require "Facility Response Plans" (FRP) covering
events which could cause substantial harm to the environment. Also,
included in publication Item C-77 is the National Response Team's
Integrated Contingency Plan Guidance, Notice 6/5/96 FR pp. 28641-
64, with corrections, 6/19/96 FR pp. 31163-4, which provides
additional guidance on emergency plan preparation. An amendment
to the Facility Respone Plan requirements has been published as a
Final Rule (FR 6/30/00 pp. 40775-817) which is also included in Item
C-77.
Superfund Comprehensive Environmental
Response, Compensation & Liability Act
(CERCLA)
CERCLA Lender Liability Guidance
One of the goals of the Final CERCLA Lender Liability Rule,
published in 4/29/92 FR, pp. 18344-85, was to allow lenders to work
with their borrowers without necessarily incurring liability. However,
in February 1994, the U.S. Court of Appeals, in the case Kelly vs.
EPA, struck down this Rule, finding that the EPA lacked authority to
define the scope of liability by regulation. Following the Court action,
guidance was drafted to "translate" the Rule into a policy statement
addressing lender liability and involuntary government acquisitions.
This policy statement was issued December 11, 1995. A Fact Sheet
on effect of Superfund on lenders was published in June 1997. The
Rule and the policy statement are included in Item D-17.
Emergency Planning, and Community
Right-to-know Act (EPCRA)
Supporting the State Local Emergency Planning
Committees (LEPC)
Major requirements of the Act include emergency planning for
designated hazardous substances (Extremely Hazardous Substances, or
"EHS") above threshold reporting quantities; reporting releases of
EHS and hazardous substances above reportable quantities;
submission of Material Safety Data Sheets (MSDS) to planning
groups; and submission of annual reports on March 1, covering
inventories of hazardous substances, which for any time in the
reporting year exceed the stated reporting thresholds. These
requirements are explained in the "Community Right-to- Know and
Small Business" pamphlet, Item K-32. A final rule was published on
5/7/96 FR pp. 20473-90, effective 7/8/96, on changes in the EHS list
and reportable quantities. This Final Rule is included in Item K-30.
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EPA issued Proposed Rule 6/8/98 FR pp. 3269-317 designed
to simplify reporting under Sections 311-312 of the "Emergency
Planning and Community Right-to-Know Act" (EPCRA) This
proposed rule is also included in Item K-30. In this Proposed rule,
EPA has proposed several changes:
Higher reporting thresholds for gasoline and diesel fuel at
retail gasoline stations. Retail gas stations that store gasoline
and diesel fuel entirely underground and are in compliance
with underground storage tank (UST) regulations would be
subject to the following thresholds under section 311-312.
75,000 gallons for all grades of gasoline combined and
100,000 gallons for diesel fuel. EPA estimates that the vast
majority of retail gas stations will have less than these
quantities.
Greater reporting flexibility and elimination of routine
reporting requirements for: rock salt, sand, gravel, and other
materials. Facilities that store or handle rock salt, sand, and
gravel no longer would report these substances under sections
311-312, regardless of how much was onsite.
Clarify reporting of mixtures and change the interpretation of
the existing hazardous chemical exemption for solids under
Section 311.
Solicited comments on the changes as noted above, and also
asked for comment on several issues that would give State and
Local Governments more flexibility to implement the existing
requirements of EPCRA sections 311-312.
Partnership programs for streamlined submission of and joint
access to section 311 and 312 information;
Electronic submittal of information;
Reporting of ONLY changes in information, rather than
submitting a new inventory each year;
Allowing RCRA UST reports to fulfill EPCRA Section 312
requirements.
This notice proposes to rewrite the existing regulations under
Sections 302-312 of EPCRA in a "Plain Language" format, and
incorporates the requirements addressed in the Final rule (5/7/96 FR
pp. 20473-90). Comment is also being sought on the use of the
"Plain English" in this rule.
The texts of the proposed rule are available also in electronic
format at:hftp://www.epa.gov/ceppo/, EPA's Chemical Emergency
Preparedness and Prevention Office Home Page. EPA issued a final
rule February 11, 1999 (Relief for retail gas stations) that eliminated
reporting on gasoline and diesel fuel stored entirely underground in
tanks, fully in compliance with Underground Storage Tank (UST)
Regulations at retail gas stations with thresholds of:
75,000 gallons for all grades of gasoline combined and
100,000 gallons for diesel fuel.
Convenience stores and truck stops that sell gasoline or diesel
fuel to the public also meet the definition of retail gas stations.
Retail gas stations that meet these criteria were not required to
file Tier I or Tier II reports for calendar year 1998. This final rule
is included in Item K-30.
The other items in the proposed rule of June 8, 1988 will most
likely not be finalized until 2001.
Toxics Release Inventory (TRI) (Update)
The EPCRA Section 313 program is also referred to as the
Toxics Release Inventory or TRI. Under Section 313, facilities are
required to report releases and other waste management of
specifically listed chemicals. They also are required to support
transfers of toxic chemicals for waste management to off-site
locations. Facilities that meet all three of the following criteria are
subject to EPCRA Section 313 release and other waste management
reporting: (1) have 10 or more full-time employees or the
equivalent; (2) are in a covered SIC Code (including SIC codes 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911, 4931,
4939 (4911, 4931, 4939 limited to facilities that combust coal and/or
oil for the purpose of generating electricity for distribution in
commerce), 4953 (limited to facilities regulated under RCRA Subtitle
C, 42 U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a contract
or fee basis)); and (3) exceed any one threshold for manufacturing
(including importing), processing, or otherwise using a toxic chemical
listed in 40 CFR Section 372.65. See also the Final Rule, 5/1/97 FR
pp. 23833-92, included in K-29.
If a facility meets the employee threshold and is in a covered SIC
code, but its annual reportable amount of the toxic chemical does not
exceed 500 pounds and the facility has not manufactured, processed,
or otherwise used more than one million pounds of the toxic chemical,
the facility may submit the Form A (a two-page certification
statement) instead of the Form R. However, if the facility exceeds
either the 500 or one million pound limits, it must report on the Form
R.
Facility Expansion - On May 1, 1997, EPA published a final
rule (5/1/97 FR pp. 23833-92) to add certain industry sectors to the
current list of facilities required to report to TRI. These new
industries will begin reporting their releases and other waste
management information for activities conducted in 1998 with reports
due by July 1, 1999. This final rule adds the following seven industry
groups to TRI: metal mining, coal mining, electric utilities,
commercial hazardous waste treatment, chemicals and allied products
(wholesale), petroleum bulk terminals and plants, and solvent
recovery services. This rule is included in K-29.
Persistent Bioaccumulative Toxic Chemicals (PBTs) - On
October 29, 1999 (64 FR 58666) EPA published a final rule which
lowers the EPCRA section 313 reporting thresholds for persistent
bioaccumulative toxic (PBT) chemicals and adds certain other PBT
chemicals to the EPCRA section 313 list of toxic chemicals. The rule
also includes modifications to certain reporting exemptions and
requirements for the chemicals newly subject to the lower reporting
thresholds. These PBT chemicals are of particular concern not only
because they are toxic but also because they remain in the
environment for long periods of time, are not readily destroyed, and
build up or accumulate in body tissue. The new rule is effective
January 1, 2000. Therefore, the new requirements apply for TRI
reports on releases and waste management for the year 2000 which
must be submitted to the Agency by July 1, 2001. The list of PBT
chemicals affected by the new rule include: Aldrin;
Benzo(g,h,i)perylene*; Chlordane; Dioxin and dioxin-like compounds
category*; Heptachlor; Hexachlorobenzene; Isodrin; Methoxychlor;
Octachlorostyrene*; Pendimethalin; Pentachlorobenzene*; Polycychc
aromatic compounds category; Polychlorinated biphenyl (PCBs);
Tetrabromobisphenol A*; Toxaphene; Trifluralin; Mercury; and
Mercury compounds (PBT chemicals newly added to the EPCRA
section 313 list of toxic chemicals are indicated by an asterisk). This
rule is also included in K-29.
Lead and Lead Compounds - On August 3, 1999 (64 FR 42222)
EPA published a proposed rule that would lower the reporting
thresholds for lead and lead compounds. EPA believes that lead and
lead compounds are persistent, bioaccumulative toxic (PBT)
chemicals that warrant lower reporting thresholds than those currently
established under EPCRA section 313. The proposal includes a
limitation on the reporting of lead when contained in certain alloys
and proposed modifications to certain reporting exemptions and
requirements for lead and lead compounds. ( Also included in K-29).
Pollution Prevention Act - The Agency plans to issue a proposed
rule in the Summer of 2000 to define terms and clarify reporting
requirements to assure that data reported pursuant to the Pollution
Prevention Act (PPA) are accurate and consistent. Section 8 of the
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TRI Form R currently contains the majority of Pollution Prevention
Act reporting elements which primarily include quantities of toxic
chemicals managed as waste.
Toxics Release Inventory (TRI) Public Data Release
EPA released the 1998 TRI Data in May 2000. TRI summary
information and data access is available via the web at
www.epa.gov/tri/tri98. The TRI98 website provides fast and easy
access to the data overview and relevant TRI information (including
tables, charts, and maps). The TRI data can be accesses through a
new too!, the TRI Explorer, as well as through other tools described
on this page. In July 2000, EPA will be issuing the more detailed
1998 TRI Public Data Release Report and State Fact Sheets which
are usually released with the data. These documents will be
available on the TRI website or calling the EPCRA Hotline in July
2000 (see contact information below) The 1998 TRI Public Data
Release Report, and Data Summary will be include in OSBO Item
K-64 as they become available.
The 1997 Toxics Release Inventory (TRI) Public Data Release
was released in 1999. The titles and publication numbers for the
two documents released in 1999 include: the 1997 Toxics Release
Inventory, EPA 745-R-99-003 and the 1997 Toxics Release
Inventory, Public Data Release, State Fact Sheets, EPA 745-F-99-
001. (Item in K-63).
(Copies of these documents may be obtained by calling the
Emergency Planning and Community Right-to-Know Act (EPCRA)
Hotline at (800) 535-0202 (in the Washington, DC area call
(703)412-9877). Information is also found at the Web site
http://www.epa.gov/tri
Toxic Substance Control Act (TSCA)
Asbestos Worker Protection Rule Amendments;
Proposed
EPA is proposing to amend the Asbestos Abatement Projects,
Worker Protection Rule (WPR), by incorporating certain revisions
that were made to the Occupational Safety and Health
Administration (OSHA) asbestos workplace standards issued since
EPA's WPR was promulgated in 1987 to the extent that OSHA
revisions are consistent with applicable EPA statutes. The proposal
generally extends the coverage provided under the OSHA Asbestos
Standard for Construction to State and local government employees
who are not covered by OSHA or EPA approved State plans. FR
4/27/00 pp. 24806-248-31. Item E-19
Lead; TSCA Section 403; Identification of
Dangerous Levels of Lead
In accordance with Section 403 of TSCA, as amended by the
Residential Lead-Based Paint (LBP) Hazard Reduction Act of 1992,
EPA is to promulgate regulations that identify lead-based paint
hazards, lead-contaminated dust, and lead-contaminated soil. An
interim guidance was published in 60 FR 47276, 9/11/95 which will
continue to serve as EPA's official policy until the final rule is
promulgated. A proposed rule was published in 63 FR 30302,
6/3/98; Part 745, Subpart D, Lead-Based Paint Hazards. Item E-45.
Lead-based Paint (LBP); Fees for Accreditation and
Certification Activities
The Toxic Substances Control Act (TSCA), Section 402(a),
mandates implementing a fee schedule for the accreditation as
certified individuals and firms engage in LBP activities and persons
operating accredited training programs. Certification applies to the
following disciplines: inspector, risk assessor, supervisors, project
designer, abatement worker. 40 CFR Subpart L 745.238, Item E-48
Lead: Management and Disposal of Lead-based Paint
Debris
EPA is proposing a rule under TSCA to provide new standards
for the management and disposal of LBP debris generated by
contractors. EPA also is separately proposing temporary suspension
of the regulations under Subtitle C of the Resource Conservation and
Recovery ACT (RCRA), which currently apply to LBP debris. The
new TSCA standards do not address LBP debris generated by
homeowners in their own homes. The notice of the proposed rules
were published in the FR 12/18/98, pp 70190 and 70233. Subpart P
Item E-47.
General
National Environmental Laboratory Accreditation
Conference (NELAC)
In 1990, after receiving complaints from the laboratory
community regarding the burden of multiple accreditations due to lack
of a nationally recognized environmental laboratory accreditation
program, former Deputy Administrator Hank Habicht established an
internal work group to consider the feasibility and advisability of such
a program. The work group concluded that EPA should consult with
representatives of all stakeholders. As a result, the National
Environmental Laboratory Accreditation Conference (NELAC) was
established by the current administration to redress the following
problems:
1. inspections
2. no reciprocity among states
3. loss of accreditation in one state does not affect status in other
states
4. accreditation not available for all EPA programs
5. clients have no information on lab status
6. accreditation not recognized in foreign markets
7. some labs never accredited
The first annual meeting was held in February 1995. The state
and federal officials agreed on the roles and responsibilities of all
parties, including the establishment of a federal advisory committee to
obtain consensus advice from the private sector.
At the 5th NELAC annual meeting (June 28 - July 1, 1999) a
dozen state programs were recognized by EPA as being fully
compliant with the standards for accrediting authorities. Those states
will begin accepting applications from the laboratories immediately.
It is expected that the first group of laboratories will be accredited by
January 2001. Further information is available on the website at
www.epa.gov/ttn/nelac.
EPA and States to Improve Facility Information
EPA and the States are working to improve the way regulated
facilities are identified in environmental databases. One goal of this
effort is to reduce duplicate reporting of facility identification
information from companies, thereby reducing the reporting burden
on the regulated community.
The first phase of this process was to establish a standard set of
data elements for facility identification. These data elements include
the facility name, address, locational data, business classification and
contact information. The second phase was to make existing facility
identification data available on the Internet through the EPA's
Envirofacts Warehouse (http://www.epa.gov/ enviro/). Using this
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application, a company can search EPA's databases to find all
occurrences of the company and related facility information.
During this phase, EPA is working with States to improve the
accuracy of the facility identification data.
The third phase, which is now underway, is to develop a single
master record with accurate facility identification information for
each facility. Once this is accomplished, EPA will identify where
similar data are collected in separate regulatory information
collections and, where possible, eliminate the duplicated reporting.
For further information, companies are urged to visit the Internet
site identified above.
Sector Facility Indexing Project
Sector Facility Data Put on The Internet
Information gathered under EPA's Sector Facility Indexing
Project (SFIP) on the environmental performance of hundreds of
facilities in five major industries is now available through the
Internet.
The industrial sectors currently covered are automobile
assembly, pulp manufacturing, petroleum refining, iron and steel
production, and the primary smelting and refining of aluminum,
copper, lead and zinc (nonferrous metals).
The new database covers approximately 650 facilities with the
five sectors, and for the first time collects in one place information
the facilities must provide under a number of federal environmental
statutes. The data includes information on past inspections and
enforcement actions, the size of the facilities and their annual
releases of chemicals into the environment, and demographic data
about communities near the facilities.
The database has multiple uses, facilities can benchmark their
data against that of other similar facilities, or simply monitor their
own regulatory performance. The database gives environmental
and community groups easier access to information they can use to
leam about the environmental performance of individual facilities.
Government agencies can use the information as a planning tool.
EPA stakeholders, including environmental and community
organizations, have commented on the project. Each facility
included in the pilot project received a copy of its compliance and
enforcement data and was given an opportunity to submit
comments. State agencies also received the information for review,
since a large portion of the data is provided to EPA by state
governments. EPA modified the data as appropriate, but found
most of the data to be accurate. The agency has developed a
comment process so that all users can continue to provide
feedback..
The database is available at Internet address
http://www.epa.gov/oeca/sfi. Since it has been available, the
website has been used extensively for research and is considered a
valuable tool. In keeping with SFIP's policy to incorporate
information as it becomes available, the data included within the
project have been updated 6 times since the project's release.
The Agency has completed a formal evaluation of SFIP's
initial year of availability. Obtaining feedback from all
stakeholders (government, facilities, trade association,
environmental groups), the evaluation has shown SFIP to be
successfully meeting its goals of providing greater public access to
accurate compliance and facility-level information as well as
improving multimedia facility profiling and sector based analysis.
The evaluation also identified widespread interest for an expansion
of SFIP. This, after taking into consideration the comments
received, the Agency will be expanding SFIP to include a subset of
Federal facilities. The Agency's goal is to complete the expansion
by year's end. The evaluation report is electronically available on
the project's website. We have included more information on the
Sector Facility Indexing Project in the OSBO Item A-12.
Environmental Technology Verification Program
The Environmental Technology Verification Program (ETV) was
started by the U.S. Environmental Protection Agency (EPA) in
October 1995 to address the need for credible environmental
technology performance data to help businesses and communities
better utilize the available environmental technology choices. ETV
verifies the performance of commercial-ready, private sector
technologies. Over 897 stakeholders, serving on 18 different groups,
play a major role in the design and operation of the program. The
goals and operating principles of ETV are described within the ETV
strategy. Information on the ETV program may be accessed at the
ETV web site: www.epa.gov/etv.
The ETV program also has a listserv, ETVoice, which sends a
brief monthly message to anyone interested in the ETV program
highlighting new and updated information on the web site. You may
subscribe to ETVoice though the web site.
As of May 2000, 67 air, water, monitoring, and pollution
prevention technologies have been verified, 105 technologies are in
the testing process, and an additional 108 applications are pending for
the testing process.
The ETV Program Director is Penelope Hansen who may be
reached at hansen.penelope@epa.gov. or at 202-564-3211
Environmental Management Systems (EMS)
Implementation Guide
Recognizing the potential difficulties faced by small and medium
sized organizations wishing to put EMSs in place, EPA's Offices of
Water and Compliance Assurance have produced a guide to EMS
implementation specifically to the needs of these types of
organizations. The Guide is based on the elements of the ISO 14001
standard and is written in plain, easy to understand language. Several
small organizations worked with EPA and NSF International (NSF) to
design and review the Guide and hundreds of organizations
throughout the world are presently using it. The Guide provides a
step-by-step approach for putting an EMS in place and gives a number
of examples from companies that have already done so. Contact
person is Jim Home, (202) 260-5802. INTERNET:
http://www.epa.gov/owm/iso2.html. The Guide also provides tips for
putting in place an effective approach for managing an organization's
compliance with regulatory requirements and using pollution
prevention techniques to enhance the environmental management
system. For copies of the Guide, call 1- (800) 368-5888, Item B-12.
EPA Reviews Public Participation Policies
The Common Sense Initiative (CSI), a bold reinvention effort
launched by EPA Administrator Browner in 1994, held its final
meeting on December 17, 1998. Using an inclusive and
unprecedented process, CSI brought together industry, state and local
governments, environmental and environmental justice groups, and
organized labor to work together to find strategies that work more
fairly, efficiently and cost effectively for industry and other
stakeholders.
One of the final and lasting accomplishments of the CSI multi-
stakeholder group was for EPA to adopt a new Stakeholder
Involvement Action Plan that builds on CSI experience and outlines
what the Agency will do differently in the future to enhance EPA's
Stakeholder Involvement Programs. The primary goal of the Action
Plan is to better integrate stakeholder involvement activities
throughout the Agency.
The first item in the Action Plan calls for EPA to assess and
establish agency-wide principles for stakeholder involvement. This
effort is a direct link to a July 1999 Report entitled, "Aiming for
Excellence - Actions to Encourage Stewardship and Accelerate
Environmental Progress, Report of the EPA Innovations Task Force,"
which pledges the Agency to evaluate and update EPA's public
participation requirements. To address these joint concerns, EPA
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convened a workgroup that is scheduled to give a report to the
Administrator by January 31, 2000, which will contain an inventory
of EPA regulations and policies regarding public participation and
an initial assessment of how well these regulations and policies
ensure public participation in decision making. To fulfil this
commitment, the workgroup is seeking public comment on two
issues:
1. What changes need to be made to the 1981 Policy on Public
Participation? What is working well, and how does the experience
of the past nineteen years suggest the need for improvements in the
general procedures for involving the public in EPA programs and
decisions?
2. How can we further engage the public in the effort to revise
the 1981 Policy and other EPA regulations and policies which may
need to be updated in regard to public participation? What are the
suggested elements of a strategy to further engage the public in
updating requirements and filling gaps in EPA's regulations and
policies concerning public participation?
These questions were recently posed in a federal register notice with
a 30 day public comment period that ended December 30,1999. As
stated in the original notice, EPA is still seeking input on these
questions and will use your comments as the Agency moves further
injapdating the 1981 policy and other stakeholder involvement
regulations and policies. For a copy of the federal register notice,
go to EPA's stakeholder website at www.epa.gov/stakeholden To
provide comments, contact Deborah Dalton at EPA by fax at 202
260-5478 or submit comments through the stakeholder website.
Keep an out on the website for a posting of all comments received
on this issue.
Revised Small Lab Environmental Management
Guide
See the special announcement on the Guide's availability in
this Newsletter. The Guide can also be found and downloaded from
the EPA Small Business Ombudsman's Home Page
www.epa.gov/sbo and the State Small Business Home Page
www.small.biz.enviroweb.org. We have completed a project to
update and expand the Guide. There is more comprehensive
coverage of environmental management issues affecting small labs
New areas of coverage include radioactive materials and
biologically active substances. A summary of hazardous waste
management techniques allowing on-site treatment is included, as
well as, expanded pollution prevention opportunities, and
opportunities for cost efficiencies. See Item B-16
Consolidation of Good Laboratory Practice
Standards (GLPS) Regulations Currently Under
TSCA And FIFRA Into One Rule
On November 29, 1983, EPA published Good Laboratory
Practice Standards (GLPS) regulations intended to help ensure data
integrity for studies required to support marketing and research
permits under the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) and the Toxic Substances Control Act (TSCA). These
rules were last amended on August 17, 1989. GLPS data integrity
measures can be applied to a wide variety of scientific studies.
Although the TSCA and FIFRA GLPS contain identical provisions,
they were published as separate rules to account for statutory and
program differences between TSCA and FIFRA, such as differences
in records retention requirements. EPA believes it will be able to
address the differences between TSCA and FIFRA, such as
differences in records retention requirements. EPA believes it will
be able to address the differences of those programs without
duplicating the entire GLP standard in two places.
This action is intended to consolidate EPA's GLPS into one rule.
Program specific requirements will be addressed in either separate
sections of the consolidated rule, or in separate rules as is determined
appropriate. This action is not intended to change the requirements,
applicability, or enforceability of GLPS with respect to any statute.
EPA has received comments from stakeholders regarding the
understandability of many aspects of the GLPS, and over the years has
issued numerous clarifications. EPA believes that some clarifications,
if included directly in the rule, would make the rule easier to
understand and enhance compliance. Therefore, EPA intends to
include such clarifications where appropriate in this rulemaking.
Finally, in the interest of maintaining consistency between EPA's and
Food and Drug Administration's regulations, EPA will determine any
modifications that have occurred to the FDA GLP rule and consider
incorporation such changes into the EPA rule. This action will serve
to reduce the total regulatory text in the Code of Federal Regulations
by an estimated 10 pages, by consolidating 23 pages of text to
approximately 13. In the process it will provide a generic GLP rule
that may be used by other programs in the Agency.
Resource Guide For Small Business Environmental
Assistance
Under a grant from the Office of the Small Business Ombudsman,
the Iowa Waste Reduction Center (IWRC), University of Northern
Iowa developed a multi-media Resource Guide for Small Business
Assistance Providers. This Guide provides a quick and convenient
reference tool for locating environmental assistance materials
(regulatory and non-regulatory) that have been developed mostly by
the states, and some by EPA. The Guide was prepared in cooperation
with all the states and is primarily for assistance providers to be used
as reference document. The information included is extremely useful
in helping locate readily available materials from other states in an
effort to not "reinvent the wheel."
These materials are also useful to state and local assistance
providers and small businesses in becoming educated on
environmental regulations and pollution prevention.
The Guide is available in electronic format with search and report
generation capabilities, and detailed instructions. There is also a
rating system which indicates relevance and type of use for which
most suitable. The Guide has had extensive state review. See Item B-
18.
Upgraded Source Book on Environmental Auditing
for Small Business
EPA's Environmental Auditing Source Book for Small Business
is now an upgraded compilation of the bibliography references,
training information, and a summary matrix of auditing tools for quick
reference. This book also contains information on environmental
auditor standards and qualifications. SeeB-14. Also available is the
Small Business Environmental Assistance Site Visit Manual prepared
by the Iowa Waste Reduction Center, University of Northern Iowa,
see B-17. Both of these documents can be obtained by calling the
EPA SBO's Office at 1-(800) 368-5888.
New Booklet - Little Known But Allowable Ways to
Deal With Hazardous Waste
The EPA has identified a number of allowable ways that small
businesses can minimize their hazardous waste on site. This document
provides information on five of these methods:
Domestic Sewage Exclusion;
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Elementary Neutralization;
Recycling;
Treatment in Accumulation Containers, and
Burning in Small Boilers and Industrial furnaces
This Guide provides information and answers the question of
whether any of these methods might work for you. The Guide
contains two principal sections. The introduction provides
background information on the purpose of the Guide, a brief
overview of the EPA Hazardous Waste Program as it applies to
small businesses, and a summary of the five EPA allowed
hazardous waste minimization methods identified above.
The second section is a state-by-state review of these
allowable ways to minimize hazardous waste. The section provides
summary information for each state including their definition of
hazardous waste, allowances for each of the five EPA allowed
waste minimization methods, and information on special state
hazardous waste management program considerations. This
document can be obtained by calling EPA SBO's Office at 1-(800)
368-5888
EPA Compliance Assistance Tools
The Office of Compliance (OC) has produced a booklet, Item
B-8, that offers a comprehensive listing of all OC projects that are
currently available and/or under development. The projects are
organized by industry sector, with 20 sectors covered. The tools
include: databases, documents, web sites, video, plain-language
guides, sector notebooks, etcetera. A contact person is listed for
each document to acquire more information. To get a copy of the
document, call 1-800-368-5888.
Performance Measurement Tools And Success
Stories Still Needed!
The performance measurement tools and success stories
database still has over 65 performance measurement tools and
success stories available for direct downloading, revision, and use
from the Small Business Environmental Home Page at the
following address: www.epa.gov/sbo
WE STILL NEED YOUR HELP TO IMPROVE THIS
RESOURCE! Please send any performance measurement
tools/surveys/success stories to Audrey Zelanko at CTC, 320
William Pitt Way, Pittsburgh, PA 15238. Electronic copies in word
perfect or word formats would be the most helpful. You can send
disks to the above address, or email attachments to:
zelankoa@ctc.com, audreyz@ccia.com, and bosilovich@ctc.com.
If electronic copies are not available, you can fax hard copies to:
(412) 826-6810 or mail them to the above address. If you have any
questions, please call Audrey Zelanko at: (412) 577-2649
THANKS in advance for your help!
New Jersey Chemical Industry Project
The New Jersey Chemical Industry Project of the Industry
Sector Policy Division in the Office of Policy concentrated on four
stakeholder-selected environmental protection strategies: Effluent
Trading, Materials Recycling, Compliance Assistance, and Flexible
Track.
The Effluent Trading Team has prepared a report titled
Sharing the Load: Effluent Trading for Indirect Dischargers, EPA
231-R-98-003, May 1998, on trading local pretreatment limits
among indirect dischargers. The Materials Recycling Report, titled
Promoting Chemical Recycling. Resource Conservation in Chemical
Manufacturing, EPA-231-R-99-001, May, 1999, describes five typical
batch chemical process scenarios that present opportunities to recycle
materials.
The Compliance Assistance Pilot Team sought to improve
compliance among New Jersey facilities by preparing a set of
compliance assistance materials which include:
Plain Language summaries of 20 New Jersey environmental
regulations;
Detailed applicability flowcharts for six regulations that show if
and how the regulations apply to a facility;
Summaries of New Jersey compliance assistance programs; and
information on how to obtain additional resources, such as training
materials and regulatory guides.
The materials are available at the New Jersey Department of
Environmental Protection web site:
httpV/www state.nj.us/dep/enforcement/home.htm. The Team also
prepared a report: Inspiring Performance: The Government-Industry
Team Approach To Improving Environmental Compliance, EPA 231-
R-99-002, May, 1999.
The Flexible Track Team has developed a program that provides
incentives for facilities that are good environmental performers to
maintain and improve that performance. For additional information
on the New Jersey Chemical Industry Project or for copies of any of
the Project's reports contact Catherine Tunis, 202-260-2698, 401 M
St., SW (2128), Washington, DC 20460.
2001 STATE SMALL BUSINESS OMBUDSMAN AND
TECHNICAL ASSISTANCE PROGRAM CONFERENCE
SCHEDULED FOR AUSTIN, TEXAS
The State Small Business Ombudsman and Small Business
Technical Assistance Programs, which are required under Section
507 of the 1990 Clean Air Act Amendments to aid small businesses
impacted by air quality regulations, will hold their annual
conference in Austin, Texas in the Spring of 2001.
Specialized training classes will be offered before the
conference.
For speeches and other presentation materials from the 2000
conference, held on June 20-22, 2000, in Missoula, Montana, they
can be downloaded from the Internet via a direct link at
http:///www.epa.gov/ttn/sbap/confOOa.html
"WHAT OUR CUSTOMERS MEAN TO US"
"Customers are the most important people in our business.
"Customers do not depend on us, we depend on them.
"Customers never interrupt our work, they are our work.
"Customers do us a favor when they call; we don't do the favors
by letting them in.
"Customers are part of our business, not outsiders.
"Customers are flesh-and-blood human beings, not cold statistics.
"Customers bring us their wants; we fulfill them.
"Customers are not to be argued with.
"Customers deserve courteous attention.
"Customers are the lifeblood of this and every other business.
"Customers are who we are when we're not working (So let's treat
them the way we want to be treated ourselves!)
"All these guidelines are saying the same thing:
Concentrate on the customer. You can't make many catches if
you take your eyes off the ball."
EPA SMALL BUSINESS OMBUDSMAN
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Six Key Aspects of the SBREFA Legislation
The Small Business Regulatory Enforcement Fairness Act (SBREFA) became law in March, 1996 to foster a
government environment that is more responsive to small business and other small entities. The Act contains the
following six key areas of regulatory reform:
Regulatory Compliance Simplification: Federal regulatory agencies must develop compliance
guides written in plain English to help small businesses understand how to comply with regulations
that may have a significant effect on them. Agencies must also develop a program for .providing
small entities with informed guidance on complying with applicable laws and regulations.
Equal Access To Justice Amendments: Under certain circumstances, small businesses can recover
attorney's fees and court costs in a court or administrative hearing, even when they lose.
Congressional Review: Congress has provided itself with a process by which it can review and, if
necessary, disapprove regulations with which it takes issue.
Regulatory Enforcement Reform of Penalties: Each regulatory agency must establish a policy to
reduce and, where appropriate, even waive civil penalties for minor violations under certain
circumstances.
Small Business Advocacy Review Panels: For proposed rules subject to the Regulatory Flexibility
Act, EPA must solicit input from the small businesses that will be subject to the rules and make
these findings public. This process is aided by SBA's Office of Advocacy and the Office of
Management and Budget.
Oversight of Regulatory Enforcement: Aida Alvarez, the SBA Administrator, appointed Gail
McEkmald,, as the Small Business and Agriculture Regulatory Enforcement Fairness Ombudsman.on
February 1, 2000. She also appointed the members of 10 regional Regulatory Fairness Boards to
assist the National Ombudsman in receiving small businesses' comments about enforcement
activities of federal regulatory agencies. The five (5) Fairness Board members appointed in each
region are small business owners and operators.
Brief Explanations of the National Ombudsman and
Regional Fairness Boards
Subtitle B of SBREFA created the National Ombudsman and 10 Regional Fairness Boards to provide small businesses
with the opportunity to comment on enforcement activity by federal regulatory agencies. Through this provision, Congress and
the President have provided a way that small businesses can express their views and share their experiences about federal
regulatory activity.
The National Ombudsman and the Fairness Boards will receive comments about federal compliance and enforcement
activities from small businesses, and report these findings to Congress every year. The report will give each agency a kind of
"customer satisfaction rating" by evaluating the enforcement activities of regulatory agency personnel and rating the
responsiveness to small business regional and program offices of the regulatory agencies.
Regulatory Enforcement Ombudsman 10 Regional Fairness Boards
Receive comments from small business on Members are small business owners/operators
compliance and enforcement actions Report to the National Ombudsman about
Review small business concerns comments and issues specific to their regions
Report annually to Congress Contribute to the annual report to Congress.
For additional information about SBREFA, the Ombudsman, or the Regulatory Fairness Boards, call SBA's toll free
1-888-REG-FAIR or visit our Web site at www.sba.gov/regfair.
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SBA REGIONAL SMALL BUSINESS REGULATORY FAIRNESS BOARDS
Regions/Members July,2000
1 Roxanna Adams
Atlantic Awards, Inc
840 Hammond Street
Bangor, ME 04401
(207) 942-6464
2 Joan Haberle
Joan Haberle Agency
# 1 S Mam Street
Lambertville, NJ
08530
(609) 397-9606
3 Wilkins McNair, Jr
Wilkms Acctg Firm
201 N Charles Street
Suite 910
Baltimore, MD 21201
(410)962-5252
4 Jeffery Adduci
Regional Invest
Bankers
171 Church Street
Suite 260
Charleston, SC 29401
(843) 577-2000
5 Hardie Blake
Bethel Business, Inc
118 Lincoln Way E
Mishawaka, IN 46544
(219)259-1527
6 Ehse McCullough
Staffing Sol, LLC
1305 Dublin Street
New Orleans, LA
70118
(504) 864-9900
7. J. Scott George**
Mid Amer. Dental Ctr
1050 W Hay ward Dr
Mt. Vernon, MO
65712
(417)466-7184
8 Donna Davis
Eagle Butte Co-op
P.O. Box 370
Eagle Butte, SD
57625
(605) 964-2226
9. Joseph Cerbone
Travis Morgan Sec.
18952McArthurB!vd
Suite 31 5
Irvine, CA 92612
(949)261-2906
10 Keith Saltier
Saltier & Heslop
71 8 6th Street
Prosser, WA 99350
(509) 786-2404
Dr Vmh Cam, Ph D *
Global Environment
PO Box 3 1134
Greenwich, CT 06831
(203)532-1252
Sandra Lee
Harold Lee Insurance
31 PellSt
New York, NY 10013
(212)962-6656
Kennelh Ridriguez
Rodriguez Enterprises
pobox 389
Sewickley, PA 15143
(412)749-7810
Robert G Clark**
Clark Communi Corp
149N Hanover Ave
Lexington, KY 405023
(606) 233-7623
John Hexter
Hexter & Assoc
22199ShelbumeRoad
PO Box 22054
Cleveland, OH
44122-2049
(216)378-2080
Massey Villarreal
Precisions Task Group
9801 Westheimer
Suite 8
Houston, TX 77042
(713)781-8912
Alonzo Harrison
HDB Conslr.
729 Wear Ave.
Topeka, KS 66607
(785) 232-5444
Albert C. Gonzales
Gonzales Consull Svcs
633 E. 1 7th St,# 1600
Denver, CO 80202
(303) 383-5500
Tim Moore * *
Old Lahama Cafe &
Luau
1287 Front Si
Lahaina, HI 96761
(808) 667-2998
Larry E Morse **
Docu-Pnnl Inc
10 Boyd Avenue
E Providence, RI02914
(401)435-2500
E Peter Ruddy *
WESTNY Bldg Product
2580 Walden Ave
Buffalo, NY 14225
(716)681-2000
Shawn M Marcell
Pnma Facie, Inc.
1006 W 8th Ave , #A
King of Prussia, PA
19406
(610)491-9200
Rita P Mitchell *
Sun Trust Securities
PO Box 305 110
Nashville, TN 37230
(615)748-4560
Donald Magett
Magic P I & Security
529 Northhampton Rd
Kalamazoo, MI 49006
(616)381-2324
Stella J Olson
Stat Enterprises, Inc
4444 Vaile
Flomsant, MO 630341
(3141)972-1556
Mary Thoman
Thoman Ranch
HC65 Fontenelle Route
Kemmerer, WY83101
(307)877-3718
Kalhy Chavez-Nopoh *
Si C Truck Wreckers
795 Comstock St
Santa Clara, CA 95054
(408) 727-6655
Gretchen Mathers **
Gretchen's Course
2415 Airport Way, So
Seattle, WA 98 134
(206)623-8194
Judith Obermayer
Obermayer Assoc
239 Chestnut St
W Newton, MA 02 165
(617)244-8990
Phyllis Hill Slater
Hill Slater, Inc
45 N. Station Plaza
Great Neck, NY 11021
(516)773-7779
Ann P Maust, Ph D **
Research Dimens, Inc
1 108 E. Mam St, #1000
Richmond, VA 232 19
(804)643-1082
Leroy Walker, Jr
LTM Enterprises
2310Hwy80 W
Jackson, MS 39204
(601)352-1742
Thelma Alban *
Stevenson Associates.
680 N Lake Shore Drive
Chicago, IL 606 11
(312)335-0067
Larry Mocha *
Air Power Systems
8178E 44th St
Tulsa, OK74147
(918)622-5600
Dan Morgan *
Morgan-Davis, Intern'tl
Morgan Ranch
HC79 Box 42
Burrell, NE 68823
(308) 346-4394
Linda Nielsen *
Glasgow Stockyards
HC67,Box 175
Nashua, MT 59248
(406) 228-9306
Thomas Gutheria
So. Nevada Certified
Development Corp
2770 S Maryland Pkwy
Suite 21 2
Las Vegas, NV 89109
(702) 732-3998
Clyde Stryker *
Spirit Communication
20493 SW Avery Court
Tualatin, OR 97062
(503)612-0600
Ronald Williams
W&RBus Affiliates.
194 Capen St.
Hartford, CT 06 120
(860)727-1181
Manuel Cidre
Pastelena Los Cidnnes
Rey Federico
257 Villas De Tomma
Guaynabo, PR 00965
(787)9732
Victor Tucci * '
Three Rivers Hlth & Sfty
406 Edwards Road
New Kensington, PA
15068
(412)826-5599
Livia Whisenhunt
PS Energy Group, Inc.
2957 Clairmont Rd
Suite 510
Atlanta, GA 30359
(404)321-5711
Reid Ribble
The Ribble Grp, Inc.
W6893 Manitowoc Rd
Menasha, WI 54952
(920)766-7904
Wallace Caradine **
Caradine & Co.
2200 S. Mam Street
PO. 16430
Little Rock, AR 72206
(501)372-4199
Joanne Stockdale
N IA Die Casting Co
702 E Railroad St.
Lake Park, IA 5 1347
(712)832-3661
Vernon Thompson
Vern's Trucking
P.O. Box 25
Minnewaukan, ND 58351
(701)473-5720
C. K. Tseng
Northbridge Travel
9700 Reseda Blvd.
Northbndge, CA 91324
(818)886-2000
Serena McAlvain
McAlvain Construction, Inc
5559 W. Gowen Rd.
Boise, ID 83709
(208) 362-4356
1 Chair
** Vice Chair
24
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Regulatory Flexibility Act (RFA)
Small Business Regulatory Enforcement Fairness Act (SBREFA)
Tom Kelly
Small Business Advocacy Chair
Under the RFA as amended by SBREFA, EPA must convene a Small Business Advocacy Review
Panel for certain regulations prior to their proposal. EPA's Small Business Advocacy Chair
assembles each Panel to include representatives from the Small Business Administration, the Office
of Management and Budget, and the EPA office responsible for the rule. The Panel prepares a
report to the Administrator of EPA with recommendations on ways to reduce the potential impact of
the rule on small entities (whether businesses or governments). The Panel report is part of the
rulemaking record that accompanies the proposed rule.
Small Business Advocacy Review Panels are no longer novelties.
EPA convened its 21st Panel on April 25, 2000. This year alone we completed 7 Panels, with
many more on the horizon. The completed Panels reviewed rulemakings on lead-based paint
renovation and remodeling, heavy-duty engine and diesel fuel sulfur standards, effluent guidelines
for metal products and machinery, emission standards for composite plastics fabrication, treatment
standards for microbial contamination of drinking water, and control of disinfection by-products.
They are producing meaningful change...
In the four years since the passage of SBREFA, EPA has made significant changes to
regulations under development. EPA has considered over 140 Panel recommendations to address
the particular concerns of regulated small entities. Some these changes include:
The Class V Underground Injection rule, which allows many small businesses to continue use
of their wells under permit (as opposed to a contemplated ban) and allows funeral homes to
continue use of their wells, pending further study;
The proposed rule addressing the Sulfur Content of Gasoline, which provides an extended
period (four to six years) for small refineries to comply with rule requirements, without
damage to the fuel supply.
The Panel for the Industrial Laundries Effluent Guideline, which re-evaluated the risks posed
by the many small businesses likely to be regulated. The Panel recommended the Agency
take comment on a "no-regulation" option. EPA eventually withdrew the regulatory proposal,
while the industry introduced a voluntary pollution-prevention program.
...And we're seeing a larger effect.
Since Panels apply only to those rules that impose a significant economic impact on a
substantial number of small entities, what about rules that have lesser effects, or cover relatively few
small businesses? One effect of the Panel process has been to demonstrate emphatically that
regulations can be both environmentally effective and reasonably considerate of the resource and
competitive constraints characterizing small entities. EPA's involvement of small businesses and
governments in all rules that affect them has never been higher or more responsive.
Soon you can follow our progress on-line.
Shortly EPA will launch an RFA/SBREFA website. This site (www.epa.gov/sbrefa) should be
active by August and will give you direct access to Panel reports, Small Entity Compliance Guides,
and other pertinent documents. We look forward to your feedback on it, so please check it out!
Contact: SBREFA Team Leader Stuart Miles-McLean (202) 564-6581
25
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Stats on EPA Innovation Over the Past Decade
Cleaner, Cheaper, Smarter, Results -
> Superfimd cleanups nearly 20% cheaper and faster. $1.5 billion saved in remedy
selection.
> 300 Brownfields sites, with nearly $2 billion in public/private investment.
> Emissions causing acid rain reduced by 30% more than law requires. Eastern US rainfall
now 25% less acidic - New England starting to recover. Cost of program 75% lower than
predicted.
> National sulfur dioxide emissions down by 4 million tons annually.
* Nitrogen oxide emissions down 20% lower than law requires, and 50% lower than 1990
levels.
> 50 States, 6 Territories, 80 Tribes completed comprehensive watershed assessments -
First coordinated overview of Water Quality priorities.
* 675 companies voluntarily identified potential violations at 2700 facilities.
Partnerships -
> > 7000 businesses participate in voluntary partnerships with EPA. Partners conserved
1.8 billion gallons of water, eliminated 7.8 million tons of solid waste, and prevented air
pollution equivalent to taking 13 million cars off the road each year. Saved $3.3 billion.
* Project XL has 25 projects underway, 25 more being developed.
> 35 States signed on to National Envir. Perf. Partnership System agreements.
* 45 States consolidated grants from EPA.
Stronger Public Role -
ป Stakeholders involved in almost all decisions:
Worked with industry to develop standards for air emission from 174 categories
of industrial facilities.
Stakeholders helped design XL Projects.
Community concerns considered in settling enforcement cases.
> Greater access to better environmental information
Through TRI, improved environmental performance from 1988 through!997:
air releases down 55%
water releases down 63%
Underground waste injection down 22%
Onsite disposal down 26% (with only 1% increase of offsite disposal).
>70 million hits a month on EPA's website (which includes Spanish language
sites)
Consumer info on drinking water quality, lead paint hazards in homes.
Citizens in 85 metro areas can get current info on local envir. quality.
For further information contact Cheryl Hawkins at: (202) 564-6677
26
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Update on the Office of Environmental Information
Last fall, EPA Administrator Carol Browner announced the creation of the new Office of
Environmental Information (OEI), which would be responsible for information management,
policy and technology. OEI would be charged with meeting the demand for high-quality
information by improving the way EPA collects, manages, analyzes, and provides access to
environmental information to the public. Creating the office was a collaborative process
involving a wide range of input from stakeholders and partners.
The US General Accounting Office reported that "one of the office's most pressing
challenges will be to develop a plan that identifies clear priorities for the office and the resources
it will need to successfully lead the Agency's efforts to make significant improvements in
information management." The first step toward the development of the Agency's Information
Plan has been the recent creation of the FY 2000 OEI Action Plan, which summarizes the key
projects being initiated or advanced during this calendar year.
One of the most significant OEI accomplishments since it's creation has been to initiate the
development of a new Agency priority, the Environmental Information Exchange Network. The
network is a partnership with the States to develop and implement a national plan for the purpose
of integrating and exchanging environmental information with one another, and EPA.
Many improvements in the way EPA collects and manages it's environmental data are also
underway including the development of specific data standards which outline agreed upon
formats and procedural rules for exchanging information. A new Facility Registry System has
been launched creating a centrally managed repository of information on facilities that are
subject to environmental regulation or of environmental interest. This system will reduce long-
term reporting burdens on providers of information, help to reduce errors in facility records, and
provide greater ability to conduct cross-media analyses. OEI is also developing the infrastructure
for a Central Data Exchange, a single point-of-entry for environmental data submitted to the
Agency. The exchange will allow receipt of data in multiple electronic and paper formats.
OEI also has been exploring ways to improve the Agency's ability to provide the public with
high quality information to enhance their environmental decision making through the
development of a Public Access Strategy. The Agency's web page has been redesigned to make
it easier to find information, and for the first time this year, the TRI annual data (1998) was
released via the web and through Envirofacts. Reports can now be generated from the TRI
database on-line with the recent release of the TRI Explorer tool.
In addition, the Agency under OEI's leadership, has made significant enhancements in the
security of our information and computing infrastructure to keep pace with intrusion threats that
come with greater use of the Internet.
To learn more about OEI's activities or to receive a copy of it's FY 2000 Action Plan, visit their
web site at http://www.epa.gov/oei. For further information contact: Outreach Coordinator,
Don Flattery, (202) 260-7070
27
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Performance Track Recognizes Environmental Excellence
EPA launched the National Environmental Performance Track June 26th in Washington D.C.
The National Environmental Performance Track is designed to motivate and reward top environmental
performance. The first level of the Performance Trackthe National Environmental Achievement
Trackis open to companies and facilities of all types, sizes, and complexity, public or private,
manufacturing or service-oriented. Multi-facility corporations are encouraged to develop company-wide
policies supporting participation. Applications for the Achievement Track are now being accepted and
those whose applications are approved by September 1 will be part of a distinguished Charter Group.
Through a systematic approach to managing environmental responsibilities, taking extra steps to
reduce and prevent pollution, and being good corporate neighbors, many companies today are modeling
the way to environmental excellence. At the same time, they are saving money and improving
productivity. The Performance Track defines what it means to be a top environmental performer and
provides incentives to motivate further improvements.
The National Environmental Performance Track creates a system that recognizes performance at
two levels: Environmental Achievement and Environmental Stewardship. Many companies today have
witnessed the business value of continuous environmental improvement and of communicating progress
to their stakeholders. As top environmental performers, participants earn access to a unique package of
incentives that reward and support continued environmental improvement. These include:
Recognition
Use of the Performance Track logo Visibility in EPA publications, Web sites, and events Special
recognition for Charter Participants
Access to "State-of-the-Art" Information
Best practices database Peer exchange networking opportunities Informational briefings with
senior EPA officials
Streamlined Monitoring and Reporting
Streamlined reporting and record keeping under the Clean Air Act* Reductions in discharge
monitoring and reporting under the Clean Water Act Streamlined monitoring, reporting and
procedural requirements for Publicly-Owned Treatment Works* Consolidated environmental
reporting*
Streamlined Administrative Procedures
Increased flexibility in installation of Best Available Control Technology (BACT) under the
Clean Air Act Reduced loan rates, extended pay-back periods and other advantageous terms
under Clean Water Act loan programs Allow Publicly-Owned Treatment works to report certain
compliance information on the Internet* Expedited review of new reduced risk pesticides
For more information about the National Environmental Performance Track, visit
www.epa.gov/performancetrack or call 1-888-339-PTRK.
* Indicates it is part of a set of changes EPA will propose to make in its regulations to accommodate
Performance Track Facilities
28
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State Small Business AssistanceProgram (SBAP)
Success Stories
(from the 1999 state reports)
In Missouri, the On-site Assessment Team is visiting many facilities across the state, and their services have been well received.
The Team provides each facility with a comprehensive, easy to understand report describing areas that need improvement, areas
that are in compliance, and pollution prevention tips and opportunities. The regulatory programs have commented that when the
Technical Assistance program helps a facility complete a permit application or other document, the application or document
takes much less time to review and process. In Team evaluation surveys, many facilities indicated the assistance was very
helpful and that they achieved compliance partly due to the information provided through these efforts.
In Ohio, ninety nine percent of our site visit customers said they would contact us again for help. In 1999, the SBAP staff
traveled 29,073 miles in providing on-site assistance to 144 companies located in 44 of 88 OH counties.
Pennsylvania introduced its Pollution Prevention Assistance Account, a low-interest loan program available to small businesses
that want to undertake pollution prevention and energy efficiency projects. The state also started the Pollution
Prevention/Energy Efficiency Site Assessment Grant Program, which provides up to $5,000 to small businesses that want to hire
a private consultant to conduct P2/E2 assessments
In August 1999, the Virginia SBAP and the State Advisory Board on Air Pollution launched the Virginia EnviroMENTOR
Program on a pilot basis. This program provides volunteer mentors to assist small businesses achieve compliance or institute
pollution prevention activities. This initiative was modeled after the original Texas EnviroMENTOR program, which also
provided guidance in starting the Virginia program.
Gulf Wire Corporation, New Orleans, Louisiana, was the recipient of the first pollution prevention award for a small business.
The company reduced its use of trichloroethylene, used to clean the welding wire it produces, by 20 percent.
Missouri's on-site assessment team advised an aluminum smelting facility to recycle their pallets and cardboard. The team
located an appropriate recycling facility to take the materials, which resulted in a savings of approximately $2000 per month in
disposal costs.
Ohio's SBAP worked to reduce the permit fees for a customer. After many conversations, phone calls, e-mails, and meetings
between the district and HQ staff, misunderstandings about the size and emission potential of the permitted sources were
resolved. As a result, the permit fee was reduced from $4000 to $300!
Neighbors of a woodworking facility in central Pennsylvania complained about dust from the operation, and a DEP inspector
told the facility to correct the problem. ENVIROHELP staff conducted a site visit and informed the facility that the air pollution
control device was overloaded and recommended installing a second device such as a fabric filter. ENVIROHELP also provided
information about financing available through DEP. Ultimately, the company used one of the financing options to purchase a
fabric filter.
A business in northeastern Pennsylvania was given three weeks by DEP to complete two "requests for determination" forms.
The business enlisted ENVIROHELP to calculate emissions from their cardboard bailer and various printing inks.
ENVIROHELP explained the information, calculations, and documentation necessary to estimate emissions from the inks and
identified whether any other air pollution control requirements applied. ENVIROHELP reviewed their "request for
determination" forms, which were submitted to DEP on time.
In Texas, the Small Business Local Government Assistance (SBLGA) spurred the development of the "de minimis" concept,
referring to a cut-off level for air emissions, below which businesses would be exempt from all air authorization requirements.
The de minimis concept has been incorporated into Senate Bill 766, which will completely overhaul air pollution authorization
in TX. The SBLGA has successfully developed a list of more than 40 de minimis facilities and has been an integral part of
building a structure of six de minimis categories and additional subsets of chemicals based on use rates. Texas also implemented
a Compliance Commitment Partnership program, in which businesses that receive site visits and agree to implement all
recommendations made by the consultant receive a one year reprieve from routine inspections. This program serves as an
incentive for businesses to voluntarily increase compliance and environmental awareness.
Wisconsin SBAP staff provided compliance assistance to a wood frame manufacturer. The company was frustrated with the WI
air regulations and permitting requirements and was contemplating a move to another state. Thanks to the assistance efforts, the
business saved over $1000 in consultant fees, and the company remained in the state retaining over 75 jobs.
The Wisconsin SBAP brought a permitting issue to the attention of the WI DNR, which resulted in the agency drafting a
permitting exemption for auto body shops. The way current regulations are written, very small sources of air pollution were
unable to fall under a permitting exemption. Although most body shops are well below the permitting threshold, they still need
to apply for an air permit. The SBAP initiated a meeting and several site tours of body shops so the DNR rule writers could get a
better idea of the emissions from these small sources. As a result, the agency agreed to a variance to the permitting regulations
to exempt small auto body shops. For more information contact Angel Martin-Diaz, (412) 577-2643
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10 INNOVATIVE STATE PROJECTS SELECTED TO ENHANCE
EFFECTIVENESS OF SMALL BUSINESS ASSISTANCE
In October 1999, EPA's Office of Small Business Ombudsman announced ten demonstration projects funded under a
Small Business Assistance Cooperative Agreement Program. These projects are designed to improve state programs
environmental assistance to small businesses with an emphasis on estimating the emissions reductions achieved, as well as
other benefits. These awards, for up to a two-year period, ranged from $60,000 to $100,000.
The awards reflect EPA's commitment to innovation in state assistance networks that help businesses prevent
pollution and comply with the law. The projects chosen for funding service a wide range of small business sectors and
offer the potential for demonstrating innovations that have far-reaching benefits to state assistance programs.
In March, 2000, the ten State project managers met in Washington, DC, with EPA's Office of Small Business
Ombudsman for a 2-day work session. The group developed an approach to measuring projects and compared and aligned
the ten efforts to assure commonality over the life of the Cooperative Agreements. It was concluded that the ten projects,
taken together, have the potential to demonstrate three major program capabilities:
the capability to approach 100% regulatory compliance in a targeted industry sector
the capability to create partnerships that extend the reach and impact of state compliance assistance programs
the capability to deploy powerful program assets, such as outreach channels, information systems, smart
business models, one-stop shopping and referral, ... that can reach and engage small businesses
Results from the March 2000 project planning session were presented at the June 2000 EPA/State SBO/SBAP National
Conference held in Missoula, Montana.
The 10 demonstration projects are:
California: South Coast Air Quality Management District. The project is testing a multi-state, public-private
partnership approach to assist small businesses in reducing air emissions. The test is focusing on the water heater
and boiler manufacturing industry.
Colorado: Department of Public Health and the Environment. Project is developing a network of partners to
expand the reach of its small business assistance program. It is integrating resources of several assistance
providers, and, integrating assistance tools tailored to specific customer needs.
Kansas: State University Pollution Prevention Institute. Project is testing an approach to assure cost effective,
one-on-one assistance to small businesses. Retired engineers will provide direct assistance in three industries:
dry cleaners, automotive repair/auto body and metal finishing.
Maine: Department of Environmental Protection. The project is testing a strategy to reduce pollution by
changing business practices in a targeted sector. One-on-one assistance is designed to help businesses switch to
optimum, clean technologies. The test focuses on auto repair and auto body shops.
Minnesota: Pollution Control Agency. Project is creating partnerships to provide on-going assistance to an
entire industry. Compliance assistance is being provided to the reinforced plastics and boat manufacturing
industries.
Montana: Department of Environmental Quality. Project will develop and test marketing methods to stimulate
requests for assistance from the small business community and to increase business and public awareness.
New Jersey: Department of Environmental Protection. Project will build leverage to expand the reach and
impact of a small compliance assistance program. The leverage will come through partnerships with other
assistance providers using high impact materials. Partners are mobilized for direct outreach to small businesses.
New York: Environmental Facilities Corp. Project will demonstrate how well organized, focused assistance
programs can move an industry sector toward full compliance. The demonstration proposes to move 2,700
gasoline stations into compliance with leak test requirements.
South Carolina: Department of Health and Environmental Control. Project will reach out to small auto repair
shops and salvage yards that are often beyond the reach of the regulatory sector. Partnerships will be used to
reach businesses with specific materials and training.
Wyoming: Department of Environmental Quality. The project is testing a business involvement approach.
Businesses will participate up-front in the introduction of new regulatory standards and develop collaborations
for optimum business solutions to their compliance. Formal process includes review of proposed new standards
and state information system capability to locate small business customers for direct compliance assistance.
There will be periodic updates on the progress of these projects over the two-year period. After the projects are completed
in middle of the year 2001, results will be reported to the U.S. Congress under a Congressional mandate and, published
and distributed to the small business community and other interested groups. For more information contact: Bob Rose, at
(202) 260-1133 or, by e-mail at rose.bob@epa.gov.
30
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STATE SHOWCASE OF SUPERIOR ASSISTANCE TOOLS FOR
SMALL BUSINESSES
MICHIGAN MANUFACTURERS' GUIDE TO ENVIRONMENTAL AND
SAFETY AND HEALTH REGULATIONS
The Michigan Departments of Environmental Quality (DEQ) and Consumer and Industry Services (CIS)
offer assistance to Michigan manufacturers facing the challenges of daily business regulations. The two
Departments have designed a first-of-its-kind users guide. Packed full of easy-to-read discussions about
state and federal environmental rules, the "Michigan Manufacturers' Guide to Environmental and Safety
and Health Regulations" also summarizes the MIOSHA programs that affect manufacturers of all sizes.
The book begins with a self-assessment checklist to steer a manufacturer through the regulations that
affect their business.
Each chapter of the book is produced by a department program specialist. Along with easy-to-read
overviews of relevant regulations, telephone numbers, web sites, and additional publications lists are
included in each of the 32 chapters.
We realize how complex and voluminous government regulations are. We also understand the huge
responsibility manufacturers face to keep the environment clean, their workers safe, and their business
profitable. The "Michigan Manufacturers' Guide to Environmental and Safety and Health Regulations"
can help a manufacturer meet this purpose.
The guidebook, complete with binder and 40 tabs, is available for $25 or it can be viewed and printed
from the following Web site (www.deq.state.mi.us/ead/pub/caap/manufguide/). This Web site also
contains the order form if interested in purchasing a copy. If you have any questions or comments about
the guidebook, please contact Dave Fiedler, Michigan Department of Environmental Quality,
Environmental Assistance Division at (517) 373-0607 or e-mail (fiedlerd@state.mi.us).
For Further Information contact: David Fiedler at (517) 373-0607
FLORIDA'S SBAP DRY CLEANERS CALENDAR SUCCESS
In 1996, Florida Department of Environmental Protection held statewide compliance assistance
workshops to increase awareness of upcoming PERC regulations. These workshops, and the following
year's hands-on compliance training, indicated a pressing need to improve record keeping and reporting.
This led to development of dry cleaner compliance calendars that enabled businesses to easily track
inspections and record PERC usage directly on their calendars. They could then tear off the information
sheet each month to meet compliance requirements. Results were dramatic. From 1996 to FY 98-99,
record keeping and reporting compliance improved from 31 to 77 percent, a 148 percent increase.
Further improvement in compliance is expected with the roll out of a Spanish compliance calendar in
2001, targeted towards South Florida's substantial Spanish speaking population
A downloadable version of the calendar was posted on Florida's SBAP web page in 1999 and
subsequently on the EPA SBO website as well. Based on informal feedback, we understand that 14 states
have adopted or are in the process of adopting the calendar for use in their programs to date. We are in
the process of developing a formal survey to assess the degree of replication in order to fully measure the
calendar's success.
Given the success of the calendar approach for the dry cleaning industry, we are currently in the process
of developing a comparable calendar for the surface coating industry and are also considering this
approach for several other industries.
For further information contact: Elsa Bishop, (850) 414-8399.
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NEW DOCUMENTS AVAILABLE FROM EPA!
Three new documents that provide information to small businesses and laboratories about environmental
management, auditing, and hazardous waste management are available from EPA. The documents are
"Environmental Management Guide for Small Laboratories, " "Little Known But Allowable Ways to Manage
Hazardous Waste, " and "The Small Business Source Book on Environmental Auditing. "
"Environmental Management
Guide for Small Laboratories,
The Second Edition "
When is a waste a waste? What
exactly is a satellite accumulation
area? Is sink disposal of
hazardous waste allowed? Is an
air permit required for laboratory
ventilation devices? How is
pollution prevention incorporated
into everyday laboratory
practices? To assist small labs in
answering these and many more
questions, EPA offers the second
edition of the successful and
popular "Environmental
Management Guide for Small
Laboratories" (Guide).
The Guide helps users manage
unique environmental
considerations common to labs
and provides practical guidance
on solving problems associated
with compliance and the
implementation of best
management practices.
Special Issues about Labs
Most labs are small independent
businesses or small entities
affiliated with a larger
organization. In these labs,
environmental management is
most likely a shared
responsibility or administered by
part-time staff or through
collateral duty. The updated
Guide will be geared toward
providing lab staff with current
and concise information on
regulations and management
practices as well as pollution
prevention (P2) and waste
minimization. Labs present
unique environmental risks
because there are numerous
substances used, there is high
variability in operations,
there is a high likelihood of
creating a new substance, and
there is a high degree of
independence among the
individual labs. Labs further
face the challenge of
adopting environmental
regulations that are geared
toward manufacturing and
industrial facilities. OSHA
estimates that there are
approximately 35,000 labs in
the U.S.
What Changes were Made?
The original Guide, published
in 1998, addressed many
unique issues and challenges
labs face from existing
environmental regulations.
The success of the original
Guide prompted EPA to
produce a second edition that
contained updated
information and
improvements. The result is
a Guide which:
More uniformly
addresses environmental
issues.
Provides a bridge to
regulatory programs not
managed by the EPA
(e.g., OSHA, Department
of Transportation (DOT),
Nuclear Regulatory
Commission (NRC)).
Expands and integrates
P2 and waste
minimization opportunities.
Adds a fifth chapter titled
"Little Known But Allowable
Ways to Manage Hazardous
Waste."
Incorporates additional
information including
Environmental Training,
Biologically Active
Substances and Wastes,
Radioactive Sources, Special
Wastes (universal waste, used
oil, and battery management),
Hazardous Materials
Handling and Storage, and
Sustainable Practices (green
purchasing, energy and water
conservation).
Guide Organization
The body of the Guide
consists of sections covering
15 key environmental
management issues.
Each section is organized to
provide information on
regulatory considerations (an
overview of Federal
regulations), management
issues (developing
procedures and plans and
establishing programs), and
P2.
Management suggestions and
real-life examples are
presented in each section,
which concludes with a
checklist that is ideal for self-
auditing.
The final chapter of the
Guide contains the "Little
Known but Allowable Ways
to manage Hazardous Waste"
document.
32
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"Little Known But Allowable
Ways to Manage Hazardous
Waste"
"Little Known But Allowable
Ways to Manage Hazardous
Waste" provides information on
allowable alternatives to the
traditional and costly methods of
hazardous waste disposal off-site.
What are the Five Methods of
On-site Disposal or Treatment?
The Clean Water Act allows for
certain types of hazardous waste
to be disposed of down the drain
under the domestic sewage
exclusion (DSE), and the
Resource Conservation and
Recovery Act provides for on-site
generator treatment without a
permit through elementary
neutralization, recycling,
treatment in accumulation
containers, and small-quantity
on-site burning.
Organization
The document describes the
five methods and identifies
which states allow each.
The document also provides
information on where and
how to get the state
hazardous waste regulations
and current and tested
contacts for further
assistance.
"The Small Business Source
Book on Environmental
Auditing"
"The Small Business Source
Book on Environmental
Auditing" (Source Book)
provides information on
environmental auditing resources
relevant to small businesses.
Large businesses have long
recognized the value of auditing
as a tool that helps minimize
liability, avoids compliance
costs associated with new
projects, and identifies
opportunities for improved
operating practices.
However, small businesses
have been slower to accept
auditing as a valuable
business practice. The
Source Book should be useful
to small business owners,
representatives, and
assistance providers to learn
about auditing practices and
the value of auditing by
directing them to the most
relevant sources of
information and training.
What is Environmental
Auditing?
EPA defines environmental
auditing as a periodic,
objective, and documented
assessment of an
organization's operations
compared to audit criteria.
Audit criteria may be
compliance requirements
such as regulations, or may
be management practices that
benefit the environment. In
either case, an audit provides
information on the
operational status of an
organization compared to
management's environmental
performance expectations.
Why Conduct an Audit?
It is useful to think of an
audit as a diagnostic exam
and operations tune-up.
Afterwards, the business
should run more smoothly.
By conducting the exam, a
business gains a better
understanding of where its
operations stand compared to
audit criteria and indicates what
areas need to be addressed to
improve performance. Like other
tune-ups, an audit should be
conducted periodically.
Also, for those not sufficiently
trained, the services of an expert
may be needed.
Source Book Organization
The Source Book has five
chapters addressing General
Resources; Auditing
Standards and Guidance;
Audit Criteria; Audit Tools;
and Audit Training Courses.
The information within each
chapter is organized by
source type: Book, Checklist,
Manual, Web Site, Software,
Standard, Training, and
Reference Web Site.
Each source is described and
then graded on a scale of 1-3
with 1 being most relevant to
small business.
The "Environmental
Management Guide for Small
Laboratories," "Little Known
But Allowable Ways to Manage
Hazardous Waste, " and "The
Small Business Source Book on
Environmental Auditing" are
available from the U.S. EPA
Small Business Division, Ariel
Rios Building, MC 2131, 1200
Pennsylvania Avenue NW,
Washington, DC 20460; the toll
free hotline, 1-800-368-5888, or
the Small Business Division web
site {HYPERLINK
"http://www.epa.gov/sbo" }. Ask
or look for documents EPA 233-
B-00-001, EPA 233-B-00-002,
and EPA 233-B-00-003
respectively.
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What's New With the Risk Management Program
Carole L. Cameron
EPA's Chemical Emergency Preparedness and Prevention Office
compiled June 10, 2000
Regulatory Developments
On April 27, EPA and the Department of Justice proposed a rulemaking that deals with public access
to Off-site Consequence Analysis (OCA) information that was submitted to EPA under the Clean Air
Act Section 112(r) by June 21, 1999. The 1999 Chemical Safety Information, Site Security and
Fuels Regulatory Relief Act required the government to assess both the chemical risk
reduction benefits of allowing public access to OCA information and the increased
risk of terrorist and other criminal activity from posting the information on the
Internet. Based on these assessments, conducted by EPA and DOJ respectively,
the proposed rule would allow public access to the OCA portions of the RMPs in
ways that minimize the likelihood of chemical accidents as well as the increased
risk of terrorist and criminal activity associated with Internet posting. A public
hearing was held May 9. Comments on the proposed rule are due June 8. A final rule is expected to
be published by Aug. 5. To see a copy of the proposal, visit the CEPPO website at
http://www.epa.gov/ceppo/pubs/OCArule.pdf Copies of the assessments can be downloaded at
http://www.epa.gov/ceppo/whatnew.html A fact sheet that summarizes the proposed rule can be
found at http://www.epa.gov/ceppo/pubs/sisruleFACT.pdf
New regulatory developments are posted the same day on the "What's New?" page at
www.epa.gov/ceppo. EPA's Hotline is also immediately notified of any developments in our
program. Call them at (800)-424-9346 to get the latest news. And, as always, be sure to keep in
touch with the Small Business Assistance Program in your State.
Chemical Safety Alerts
A recent chemical safety alert on anhydrous ammonia theft discusses the potential hazards of
anhydrous ammonia releases caused by theft, steps businesses can take to prevent theft and how to
minimize health and safety risks associated with accidental releases. This alert should be read by
individuals who operate and maintain agricultural retail operations, facilities with ammonia
refrigeration systems and farmers who apply anhydrous ammonia as a fertilizer.
The National Institute for Occupational Safety and Health (NIOSH), EPA , and the Ethylene Oxide
Sterilization Association (EOSA) request assistance in preventing explosions at industrial
ethylene oxide (EtO) sterilization facilities and EtO repacking plants. EtO is a
flammable gas. During sterilization procedures, EtO can easily form explosive
mixtures when it is vented to certain types of emission control devices such as
catalytic oxidizers.
Between 1994 and 1998, EtO was involved in 10 explosions. One of these explosions
caused 1 death and 59 injuries among workers. All of these incidents caused
damage to the plants, most of which used catalytic oxidizers to control EtO
emissions. The alert recommends ways to prevent these explosions.
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Waste fuel/oxidizer reaction hazards are addressed in a case study regarding lessons learned from
a March 26, 1997, accident at Chief Supply Corporation in Haskell, Oklahoma. The accident killed
one worker and injured two others. The immediate cause of the accident was most likely a violent
reaction of oxidizers that were put into a mixer with flammable liquid solvents. The
potential for such an incident exists whenever strong oxidizers are mixed with oxidizable and
combustible organic substances.
All of the alerts can be found at http://www.epa.gov/ceppo/ap-chsa.htm
Public Meeting Update
The Chemical Safety Information, Site Security and Fuels Regulatory Relief Act required facilities
that submitted an RMP for a Program 2 or Program 3 process to announce and hold a public meeting
by Feb. 1, 2000, to discuss their Risk Management Program, including the off-site consequence
analysis sections (sections 2 through 5 of the RMP). Small business stationary sources could opt to
publicly post a summary of their OCA information. Facilities that submitted an RMP for a Program
1 process are exempt from this requirement. To date, the FBI has received approximately 12,000
notices. Certifications were due by June 5, 2000, to the FBI noting that a meeting has been held or a
summary has been posted.
A list of facilities that have notified FBI of their compliance is located at
http://www.epa.gov/ceppo/meetings/
RMP Guidance Materials Updated
The "General Guidance for Risk Management Programs" and the
Industry Sector RMP Guidance documents for Ammonia Refrigeration, Warehouses, Chemical
Distributors, and Wastewater Treatment Plants have recently been revised to reflect changes in the
program required by the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act.
The updated guidance material can be accessed at http://www.epa.gov/ceppo/p-tech.htm .
Keep In the Loop!
Now, you can receive weekly updates through our new listserv to keep you posted on the latest news
about chemical accidental prevention and regulatory developments. We provide hotlinks to new
documents and cover a wide range of topics to give you a complete picture
of what is happening in the chemical safety arena.
To register now:
1. Send an e-mail to: listserver@unixmail.rtpnc.epa.gov (no quotation
marks).
2. Leave the subject area blank.
3. In the body of the message, write "SUBSCRIBE EPA-CEPP ", no
quotation marks. An example is: subscribe epa-cepp John Smith.
4. Send the e-mail with no further text in the body of the message.
5. Wait for the listserv confirmation of a completed subscription request.
Once you receive confirmation, usually within 24 hours, your listserv mail should be
activated. Retain the confirmation e-mail for future reference. Contact: Carole L. Cameron,
(202) 260-7938
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THE HIGH PRODUCTION VOLUME CHALLENGE PROGRAM
AND
SMALL BUSINESSES
U.S. EPA's Office of Pollution Prevention and Toxics
HPV Challenge Program Update:
June, 2000
The "High Production Volume" (HPV) Challenge Program is the result of separate studies by Environmental Defense (formerly
the Environmental Defense Fund), the American Chemistry Council (ACC) (formerly the Chemical Manufacturers Association),
and the EPA. Those studies confirmed that basic toxicity testing data were not publicly available for a great majority of the
industrial chemicals used in highest volume in the U.S. economy (those produced or imported in quantities of more than one
million pounds per year). Of the more than 2,800 chemicals that were identified as being HPV, 43 percent were found to have
absolutely no publicly available data, while only seven percent could be characterized as having the full set of data available.
Without this basic hazard information, it is difficult to make sound judgments about what potential risks these chemicals could
present to people and their environment.
The lack of data in the public domain prompted the Vice President in 1998 to challenge industry to supply the missing
information on a voluntary basis. The resulting HPV Challenge Program has been an ambitious effort to tackle the problem by
uncovering and assembling existing toxicity data that already exist outside of the public domain and then testing chemicals
where data gaps remain The final, and by no means least important part of the Program, will be to make these important data
readily available to scientists, policy makers, concerned citizens, communities, industry, environmental advocates, and the EPA.
Rising to the Challenge:
Since the HPV Challenge Program was announced in late 1998, over 430 companies, working either independently or through
155 consortia, have publicly committed to make screening level health and environmental hazard data publicly available by the
year 2005 on approximately 2,100 chemicals. Commitments to the HPV Challenge Program have come from companies and
consortia of all sizes around the world. There have even been commitments from companies that were not asked to participate,
while others have volunteered chemicals that were not on the original list. The Agency has now updated both the HPV
Challenge Program Chemical List and the 1994 List of HPV Additions to reflect responses that had been received through the
close of business on May 26, 2000. This most recent update captured all the commitments that had been received by the close of
the voluntary sign-up period on December 1, 1999. (Company and consortium letters that have been received since December 1,
1999, reflect clarifications to previously submitted commitments, rather than new commitments.) As of the present time, no new
commitments have been received. (A list of the currently sponsored HPV Challenge Program Chemicals can be found at
http://www.epa.gov/chemrtk/spnchems.htm, where there is also a link to the summary report of companies and consortia, as
well.)
Why Are Companies Participating?:
Many companies are participating because they understand that under the industry's principles of Responsible Care they can and
should do nothing less. They also were troubled when they saw how few HPV chemicals had complete public test data available
and they agreed that the existing gaps needed to be filled. In addition, they recognized that there were real practical advantages
to participating in a voluntary program, rather than waiting for the imposition of a test rule. For example, under the voluntary
program there is much more flexibility in the ways that the data can be acquired and made available. Now that the voluntary
sponsorship phase of the HPV Challenge Program has ended, any HPV chemicals that have not been sponsored are subject to
being included in a Test Rule under Section 4 of the Toxics Substance Control Act (TSCA). Under TSCA-directed testing there
is no such flexibility.
Who is Participating?:
It initially appeared that the majority of the companies who first signed up to sponsor chemicals, either individually or as part of
consortia, were among the larger companies in the industry. For example, about 70 percent of the largest Fortune Magazine
chemical companies are on the list of sponsoring firms (seven of the top ten firms and 18 of the top 25). Many of the sponsoring
companies are also members of one or more of the larger trade associations, such as ACC or the American Petroleum Institute
36
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(API), and are participating in consortia that are sponsored by those organizations. Early in the program, the smaller firms,
particularly those among the specialty and batch producing segment of the industry, had expressed concerns about their ability to
participate and were not as well represented on the sponsors' list. As the volunteer period drew to a close, however, many of the
smaller firms had also begun to respond -- particularly as members of the consortia that were established by the trade
associations that represent their segment of the industry The Synthetic Organic Chemical Manufacturers Association (SOCMA)
and its members can be specially recognized for their efforts here, as well as the members and trade associations of the dye and
pigments, and flavors and fragrance, industries.
It is important to note here that the actual conduct of the HPV Challenge Program should have only a minimal effect on small
business, since there already exists a small business exemption in TSCA-related activities, including the Inventory Update Rule
(IUR) reporting. Companies that produce less than 10,000 pounds of a substance per year are exempt from reporting under the
Inventory Update Rule (and it was the 1990 IUR which was used to generate the actual HPV Challenge Chemical list that is,
those chemicals for which the aggregate production volume was one million pounds or greater). Irrespective of their
participation in this program, our dialogues with the smaller companies and the trade organizations that represent them
continues. We remain committed to working with small businesses, particularly those within the specialty and batch chemical
industry and their representatives, on the issues of particular concern to them.
Key Dates and Timeline:
Companies had until December 1st, 1999 to sign-up and sponsor chemicals under the voluntary phase of the Program. At that
time the voluntary phase closed. Yet, some companies might still decide that they wish to enter into the HPV Program, either
individually or as members of the various consortia. In that case, they may still be able to participate prior to their chemicals
being listed on a final test rule. For example, they might be able to participate in either the International Council of Chemical
Associations (ICCA) or the Organization for Economic Cooperation and Development (OECD) international programs. In any
event, they should make their desires known to the Agency as soon as possible. One of the easiest ways to send a comment or
request information on the HPV program is through the ChemRTK web page at http://www.epa.gov/chemrtk . (Enter the site
and click on the "Submit Technical Questions" button.)
Although the period to sign up to sponsor HPV chemicals has ended, the actual program implementation and its generation of
the necessary testing information will continue through 2004 with all data to be available by 2005. Through both voluntary and
regulatory means, EPA will assure that testing and data collection will meet the goals set by the Vice President.
Next Steps:
Companies and consortia are now submitting the first test plans and robust summaries of the existing data that they
are uncovering. All information regarding these submissions is available on the ChemRTK website. Stakeholders
are encouraged to participate in the public review process and may comment on the completeness and adequacy of
these submissions by way of the "submit comments" button on the ChemRTK website.
Open Stakeholder Meetings:
While new rounds of stakeholder meetings have not yet been scheduled, it is all but certain that future meetings will be
scheduled as the program matures from its solicitation to its implementation phases.
How can you find out more about this Program?
For more information on the Program and to learn of new developments as they occur, you may visit our Web Site at
www.epa.gov/chemrtk.
How can you express your concerns/issues to EPA on this Program?
You may submit comments on our Web Site (www.epa.gov/chemrtk). as noted above, or you may contact the Office of Pollution
Prevention and Toxic's Small Business Liaison Frank Neumann at (202) 260-1772 or at neumann.frank@epa.gov.
In conclusion, we are interested in hearing any ideas you might have on how we might ensure that small business concerns are
well-represented, so please write me:
Frank Neumann
Office of Pollution Prevention and Toxics
Mailcode 7408
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
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Policy Office Builds Small Business
Sector Programs
Office of Policy, Economics and Innovation / Sector Strategies Division
Jbu/A
Sustainable _
Industry
Since 1993, EPA has been working in partnership with
industry sectors to find new ways to improve environ-
mental performance while easing the burdens of regula-
tion. The Office of Policy, Economics and Innovation
(OPEI) directs cross-media sector programs in which
government and other stakeholders team with businesses
to learn about factors that influence environmental man-
agement decisions (drivers-barriers analysis) and then
test ways to improve performance. OPEI helps put them
into operation if they bring cleaner, cheaper results.
After success using this approach with the metal finish-
ing industry, OPEI is now building new programs with
other small business sectors: meat processing, metal
casting, specialty-batch chemicals, ship building and
repair, and travel & tourism. OPEI also is leading de-
velopment of a 5-year sector strategy for EPA. Following
are just a few highlights of progress in all these areas.
TRAVEL & TOURISM: VOLUNTARY
ENVIRONMENTAL IMPROVEMENTS PLANNED
AT SKI AREAS
On June 14, EPA joined with the National Ski Areas As-
sociation in a partnership to assist the industry's efforts to
exceed environmental compliance requirements. The vol-
untary initiative establishes a set of principles for a broad
range of improvements in areas such as smart growth, air
quality and waste management. To support the ski indus-
try, EPA will provide technical assistance, using partner-
ship programs such as the Water Alliance for Voluntary
Efficiency, Waste Wise, Energy Star, Smart Growth, and
demonstration projects for environmental management
systems and transportation improvements. Other federal
agencies and non-profits are partners in the effort. For
more information, see: {HYPERLINK
http://www.epa.gov/ispd/travtour.htm }
CASTING INDUSTRY BEGINS PERFORMANCE
IMPROVEMENT PROJECTS
The metal casting industry recently decided to undertake
four projects with EPA and states to address performance
drivers and barriers. An air permitting New Source Re-
view Guidance Manual will be prepared to help metal
casters and regulators speed up the permit process and
improve compliance. A Beneficial Uses of Foundry Sand
project will help states decide safe uses for non-hazardous
spent sand and open markets for the material. Various
Environmental Assistance initiatives will improve com-
pliance and "beyond compliance" behavior. A Casting
Industry Stewardship Performance Track program will
provide incentives for exceptional environmental perform-
ance. EPA expects that use of these products and services
will bring significant environmental improvements in metal
castingparticularly air emissions reductions and waste
minimization.
BUILDING ENVIRONMENTAL STEWARDSHIP IN
THE MEAT PROCESSING INDUSTRY
Meat industry leaders have joined with EPA, USD A, and
states to identify opportunities for improving environmental
performance and act on them. Stakeholders have proposed a
five-point Meat Processing Environmental Stewardship Pro-
gram: a Performance Track similar to the one being devel-
oped by the casting industry (see above); a sector-specific
Environmental Management System; expanded compliance
assistance; External Stewardship initiatives for processors to
work with suppliers and communities; and environmental
research and technology development. Stakeholders will
define the program over the coming months.
METAL FINISHING: OPERATING PROGRAMS
UNDERWAY
OPEI's Sector Strategies Division leads the National Metal
Finishing Strategic Goals Program (SGP), a first-of-its-kind,
sector-wide environmental stewardship program. Participat-
ing companies voluntarily strive to achieve good compliance,
resource conservation, and emission reductions. Government
regulators at all levels provide assistance and remove barriers
to better performance, rewarding firms that show progress.
As of June, over 425 companies, 21 states, and 75 local gov-
ernments are partners with EPA in the SGP. Over 100 of
these stakeholders took part in the 2nd annual SGP summit
meeting in Chicago, sharing success stories, tackling com-
mon problems, and reviewing data on progress made to date.
SHAPING EPA'S SECTORS STRATEGY
OPEI/SSD is developing a five-year Agency sectors strategy.
Slated for release this fall, the strategy will serve as guide-
book to develop, implement, and measure progress in sector
work across EPA. It is being created in concert with the
multi-stakeholder National Advisory Council for Environ-
mental Policy and Technology (NACEPT) and EPA program
and regional offices. Sector work within EPA is now being
assessed: what work is underway in what parts of the
Agency, and how different projects are selected, managed,
implemented and measured. The strategy will contain a vi-
sion for the future of sectors, the current state of sectors, and
framework, implementation and measurement sections.
FOR MORE INFORMATION
Visit EPA's Sustainable Industry website at {HYPERLINK http://www.epa.gov/sustainableindustry }, or contact the Sector
Strategies Division, (202) 260-1246, US Environmental Protection Agency (Mail Code 2128), Washington, DC 20460.
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DfE: Environmental Health and Safety Consultant to Small Businesses
The Challenge
The EPA's Design for Environment (DfE) Program evaluates technology alternatives based on human health
and environmental risks, as well as performance and cost. DfE specializes in partnering with small business-
dominated industries, such as auto refmishing and printing, to help them incorporate these concerns into their daily
business practices. Small businesses usually do not have environmental, health and safety (EHS) personnel or
financial resources to address these matters. Therefore, DfE serves as a facilitator by providing resources and
consultation to them and their industry representatives.
DfE's Auto Refinish Project
The DfE Auto Refinish Project works with auto refmishers to identify and adopt safer, cleaner, and more
efficient technologies and practices. From an EHS perspective, the primary concern in auto refmishing is worker
exposure to harmful chemicals during the painting process, such as isocyanates, solvents, and paint additives.
Chemical releases to the surrounding community are alarming as well, especially when schools or residents are
within close vicinity to the shops. DfE provides industrial hygiene consultation to identify health and safety
improvements that will reduce chemical exposures and releases, while improving efficiency and decreasing costs.
DfE has developed expertise in best practices, as well as overcoming barriers to their use, through collaboration
with auto refmishing shops. DfE is partnered with the Pennsylvania Small Business Development Center to
encourage the adoption of these best practices and equipment. For example, DfE is working with shops in the
Philadelphia area to increase the use of HVLP (High Volume Low Pressure) spray guns which increase transfer
efficiency and reduce paint overspray and waste. HVLP guns decrease chemical exposure to workers and the local
community. In addition, less money is spent on the purchase of paint and waste disposal. DfE has also partnered
with CCARฎ (Coordinating Committee for Auto Repair) to develop a virtual autobody shop website (online at
www.ccar-greenlink.org). DfE's knowledge of the EHS aspects of auto refmishing is an invaluable resource for any
autobody shop desiring to increase worker health and safety in practical, affordable ways.
DfE's EMS: Screen Printing
The DfE/EMS, an enhancement of the ISO 14000 approach, is designed as a sector-specific tool for companies
to make informed decisions based on EHS information. DfE is currently working on an EMS pilot project with the
screen printing industry. Small businesses dominate this industry, with fifteen employees at the average shop. DfE
helps educate printers so that they can develop stronger roles in managing EHS matters in their businesses. The
EMS focuses on reducing wasted ink and minimizing VOC emissions, solid waste, and polluted wastewater so
printers can run their shops more efficiently. Marcia Kinter of the Screenprinting & Graphic Imaging Association
International (SGIA) describes the EMS as "a way of integrating environmental issues into your normal business
decision-making activities."
Overall, the DfE/EMS is a useful tool for any industry aspiring to manage EHS issues more effectively. DfE
encourages the use of EMS in other industry sectors. DfE has found that linking up with trade associations,
especially ones demonstrating commitment to environmental leadership, is an effective way to bring EMS to an
industry. If you believe your trade association may be a good DfE/EMS partner, please contact us.
The Bottom Line
As these examples demonstrate, DfE plays an important role in improving business practices by
analyzing current technologies and providing educational materials and training to small businesses. The
result thus far has been healthier, more profitable businesses. For more information about DfE, or to
obtain copies of DfE materials, please visit our website at www.epa.gov/dfe. If you have an interest in a
future DfE project, please call us at 202-260-1678.
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INNOVATIONS IN COMPLIANCE ASSISTANCE
It has been one year since the Environmental Protection Agency (EPA) released the
"Aiming for Excellence" Report. This Report, in part, committed EPA to take a number of
actions to enhance our compliance assistance efforts. In an earlier SBO newsletter we published a
detailed description of each project along with a request for your participation_to help in their
development. This article will discuss the remarkable work undertaken during the past year to
meet our compliance assistance commitments.
Compliance Assistance Advisory Committee
In the Fall of 1999, EPA's National Advisory Council on Environmental Policy and
Technology (NACEPT) created a new standing committee - the Compliance Assistance
Advisory Committee (CAAC). The CAAC's twenty-two members include representatives from
small and large businesses, trade associations, community and environmental groups, and state
and local governments. This group provides a continuing forum for the Agency to receive
valuable advice on compliance assistance activities. During their short tenure the CAAC helped
the Agency identify cross-cutting issues, plan for the Agency's Compliance Assistance Forum,
develop a Compliance Assistance Activity Plan, create a user-friendly virtual Clearinghouse and
provide recommendations for future compliance efforts. Details of these efforts are addressed
below.
Forum 2000
On March 1st and 2nd, EPA sponsored Forum-2000, Building Compliance Assistance
Partnerships, (Forum) in Atlanta, GA. Nearly 300 federal, state, local, and tribal government
officials as well as community and industry compliance assistance providers attended. The
Forum provided opportunities for compliance assistance providers to network, identify key
issues, share solutions and success stories. It also provided an opportunity for stakeholders to
provide input on EPA's first Annual Compliance Assistance Activity Plan and Clearinghouse.
Many topics were covered including opportunities to use compliance assistance for: going
beyond compliance with regulatory requirements; integrating compliance with other tools such
inspections and enforcement; and enhancing compliance at small- and large-sized facilities.
Participant feedback was so positive that EPA is considering a second Forum this winter. As
with Forum-2000, we hope to work with small businesses to develop the next Forum.
EPA Annual Compliance Assistance Activity Plan
In March of 2000, EPA completed a draft of the first Annual Compliance Assistance
Activity Plan (Plan). The goal of the Plan is to coordinate the key compliance assistance
activities across the Agency to ensure resource efficiency. The Plan lays out the Agency's
priorities and the type of compliance assistance to address those priorities. In turn, stakeholders
can use the information in the Plan to help focus their resources without duplicating EPA's
efforts and to identify opportunities for partnerships.
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To draft a Plan for FY 2001 and to begin thinking about subsequent Plans, EPA solicited
stakeholder feedback through the Forum 2000, the Federal Register and other meetings held by
various EPA offices including our Small Business Office. We received valuable comments
from the small business community and other stakeholders that were reviewed by both the
Agency and the CAAC.
The CAAC drafted consensus recommendations on the Plan which are expected to be
finalized and submitted to EPA's Administrator this July. The recommendations will be
available on the Compliance Assistance Project web site at www.seattle.battelle.org/epa-icaa.
EPA is reviewing the comments to help enhance the FY 2001 Plan and subsequent Plans.
Our goals are to 1) identify an approach for working with stakeholders throughout the year to
identify your compliance assistance needs and opportunities for partnerships; 2) provide timely
recommendations for identifying Agency priorities to ensure Agency resources are targeted to
the most significant problems; and 3) collaborate across the Agency's offices to use the expertise
and resources necessary.
Compliance Assistance Clearinghouse
In response to the need for having a central repository of compliance assistance
information and resources, EPA is developing a Compliance Assistance Clearinghouse
(Clearinghouse). The Clearinghouse is intended to be the gateway for easy access to compliance
assistance materials by providing links to EPA, state and other compliance assistance providers'
web sites. It is also intended to help build a closer network and stronger community for those
who provide compliance assistance. The three main components of the Clearinghouse to help
achieve these goals are: 1) a providers directory to facilitate referrals and finding experts 2) a
user-friendly navigation system that allows users to quickly locate compliance assistance tools
and information and 3) a communications forum to foster exchange of new ideas and
information.
During the development of the Clearinghouse EPA received input from the Forum 2000,
the CAAC, and from various organizations such as the Small Business Assistance Providers and
the Pollution Prevention Technical Assistant Providers. The Clearinghouse is scheduled to be
operational in September 2000.
Our objective is to ensure that the users can access information from all compliance
assistance providers quickly through the Clearinghouse. This requires direct links to relevant
information on your web sites. Therefore, the full participation of compliance assistance
providers is key to the success of the Clearinghouse. You can provide us links to your web site
by using the "add-a-link" feature in the Clearinghouse test site at
www.seattle.battelle.org/clearinghouse.
Future Direction
EPA looks forward to continuing to strengthen our partnership with small businesses and
other stakeholders. We need your involvement to assure that the small business community
needs are heard as we continue to improve the environment through compliance assistance. For
additional information on these projects or how to participate contact: Gina Bushong at 202-
564-2242.
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EPA Issues Five More Audit Protocols for Three Statutes;
Four More Under Development
EPA recently issued five more voluntary environmental compliance audit protocol manuals as part of an on-going
effort to produce a set of 13 multi-media document to assist the regulated community, including small businesses, in
conducting environmental audits. The five audit protocols EPA issued in May 2000 include coverage of the Resource
Conservation and Recovery Act (RCRA), The Safe Drinking Water Act (SDWA), and the Toxic Substance Control Act
(TSCA). The RCRA protocols issued in May include, RCRA regulated storage tanks (above and underground storage
tanks), universal waste and used oil under RCRA, and RCRA Subtitle D waste. EPA also issued audit protocols for
PCBs, asbestos and lead-based paint regulated under TSCA, and, public water systems regulated under the Safe
Drinking Water Act.
To date EPA has produced a total of nine audit protocol documents including the first four produced last year
(hazardous waste generators under RCRA, RCRA treatment storage and disposal facilities, EPCRA and CERCLA).
EPA developed these protocols in support of several EPA policies and programs, such as EPA's Small Business
Policy which is designed to promote environmental compliance by providing compliance assistance and incentives like
penalty waivers to eligible facilities with 100 or fewer employees. In addition, the protocols were designed to
encourage businesses and organizations to perform environmental audits and disclose violations in accordance with
EPA's Audit Policy. The audit protocols are intended to help provide guidance to regulated entities conducting
environmental compliance audits and to ensure that audits are conducted in a thorough and comprehensive manner.
Each protocol offers guidance on key requirements, defines regulatory terms, and provides an overview of the
federal laws affecting a particular environmental management area. It also includes a checklist containing detailed
procedures for conducting a review of facility conditions. The checklists actually outline performance objectives for
the auditor and offer a line of inquiry when evaluating a facility for compliance.
Nine of the audit protocols have already been completed and are available to the public: These include the
folio whig documents (by title):
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under the Resource
Conservation and Recovery Act (EPA Document No., EPA-305-B-98-005)
Protocol for Conducting Environmental Compliance Audits of Treatment Storage and Disposal Facilities under the
Resource Conservation and Recovery Act (EPA Document No., EPA-305-B-98-006)
Protocol for Conducting Environmental Compliance Audits Under the Emergency Planning and Community Right-
to-KnowAct (EPA Document No., EPA-305-B-98-007)
Protocol for Conducting Environmental Compliance Audits Under the Comprehensive Environmental Response,
Compensation and Liability Act (EPA Document No., EPA-305-B-98-009).
Protocol for Conducting Environmental Compliance Audits of Facilities Regulated under Subtitle D of RCRA (EPA
Document No., EPA-300-B-00-001)
Protocol for Conducting Environmental Compliance Audits of Used Oil and Universal Waste Generators under the
Resource Conservation and Recovery Act (EPA Document No., EPA-300-B-00-002)
Protocol for Conducting Environmental Compliance Audits of Storage Tanks under the Resource Conservation and
Recovery Act (EPA Document No., EPA-300-B-00-006)
Protocol for Conducting Environmental Compliance Audits of Facilities with PCBs, Asbestos, and Lead-based Paint
Regulated under TSCA (EPA Document No., EPA-300-B-00-004)
Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking Water
Act (EPA Document No., EPA-300-B-00-005)
EPA expects to issue four more audit protocols to the public by December 2000 including: Management of
Pesticides; Clean Air Act; Clean Water Act; and TSCA.
You can obtain hard copies of the protocols by contacting EPA's National Service Center for Environmental
Publications (NSCEP) at 1-800-490-9198. When ordering copies from NSCEP, please reference the title and the
document number of the protocol(s) you've selected. The protocols can also be obtained electronically via EPA's Web
site: www.epa.gov/oeca/ccsmd/profile.html. For further information on the protocols, contact Richard Satterfield
(202) 564- 2456.
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United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA's Small Business
Innovation Research
(SBIR) Program
The Environmental Protection Agency (EPA) is one of 10 federal agencies that
participate in the SBIR Program established by the Small Business Innovation
Development Act of 1982. The purpose of this Act was to strengthen the role of
small businesses in federally funded R&D and help develop a stronger national base
for technical innovation. A small business is defined as a for profit
organization with no more than 500 employees. In addition, the small
business must be independently owned and operated, not dominant in the field of
operation in which it is proposing, and have its principal place of business located in
the United States. Joint ventures and limited partnerships are eligible for SBIR
awards, provided the entity created qualifies as a small business.
EPA issues annual solicitations for Phase I and Phase II research proposals from
science and technology-based firms. Under Phase I, the scientific merit and technical
feasibility of the proposed concept is investigated. EPA awards firm-fixed-price Phase
I contracts of up to $70,000 and the period of performance for these contracts is
typically 6 months. Through this phased approach to SBIR funding, EPA can
determine whether the research idea, often on high-risk advanced concepts, is
technically feasible, whether the firm can do high-quality research, and whether
sufficient progress has been made to justify a larger Phase II effort. The Phase I
report also serves as a basis for follow-on commitment discussions.
Phase II contracts are limited to small businesses that have successfully completed
their Phase I contracts. The objective of Phase II is to further develop the concept
proven feasible in Phase I. Competitive awards are based on the results of Phase I
and the scientific and technical merit and commercialization potential of the Phase II
proposal. Under Phase II, EPA can award contracts of up to $295,000 and the
period of performance is typically 2 years. The goal of Phase II is to complete die
R&D required to commercialize the technology or product.
EPA's next Phase I Solicitation will open on March 29,2001, and will
close On May 24, 2001. The solicitation will be posted on the National Center
for Environmental Research WEBSITE at:
http://www.epa.gov/ncerqa/sbir
Please note that the last Phase I solicitation, which closed on May 25, 2000, is still
on the WEBSITE for informational purposes only. The solicitation includes a
description of the program and descriptions of typical topic areas. The solicitation
also is available by fax. If you need a fax copy of last year's solicitation or if you have
any questions, please call the EPA SBIR Helpline at:
1-800-490-9194
43
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CAGE is a free Internet pollution prevention tool designed to aid coaters
of metal and plastic substrates. CAGE identifies low-emitting coating
alternatives as potential drop-in replacements for current processes.
Expert System
Based on users' answers to questions, CAGE provides a relative
ranking of coating choices. Each technology is hyperlinked to
summarized information like process considerations, application
methods, and case studies.
Coatings Alternatives
CAGE compiles information on over 25 different, generic coating
chemistries including solvent-borne, water-reducible, and solvent-
free coatings (e.g., powders, radiation-curable). On-line
information is summarized from various coatings journals, trade
publications, engineering manuals, and expert advice.
( -- - ~
. - Process Conversions
Users can estimate the costs involved when switching from their
current coating process to a new coating technology. Applied
material, equipment, energy, and labor costs are some of the costs
included in the conversion cost tool.
Product Guide (Coming Soon!)
CAGE will provide lists of low-emitting paint formulations. Users
can search for coating chemistries by VOC content, producer's
name, and type of coating. For more information, users can
hyperlink directly to a manufacturer's contact name and number.
uidien
>..,v^-, .. ,. .--.-.-f- Y '.gp-^JV? .--.---- - --.- : .-.yj,--^^v-Wi-^.--^H-;;
audience includes small- and medium-sized
businesses that coat metal and plastic parts, state technical assistance
offices, and anyone seeking information on coatings.
http://cage.rti.org
CONTACT: Dean Cornstubble, RTI (919) 541-6813, dean@rti.org and Michael Kosusko, EPA (919) 541-2734, kosusko.mikeฎ epa.gov
ฉResearch Triangle Institute, 1999.
-------
f Compliance^.
I AssistanceN
Access the Compliance Assistance
Centers at www.assistancecenters.net
The U.S. Environmental Protection
Agency has sponsored partnerships
with industry, academic institutions,
environmental groups, and other federal
and state agencies to establish
Compliance Assistance Centers for ten
industry and government sectors.
If you own a small business in one of
these sectors, these resources can
help you understand your environmen-
tal obligations, improve compliance,
and find cost-effective ways to comply.
CCAR-GreenLinkฎ
Helps the automotive service and
repair community identify flexible,
common sense ways to comply with
environmental requirements.
www.ccar-greenlink.org
ChemAlliance
Provides innovative Web site
features to direct chemical manufacturers to
information resources and plain-language
compliance assistance material.
www.chemalliance.org
Local Government Environmental
Assistance Network (IGEAN1
Serves as a "first-stop-shop" by provid-
ing environmental management, plan-
ning, and regulatory information for
local government officials, managers, and
staff, www.lgean.org
National Agriculture Compliance
Assistance Center tAg Center)
Serves as the "first stop" for informa-
tion about environmental require-
ments that affect the agriculture com-
munity. www.epa.gov/oeca/ag
(This is a government run center)
LGEAN
Ag Centers
National Metal Finishing
Resource Center
National Metal Finishing Resource
Center (NMFRC)
Provides comprehensive environ-
mental compliance, technical assistance, and
pollution prevention information to the metal
finishing industry, www.nmfrc.org
RCRC
Paints and Coatings
Resource Center
Paints and Coatings
Resource Center
Provides regulatory compli-
ance and pollution prevention
information to organic coating facilities,
industry vendors and suppliers, and others.
www.paintcenter.org
Printed Wiring Board ซป-.,..-
Resource Center *"ซ""Cent"
Provides regulatory compliance and pollution
prevention information to printed wiring
board manufacturers, industry vendors and
suppliers, and others, www.pwbrc.org
Printers' National Environmental
Assistance Center (PNEAC)
Provides compliance and pollu-
tion prevention fact sheets, case studies, and
training, as well as two e-mail discussion
groups on technical and regulatory issues.
www.pneac.org
Transportation Environmental IEEESฉ
Resource Center (TERC)
Provides compliance assistance information
for each mode of transportation - air, ship-
ping and barging, rail, and trucking.
www.transource.org
Fed Site
Serves as the "first stop" for infor-
mation about environmental laws
and regulations that affect Federal
departments and agencies.
www.www.epa.gov/oeca/fedfac/cfa
(This is a government run center)
For more information, contact Tracy Back, 202-564-7076 or e-mail: back.tracy@epa.gov
45
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What do the Centers Provide?
Each Center can help small businesses in
specific sectors by providing relevant fed-
eral environmental regulations in plain
language. Visit the Centers to obtain:
Updates on industry-specific
regulatory develop-
ments
Sector-specific regulato-
ry explanations
Compliance tools
Process-specific training
A place to ask questions
and get answers
Databases on technolo-
gies and techniques
Pollution prevention
tips and ideas
Links to other assis-
tance providers, ven-
dors, & suppliers
Contact points for
responses to specific
compliance questions
and answers
the Centers is increasing steadily. At the
time of this printing, the Centers are vis-
ited over 890 times a day by businesses,
farmers, local governments, federal facili-
ties, and technical assistance providers.
/ am made
aware of topics
that I normally
would not be
notified for sev-
eral months."
Are the Centers
being usedP
Businesses, local govern-
ments, and assistance
providers are using the
Centers to get answers to
their compliance questions.
In 1999, the Centers experienced over
260,000 visits. And we see that use of
The Centers are being used - and use is on
the rise. And through use, the Centers are
helping the regulated community address
environmental problems, save money
through actions taken, and make environ-
mental improvements.
"Identified
requirements
that I was
unaware of and
information on
different means
to comply**
Oo the Centers help busi-
nesses and local govern-
ments better understand
applicable environmental
requirements?
Survey data demonstrates
that Center users find the
Centers very useful and
use improves environmental
performance! Based on eight
voluntary Internet surveys,
over 70% of the company and
local government respon-
dents said they took one or
more positive action
(e.g.,changing the handling of
waste, obtaining a permit,
changing a production
process, contacting a regula-
tory agency) as a result of
Center use and over 50% of
these companies and local
governments felt they had a
cost savings resulting from
these actions when applica-
ble. Furthermore, over 58%
of company and local government respon-
dents stated that they realized one or
more environmental improvements as a
result of using a Center (e.g. reduced air
emissions, conserved water).
Visit the Centers as a "first stop" for sector-
specific compliance assistance support
46
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EPA POLICIES ASSIST SMALL BUSINESSES WITH ENVIRONMENTAL COMPLIANCE
EPA's Office of Enforcement and Compliance Assistance (OECA) has recently revised the following policies to respond to the environmental
compliance needs of small business: \Pohcyon Compliance Incentivesfor SmallBusmess^-andthe Final Policy on Environmental Self-Auditing and Self-
Disclosure. The Enforcement Response Policy was not modified. Under these policies, the Agency will protect public health and the environment by
providing small businesses with incentives to proactively pursue environmental compliance and pollution prevention activities. These policies are briefly
described below
SMALL BUSINESS COMPLIANCE POLICY
EPA issued the revised Small Businesses Compliance Policy, effective May 11, 2000, to provide small businesses with incentives to participate
in compliance assistance activities and programs, or conduct environmental audits. This policy supersedes the June 1996 version and expands upon
EPA's 1994 Enforcement Response Policy under the Clean Air Act Section 507. The policy implements, in part, the Executive Memorandum on
Regulatory Reform (60 FR 20621, April 26, 1995) and Section 223 of the Small Business Regulatory Enforcement Fairness Act of 1996 (signed into
law on March 29, 1996) (SBREFA). Under this policy, EPA will eliminate or reduce civil penalties provided the small business satisfies all of the
following four criteria:
The small business has voluntarily discovered a violation These may be discovered by the business by participating in compliance assistance
programs, mentoring, use of checklists from the Internet or by voluntary audits.
The small business voluntarily discloses the violation within 21 days. This disclosure must be sent in writing to the regulatory agency. Businesses
may disclose to the EPA Region or to the appropriate State and Tribal agencies if they have similar policies.
The small business corrects the violation and remedies any associated harm within 180 days of discovery; an additional 180 days may be granted
if pollution prevention technologies are being used.
The small business has not used this Policyor been subject to enforcement action for the same or similar violation in the past three years and has
not been subject to two or more enforcement actions for environmental violations in the past five years. The violation has not caused serious harm
to public health, safety, or the environment; it does not present imminent and substantial endangerment to public health or the environment; and
it does not involve criminal conduct.
Please see the actual Policy for more specifics on the criteria and on violations that are ineligible. Information about using the Policy, questions and
answers, and the types of violations that have been disclosed will be posted and periodically updated on the website. For more specific information on
this policy, contact Ginger Gotliffe, Office of Compliance, at (202) 564-7072 or visit http://www.epa gov/oeca/smbusi.html
POLICY ON ENVIRONMENTAL SELF-POLICING
EPA issued the revised Final Policy on "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations" in the Federal
Register on April 11, 2000 (65 Fed. Reg. 19,617). Commonly referred to as the EPA Audit Policy, it provides regulated entities of all sizes with
incentives to voluntarily discover, disclose, and correct violations of environmental laws and requirements.. Under the Audit Policy:
EPA will not seek gravity-based penalties from entities that systematically discover potential environmental violations, promptly disclose them to
EPA, expeditiously correct them and meet all other conditions of the Policy.
For entities that disclose violations that were not systematically discovered, EPA will reduce gravity-based penalties by 75% provided all other
Policy conditions are met.
EPA will generally not recommend criminal prosecution for entities that discover, promptly disclose, and expeditiously correct violations which
are potentially criminal, provided all other Policy conditions are met.
The Policy excludes repeat violations, violations that result in serious actual harm and violations that may present an imminent and substantial
endangerment. EPA retains its discretion to recover any economic benefits realized as a result of noncompliance.
Issuance of the revised Policy followed a two-year evaluation of the 1995 Audit Policy. Key revisions include lengthening the period for prompt
disclosure from 10 to 21 days, clarifying that the Audit Policy is available in the multiple-facility context, and clarifying how the prompt disclosure and
repeat violation conditions apply in the acquistions context.
For more information on this policy, contact Catherine Malinin Dunn at (202) 564-2629
ENFORCEMENT RESPONSE POLICY
EPA issued the Enforcement Response Policy, effective August 12,1994, to provide small businesses with a limited grace period to correct violations
revealed during requested assistance from a State Small Business Assistance Program (SBAP) established under Section 507 of the Clean Air Act. Under
the policy, two options are provided:
SBAPs may offer small businesses a limited correction period for violations detected during compliance assistance. Small businesses may have
up to 90 days to receive compliance assistance from the SBAPs, with the possibility of an additional 90 days to correct any violations discovered
under the program. After that time, violations would be subject to existing enforcement policies.
SBAPs may offer compliance assistance on a confidential basis. Under this option, the state retains the ability to investigate and/or take enforcement
actions at any time for violations discovered independently from the Section 507 program. Under the Small Business Compliance Policy, small
businesses that receive confidential assistance from the SBAP may receive a correction period if the small business voluntarily discloses the violation
to the appropriate regulatory agency.
For more information on this policy, contact Ginger Gotliffe at (202) 564-7072.
For copies of these policies, call (800) 368-5888 and ask for Item 13.
47
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EPA'S REVISED AUDIT POLICY - Effective May 11, 2000
General Information
Formal Title: "Incentives for Self-Policing:
Discovery, Disclosure, Correction
and Prevention of Violations"
Citation: 65 FR 19,617 (April 11, 2000)
Web Site: www.epa.gov/oeca/auditpol.html
Purpose - To encourage regulated entities to
voluntarily discover, disclose, correct and prevent
violations of Federal environmental requirements
Incentives Available Under the Audit Policy
Penalty mitigation - Entities that meet all of the
conditions contained in the Audit Policy are eligible
for 100% mitigation of all gravity-based penalties.
Entities that meet all of the conditions except for
"systematic discovery" of violations are eligible for
75% penalty mitigation. EPA retains its discretion to
collect any economic benefit that may have been
realized as a result of noncompliance.
No recommendation for criminal prosecution -
For entities that disclose violations of criminal law
and meet all applicable conditions under the Policy,
the Agency will refrain from recommending criminal
prosecution for the disclosing entity.
No routine requests for audit reports - In general,
EPA will not request audit reports from those who
disclose under the Audit Policy.
To Make a Disclosure Under the Audit Policy
Disclosures of civil violations should be made to the
EPA Region in which the entity or facility is located
or, where multiple Regions are involved, to EPA
Headquarters. For more information, contact Leslie
Jones at 202-564-5123.
Disclosures of criminal violations should be made to
the appropriate EPA criminal investigation division,
to EPA Headquarters, or to the U.S. Department of
Justice. For more information, contact Michael
Penders at 202-564-2526.Conditions of the Audit
Policy - Entities that satisfy the following conditions
are eligible for Audit Policy benefits. (Note: entities
that fail to meet the first condition - systematic
discovery - are eligible for 75% penalty mitigation
and for no recommendation for criminal
recommendation).
Systematic discovery of the violation through an
environmental audit or a compliance management
system.
Voluntary discovery, that is, not through a legally
required monitoring, sampling or auditing procedure.
Prompt disclosure in writing to EPA within 21 days
of discovery or such shorter time as may be required
by law (discovery occurs when any officer, director,
employee or agent of the facility has an objectively
reasonable basis for believing that a violation has or
may have occurred).
Independent discovery and disclosure, before EPA
likely would have identified the violation through its
own investigation or based on information provided
by a third-party.
Correction and remediation within 60 calendar
days, in most cases, from the date of discovery.
Prevent recurrence of the violation.
Repeat violations are ineligible, that is, those that
have occurred at the same facility within the past 3
years or those that have occurred as part of a pattern
of violations within the past 5 years at another
facility(ies) owned or operated by the same company;
if the facility has been newly acquired, the existence
of a violation prior to acquisition does not trigger the
repeat violations exclusion.
Certain types of violations are ineligible - those
that result in serious actual harm, those that may
have presented an imminent and substantial
endangerment, and those that violate the specific
terms of an administrative or judicial order or
consent agreement.
Cooperation by the disclosing entity is required.
48
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EPA's Small Business Compliance Policy
Background and Purpose
This Policy promotes environmental compliance among small businesses by providing them with special
incentives. EPA will eliminate or reduce penalties for small businesses that voluntarily discover, promptly
disclose, and correct violations in a timely manner.
EPA wants to encourage small businesses to learn about environmental compliance and pollution
prevention through the wide range of training, checklists, mentoring, and other activities now available to
small businesses through regulatory agencies, private organizations, non-profit organizations, and the
Internet. Therefore small businesses that voluntarily discover a violation because they utilized these types
of activities may have the penalty eliminated if they meet all the criteria in the Policy.
Effective Date and Citation
This Policy is effective May 11, 2000 and supersedes the June 1996 version. It was published in the
Federal Register on April 11, 2000, 65 FR 19630.
Who Qualifies to Use this Policy
For purposes of this Policy, a small business is defined as a person, corporation, partnership, or other entity
that employs 100 or fewer individuals across all facilities and operations owned by the entity. Entities can
also include small governments and small organizations.
How to Qualify for Penalty Elimination or Reduction
EPA will eliminate the entire civil penalty* if a small business satisfies all four of the criteria below:
O The small business voluntarily discovers a violation. Violations could be discovered after
attending training classes or seminars, receiving on-site compliance assistance, participating in
mentoring programs, or using compliance guides or checklists downloaded from the Internet.
ฉ The small business voluntarily discloses the violation within 21 days. This disclosure must be sent
in writing to the regulatory agency.
ฎ Corrections Period - the business corrects the violation and remedies any damage associated with
the violation within 180 days of its discovery. However, if the correction will take longer than 90
days, a written schedule will be necessary. For small businesses that are correcting the violation
by using pollution prevention technologies, they may have an additional period of 180 days, i.e.
up to a period of 360 days.
O The Policy applies if the:
a. violation has not caused actual serious harm to public health, safety, or the environment;
b. violation is not one that may present an imminent and substantial endangerment to public
health or the environment;
c. violation does not involve criminal conduct;
d. facility has an appropriate compliance record. The small business hasn't used this Policy
for a violation of the same or similar requirement within the past 3 years and has not
been subject to two or more enforcement actions for any environmental violations in 5
years; and
e. violation has not already been discovered by the agency through inspections or citations,
or other methods. A legally required monitoring procedure was not violated.
49
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Please see the actual Policy for more specifics on the criteria and on violations that are ineligible.
*In the rare instance where the small business has obtained a significant economic benefit from the
violation(s) (i.e., economic advantage over its competitors), EPA will waive 100% of the gravity
component of the civil penalty, but may seek the full amount of any economic benefit associated with the
violations. As of March 2000, EPA has never sought to collect economic benefit since this Policy was
originally issued in 1996.
Applicability to States
EPA will defer to comparable State and Tribal Policies if they are generally consistent with this Policy.
For More Information contact Ginger Gotliffe at 202-564-7072 or visit http://www.epa.gov/oeca/smbusi.html
Information about using the Policy, questions and answers, the types of violations that have been disclosed and any
disclosures that have prompted EPA to collect economic benefit will be posted and periodically updated on the
website.
Listed below are the regional contacts for the Policy and small business issues. The Small Business Liaisons may
also be able to provide more general information on compliance assistance and this Policy.
EPA Regional Contacts
Policy Contacts
Small Business Liaison
Region 1:
Region 2:
Region 3:
Region 4.
Region 5:
Region 6:
Region 7:
Region 8:
Region 9:
Region 10:
Joel Blumstein
Sam Silverman
Daniel Kraft
John Wilk
Janet Viniski
Lydia Isales
Angela Blackwell
Bill Anderson
Carol Baschon
Bertram Frey
Tmka Hyde
Jodi Swanson-Wilson
Marcia Moncrieffe
Efren Ordonez
Charles Sheehan
Becky Dolph
David Rochlin
Leslie Guinan
George Hays
Brian Riedel
Jackson Fox
Meg Silver
Adan Schwartz
617-918-1771
617-918-1731
732-321-6669
212-637-3918
215-814-2999
215-814-2648
404-562-9527
404-562-9680
404-562-9528
312-886-1308
312-886-9296
312-886-0879
214-665-7343
214-665-2181
214-665-2175
913-551-7281
303-312-6892
415.744.1339
415-744.1399
415-744-1380
206-553-1073
206-553-1476
206-553-0015
Dwight Peavey
John Wilk
David Byro
Annette Hill
Glynis Zywicki
David Gray
Jan Lambert
Rob Laidlaw
Mark Samohs
Bill Dunbar
617-918-1829
212-637-3918
215-814-5563
404-562-8287
312-886-4571
214-665-2200
913-551-7768
303-312-7064
415-744-2331
206-553-1138
SBCP Fact Sheet June 2000
50
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STATE SMALL BUSINESS ASSISTANCE PROGRAMS
SMALL BUSINESS SPECIAL NEEDS:
Congress recognized the particular problems that many small businesses would have in dealing with the 1990
Clean Air Act Amendments complex requirements. A typical small business employs fewer than 50 people, and is
the only business operated by the owner. It is the corner dry cleaner, the "mom and pop" bakery, the auto body
repair shop, gasoline service station, the machine, tool and dye company, or one of a host of other local business
establishments. Many have been in the same family and neighborhood for generations.
Air pollution control regulation may seem very complex to many small businesses. Many may not be able to
afford to hire lawyers or environmental specialists to interpret and comply with all the requirements they may be
responsible for in the new Act. Most may be hard pressed to inform themselves about the most basic requirements
and deadlines of the control programs that will affect them, let alone the more complicated issues they are going to
have to address to control air emissions, such as:
The types of pollutants their company emits that are subject to the Act's requirements;
The methods they can use to estimate emissions for a permit application;
The types of control technologies that are best and least costly for controlling a specific production process
or chemical substance they use to make goods and services; and
Process or substance substitutes they can use to prevent or reduce emissions.
STATE LEAD FOR PROVIDING SMALL BUSINESS ASSISTANCE:
The 1990 Clean Air Act Amendments gives each state government the lead in developing and implementing a
Small Business Technical and Environmental Compliance Assistance Program as part of legally enforceable state
implementation plans.
THE ACT'S DEFINITION OF A SMALL BUSINESS:
The Act establishes certain criteria that a company must meet to qualify for assistance as a small business. It
must be a small business as defined in the Small Business Act which generally means that it is an independently
owned and operated concern that is not dominant in its field. The business must be owned by a person who
employs 100 or fewer individuals, and cannot be a major stationary source of either a primary urban (so called
"criteria") pollutant or toxic air pollutant. It cannot, in fact, emit 50 tons or more of a single pollutant a year, or
more than 75 tons of all regulated pollutants. State governments can modify some of these requirements provided
that the particular source does not emit more than 100 tons a year of all regulated pollutants.
FEDERAL OVERSIGHT AND SUPPORT:
EPA will be providing several forms of guidance and assistance to these state assistance programs for the full
duration of the Act.
Federal Guidelines: EPA published final guidelines for states to draw upon to develop their assistance
programs. The Agency has approved each state compliance and assistance program to ensure that it meets the
Act's requirements.
Oversight and Monitoring: The EPA Small Business Ombudsman oversees and monitors all state assistance
programs and makes periodic reports to Congress on each state's progress. Among other things, the EPA
Ombudsman determines how well the state programs are working and makes sure that the information and
assistance the states provide is understandable to the layman.
Technical Assistance and Research: EPA shares information and research that it has developed nationally
with each state assistance and compliance program. States are able to receive technical assistance through
several EPA Centers and Hotlines. These Centers and Hotlines provide a broad range of assistance including
information concerning the Clean Air Act requirements, control technology data, pollution prevention methods
and alternatives, emission measurement methods, air pollution monitoring devices, and prevention of accidental
releases of toxic chemicals into the environment.
51
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COMPONENTS OF AN OVERALL STATE ASSISTANCE PROGRAM
By November, 1992, each state was required to develop a plan for implementing a Small Business Stationary Source
Technical and Environmental Compliance Assistance Program. Congress envisioned that these programs would be in place
before small businesses begin to feel the direct effects or deadlines of the Act.
Each state program is required to include three components: (1) appointment of a state small business ombudsman; (2)
establishment of a comprehensive small business assistance program; and, (3) appointment of a seven-member state compliance
advisory panel.
1. State Ombudsman: The first component is the State Ombudsman who acts as the small business community's
representative in matters that affect it under the Clean Air Act. Other responsibilities of the State Ombudsman could
be to:
Review and provide comments and recommendations to EPA and state/local air pollution control authorities
regarding the development and implement of regulations that impact small businesses;
Help disseminate information about upcoming air regulations, control requirements, and other pertinent matters
to small businesses;
Refer small businesses to the appropriate specialists in state government and elsewhere for help with particular
needs (e.g., available control technologies and operating permit requirements); and,
Conduct studies to evaluate the effects of the act on state and local economies, and on small businesses generally.
2. Small Business Assistance Program (SBAP): The second component of the overall state program is the Small Business
Assistance Program which is the technical and administrative support component within the state government. The
SBAP staff has access to air quality experts, technically proficient engineers, scientists and managers, and environmental
specialists who provide support and technical assistance needed by small businesses to comply with the Act's
requirements. Related responsibilities include:
Informing businesses of all requirements in the Clean Air Act that apply to them and the dates these requirements
will apply;
Helping small businesses deal with specific technical, administrative and compliance problems;
Disseminating up-to-date information about the Clean Air Act to the small business community, including easy to
understand public information materials; and,
Referring small businesses to environmental auditors who can evaluate how effective a company's work practices,
monitoring procedures, and record-keeping are for complying with applicable clean air requirements.
3. State Compliance Advisory Panel: The third component of the overall state assistance program consists of a seven-
member state compliance advisory panel in each state for determining the overall effectiveness of the state SBAP. Four
of these members must be small business owners or representatives selected by the state legislature; the governor of each
state selects two other members to represent the "general public." The seventh member is chosen by the head of the
state agency responsible for issuing operating permits.
The State compliance advisory panels reviews and renders advisory opinions on the effectiveness of the state SBAP,
and makes periodic progress reports to EPA's Small Business Ombudsman concerning compliance of the small business
program with other pertinent federal regulations. The compliance advisory panels also makes certain that information
affecting small business is written in a style that is clear and understandable.
TYPES OF BUSINESSES SUBJECT TO AIR POLLUTION CONTROLS
This is a general list of the typical kinds of small type businesses affected by one or more of the air pollution control
programs under the 1990 Clean Air Act Amendments. All small businesses should consult their state pollution control agency
for more specific details about the controls that will be required in their area.
Agricultural Chemical Applicators Furniture Manufacturers Newspapers
Asphalt Manufacturers Furniture Repairs Pest Control Operators
Asphalt Applicators Gasoline Service Stations Photo Finishing Laboratories
Auto Body Shops General Contractors Printing Shops
Bakeries Hospitals Refrigerator/Air Conditioning
Distilleries Laboratories Service and Repair
Dry Cleaners Lawnmower Repair Shops Tar Paving Applicators
Foundries Lumber Mills Textile Mills
Metal Finisners Wood Finishers
52
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JULY 2000 CLEAN AIR ACT
SMALL BUSINESS OMBUDSMEN AND TECHNICAL ASSISTANCE DIRECTORS
STATE
AL
AK
AZ
AZ
MARICOPA COUNTY
AR
CA
CA
South Coast AQMD
CO
CT
DE
DC
FL
GA
HI
ID
IL
IA
IN
KS
KY
LA
MA
MD
ME
MI
MN
MO
MS
OMBUDSMAN
Blake Roper
Tom Turner
Kathleen Tschogl
La Ronda Bowen
Cathy Heald
Tracy Babbidge
To be Announced
Sandra Handon
Elsa Bishop
Marvin Lowry
Patrick Felling
Sally Tarowsky
Don Squires
Linda King
Erika Seydel-Cheney
Janet Neff
Rose Marie Wilmoth
Jim Friloux
Don Jackson
Ron Dyer
Dana Cole
Charlie Kennedy
Angie Heffner
Jesse Thompson
PHONE
(334) 394-4335
(N) (800) S33-2336
(907) 269-7582
(800J-510-2332
(916)323-6791
(S) (800) 272-4572
(909) 396-3235
(S)(800)388-2121
(303) 692-2034
(S) (800) 886-7689
(860) 424-3382
(S) (800) 760-7036
(302) 739-6400
(202) 535-2255
(850) 414-8399
(S) 800-722-7457
(404) 362-2656
(808) 586-4527
(208) 373-0472
(217) 785-1625
(S) (888) 372-1996
(N) (515) 242-4761
(S) (800) 358-5510
(317)232-8598
(S) (800) 451-6027
(785) 296-0669
(N) (800) 357-6087
(502) 564-2150 X128
(N) (800) 926-81 11
(225) 765-0735
(S) (800) 259-2890
(410) 631-3165
(S) (800) 633-6101, X 3772
(207) 287-4152
(S) (800) 789-9802
(517) 241-3518
(651) 297-8615
(S) (800) 985-4247
(573) 751-3222
(N) (800)361-4827
(601) 961-5167
(N) (800)725-6112
TECH. ASST. DIR.
Mike Sherman
Tom Chappie
Jack Bale
Richard Polito
Joe Bob Garner
Peter Venturini
Larry Kolczak
Nick Melliadis
Olivia Achuko
Elsa Bishop
Anita Dorsey-Word
Robert Tarn
Roslyn Jackson
John Konefes
Cheri Storms
Jean Waters
Gregory Copley
Dick Lehr
Rick Reibstein
Andrew Gosden
Roy Krout
Dave Fiedler
Troy Johnson
Byron Shaw
Randy Wolfe
PHONE
(334) 271-7873
(N) (800) 533-2336
(907) 269-7686
(S) (800) 510-2332
(602) 207-2254
(S) (800) 234-5677, x 4337
(602) 506-5102
(501)682-0866
(916) 445-0650
(S) (800) 272-4572
(909) 396-3215
(S)(800)388-2121
(303) 692-3175
(N) (800) 333-7798
(202) 535-2997
(850) 414-8399
(S) 800-722-7457
(404) 362-4842
(808) 586-4200
(217) 524-0169
(S) (800) 252-3998
(319) 273-8905
(S) (800) 422-3109
(317) 233-1041
(S) (800) 451-6027
(785) 532-4698
(N) (800) 578-8898
(606) 257-1131
(N) (800) 562-2327
(225) 765-2453
(S) (800) 259-2890
(617) 727-3260 X688
410-631-4158
(S) ( 800)633-6101,x4158
(207) 287-8550
(S) (800) 789-9802
(517)373-0607
(N) (800)662-9278
(651) 296-7767
(S) (800)657-3938
(573) 526-6627
(N) (800) 361-4827
(601)961-5166
(N) (800)725-6112
-------
STATE
MT
NC
NE
NH
NJ
NM
NV
NY
ND
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
OMBUDSMAN
Karen Ekstrom
Ed> the McKinney
Joe Francis
Rudolph Cartier
Lauren Moore
Robert Horwitz
Marcia Manley
Tria Case
Jeff Burgess
Mark Shanahan
Steve Thompson
Paul Burnet
CregCzarnecki
Luis Velez
Phyllis Copeland
Joe Nadenicek
Ernest Blankenship
Israel Anderson
Stephanie Bernkopf
John Daniel
Marylyn A. Stapleton
Dave Bassage
Hampton Rothwell
Dan Clark
PHONE
(406) 444-2960
(N) (800) 433-8773
(919) 733-0823
(N) (800) 829-4841
(402)471-3413
(603) 271-1379
(609) 292-3863
(N) (800) 643-6090
(505) 827-9685
(N) (800) 810-7227
(775) 687-4670, X3162
(S) (800) 992-0900
(212) 803-2280
(N) (800) 782-8369
(701)328-5153
(S) (800) 755-1625
(614) 728-3540
(S) (800) 225-5051
(405) 702-7100
(503) 229-5776
(800) 452-401 1(S)
(717) 772-8951
(787) 384-8614
(803) 898-3997
(N) (800) 819-9001
(605) 773-3836
(S) (800) 438-3367
(615) 532-6262
(N) 800-734-3619
(512) 239-5319
(N) (800) 447-2827
(801) 536-4479
(N) (800)458-0145
(804)698-4311
(S) (800) 592-5482
(340) 777-4577,x228
(304) 558-5929 X203
(608) 267-0313
(N) (800) 435-7287
(307) 777-7388
TECH. ASST. DIR.
Warren Norton
Tony Pendola
Rudolph Cartier
Chuck McCarty
Cecilia Williams
Janet Goodman
Marian. Mudar, Ph.d
Tom Bachman
Rick Carleski
Alwin Ning
Jill Inahara
Cecily Beall
Maria Rivera
Pam Annarummo
Natalie Loquist
Bryan Gustafson
Linda Sadler
Tamra Shae-Oatman
Ron Reece
Judy Mirro
Richard Rasmussen
Marylyn A. Stapleton
Bernard Brady
Fred Durham
Pam Christenson
Charles Raffelson
PHONE
(406) 444-5281
(N) (800) 433-8773
(919) 733-0824
(N) 800-829-4841
(603) 271-1379
(609) 292-5565
(505) 827-0042
(N) (800) 810-7227
(775) 687-4670, X3164
(S) (800) 992-0900 X4670
(518) 457-9135
(S) (800) 780-7227
(701)328-5188
(S) (800) 755-1625
(614)728-1742
(405) 702-6100
(503) 229-6147
(S) (800) 452-4011
(215)656-8709
(N) (800) 722-4743
(787) 767-636-9999
(401) 222-6822 X7204
(S) (800)253-2674
(803) 898-3981
(N) (800) 819-9001
(605) 773-7171
(S) (800) 438-3367
(615) 532-8012
(N) (800) 734-3619
(512) 239-1066
(N) (800) 447-2827
(801) 536-4091
(N) (800)270-4440
(802) 241-3745
(S) (800) 974-9559
(804) 698-4394
(S) (800) 592-5482
(340) 777-4577,x228
(360) 407-6803
(304) 926-36474
(S) (800) 982-2474
(608) 267-9214
(N) (800) 435-7287
(307) 777-7347
Note: (S) = State (N) = National
-------
State Pollution Prevention Technical Assistance Programs
Region 1
US EPA Region 1
Abby Swaine
1 Congress St
Suite 1100(SPN)
Boston, MA 02214-2023
Ph-617/918-1841
Fx-617/918-1810
swaine abby@epa.gov
Connecticut DEP
Kim Trella
79 Elm St
Hartford, CT 06106
Ph 860/424-3234
Fx 860/424-4081
Maine OEP
Chris Rushton
State House Station 17
Augusta, ME 04333
Ph 207/287-7100
Fx 207/287-2814
chns rushton@state me us
Massachusetts OTA
Scott Fortier
100 Cambridge St Rm2109
Boston, MA 02202
Ph 617/626-1090
Fx 617/6261095
scott.fortier@state ma us
MA STEP Program
Paul Richard
100 Cambridge St Rm 2000
Boston, MA 02202
Ph 617/626-1042
paul nchard@state ma us
Toxics Use Reduction Institute
Janet Clark
One University Avenue
Lowell, MA 01854
Ph 978/934-3346
Fx 978/934-3050
clarkjan@turi org
New Hampshire DES
Stephanie D'Agostino
6 Hazen Drive
Concord, NH 03301
Ph: 603/271-6398
Fx 603/271-2867
s_dagostino@des state.nh.us
Rhode Island DEM
Richard Enander
235 Promenade St
Room 250
Providence, Rl 02908
Ph: 401/222-4700
Fx 401/222-3810
Narragansett Bay Commission
James McCaughey
235 Promenade St
Providence, Rl 02908
PIT. 401/222-6680
Fx 401/222-2584
ppf@narrabay com
Vermont ANR
Gary Gulka
103 South Main St
Waterbury, VT 05671
Ph: 802/241-3626
gafyg@ctee anr state vt us
NEWMOA
Tern Goldberg
129 Portland St, Suite 602
Boston, MA 02114
Ph: 617/367-8558
Fx: 617-367-0449
neppngjh'ae net
Region 2
US EPA Region 2
Danielle Fuligni
290 Broadway (SPMMB)
New York, NY 10007
Ph 212/637-3584
Fx 212/637-3771
fuligm dan!elle@epa gov
New Jersey DEP
Melmda Dower
401 E StateSt, PO Box 423
Trenton, NJ 08625
Ph 609/292-1122
Fx 609/777-1330
mdower@dep state nj us
NJTAP
Laura Battista
138 Warren St
Newark, NJ 07102
Ph 973/596-5864
Fx 973/596-6367
battista@megahertz njit edu
New York DEC-P2 Unit
Mary Werner
50 Wolf Rd
Albany, NY 12233
Ph 518/457-2553
Fx 518/457-2570
mhwerner@gw dec state ny us
Puerto Rico Environment
Carlos Gonzales
Ph 809/765-7517x381
Fx 809/765-6853
Region 3
US EPA Region 3
Jeff Burke
1650 Arch St
Philadelphia PA 19103
Ph 215/814-2761
Fx 215/814-2782
burifejeff@epa.gov
Delaware DNR
Andrea Kreiner
PO Box 1401
89 Kings Highway
Dover, DE 19903
Ph: 302/739-3822
Fx 302/739-6242
akreinengdnrec state de us
MD Dept of Environment
Laura Armstrong
2500 Broening Hwy
Baltimore, MD 21224
Ph 410/631-4119
Fx 410/631-4477
larmstrong@mde state md us
PA Dept of Environment
Meredith Hill
PO Box 2063
Harrisburg, PA 17105
Ph 717/783-8727
Fx. 717/787-8470
hill meredith@dep state pa us
PA Technical Assistance
jack Gido
110 Barbara Bldg II
University Park, PA 16802
Ph 814/865-0427
Fx 814/865-5909
Virginia DEQ
Sharon K Baxter
PO Box 10009
Richmond, VA 23240
Ph 804/698-4344
Fx- 804/698-4277
skbaxter@deq state.va us
West Virginia DEP-OWR
Leroy Gilbert
HC 61 Box 384
Danese, WV 25831
Ph 304/484-6269
Fx 304/558-2780
llgilbert@hotma/l.com
Region 4
US EPA Region 4
Dan Ahern
61 ForsythStSW
Atlanta, GA 30303
Ph 404/562-9028
Fx 404/562-9066
ahem dan@epa gov
Alabama DEM-P2 Unit
Gary Ellis
PO Box 301463
Montgomery, AL 36130
Ph 334/213-4303
Florida DEP - P2 Program
Julie Abcanan
2600 Blair Stone Road
Tallahassee FL 32399
Ph. 850/488-0300
Fx 850/921-8061
julie abcanan@dep state fl us
Georgia DNR- P2AD
Jancie Hatcher
7 MLK Jr Dr Suite 450
Atlanta GA 30334
Ph 404/651-5120
Fx 404/651-5130
p2ad@ix netcom com
Kentucky DEP
Vicki Pettus
14 Reilly Road
Frankfort, KY 40601
Ph 502/564-6716
Kentucky P2 Center
Cam Metcalf
420 Lutz Hall
Louisville, KY 40292
Ph. 502/852-0965
Fx 502/852-0964
jcmetc01@gwise louisville eud
Mississippi DEQ
Thomas E Whrtten
POBox 10385
Jackson, MS 39289
Ph. 601/961-5241
Fx. 601/961-5349
North Carolina DEHNR
Gary Hunt
PO Box 29569
Raleigh, NC 27626
Ph 919/715-6500
Fx. 919/715-6794
gary_hunt@owr ehnr state nc us
South Carolina DHEC
Robert Burgess
2600 Bull St
Columbia. SC 29208
Ph 803/898-3971
burgesre@columb30 dhec state sc us
Tennessee DEC
Angie Prtcock
401 Church St
Nashville, TN 37243
Ph 615/532-0760
Region 5
US EPA Region 5
Phil Kaplan
77 West Jackson Blvd
Chicago, IL 60604
Ph. 312/353-4669
Fx 312/353-4788
tap/an phil@epa.gov
Illinois EPA
Kevin Greene
1021 N Grand Ave East
Springfield, IL 62794-9276
Ph 217/785-0833
Fx 217/557-2125
epa8603@epa.state.il us
Illinois Waste Mgmt and Research
Center
Tim Lmdsey
One East Hazelwood Dr
Champaign, IL 61820
Ph 217/333-8955
Fx 217/333-8944
tlindsey@wmrc uiuc edu
Indiana DEM
John Chavez
100 N Senate Ave PO6015
Indianapolis, IN 46206
Ph 317/233-6658
Fx. 317/233-5627
jcnavez@dem state in us
Clean Manufacturing Tech & Safe
Materials Institute
Alice Smith
2655YeagerRd Suite 103
West Lafayette, IN 47906
Ph 765/463-4749
Fx 765/463-3795
a/ice@ce-ecn purdue edu
Michigan DEQ
Marcia Horan
PO Box 30473
Lansing, Ml 48909
Ph 517/373-9122
Fx 517/335-4729
horanm@state mi us
Minnesota (MN TAP)
Cindy McComas
1313 5th StSW Suite 207
Minneapolis, MN 55414
Ph 612/627-4556
Fx 612/627-4769
mccom003@(c umn edu
MN Pollution Control
Agency
Cindy Hilmoe
520 Lafayette Road North
St Paul, MN 55155
Ph 651/296-7783
Fx- 651/297-8676
cynthia hilmoe@pca state mn.us
MN Office of Environmental Assistance
Phillip Muessig
520 Lafayette Road North
St Paul, MN 55155
Ph 651/215-0204
Fx 651/215-0246
phillip muessig@moea state.mn us
MN Technology Inc.
Kevin O'Donnell
111 3rd Ave South
Minneapolis, MN 55401
Ph 612/672-3446
Fx 612/497-6475
fcodonneff@mai( mnfecfi org
Ohio EPA
Michael Kelley
PO Box 1049
Columbus, OH 43216-1049
Ph. 614/644-3469
Fx 614/728-2807
michael kelley@epa state oh us
University of Wisconsin
Rick Grate
610LangdonSt, Rm530
Madison, Wl 53703
Ph 608/265-3055
Fx 608/262-6250
grateฎ wmep.ory
This list is updated and maintained on the EPA P2 Home Page at www.epa.gov/p2/p2statecontacts.htm
55
5/00
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State Pollution Prevention Technical Assistance Programs
Nat'l Farmstead Program
Liz Nevers
6142 Steenbock Library
Madison Wl 53706
Ph 608/265-2774
Fx 608/265-2775
enevers@facstatt wise edu
Wisconsin DNR
Lynn Persson
PO Box 7921
Madison, Wl 53707
Ph 608/267-3763
Fx 608/267-0496
Region 6
US EPA Region 6
Eli Martinez
1455 Ross Ave Suite 1200
Dallas, TX 75202
Ph 214/665-2119
Fx 214/665-7446
mart/nez.eli@epa gov
Arkansas IDC
Alford Drtnkwater
One Capitol Mall
Little Rock, AR 72201
Ph 501/682-7325
Fx- 501/682-2703
adrinkwater@aedc/state ar us
Louisiana DEQ
Gary Johnson
PO Box 82263
Baton Rouge, LA 70884
Ph 504/765-0739
Fx 504/765-0742
garyj@deq state la us
Louisiana TAP
University of New Orleans
New Orleans, LA
Ph. 504/286-6305
Fx 504/286-5586
New Mexico ED
Patricia Gallagher
1190StFramcisDr
Sante Fe, NM 87502
Ph 505/827-0677
Fx- 505/827-2846
pat_gallagher@nmenv state.nm.us
Oklahoma DEQ
Dianne Wilkins
707 N Robinson PO Box 1677
Oklahoma City, OK 73101
Ph- 405/702-6116
Fx: 405/702-6100
dianne wilkins@deqmall state.ok us
Texas NRCC
Kathey Ferland
POBox 13087-MC112
Austin, TX 78711
Ph 512/239-3177
Fx 512/239-3165
kfertand@tnrcc state tx us
Gulf Coast Hazardous Substance
Research
Margaret Aycock
PO Box 10671
Beaumont, TX 77710
Ph: 409/880-8897
Fx. 409/880-1837
aycock@ALMA.RK lamar.edu
TX Manuf. Assistance Center
Conrad Soltero
Univ ofTX-EIPaso
500 W University , Surges
El Paso, TX 75202
Ph- 915/747-5930
Fx- 915/747-5437
conrad@utep edu
Lower Colorado River Authority
Mark Johnson
PO Box 220
Austin, TX 78703
Ph- 512/473-3200
Fx- 512/473-3579
mark johnson@lcra org
Region 7
US EPA Region 7
Marc Matthews
726 Minnesota Ave (ARTD/TSPP)
Kansas City, KS 66101
Ph 913/551-7517
Fx 913/551-7065
mattnews.marc@epa gov
Iowa DNR
Jeff Fiagle
502 E. 9th St
DesMomes, IA 50319
Ph 515/281-5353
Fx 515/281-8895
jfiagle@max state.ia.us
Iowa Waste Reduction Center
Christine Twart
1005 Technology Parkway
Cedar Fall, IA 50613
Ph 319/273-8905
Fax 319/268-3733
twait@uni edu
IOWA DED
Linda King
Small Business Liasion
Ph. 515/242-4761
Fx. 515-242-6338
Kansas DHE
Janet Neff
Bldg 283 , Forbes Field
Topeka, KS 66620
Ph 785/296-0669
Fx. 785/296-3266
jneff@kdrie state.ks us
KSU - P2 Institute
Sherry Davis
133 Ward Hall
Manhattan, KS 66506
Ph 785/532-6501
Fx 785/532-6952
sbd@.ksa edu
Missouri DNR - TAP
David Goggins
POBox 176
Jefferson City, MO 65102
Ph. 573/526-6627
Fx 573/526-5808
nrgoggd@mail state.mo us
NE Business Development Center
Rick Yoder
1135M St, Suite 200
Lincoln, NE 68508
Ph: 402/472-1183
Fx. 402/472-3363
ryoder@unomana edu
Nebraska DEQ, P2 Office
Ben Hammerschmidt
PO Box 98922
Lincoln, NE 68509
Ph: 402/471-6988
Fx. 402/471-2909
deq219@ma!l deq state.ne us
MAMTC
Anne Brown
801 Campus Or
Garden City, KS 67846
Ph: 316/276-9505
Fx 316/276-9523
abrown@midusa net
Region 8
US EPA Region 8
Linda Walters
999 18th St, Suite 500
Denver, CO 80202
Ph 303/312-6385
Fx 303/312-6741
waiters lmda@epa gov
Colorado DHE
Parry Burnap (OE-B2-PPU)
4300 Cherry Creek Dr
Denver, CO 80222
Ph 303/692-2975
Fx 303/782-4969
parry bumap@state.co us
Montana P2 Program
Michael P Vogel
109 Taylor Hall
POBox 173580
Bozeman, MT 59717
Ph 406/994-3451
Fx 406/994-5417
mvogel@montana edu
North Dakota Dept of Health
Jeffrey L Burgess
PO Box 5520
Bismarck, ND 58506-5520
Ph 701/328-5150
Fx 701/328-5200
lburgess@state.nd.us
South Dakota DENR
Dennis Clarke
523 E Capitol
Pierre, SO 57501-3181
Ph 605/773-4254
Fx 605/773^ป068
Utah DEQ
Sonja Wallace
168N 1950 West
Salt Lake City, UT 84114
Ph 801/536^(477
Fx 801/536-0061
swaWace deq state ut us
Wyoming DEQ
Stephen Roseberry
122 West 25th
Cheyenne, WY 82002
Ph 307/777-6105
Fx 307/777-3610
sroseb@state. wy us
Region 9
US EPA Region 9
Eileen Sheehan
75 Hawthorn St (WST-1-1)
San Francisco, CA 94105
Ph 415/744-2190
Fx 415/744-1680
Wilson.bill@epa gov
Arizona DEQ
Jacqueline Maye
3033 North Central Ave
Phoenix, AZ 85012
Ph 602/207-4607
Fx 602/207-2302
maye jacqueline@ev. state az.us
California EPA
Tem Cronm
8800 Cal Center Dr
Sacramento. CA 95826
California Energy Commission
David Jones
1519 9th St
Sacramento, CA 95814
Ph 916/654-4554
CA Toxic Substance Control
Kathy Barwick
PO Box 806
Sacramento. CA 95812
Ph 916/323-9560
Fx 916/327-4494
UCLA P2 Center
Billy Romam
Ph 310/825-2654
Fx: 310/206-3906
Hawaii Department of Health
Marlyn Aguilar
919 Ala Moana Blvd. Rm 212
Honolulu, HI 96814
Ph 808/586-7496
Fx- 808/586-7509
maguilar@eha.health state hi.us
Nevada Small Business Development
Center
Kevin Dick
6J.OO Neil Rd Suite 400
Reno, NV 89511
Ph 775/689-6677
Fx 775/689-6689
d/ck@unr.edu
Region 10
US EPA Region 10
Carolyn Gangmark
1200 Sixth Ave (01-085)
Seattle, WA 98101
Ph 206/553-4072
Fx 206/553-8338
gangmark carolyn@epa gov
Alaska DEC
Marianne See
555 Cordova St
Anchorage, AK 99501
Ph 907/269-7586
Fx 907/269-7600
msee@enw'rcon state ak us
Idaho DEQ
Katie Sewell
450 West State St
Boise, ID 83720
Ph: 208/373-0465
Fx 208/373-0169
ksewell@deq state id us
Oregon DEQ
Marianne Fitzgerald
811 SW Sixth St
Portland, OR 97204
Ph 503/229-5946
Fx 503/229-5850
fitzgerald,mananne@deq state or us
Washington DEC
Lynn Helbrecht
PO Box 47600
Olympia, WA 98504
Ph. 360/407-6760
Fx 360/407-6715
lhe!4B1@ecy wa gov
Pacific Northwest P2 Resource Center
Madeline Sten
1326 Fifth Ave, Suite 650
Seattle, WA 98101
Ph. 206/223-1151
Fx 206/223-1165
msten@pprc org
Washington State University-
Carol Reisenberg
501 Johnson Tower
Pullman. WA 99164
Ph 509/335-1576
Fx: 509/335-0949
andersol@wsuvml esc wsu edu
This list is updated and maintained on the EPA P2 Home Page at www.epa.gov/p2
cc
4/99
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Office of Small and Disadvantaged Business Utilization
The Office of Small and Disadvantaged Business Utilization (OSDBU), under the supervision of the
Director, is responsible for developing policy and procedures implementing the functions and duties
under sections 8 and 15 of the Small Business Act as amended by Public Law (P.L.) 95-507 (October
24, 1978) and P.L. 100-656 8(a) Reform Act. The Office develops policies and procedures
implementing the provisions of Executive Orders 11625, 12432 and 12138 and is responsible for
developing policies and procedures for implementing the requirements of Section 105(f) of P.L. 99-499
and Section 129 of P.L. 100-590. Additionally, OSDBU establishes policy, guidance and assistance to
small and disadvantaged businesses in rural areas and other socioeconomic groups. The Office
furnishes information and assistance to the Agency's filed offices for carrying out related activities, and
represents EPA at hearings, interagency meetings, conferences and other appropriate forums on
matters related to the advancement of business enterprises.
Direct Procurement Program
DESCRIPTION
The Office develops, in collaboration with the Director of the Office of Acquisition Management, Office
of Administration and Resources Management, Office of Administration and Resources Management,
and EPA senior-level officials, programs to stimulate and improve the involvement of small business,
minority business, labor surplus areas and women-owned business enterprises in the overall EPA
procurement process. OSDBU monitors and evaluates Agency performance in achieving EPA goals
and objectives in the above areas, and recommends the assignment of EPA Small Business
Representatives to assist designated Procurement Center Representatives of the Small Business
Administration to carry out their duties pursuant to applicable socioeconomic laws and mandates.
ACTIVITIES
4 Develops policy and procurements impacting socioeconomic businesses
4 Establish and monitor direct procurement goals for:
03- Small Business
"sr 8(a) Business
is- Small Disadvantaged Business
is- Women-Owned Business
a- HUBZones
os- Subcontracting
4 Compile, collect and assemble statistical data on socioeconomic programs
* Mentor-Protege Program
4 Subcontracting Reviews and Approvals
* Outreach Efforts (Economic Development Programs for Selected Urban Centers
4 Education Training Program (Co-sponsorships with Workshops, Seminars and Trade Fairs)
Provides technical and management assistance to small, disadvantaged business enterprises
and women-owned entities, Alaskan Indian/American Natives and HBCUs
4 Liaison with Trade Associations, Business Organizations, and Federal Agencies, including:
Small Business Administration, Minority Business Development Agency of Department of
Commerce, Office of Federal Procurement Policy, OMB, Congress, General Services
Administration, on Socioeconomic matters
OUTREACH CENTER - In its commitment to assure that small and disadvantaged businesses have equal access to
business opportunities with the EPA, the OSDBU has established the outreach center in concert with Howard University's
Small Business Development Center. The services of the Outreach Center are designed to enable developing, emerging
and startup firms to strengthen their competitive position in the EPA market place. Hours of operations are 9:00 am - 5:00
pm, please call for an one-on-one business counseling session on (202) 564-4584.
57
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Assistance to Minority and Women-Owned Business Program
Under Agency Financial Assistance Programs
(Grants and Cooperative Agreements)
DESCRIPTION
The Office is responsible for assuring that small, minority, women-owned and labor surplus are firms are given the
opportunity to receive a "fair share" of subagreements during the procurement phase of certain types of financial
assistance awarded by the Agency. OSDBU develops policies and procedures to aid these business entities with the
assistance of the Grants Administration Division, Office of Administration and the Grants, Contracts and General Law
Division, Office of General Counsel. Additionally, OSDBU is responsible for the collection "of data and for monitoring
the effectiveness of the program and serves as the principal focal point between EPA and the Minority Business
Development Agency of the U.S. Department of Commerce.
ACTIVITIES
* Develops and monitors policy and procedures
4 Regions establish "Fair Share" objectives with recipients of financial assistance
+ Recipients report to delegated States or to Regional Offices
* EPA reports data to the Cabinet Council for Commerce and Trade through the Minority Business Development
Agency
* Provides technical and management assistance to minority and women-owned businesses
* Provides Regional technical, management assistance and support
* Compile, collect, analyze and assemble data on DBEs, HBCUs and lAGs
* Provides reports on financial assistance program to various entities, including Congress
MBE/WBE COORDINATORS
REGION
COORDINATOR
STATES
TELEPHONE
IV
V
VI
VII
VIII
IX
X
Cincinnati
Headquarters
Sharon Molden CT,
Otto Salamon
Romona McQueen
Rafael Santamaria
Matt Robbins
Robert Richardson
Debora Bradford
Anthony Lamaster
Maurice Velasquez
Joe Ochab
Michael Letourneau
Norman White
Lupe Saldana
ME, Rl, MA, NH, VT
NJ, NY, PR, VI
DE, DC, MD, PA, VA, WV
AL, FL, GA, KY, MS, NC, SC,
IL, IN, Ml, MN, OH, Wl
AR, LA, NM, OK, TX
IA, KS, MO, NE
CO, MT, ND, SD, UT, WY
AZ, CA, HI, NV, AS, GU
AK, ID, OR, WA
(617)918-1062
(212)637-3417
(215)814-5155
TN (404)562-8110
(404) 562-8371
(312)353-5677
(214)665-7406
(913)551-7228
(303)312-6862
(415)744-1628
(206)553-1187
(513)487-2024
(202) 564-5353
Jeanette Brown
David Sutton
Mark Gordon
Elaine Rice
Trina Porter
Mryna Mooney
Director
Deputy Director
Attorney Advisor
National Program Officer
Soc. Bus. Program Officer
Soc. Bus. Prog. Ofr./Tribal
OSDBU STAFF
(202)564-4100
(202) 564-4100
(202) 260-8886
(202) 564-4141
(202) 564-4322
(202) 564-4386
Denean Jones
Tammy Thomas
Elnora Thompson
Thelma Harvey
Theresa Stewart
Frank Carpenter
Info. Mgmt. Specialist
Program Specialist
Clerk-Typist
SEE Employee
SEE Employee
Contractor
(202 )564-4142
(202) 564-4298
(202)564^139
(202)564-4138
(202) 564-2314
(202) 564-4584
OSDBU has a site on the Internet of general information and publications for small businesses interested in doing with
EPA. Our WEB address is: http://www.epa.gov/OSDBU
58
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REQUEST FOR PUBLICATIONS
Office Small Business Ombudsman (OSBO)
SUMMER 2000
EPA USE ONLY
INQ. NO.: DATE:
Inquiry Source: [Hotline: Phone
[Add: Init: Date:
Small Business Asbestos
FILLED BY:
Machine ] Fax:
[Change: Init: Date:
DATE FILLED:
U.S. Mail: Other
] [Delete: Init:
Date: ]
NAME
TELE. NO.: (
)
Organization:
Address:
City:
State:
IF YOU ARE NOT ALREADY RECEIVING THE BI-ANNUAL
PLEASE COMPLETE THIS SECTION (To receive bi-annual
Date:
Zip:
EDITIONS OF THE "UPDATE" NEWSLETTER AND WISH TO DO SO,
'Updates" and related mailings.): Yes: No:
INDUSTRY:
Consultant
(Indicate, or Circle Below)
Laboratory
Attorney
Engineer
Educational
Environmental
PUBLICATIONS REQUESTED
No. Employees: 1-99
State Govt.
County Govt.
City Govt.
Association
Individual
EPA Hq.:
100-499
500-Up
EPA Region:
Congressional
Other Fed.:
(Circle the Corresponding Alpha-Numeric Codes below):
Alpha-numeric codes refer to publications described in "Information For Small Business," available from OSBO
A- 1
A- 2
A- 3
A- 4
A- 5
A- 6
A- 7
A- 8
A- 9
A-10
A-11
A-12
A-13
A-15
A-16
B- 1
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B- 3
B- 4
B- 5
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B- 7
B- 8
B-10
B-11
B-12
B-13
B-14
B-15
B-16
B-17
B-18
C- 1
C- 8
C-9
C-10
C-11
C-12
C-13
C-14
C-15
C-16
C-17
C-18
C-19
C-20
C-21
C-22
C-23
C-24
C-25
C-26
C-27
C-28
C-29
C-30
C-31
C-32
C-33
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C-35
C-36
C-37
C-38
C-39
C-41
C-42
C-43
C-44
C-45
C-47
C-50
C-51
C-52
C-53
C-54
C-55
C-56
C-57
C-58
C-60
C-61
C-62
C-63
C-64
C-65
C-66
C-67
C-68
C-69
C-70
C-71
C-73
C-74
C-75
C-76
C-11
C-78
C-79
C-80
C-81
C-82
C-83
C-84
C-87
C-88
C-89
C-90
C-91
C-92
C-93
C-94
D- 1
D- 2
D- 3
D-4
D- 5
D- 6
D- 7
D- 8
D- 9
D-12
D-13
D-14
D-15
D-16
D-17
D-18
D-19
D-20
E- 1
E- 2
E- 3
E- 4
E- 5
E- 6
E- 7
E- 8
E- 9
E-10
E-11
E-12
E-13
E-14
E-15
E-19
E-20
E-21
E-22
E-23
E-24
E-25
E-26
E-27
E-28
E-29
E-30
E-31
E-32
E-33
E-34
E-40
E-41
E-42
E-43
E-44
E-45
E-46
E-47
E-48
E-49
E-50
E-51
E-53
E-54
E-55
E-56
E-57
F- 1
F- 2
F-3
F-4
F- 5
F- 6
F- 7
F- 9
F-10
F-11
F-12
F-14
F-15
F-16
F-17
G- 1
G- 2
G-3
G-4
G- 5
G- 6
G- 7
G- 9
G-10
G-11
G-12
G-13
G-14
H- 1
H- 2
H- 3
H-4
H- 5
H- 6
H- 7
H- 8
H- 9
H-10
I- 1
I- 2
I- 3
I- 4
I- 5
I- 6
- 8
- 9
-10
-11
-12
-13
-14
-15
-16
-17
-18
-19
-20
-21
-22
-23
-24
-25
-26
-27
-28
-29
I- 7
-30
-31
-35
-36
I-37
-38
-40
-41
-42
-43
-44
-45
I-46
J- 1
J- 2
J- 3
J-4
J- 6
J- 7
J- 8
J- 9
J-10
J-11
J-12
J-13
K- 1
K- 2
K-3
K-4
K- 5
K- 6
K- 8
K- 9
K-10
K-11
K-12
K-13
K-14
K-15
K-16
K-19
K-20
K-21
K-22
upon request.
K-23
K-24
K-25
K-28
K-29
K-30
K-31
K-32
K-33
K-34
K-35
K-36
K-37
K-38
K-39
K-40
K-41
k-42
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K-44
K-45
K-46
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K-50
K-51
K-52
K-53
K-54
K-55
K-56
K-57
K-58
K-59
K-60
K-61
K-62
K-63
K-64
K-65
Mail to:
Karen V. Brown, Small Business Ombudsman
US Environmental Protection Agency
Ariel Rios Building, 1200 Pennsylvania Ave, NW (2131)
Washington, D.C. 20460
Remarks/Other Materials Requested:
Or Telephone:
Toll Free Hotline: (800) 368-5888
In the D.C. area, (202) 260-1211,
or Telefax (202) 401-2302
Email: smallbiz.ombudsman@epa.gov
asbestos.ombudsman@epa.gov
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