5193
 1982
United States
Environmental Protection
Agency
<3ffice of the
Administrator
Washington DC 20460
vvEPA
Operating  Year
Guidance:
1982
June 1981
                                        c-1
                                      001B82100

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             FY  1982




     OPERATING YEAR GUIDANCE




            JUNE 1981
230

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                               11
     For additional copies or comments on the preparation of
this document, contact:  U.S. Environmental Protection Agency
                         Ms. Joan LaRock
                         Office of Policy and Resource Management
                         Office of Management Systems and
                           Evaluation
                         Program Evaluation Division (PM-222)
                         401 M Street, S.W.
                         Washington, D.C.  20460
                         Phone:  202/755-3975
                             -virortffienta! Protection

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                          Ill
                      CONTENTS
Overview                                           1

Air, Noise, and Radiation                          7
  Air                                              7
  Air Enforcement                                 11
  Radiation                                       13
  Noise                                           14

Water                                             15
  Water Quality                                   15
  Drinking Water                                  19
  Water Enforcement                               23

Solid Waste and Emergency Response                27
  Solid Waste                                     27
  Emergency and Remedial Response (Superfund)     30
  Waste Programs Enforcement                      32

Pesticides and Toxic Substances                   35
  Toxics Integration                              35
  Toxic Substances                                36
  Toxics Enforcement                              38
  Pesticides                                      39
  Pesticides Enforcement                          41

Research and Development                          43

Policy and Resource Management                    47

Legal Counsel and Enforcement                     55

Administration                                    59

Administrator's Executive Offices                 61
  Office of Federal Activities                    61
  Office of Public Affairs                        63
  Office of Civil Rights                          64
  Office of Inspector General                     64

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                           OVERVIEW
     This Operating Year Guidance is intended to provide
direction for planning for and initiating the major activities
the Agency will need to pursue during the remainder of Fiscal
Year (FY) 1981 and 1982.

     EPA has been given some major new responsibilities as a
result of passage of Superfund legislation.  Carrying out
these new responsibilities in a time of marked fiscal restraint
will require that we shift resources to Superfund and focus
our other resources more narrowly on those activities that
have significant public health and environmental payoff.  We
will also need to increase delegation of environmental programs
to state and local governments.  Finally, we need to eliminate
any unnecessary burdens that our regulations have created and
simplify and better coordinate our operation of programs.
We must find more efficient ways of managing our programs
so that they are less resource intensive, do not discourage
industrial growth or technological innovation, and are not
unnecessarily costly.

     The activities discussed below are the areas of most
significant change and the cross-cutting activities we expect
to emphasize most in the coming fiscal year.  Program-specific
priorities and activities are contained in the individual
program statements that follow this Overview.

Hazardous Wastes/Superfund

     The Superfund legislation allows EPA and the states to
respond to hazardous waste spills and uncontrolled waste
disposal sites.  EPA must implement Superfund in a way that
gives states a significant role in selecting sites for Super-
fund action and emphasizes private sector and state clean-up
to the extent possible.  In so doing, the Agency will need
to integrate its new Superfund responsibilities with the
Resource Conservation and Recovery Act (RCRA) Hazardous
Waste Management program and with existing functions under
311 of the Clean Water Act.

     The Agency must also ensure that facilities comply with
interim requirements under RCRA.   We must prioritize our
permitting of hazardous waste facilities to emphasize creation
of new disposal capacity.

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                             -2-
Procedural Reforms

     EPA will revise and improve its regulatory development
process as mandated by Executive Order 12291 on Federal
Regulation, the Regulatory Flexibility Act, and the Paperwork
Reduction Act.  The purpose of these reforms is to ensure
that the Agency's regulations do not impose unnecessary
costs on society in achieving their intended results.

     We will develop guidance that program offices can use to
perform the required Regulatory Impact Analyses (involving
both cost and benefit analyses) for major regulations and the
Regulatory Flexibility Analyses for regulations that will
have significant impacts on small businesses, small government
jurisdictions, and other small entities.

     Under the Paperwork Reduction Act, EPA will develop
procedures to produce an annual Information Collection Budget
and manage its information collection requirements to ensure
that we impose no more information collection burden on the
regulation population than is absolutely necessary.  We will
also review existing regulations to ensure that their require-
ments are reasonable and not overly burdensome.

Integrated Toxics Strategy

     The Agency must strengthen its toxics integration activi-
ties in order for its actions in this area to be environmentally
effective, internally consistent, and economically viable.
The Offices of Toxics Integration and Policy and Resource
Management are leading an effort to develop an Agency-wide
strategy for designating, gathering information on, regulating,
and otherwise responding to high priority problems with
toxic chemicals.   This strategy for dealing with top priority
chemicals as well as major industrial sources and geographic
concentrations of these chemicals will be outlined by the
end of FY 1981.  During FY 1982, all parts of EPA will be
required to follow the strategy the Agency adopts, providing
adequate resources for toxics integration in FY 1982 operating
plans and the FY 1983 budget.

     To ensure consistent Agency attention to high priority
chemical problems before completion of the integrated toxics
strategy, the Toxic Substances Priority Committee (TSPC) has
formulated an initial list of high priority chemicals and
associated industries for use by Headquarters and the Regions
in FY 1982.  The TSPC is preparing packages of currently
available information on each priority chemical for EPA staff
and state and local officials.  The priority chemicals/
industries list should be used by all Agency toxic programs
and all Regions to make sure that priorities for regulations,
monitoring, permitting, emergency response, and site clean-up
reflect appropriate consideration of these chemicals and the
industries which generate or discharge them.

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                             -3-
Regulatory Reform

     Because regulatory reform focuses on developing new
alternatives to pollution control regulation that encourage
pollution reduction while reducing unnecessary burdens on
industry, it is an important part of EPA's regulatory strategy,
We will reexamine our approaches to regulation so that we
employ innovative methods to reduce Agency overhead.  Special
emphasis will go to those approaches that cut the costs to
industry and to state and local governments of achieving
and maintaining environmental quality.  The Office of Policy
and Resource Management will serve as the lead in this area,
but other programs and the Regions should seek opportunities
to build on that work.

     We expect to expand use of regulatory reform efforts
such as the Bubble policy in our Air program.  We can do
this by streamlining our policies for these reforms to make
them easier to use, extending similar ideas to other program
areas where they appear advantageous, and actively promoting
the adoption of existing controlled trading reforms within
more industries and more areas of the country.

     The Agency will also promote consolidated permits in
Regional offices and in states with delegated NPDES and RCRA
programs to streamline and simplify permitting procedures.

Energy

     The environmental impacts of energy development will
be one of the major issues facing the Agency.  As fuel prices
increase there will be pressure to use alternative sources of
fuel.  The Agency should encourage clean, inexpensive, and
environmentally sound energy alternatives.  We must streamline
permitting requirements for energy facilities.  We also will
implement an integrated plan for the regulation of possible
new synfuel facilities so that those which are built are
properly controlled and are not delayed by uncertain permit
procedures.

Construction Grants

     The Agency's Construction Grants program will undergo
a major reorientation in FY 1982.  The Office of Water
will implement changes reflecting increased delegation of
the Construction Grants program to the states.  As delegation
of the program proceeds, the states will become stronger
partners in efforts to provide for municipal wastewater
treatment systems.   As more project management responsibility
goes to the states, EPA will focus on regional/national
program management and on providing the technical, fiscal,
and administrative tools to support strong state programs.

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Continuous Compliance;  Operations and Maintenance

     EPA's emphasis on compliance with regulations and
standards has for some time focused on initial compliance.
The Agency now should move actively to ensure that industries
and municipal treatment systems achieve continuous compliance
with standards.  EPA will redirect resources for monitoring,

enforcement, and research and development from initial
compliance to continuous compliance.  We will also begin to
develop basic methods and tools needed to identify, monitor,
inspect, and correct compliance problems.

Develop A More Effective Partnership with States

     EPA will delegate programs or portions of programs to
the states in as many areas as possible.  The Agency needs to
improve its ability, expertise, and mechanisms for assisting
the states in carrying out these delegated programs.

     The Agency also needs to improve joint planning efforts
with states through the State/EPA Agreements (SEAs).  We must
strengthen the use of the SEA process as a way to give states
an opportunity to negotiate priorities with EPA and to make
clear what assistance they need from EPA to most effectively
manage environmental programs.  Only if we strengthen the
balance between EPA and the states in SEA negotiations can
SEAs become a means for creating a stronger partnership
between EPA and state and local governments.

Vigorously Pursue Equal Employment Opportunity and Civil
Rights Actions

     EPA will exercise every opportunity to provide equal
employment opportunities to all persons in all of its hiring
actions.  For those actions that previously have resulted
in formal discrimination complaints, the Agency will eliminate
that backlog.  Any future complaints will be processed promptly
so that significant backlogs do not occur.

Program Evaluation

     The Agency must be able to measure its effectiveness in
achieving its goals.  To do so, it needs to build systematic
evaluations into all of its programs to determine effectiveness
and ensure a proper division of responsibility between Federal,
state, and local government.  EPA needs to increase the use
of the results of evaluations to develop proposed revisions
to existing legislation and to propose new legislation, where
appropriate.

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Monitoring and Information Management/Quality Assurance

     EPA's ability to collect adequate, accurate, and timely
data and to use it in decision-making is critical to the sound
management of the Agency's work.  For that reason, in FY 1982,
the Agency must improve its ability to measure the effectiveness
of its programs and to use environmental data in policy and
program planning.
     As stated earlier, this overview and the program state-
ments are intended to provide Operating Year Guidance that
Headquarters, Regional, and state managers can use to carry
out their immediate planning, budgeting, and other management
responsibilities.  The individual program statements that
follow identify specific program priorities on which Head-
quarters and Regional Offices should focus their efforts.
The statements contain two types of priority activities.
Level 1 priorities are those that Headquarters or Regional
Offices should plan to do and for which resources will be
available.  Level 2 priorities are activities we think are
also important, but that Headquarters and Regional staff may
only be able to undertake on a selected basis because of
limited resources.
                                         M. Gorsuch
                                    Administrator

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                             -7-
                  AIR, NOISE, AND RADIATION
             OPERATING YEAR GUIDANCE FOR FY 1982
THE AIR PROGRAM

     Our main concern in FY 1982 will be to assist the states
in implementing the requirements of the Clean Air Act.  The
states are currently working to bring all conditionally
approved SIPs to fully approved status, to complete special
analyses, where required, and to put necessary regulatory
strategies in place.  In those instances where time for
attainment of standards has been extended beyond 1982, the
states will need to develop new State Implementation Plans
(SIPs).  Special problems the states may encounter include
data base development, attainment date demonstration analysis,
and the adoption of necessary regulations.  EPA will make
technical assistance available to state and local control
agencies in their efforts to solve these problems.

     In 1981, resources from the new source performance
standard (NSPS) effort were reprogrammed to produce control
technique guidance documents for additional sources of
volatile organic compounds.  Consequently, we have not
completed NSPS for all major stationary source categories.
Work in this area will continue through FY 1982.  In
developing NSPS, the Office of Air Quality Planning and
Standards (OAQPS) will consider operating procedures which
support EPA's continuous compliance initiative.

     Increased attention should be paid to developing more
efficient ways of dealing with hazardous air pollutants, so
as to reduce the possibility of widespread exposure of the
public to significant risk from these substances.  Activities
in this area must be closely coordinated with other EPA
activities to control toxic pollutants.  In addition to
efforts in this regard by the Office of Air Quality Planning
and Standards, the Mobile Source Air Pollution Control Program
will work with ORD to assess the toxic potential of both new
fuel sources and new control technologies.

     During 1982, Regions should work closely with the states
to develop high quality Prevention of Significant Deterioration
(PSD) programs.  States will be encouraged to develop and
submit SIPs for PSD so they can assume administration of
this program.  In the absence of approved SIPs, Regions
should delegate those portions of the program which the
states are technically able to conduct.

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     In 1982, we will also continue to evaluate the extent of
the problem of acid deposition through long-term monitoring,
and will investigate alternative strategies for remedial action
if determined to be needed.  States should be urged to weigh
possible impacts on downwind areas when considering requests for
relaxation of existing sulfur dioxide (SC>2) control requirements.

     The nation is committed to increasing the use of coal
for energy production.  Coal conversion proposals must receive
expeditious and thorough reviews by the Regions and states.

     At Headquarters, we must accelerate our efforts to
improve the accuracy of our estimates of in-use fuel economy
for mobile sources and to develop ways of better informing
the public about gasoline consumption of new vehicles.
Similarly, we must improve our ambient monitoring networks
to ensure they are more scientifically valid and appropriate.

     The Air Program will encourage, through regulatory reform,
alternative approaches to achieving air program goals which
offer economic incentives and which are less costly to
administer and to implement, such as the "Bubble."

Headquarters Objectives and Activities

First Level Objectives

o  Work with Regions to improve management of the SIP process
   by strengthening states' roles in SIP decision-making;
   delegate regulatory responsibilities to states wherever
   possible; strive to eliminate the current backlog of SIP
   revisions and permit applications.

o  Establish the regulatory framework and provide technical
   guidance necessary for completion of the 1982 ozone (03)7
   carbon monoxide (CO) SIPs.

o  Continue to evaluate the extent of the problem of acid
   deposition and investigate strategies to address it.

o  Implement programs for control of toxic air pollutants
   under Section 112 and lll(d) in conjunction with Agency
   toxic-related priorities.

o  Enhance the ability of Regions and states to identify
   problems, assess control technology, and regulate
   sources of air toxics.  Emphasis should be on incinera-
   tion, the synthetic organic chemical manufacturing
   industry, and air emissions from waste disposal.

o  Assess and regulate, as appropriate, air toxic emissions
   from selected industries and pollutants to be identified
   by EPA's Toxic Substances Priority Committee.

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                               -9-
o  Maintain NSPS development schedule for major stationary
   sources.

o  Review and revise ambient air quality standards on schedule
   and publish monitoring and SIP requirement guidelines.

o  Improve the scientific validity and appropriateness of
   ambient monitoring networks.

o  Provide technical assistance to states establishing
   Inspection and Maintenance  (I/M) programs.

o  Develop and implement improvements in fuel economy measure-
   ment and labeling.

o  Evaluate the need for control of unregulated mobile
   source pollutants.

Regional Objectives and Activities

First Level Objectives

o  Strive to eliminate any backlog of pending permits or SIP
   revisions.  Investigate ways of streamlining the process
   and eliminating any possible duplicative steps or potential
   delay.

o  Provide technical assistance to states where requested
   for a smooth start-up of I/M programs.

o  Assist the states where requested in selecting and
   implementing alternative transportation strategies
   essential to the attainment of standards.

o  Work with states to develop acceptable aerometric emissions
   data bases for 1982 0^/CO SIPs by December 31, 1981.

o  Complete transfer of the TSP/S02 PSD program to remaining
   states having major industry or growth.

o  Work with the states to improve the quality of state
   new source review programs, providing assistance where
   needed.

o  Delegate the NSPS programs for all source categories
   to the extent possible in order to avoid state/EPA
   duplication in regulation of new sources.

o  Write PSD permits for new sources in non-delegated states.

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                             -10-
o  Expedite review or revision of emission limits required
   by interstate actions under Section 126, fuel/energy
   decisions, tall stack policies, litigation, etc.   The
   bubble policy should be implemented where appropriate.

o  Ensure quarterly data submissions for the National
   Air Monitoring Stations (NAMS) in compliance with all
   guidance concerning siting, design, and quality assurance.
   Special emphasis should be placed on sites to be used
   to assess 1982 attainment.

o  Maintain implementation schedule of State/Local Air
   Monitoring Stations (SLAMS).  Jointly review the status
   of existing networks with the states.

Second Level Objectives

o  Complete Major SIP Actions

   Some states will require SIPs for lead and lll(d) plans
   in FY 1982.

o  Continue Key Special Purpose Monitoring

   Maintain the network for assessing particle size in
   selected areas; report the air quality index; and
   review source-operated PSD networks.

Objectives for State/EPA Agreements and Grant Negotiations

State/EPA Agreement Objectives

o  Air Toxics Initiatives

   Improve existing mechanisms for controlling toxic
   pollutants that pose problems at the state/local level.

o  PSD

   Encourage states having major industry or growth to assume
   PSD responsibility either through an approved state plan
   or delegation from EPA.

o  In-Use Vehicle and Transportation Control Programs

   Provide states with assistance requested to minimize
   problems in their initiation of I/M and transportation
   programs.

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                               -11-
o  Regulatory Reform

   Encourage and facilitate state development of mechanisms
   for establishing and implementing regulatory reform inno-
   vations such as the "bubble."

Grant Objectives

   Grants should be made to states for the following priority
   activities:

o  1982 Oj/CO SIPs -

      Implement stationary source volatile organic compound
      controls.

   -  Implement I/M.

      Complete SIP data base and submit SIP.

      Coordinate transportation planning with lead planning
      agencies.

o  New Source Review

      Assume PSD responsibility.

   -  Cooperate with EPA audit or review programs.

      Assume full responsibility for NSPS.

o  Air Monitoring Regulations

      Report and verify NAMS data.

      Complete SLAMS network by January 1983.

      Report all necessary aerometric data.

AIR ENFORCEMENT

     In FY 1982 EPA will work with the states to develop
continuous compliance systems that will assist in dealing
more effectively with continuing intermittent noncompliance
by stationary sources.  Priorities for enforcement actions
will be developed, and appropriate enforcement tools for
continuous compliance cases developed.

     In the Mobile Source area, selective Enforcement Audits
will be the primary means of ensuring that production vehicles
meet emission standards.   States should be encouraged to
establish in-use enforcement programs.

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                               -12-



Stationary Source Enforcement

Headquarters Objectives and Activities

o    Support litigation activities.

o    Develop more flexible guidance on implementation of
     noncompliance penalties under 120 of the Clean Air
     Act.

o    Assist states in developing continuous compliance
     systems to deal more effectively with continued
     intermittent noncompliance.

o    Conduct New Source Performance Standards (NSPS) and
     National Emission Standards for Hazardous Air Pollutants
     (NESHAPS) enforcement activities.

Regional Objectives and Activities

First Level Objectives

o    Initiate, in cooperation with states, appropriate admini-
     strative and civil enforcement actions and track consent
     decrees and schedules.

o    Ensure compliance with permit conditions by new sources.

o    Assess and collect noncompliance penalties in consulta-
     tion with states, and work with states in promoting
     delegation of 120 authority.

o    Ensure compliance with NESHAPs and NSPS.

o    Work with states to bring cases against sources which
     have not made reasonable efforts to maintain continuous
     compliance with applicable regulations.

Region-Specific Objectives and Activities

o    A level 1 priority, particularly in the Western Regions,
     is working with the states in issuing and ensuring compliance
     with nonferrous smelter orders.

o    Emphasis should be given to supporting the Department of
     Energy's expanded coal conversion program.  This may involve
     issuing 113(d)(5) orders and reviewing requests for 110(f)
     suspensions in cases of alleged Regional or national energy
     emergencies.

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                             -13-
Mobile Source Enforcement

Headquarters Objectives and Activities

First Level Objectives

o    Assembly line testing and recall programs.

o    Anti-tampering and anti-fuel switching efforts.

o    The state/local anti-tampering and anti-fuel switching
     enforcement program will continue as a high priority via
     a special allocation of Section 105 air grant funds.

THE RADIATION PROGRAM

    Highest priority in 1982 should be given to work related
to radioactive waste disposal standards  in particular,
high level waste disposal, uranium mill tailings, and low
level waste (including de minimis standards).  In FY 1981,
Clean Air Act activities (regulation of radionuclides) and
radon efforts should be managed so that attention and resources
are focused on projects that can be completed.  The work
should be designed to support action related to other state
and federal management and regulatory activities.

     In the FY 1982 Regional program, particular attention
should be given to EPA Regional participation in emergency
response plan development and testing under Federal Emergency
Management Agency guidelines.

Headquarters and Regional Objectives and Activities

First Level Objectives

o  Promulgate a high level waste standard.  (HQ)

o  Complete regulations under the Uranium Mill Tailings Act.   (HQ)

o  Maintain a state of readiness in EPA response capability
   and participate in the review and testing of state
   Emergency Response Plans.  (HQ, Regions)

o  Propose standards for low level waste disposal.  (HQ)

o  Study the need for a Federal guidance document for non-
   ionizing radiation.   (HQ)

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Second Level Objectives

o  Provide support for implementing radiological standards
   and guidance.  (HQ, Regions)

o  Provide support for the Environmental Radiation Ambient
   Monitoring Systems.  (HQ)

o  Review Environmental Impact Statements.  (HQ, Regions)

Region-Specific Objectives and Activities

     Regions involved with the implementation of Mill Tail-
ings Standards should treat them as a first level priority.

Objectives for State/EPA Agreements and Grant Negotiations

State/EPA Agreement Objectives

     The Radiation Program's primary objective for inter-
action with the states must be review and regular testing
of emergency response plans.  The State/EPA Agreements should
detail the role EPA Regions will play.

THE NOISE PROGRAM

     The President's 1982 budget calls for phasing out the Noise
Program by the end of FY 1982.  As a consequence, no provision
is being made to continue Regional programs beyond September 30,
1981.

     The Agency has approximately 18 months in which to
phase out the Noise Program.  This must be accomplished in
an orderly manner.  Emphasis should be placed on transfer of
information to states and local communities which desire it
for continued noise abatement programs after the Federal
program ends.

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                               -15-
                              WATER
               OPERATING YEAR GUIDANCE FOR FY 1982


     The multiplicity and complexity of the tasks which confront
the Office of Water demand that we utilize the resources and
expertise available at the state level to the maximum extent
possible.  Delegation of programs to states for implementation
is an effective way of carrying out Agency responsibilities.  We
must orient our activities toward development of state capability
to operate effective environmental programs.  In addition, the
Office of Water must carefully re-examine all of its program
activities to ensure their beneficial effect on the public and
the environment is gained without undue regulatory cost or
administrative burden.

THE WATER QUALITY PROGRAM

     The Water Quality Program will reflect a reduced level
of available EPA resources in FY 1982.  Major emphasis will be
on implementing and improving existing programs.

     By FY 1982, regulations and planning establishing the
foundation for point source control programs will be largely
in place.  As a consequence, the Water Quality Program's major
emphasis in FY 1982 will be to encourage implementation of control
measures at the state level and carry out Federal responsibilities,
To this end, the Water Quality Program's major 1982 goals are:

o  To improve the process for setting environmental priorities
   and coordinating program activities both within the Agency and
   at the state level.

o  To improve monitoring programs.

o  To encourage states to examine the attainability of
   stream use Designations in targeted areas.

o  To develop Best Available Technology (BAT) guidelines for
   incorporation in industrial permits.  (The Office of Water
   Enforcement guidance elaborates further on this goal.)

o  To reorient the management and funding priorities of the
   Construction Grants Program to accentuate results-oriented
   management (including water quality impacts) and to shift
   the project management responsibilities to the states
   through delegation.

     The Agency will not request additional appropriations for
grants to states under the Section 208 program or the Section 314
Clean Lakes program.  Section 106 funds can be used for general
nonpoint source control program development and lake restoration
activities.

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                               -16-


Headquarters and Regional Objectives and Activities

First Level Objectives

o  Improve overall water quality program management
   and problem identification.

      Identify and characterize state environmental
      problems utilizing 305(b) reports, hot spot
      analyses, Water Quality Management plans, and
      other environmental assessments.  Develop
      Regional water media strategies reflecting
      state assessments and the national Water Quality
      Management (WQM) strategy.  (Regions)

   -  Ensure that plans for point and nonpoint source
      control measures will yield consistency among NPDES
      permits, construction grants, and WQM plans, in
      accordance with Sections 208(d) and  (e) of the
      Clean Water Act.  (Regions)

o  Improve monitoring capabilities to establish more
   statistically representative and scientifically valid
   measurements of environmental quality.  Identify
   priority areas for pollution control programs and
   track the success of these programs, emphasizing
   the Agency's intermedia pollutant priority list.

      Assisted by an interagency agreement with the
      U. S. Geologic Survey, collect and analyze
      biological and chemical monitoring data for
      assessing water quality and provide data to
      STORET in standardized format.  (HQ, Regions)

      Develop better data analysis for measurable
      water quality improvements.  (HQ, Regions)

   -  Help states improve their water monitoring
      programs by implementing the Basic Water Monitoring
      Program, water monitoring strategy,  five-year
      toxic pollutant monitoring plans, and state and
      Regional quality assurance programs.  (HQ, Regions)

      Carry out demonstration prototypes as part of the
      water monitoring strategy.  (Tentatively, Regions II,
      IV, V, and X)

   -  Perform priority pollutant analyses  to determine
      exposure/fate of pollutants.   (Regions)

o  Help states improve their water quality standards
   (WQS) development and attainment programs, including
   wasteload allocations.

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                              -17-
      Encourage states to complete WQS attainability
      assessments, modify existing use designations
      where justified, and prepare wasteload allocations,
      focusing on waterways with major permit actions
      scheduled, situations where more than secondary
      treatment is required, and areas with high priority
      toxics problems.  (HQ, Regions)

   -  Identify areas potentially in need of "hot spot"
      studies (to determine if post-BAT controls may be
      required) and track state/Regional follow-up of
      action recommendations from FY 1981.   (HQ, Regions)

o  Target solutions to site-specific problem areas iden-
   tified through state/Regional problem assessments.

      Build the nonpoint source information base and
      transfer network, using results  of nonpoint
      source prototype projects to the extent resources
      allow.  (HQ, Regions)

   -  Assist Regional permit writers to interpret and
      apply the BAT and BCT development documents,
      emphasizing pollutants on the intermedia priority
      list.  (HQ)

      Reassess EPA's involvement in the Great Lakes
      program while continuing to fulfill current
      abatement and control responsibilities under the
      Great Lakes program.

o  Reorient the management and funding emphasis of
   EPA's Construction Grants Program in PY 1982 to
   reflect more efficient and effective targeting of
   the limited personnel and grant resources.

   -  Establish and put in place a management and
      evaluation system covering Headquarters,
      Regional, and state priorities that stresses
      environmental and program results.  (HQ, Regions)

   -  Complete delegation of all project level activi-
      ties to most states and show significant progress
      toward moving EPA out of project level management
      decisions.  (Regions)

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                             -18-
   -  Complete an overall evaluation of the existing
      regulations to determine better and more efficient
      approaches to grants management, leading to signifi-
      cant regulatory and policy reform.   (HQ)

   -  Assuming passage of the Administration's legislative
      proposal to reform the Construction Grants program,
      limit funding to treatment-related projects (Needs
      Survey categories I, II and IVB) in conjunction
      with the Municipal Management System and water
      quality emphasis.  (Regions)

      Streamline the entire grants process.  (HQ, Regions)
                                             1
      Accelerate evaluations and determinations on
      applications for ocean discharge waivers (301(h)).
      (HQ, Regions)

Second Level Objectives

o  Improve state WQS programs, including wasteload
   allocations.  (Regions)

   - Confine toxics reviews to areas designated "fishable/
     swimmable" where actual toxic ambient levels jeopardize
     the use designation.

   - Perform intensive monitoring efforts in areas
     identified as "hot spots" and develop controls as
     appropriate.  (Regions)

   - Help states prepare wasteload allocations for
     minor municipal and industrial dischargers not
     addressed in first level objectives.  (Regions)

   - Develop and refine wasteload allocation procedures
     for toxic pollutants. (HQ)

o  Issue regulations (in coordination with the Department
   of Energy and the National Oceanic and Atmospheric
   Administration) for deep sea mining and ocean thermal
   energy conversion.  (HQ)

o  Conduct WQM Program Reviews.  (HQ, Regions)

o  Manage construction grants activities not delegated.

   - Administer project-related activities not yet assumed
     by delegated states, focusing on Step 1 and facility
     planning decisions and making maximum use of the
     Corps of Engineers in other areas.  (Regions)

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                             -19-


Objectives for State/EPA Agreements and Grant Negotiations

State/EPA Agreement Objectives

o  Ensure that State/EPA Agreements reference Section
   205(g) state delegation agreement timetables, EPA
   oversight functions, and the scope of delegation.

o  Negotiate with the states to give priority to funding
   treatment-related projects.

o  Negotiate a schedule for WQS attainability assessments
   to be conducted by the states with EPA assistance.

o  Negotiate with the states about plans to monitor
   toxic "hot spot" areas and develop appropriate
   control programs.

o  Negotiate with the states to identify nonpoint source
   problems and approaches to solving them.

Grant Objectives

o  Improve state water monitoring programs, scheduling of
   intensive surveys, and toxics data collection and
   analysis.

o  Improve state capability to make waste load
   allocations (WLAs).

o  Issue BAT permits.

o  Conduct compliance evaluations for point source permits
   and follow up with enforcement where appropriate.

THE DRINKING WATER PROGRAM

     The Office of Drinking Water (ODW) will provide guidance
and advisory information on health effects of unregulated
drinking water contaminants to states and localities.  It
will give priority to those chemicals on the Agency's inter-
media priority list (now under development) which are drinking
water problems.   ODW will conduct an intensive review of the
Suggested No Adverse Response Levels (SNARLs) process to
validate the scientific basis of the guidance, to incorporate
Science Advisory Board review of SNARLs prior to issuance,
and to ensure that SNARLs are in fact supportive of state
and local authorities and are not of a character as to alarm
public officials,  operators,  or users.   Where the extent of
occurrence and known adverse health effects warrant, we will
develop maximum contaminant levels levels (MCLs) as a part
of Revised Primary Drinking Water Regulations (RPDWR).

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                             -20-
     ODW will also promote compliance with existing standards
wnich deal with the traditional contaminants of concern in
drinking water.  We will give higher priority to bringing
small systems into compliance, since these systems are numerous,
constitute the majority of noncompliance cases, and have
particular financial and operating problems to overcome.

     ODW is currently launching the underground injection
control (UIC) program to protect underground drinking water.
The Regions should promote states' assumption of primacy in
the underground injection control program by working with
states to prepare UIC programs and by reviewing applications
from states as soon as they are received.  In all nonprimacy
states and on Indian lands, the Regions will implement a
Federal UIC program.

     ODW will also protect sole source aquifers by ensuring
that projects assisted with Federal funds in designated
areas do not contaminate underground drinking water.
Regions will review petitions for sole source designations
and will designate those aquifers as sole and/or principal
sources of drinking water which, if contaminated, would pose
a significant problem.

     In addition, ODW will recommend ways in which EPA can
better coordinate implementation of programs which can protect
underground drinking water sources and will strengthen its
partnership with the states which have primary responsibility
for 9round water protection.  Specifically, ODW will encourage
coordination of drinking water programs at the Regional and
state levels with programs regulating hazardous waste sites
(RCRA and Superfund) and with state assistance programs
under whose aegis states are developing specific management
plans and programs.

Headquarters and Regional Objectives and Activities

First Level Objectives

o  Propose Revised Primary Drinking Water Regulations
   (RPDWR).  (HQ)

o  Promulgate MCLs for synthetic organic contaminants
   (such as TCE; Carbon tetrachloride; tetrachloroethylene;
   1,2, Dichloroethane; 1,1,1 trichloroethane; and vinyl
   chloride).  (HQ)

o  Expand monitoring for synthetic organic contaminants
   in drinking water derived from ground water, especially
   in proximity to hazardous waste disposal facilities.
   (HQ/Regions)

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                           -21-
o  Issue scientifically sound health guidances for unregulated
   contaminants. (HQ)

o  Help the states to implement the trihalomethane (THM)
   regulations.  (Regions)

o  Work with states to implement the Compliance Strategy.
   (Regions)

o  Administer the PWS program in nonprimacy states and on
   Indian lands.  (Regions)

o  Evaluate state implementation of the PWS and UIC programs.
   (Regions)

o  Implement a vigorous program to promote state delegation
   of the UIC program.  (Regions)

o  Implement a vigorous UIC program in nonprimacy states and
   on Indian Lands.  (Regions)

o  Review UIC primacy applications and provide assistance
   to oversee the activities of newly-designated primacy
   states.  (HQ/Regions)

o  Develop guidance documents to help Regions and states
   implement the UIC program.  (HQ)

o  Coordinate UIC activities with RCRA, Superfund, sole
   source programs.  (HQ/Regions)

Second Level Objectives

o  Prepare criteria for control of corrosion within distri-
   bution systems for inclusion in the RPDWR.  (HQ)

o  Supply advice and maintain analytic capacity for monitoring
   and treatment technology.  Utilize this analytic capacity
   to generate information to support the development of
   regulations and standards and to conduct nationwide
   surveillance through a variety of special surveys of
   drinking water samples.  (HQ)

o  Develop, in cooperation with ORD, a revised laboratory
   certification manual to accompany the RPDWR.  (HQ)

o  Administer the program to regulate water supplies
   of Interstate Carrier Conveyance. (Regions/HQ)

o  Revise the MSIS computer system to accommodate data
   requirements of RPDWR.  (HQ)

o  Implement and operate the UIC ADP system for well
   inventory and permit tracking.   (Regions)

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                              -22-
o  Administer the sole source aquifer program; receive
   and review petitions for designations; review
   projects receiving Federal assistance for potential
   threats to aquifers.  (Regions)

o  Develop sole source aquifer regulations.  (HQ)

Region-Specific Objectives and Activities

o  Provide technical advice and on-site supervision of 1-190
   construction to protect the Wachusett Reservoir watershed,
   (Region I)

o  Work with Pennsylvania, Indiana, South Dakota, Wyoming,
   Oregon, American Samoa, and the Northern Marianas to
   assume primacy for the PWS program.  (Region III, V,
   VIII, IX and X)  If Iowa relinquishes primacy, implement
   a public water system supervision program in Iowa.
   (Region VII)

o  Provide review of and technical advice for Federally
   assisted projects and petitions in potential sole source
   aquifer areas.  (Regions IV)

o  Work with the states on their implementation of
   state enforcement strategies.   (Region VII)

Objectives for State/EPA Agreements and Grant Negotiations

State/EPA Agreement (SEA) Priorities

o  Public water system supervision program.

   -  Monitor for synthetic organic chemicals in drinking
      water and coordinate with related activities to
      control the disposal of hazardous wastes.

   -  Follow up noncompliance and  implement the compliance
      strategy and THM regulation.

o  Underground injection control.

      Implement state-by-state strategies leading to
      effective delegation of the  UIC program.

   -  Coordinate with other programs  (RCRA, Superfund)
      contributing to underground  water supply problems.
      Include specific provisions  which delineate Drinking
      Water program responsibilities  in assessing ground
      water contamination involving or threatening drinking
      water sources.

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                              -23-
Grant Priorities

     The priorities in the SEA should be reflected in the
grant applications.  Additionally, grant funds should be
used to support these high priority activities:

o  Public Water Systems:  (1) Assess monitoring efforts
   for synthetic organic chemicals in drinking water derived
   from ground water sources and expand where insufficient.
   Coordinate these activities with related programs to
   control the disposal of hazardous wastes.  (2) Establish
   coordinated procedures to respond to the detection of
   ground water contamination emergencies.  (3) Increase
   noncompliance follow-up activities and assist small systems
   to achieve compliance with the traditional drinking water
   contaminants:  bacteria, turbidity, ten inorganic ions,
   six pesticides, and radiation.  (4) Ensure compliance
   with new MCLs for THMs.

o  Underground Injection Control;  Permit activities including
   technical review, site investigations, data management,
   completing Class V assessments, and preparing recommendations
   on regulatory schemes should receive highest priority for
   funding.

WATER ENFORCEMENT AND PERMITTING

     Continuous compliance by Publicly Owned Treatment Works
that have completed construction to achieve secondary treatment
or other requirements should be a high priority.  In addition,
municipalities on construction schedules to comply with the
law should be tracked and enforcement actions should be taken
to ensure compliance with schedules and interim effluent
limitations.  Municipal permittees that will not meet the
1983 deadline should be put on compliance schedules.  Regions
should adhere to the priorities outlined in the National
Municipal Policy and Strategy and operate within the require-
ments of the Municipal Management System (MMS).  The level
of enforcement activity against facilities not presently on
compliance schedules may be affected in part by the operational
level of EPA's Construction Grants program.  In implementing
this guidance, our enforcement will stress environmental con-
ditions rather than number of legal actions taken.

     EPA is conducting a regulatory impact analysis of its
pretreatment program in FY 1981, as requested by the Vice
President's Task Force on Regulatory Relief.  The Regions
should provide assistance needed by states and communities
in developing local programs and implement the pretreatment
program as modified by the currently ongoing review.

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                              -24-
     Issuance of long-term best available technology (BAT)
permits for toxic pollutant discharges will also be an
important activity in FY 1982.  Regions and states will issue
permits based on effluent guidelines where available and, in
the absence of effluent guidelines, will determine limits on
a case-by-case basis using best professional judgment.

Water Quality Enforcement

Headquarters Objectives and Activities

First Level Objectives

o    Take action on ongoing cases.

o    Fully develop a Discharge Monitoring Reports (DMR)
     Quality Assurance program to improve NPDES compliance
     data.

o    Overview the implementation of the National Municipal
     Policy and Strategy through the Municipal Management
     System (MMS).

o    Initiate improvements in the Enforcement Management
     System (EMS).

o    Provide guidance and overview for continuous compliance
     by major municipal facilities.

Second Level Objectives

o    Provide support for maintenance of an automated DMR review
     using the Permit Compliance System.

Regional Objectives and Activities

First Level Objectives

o    Initiate and prosecute civil actions and track consent
     decrees and schedules.

o    Support litigation activities.

o    Take action on ongoing cases.

o    Implement a fully developed DMR Quality Assurance Program
     to improve NPDES compliance data.

o    Implement the National Municipal Policy and Strategy
     through the Municipal Management System.

o    Expand monitoring and enforcement activities for toxics,
     priority pollutants, and BAT.

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                              -25-
o    Maintain automated DMR review using the Permit Compliance
     System.

o    Implement a continuous compliance program for major
     municipal permittees.

Second Level Objectives

o    Conduct compliance inspections of major permittees.

o    Conduct follow-up activities on inspections.

o    Continue non-NPDES enforcement activities (404 and
     311).

NPDES Permits Issuance

Headquarters Objectives and Activities

First Level Objectives

o    Coordinate NPDES permitting with RCRA and Underground
     Injection Control (UIC) programs.

o    Coordinate the inter-media priority pollutants list with
     second round NPDES permitting.

o    Coordinate and target BAT engineering studies as closely
     as possible toward abatement of inter-media priority
     substances.

o    Manage second round BAT permit issuance and provide
     training to permit writers.

o    Track major new source permits and implementation of the
     Priority Energy Project Tracking System.

o    Prepare a regulatory impact analysis of the pretreatment
     program and take steps called for as a result of that
     analysis.

o    Develop ways to allow states greater authority and flexi-
     bility in pretreatment decisions.

Regional Objectives and Activities

First Level Objectives

o    Issue the second round of major NPDES industrial permits,
     with special attention to the major primary industries.

o    Ensure that all second round permits take account of
     inter-media priority pollutants in permitted effluents.

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                             -26-
o    Issue energy-related permits, especially for offshore
     oil and gas operations.

o    Implement the Municipal Management System.

o    Promote assumption of the NPDES program by the states.

o    Carry out pretreatment programs responsibilities as
     indicated by the results of the regulatory impact
     analysis currently underway.

Second Level Objectives

o    Review 301(h) Marine Discharge Variance requests.

o    Conduct and settle Evidentiary Hearings, including
     pending and new requests, where environmental gains
     will be the greatest.

o    Propose and issue general permits.

Drinking Water Enforcement

Headquarters Objectives and Activities

First Level Objectives

o    Provide guidance and overview to Regions operating UIC
     programs in non-primacy states.

o    Develop a nationally consistent enforcement management
     system for the UIC programs.

Regional Objectives and Activities

First Level Objectives

o    Enforce health-related Primacy Drinking Water Regulations
     in non-primacy states.

o    Issue UIC permits in non-primacy states and Indian lands.

Second Level Objectives

o    Review the enforcement portions of state applications
     for Underground Injection Control (UIC) program primacy.

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                             -27-

              SOLID WASTE AND EMERGENCY RESPONSE
             OPERATING YEAR GUIDANCE FOR FY 1982

THE_SO_L^D_WASTE_PROGRAM

     In FY 1982, the Office of Solid Waste will emphasize
full implementation of the RCRA Subtitle C Hazardous Waste
Regulations.  The preliminary stages of implementation 
authorization of states' programs, the manifest system, and
the interim status standards  are being initiated in FY 1981.
Final state authorization and facility permitting will be the
main facets of national Subtitle C implementation in FY 1982.
At the same time that the Office of Solid Waste and Emergency
Response (OSWER) proceeds to implement new program elements,
it will carefully review program experience to date to ensure
the efficacy and reasonableness of program requirements.
Consistent with its legal and program responsibilities, OSWER
will make whatever regulatory or administrative changes that
may be necessary to minimize regulatory cost, management
overhead, reporting requirements, and time lapse in processing
permit actions.

     The Regions should assist the states in developing programs
which will qualify for interim authorization phases.  Where
states are ineligible for any phase of interim authorization,
the Regions will enter into Cooperative Arrangements to
effectively operate the Federal program with maximum delegation.
Where this alternative mechanism is used, states will implement
elements of the RCRA program on EPA's behalf, commit to a
schedule for obtaining authorization, and remain eligible
for Federal assistance.  Non-authorized states that do not
enter into Cooperative Arrangements will not be eligible to
receive hazardous waste grants.  Funds allocated to states
but which cannot be awarded will be reprogrammed for operation
of the Federal program in the states by contractors.

     Regions will implement their quality assurance plans in
FY 1982 and ensure that states provide for quality assurance
for hazardous waste testing, sampling, and analytical activities,
whether performed in public or contracted laboratories.
OSWER will take steps to ensure the scientific validity and
appropriateness of required monitoring of hazardous wastes
and their proximate environment.

     In FY 1982 Headquarters will take over from the Regions
primary responsibility for management of the close-out of the
61 Resource Recovery Cooperative Agreements.
First Level Objectives

o  Review the hazardous waste regulatory program, as requested
   by the Vice President's Task Force on Regulatory Relief,
   focusing on ways to improve accountability with reduced
   regulatory and information collection burdens.  (HQ)

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                              -28-
o  Maximize the number of states receiving authorization
   as early as possible by helping states develop qualified
   hazardous waste programs under Subtitle C.  (Regions)

      Negotiate interim authorization phases according to
      the regulatory schedule and national implementation
      guidance.  (HQ)

o  Negotiate and enter into Cooperative Arrangements with
   those states not qualifying for Interim Authorization.
   (Regions)

   -  Assist states in preparing development plans for
      authorization.

      Administer non-delegable elements of the Federal
      hazardous waste program.

   -  Work with states to ensure compliance with
      Cooperative Arrangement provisions.

o  Develop technical conditions for interim land disposal
   facility permits and, in states without appropriate
   phases of interim authorization, for incineration,
   treatment, and storage permits.  These should be in
   line with Regional strategy for issuing priority permits,
   considering proper control for Agency-designated priority
   toxic chemicals, Regional capacity, and the states' siting
   programs and promoting consistency of state permitting
   procedures with Federal requirements.  (Regions)

o  Make expert teams available for initial development of
   significant permits.  (HQ)

o  Develop a uniform manifest form for all states and a means
   for its implementation.   (HQ/Regions)

o  Operate the Federal manifest system in non-authorized
   states.  (Regions)

      Provide technical assistance on requirements to states
      and to generators, transporters, and owners/operators
      of treatment, storage, and disposal facilities.

   -  Review exception and discrepancy reports.

Second Level Objectives

o  Implement Quality Assurance Program and Project
   Plans submitted in FY 1981.  (Regions)

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                             -29-
o  Manage any remaining Technical Assistance Panels
   contractor capabilities carrying over from FY 1981,
   with emphasis on assistance in hazardous waste
   management.  (Regions)

Region-Specific Objectives and Activities

o  Help the 26 Indian reservations come into compliance
   with RCRA (Region VIII).

Objectives for State/EPA Agreements and Grant Negotiations

State/EPA Agreement Objectives

o    Implement EPA-authorized state hazardous waste programs.
     Emphasize operation of a manifest system and adherence
     to national permit priorities.

o    Ensure that states without interim authorization
     support the Federal program through Cooperative
     Arrangements and concentrate developmental
     activities on refining statutory authority, pro-
     viding increased resources, expanding compliance
     and enforcement activities, and providing
     appropriate permit mechanisms.

o    Implement EPA-approved state Solid Waste Plans with
     emphasis on the development of compliance schedules
     and enforcement against open dumps, implementation of
     codisposal and resource recovery strategies, and facilities
     planning.

Grant Objectives

     Commitments in State/EPA Agreements should be supported
in grant applications and awards.  Additionally, Hazardous
Waste grant funds should be used as follows:

o  To assist states with interim authorization to operate
   effective interim authorized programs and work toward
   full authorization.

o  To assist states that do not receive interim authori-
   zation in FY 1982 to contribute the full amount of program
   assistance that is legally and financially possible while
   also working with EPA to effectively implement the Federal
   program.

o  To support planning  and siting programs for hazardous
   waste facilities.

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                             -30-
THE EMERGENCY AND REMEDIAL RESPONSE PROGRAM (SUPERFUND)

     In FY 1982, the Agency will expand its emergency response
and remedial action programs in conformance with the Comprehen-
sive Environmental Response, Compensation, and Liability Act
of 1980, commonly referred to as Superfund.  This legislation
charges EPA with responsibility for dealing effectively with
emergencies involving releases to all environmental media,
remedial actions at uncontrolled hazardous waste sites,
environmental damage assessments, and restoration of natural
resources.  Regions and states will share major roles in the
implementation of this program, with short- and long-term
success of depending to a large extent on state participation
in the program.  As in its other program areas, OSWER will
examine Superfund requirements to ensure they exact the lowest
cost to the public commensurate with the needs of environmental
preservation and cleanup.

     The highest priority activity of the Superfund program
will be containment and clean-up of the most serious hazardous
waste emergencies.  Superfund expands the earlier emergency
program by authorizing response to releases of hazardous
substances to ground and surface waters, air, and land, as
well as navigable waters.  This includes not only "classical"
spills such as train derailments or truck accidents, but
also releases from uncontrolled hazardous waste sites where
an emergency situation exists.  The oil spill response and
prevention programs will be carried out by private contractors
under state or EPA programs in accord with the mandate in
Section 311 of the Clean Water Act.

     Remedial activity during the first year and a half of
the Superfund program will emphasize identifying the uncon-
trolled sites that pose the greatest risk to public health
and the environment.  In-depth investigation and engineering
design work that must preceed an actual remedial action will
be started at 70 to 80 sites.  For those sites where planning
has already been completed or is under way, the on-site
clean-up work will begin during the next eighteen months.
Otherwise it will be 1983 before any large number of sites
are ready for remedial action.

Headquarters Objectives and Activities

First Level Objectives

o  Evaluate the current emergency response strategy and make
   necessary program changes and improvements.

o  Provide technical assistance to field operations through
   the emergency response team.

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                               -31-
o  Develop specifications and guidelines for cooperative
   agreements with states.

o  Develop and conduct training programs in safety and
   investigative techniques for field personnel.

o  Award and manage contracts for emergency response and site
   management.

o  Complete and/or refine regulations, strategies, and
   systems which are required to implement Superfund 
   specifically, management information systems, fund
   administration strategies, and improved field
   guidance for site response.

o  Develop protocols for environmental damage assessments
   with assistance from the Office of Research and Development
   and private contractors.

Regional Objectives and Activities

First Level Objectives

o  Develop cooperative agreements which give states primary
   responsibility for designated removal and remedial functions
   or actions.

o  Arrange to provide on-scene response as needed to all serious
   spills of oil and hazardous substances.

o  Arrange to provide emergency assistance and remedial action at
   the most critical uncontrolled hazardous waste sites.

o  Help states develop site inventories and systems for determining
   priorities for remedial action.

o  Strengthen investigative support of enforcement actions at
   hazardous waste sites.

Second Level Objectives

o  Monitor responsible and third party clean-up of oil
   and hazardous spills.

o  Help states upgrade their removal and remedial capabilities.

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                             -32-
o  Process notifications of the existence of hazardous waste
   sites in conformance with Section 103(c) of the Compre-
   hensive Environmental Response, Compensation and Liability
   Act of 1980 (Superfund).

o  Coordinate efforts of other Federal, state, and local
   agencies in environmental damage assessments and
   restoration of natural resources.

o  Update Regional Contingency Plans to conform with the
   revised National Contingency Plan.

HAZARDOUS WASTE ENFORCEMENT AND PERMITTING

     In late FY 1980 the scope of the enforcement program was
expanded by enactment of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (Superfund),
and amendments to the Resource Conservation and Recovery Act.
Implementation of this legislation through the development of
clear and consistent policies and operating practices at both
Headquarters and Regional levels will be a high priority
during 1981.

     During 1982, Headquarters and Regional Offices will
streamline and standardize the initiation and management of
enforcement activities and judicial actions involving hazardous
waste problems.  In addition, throughout FY 1982, Headquarters
and Regional Offices will provide case-specific assistance to
states and assist in development of state programs, including
legislative initiatives, as requested.

     An intensive permitting effort for hazardous waste
management facilities is essential in FY 1982.  It will be
supported by additional resources in the FY 1982 budget.
Existing hazardous waste management facilities will be subject
to compliance monitoring, inspection, sampling, and enforcement
under the interim status standards.  Priorities for processing
RCRA permits will be:  1) applications for new facilities and
for potentially dangerous facilities; and 2) applications for
existing facilities with potential for permit consolidation
or which employ innovative or model processes or techniques.
In certain Regions a further ordering of applications for new
facilities will be necessary.  Depending upon Regional capacity
and the number of new facility applications, it may be necessary
to process permits for off-site facilities first.  All hazardous
waste permit efforts will be top priority tasks during FY 1982.
Implementation of the permit program will take place according
to the draft hazardous permit priorities guidance issued
during FY 1981 and other permit guidance.  OSWER will take
steps to issue permits as simply, economically and quickly as
the law allows.

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                                  -33-
Hazardous Waste Enforcement

Headquarters Objectives and Activities

First Level Objectives

o    Provide legal and technical support for enforcement actions
     in situations involving substantial threats to health or
     the environment.

o    Develop and evaluate improved information procedures and
     enforcement techniques and train legal and investigative
     staff.

o    Develop guidance and evaluate enforcement of Subtitle C
     of RCRA.

o    Conduct investigations of suspected criminal activities.

o    Coordinate transportation-related requirements with the
     Department of Transportation.

Regional Objectives and Activities

First Level Objectives

o    Provide assistance to states working toward final authoriza-
     tion and review state plan submissions.

o    Conduct investigations of suspected criminal activities.

o    Ensure compliance with interim status standards.

o    Ensure compliance with permit requirements and conditions.

o    Ensure that all hazardous waste generators, transporters,
     and disposers have notified EPA of their status and are
     properly complying with Section 3002 requirements.

o    Initiate and prosecute appropriate civil actions.

Hazardous Waste Permit Issuance

Headquarters Objectives and Activities

First Level Objectives

o    Provide national guidance and coordinate Regional per-
     mitting procedures.

o    Provide strategy to ensure that newly permitted waste
     sites adhere to permit conditions.

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                               -34-


Regional Objectives and Activities

First Level Objectives

o    Issue on- and off-site hazardous waste management permits
     to the following types of facilities:  new facilities,
     potentially dangerous existing facilities, existing facili-
     ties employing innovative or model processes or techniques.

o    Encourage development of adequate state Hazardous Waste
     Management programs.

Uncontrolled Hazardous Waste Sites Enforcement

Headquarters Objectives and Activities

o    Develop and issue enforcement guidance to implement
     and integrate hazardous waste enforcement authorities.

o    Provide assistance to state enforcement activities.

o    Participate in joint development of  "Regionally-managed"
     cases with Regions and the Department of Justice.

o    Prepare and prosecute "Nationally Managed Cases."

o    Provide specialized investigatory assistance.

o    Continue to update and implement protocols for non-standard
     samples and provide high-hazard lab  capability.

o    Participate in Agency regulation and guidance development
     processes related to hazardous waste control.

Regional Objectives and Activities

First Level Objective

o    Respond to imminent hazard situations.

o    Provide assistance to state enforcement activities.

o    Provide technical and legal support  to ongoing litigation.

o    Participate in hazardous incident assessment committees,
     assessment process management, on-site investigations,
     and evidence gathering.

o    Initiate and prosecute appropriate civil actions.

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                             -35-
               PESTICIDES AND TOXIC SUBSTANCES
             OPERATING YEAR GUIDANCE FOR FY 1982
     The Office of Pesticides and Toxic Substances  (OPTS)
will have regulatory and enforcement responsibilities  for  the
implementation of the Toxic Substances Control Act  (TSCA);
the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA); and portions of the Federal Food, Drug, and Cosmetic
Act (FFDCA).  OPTS will place increased emphasis on exploring
non-regulatory solutions to health and environmental problems,
identification of and concentration of resources in critical
problem areas, review of existing regulations for possible
efficiencies and regulatory reforms, and effective  intra-
and interagency integration of its activities.  In addition,
OPTS will co-chair the development of the Toxic Integration
strategy in conjunction with the Office of Policy and  Resource
Management.  This policy is targeted to be on-stream in
early FY 1982.

     Other key concerns of OPTS will be to reduce the  backlog
of actions and petitions, to examine procedures for streamlining
permitting, and to work toward regulatory relief which will
not dilute protection of health and the environment.

     The remainder of this guidance deals with specific
program areas.
EFFORTS UNDER TSCA
TOXICS INTEGRATION PROGRAM

     The Office of Toxics Integration  (OTI) has functional
responsibility in four areas:

o  Coordinating with the Toxics Integration Project in managing
   the development of an Agency-wide toxics strategy;

o  Providing leadership in integrating current actions related
   to toxic substances throughout the Agency, including chairing
   and staffing the Toxic Substances Priorities Committee
   (TSPC);

o  Representing EPA with international organizations
   dealing with chemical control;

o  Administering the interagency Chemical Substances
   Information Network (CSIN); and

o  Representing the Agency on the Interagency Regulatory
   Liaison Group (IRLG).

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                             -36-


Headquarters Objectives and Activities

First Level Objectives

o    In conjunction with EPA's Office of Policy and Resource
     Management, develop and begin implementing an Agencywide
     strategy for integration of toxic substances activities.

o    Encourage state and local agencies to control local/
     Regional toxic chemical problems.  Provide guidance,
     backup and foster consistency in approaches.

o    Work closely with other agencies through the Interagency
     Regulatory Liaison Group (IRLG) and other mechanisms to
     foster interagency coordination of efforts to assess
     health risks related to toxic chemicals and to promote
     use of the most efficient ways of responding to such
     risks.

o    Make the Chemical Substances Information Network (CSIN)
     available to more users, including public, state and
     local, Federal, and industry users, and improve data
     systems available to them.  In addition, develop a
     system of user charges to make CSIN self-supporting as
     far as possible.  Explore integration with and accessi-
     bility from existing commercial and Federal data bases.

o    Work to ensure international approaches to toxic chemicals
     are more consistent and based on sound scientific data.
     Make resources available for shared testing and risk
     assessment and for exchanges of scientific and technical
     information.

Second Level Objectives

o    Participate in technical discussions with the European
     Community and individual countries to encourage consistent
     implementation of legislation affecting chemicals.

o    Work toward reaching an international consensus on how
     to implement and enforce principles of Good Laboratory
     Practices (GLP).

THE TOXIC SUBSTANCES PROGRAM

     Under TSCA, the Office of Toxic Substances  (OTS) develops
and operates several programs to induce the chemical industry
to evaluate and control human health and environmental risks
presented by commercial chemicals.  Chemical manufacturers
and processors can be required to test chemical  substances
and mixtures, to notify EPA of their intent to manufacture

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                             -37-
new chemicals or existing chemicals for significant new
uses, and to maintain records and report information.  EPA
can initiate regulatory action to restrict or prohibit the
commercial activities involving new or existing chemicals.
The Agency will work out arrangements under which chemical
companies undertake testing and other TSCA-related activities
voluntarily.  OTS will continue to seek non-regulatory
alternatives and approaches to regulation development which
fulfill the objectives of TSCA without imposing undue burdens
on the regulated industries.

     There will be no Regional Office Toxics Management
activities in FY 1982.  As a result, the Office of Toxic
Substances will seek and rely on alternative ways to carry
out activities related to asbestos in schools.  Public, industry,
and other requests for information should be directed to the
national toll-free telephone line.

Headquarters Objectives and Activities

First Level Objectives

o    Fully operate the key elements of the new chemical
     review program and streamline the review process as
     much as possible.  OTS expects to receive notifications
     on at least 800 new chemicals.  To the extent possible,
     Section 5(h)(4) exemptions will be used to reduce burdens
     on the chemical industry and EPA, and significant new
     use rules will be used to promote evaluation of potential
     health and environmental impacts.  Review existing
     regulations and procedures for effectiveness and need.

o    Meet or exceed the court-approved schedule for deciding
     upon the need for industry to test priority chemicals
     selected by the Interagency Testing Committee.

o    Meet or exceed the court-approved schedule for new
     rulemaking on the use of polychlorinated biphenyls
     (PCBs) in electrical equipment and on the concentration
     cut-off for the PCB regulations.

o    Improve OTS1 ability to review the impacts of TSCA
     implementation on the economy and on innovation in the
     chemical industry.

o    Develop and promulgate, where practicable and permitted
     by statute, environmental and health test standards
     consistent with IRLG and OECD guidelines.

o    Where possible, perform multi-media hazard and exposure
     evaluations and risk assessments.

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                             -38-
Second Level Objectives

o    Promulgate a rule covering exemptions from the ban
     on nonessential aerosol uses of chlorofluorocarbons.

o    Operate the program to address hazardous exposure
     to asbestos in school buildings.

o    Develop procedures to encourage the private, voluntary
     allocation of the costs of conducting tests among the
     manufacturers and processors of chemicals for which
     testing is required.

o    Evaluate the need to control human and environmental
     exposure to chemicals not dealt with as first level
     objectives.

o    Implement procedures within EPA, in conjunction with
     the Toxics Integration Program, for sharing information
     received via new chemical notifications, substantial
     risk notifications and other TSCA sources.

TOXICS ENFORCEMENT

     The enforcement function will support the Agency's effort
to develop an integrated toxic pollutant strategy and will
attempt to take a cross-media approach to toxics enforcement
whenever possible.  In addition, toxics enforcement will be
concerned with the enforcement of existing TSCA Section 6
chemical control regulations and other toxic chemicals which
will be regulated under Section 6.  Regional support of such
new enforcement programs must be timely and effective.

Headquarters Objectives and Activities

First Level Objectives

o    Fully support the integrated toxics strategy.

o    Provide legal and technical support to Regions in case
     development and prosecution.

o    Coordinate toxics integration strategies with the
     consolidated permit program.

o    Conduct compliance monitoring and enforcement activities
     in support of Section 4 (laboratory data audits which will
     involve Regional Office personnel), 5, 5(e), 5(f), and 6
     (inspections of CFC manufacturers).

o    Develop, implement, and monitor enforcement grants-in-
     aid with six states.

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                              -39-


Regional Objectives and Activities

First  Level Objectives

o    Conduct a compliance monitoring  and  enforcement  program
     under Sections 4, 5, 6,  8, and 13 with particular emphasis
     on Section  4, ecological effects good-laboratory-practices
     inspections; Section 5,  premanufacturing  notice  inspections;
     and Section 6, PCB and asbestos-in-schools  inspections.

o    Assist in development, implementation, and  oversight  of
     state cooperative enforcement grants-in-aid.

o    Consider reorganizing to ensure  that the  functions and
     resources of both Toxics Substances  and Pesticides Enforce-
     ment are integrated into a single unit.

o    Initiate and prosecute appropriate civil  actions.


ACTIVITIES UNDER FIFRA AND FFDCA


THE PESTICIDES PROGRAM

     The Office  of Pesticide Programs (OPP) will carry out its
responsibility under FIFRA and FFDCA  for  controlling  use of
pesticides, with  the objective of controlling  of agricultural
and other pests  without causing unreasonable adverse  effects
on human health  or the environment or impose unnecessary
costs or delays  on the pesticides industry.  OPP's major
activities in FY  1982 will include:

o  Granting registrations to permit the use of new pesticides
   or products similar to others already  registered.

o  Granting special registrations to permit nonregistered
   use of pesticides in emergencies and other  special
   situations.

o  Under the FFDCA, establishing pesticide residue tolerances
   to permit the use of pesticides on specific food and feed
   commodities.

o  Classifying pesticide products for general or restricted
   use.

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                             -40-
o  Undertaking risk-benefit analyses of pesticides which
   pose risks that trigger a Rebuttable Presumption Against
   Registration (RPAR).

o  Developing Registration Standards to facilitate the
   registration process and to identify gaps in available
   health and safety data.

o  Filling data gaps identified in the registration
   standards process.

o  Promoting safe and effective use of pesticides
   in conjunction with other pest control techniques.

     OPP will work more directly with state and local
agencies and other groups to help them:  respond to public
health and safety problems, including pesticide spills and
fires; develop and carry on Integrated Pest Management (IPM)
programs; and prepare registration applications and requests
for emergency exemptions.

     All pesticide abatement and control functions in EPA's
Regional Offices will be transferred to OPP by the end of
FY 1982.

Headquarters and Regional Objectives and Activities

First Level Objectives

o    Revise regulations for registration and reregistration
     of pesticides to reflect FIFRA amendments and procedural
     improvements, including the Registration Standards
     program.

o    Carry out the conditional registration program and
     process new registration applications more efficiently.
     High priority will be given to taking action on
     existing petitions.

o    Improve response time on requests for emergency
     exemptions and experimental use permits in order to
     make decisions in advance of timetables for requested
     uses.

o    Review benefits and risks of RPAR chemicals, reach
     final risk/benefit determinations, and restrict or
     eliminate some or all uses of reviewed chemicals where
     necessary.

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                             -41-


o    Prepare pesticide registration standards, including
     reassessments of tolerances.  Also modify the
     registration standard process to improve productivity
     and monitor the results.

o    In the RPAR and Registration Standards activities,
     develop consistent regulatory positions on chemicals
     having the same major uses.

o    Complete the FIFRA guidelines for development of
     data needed for pesticide registration and operate
     a data call-in program to obtain health and
     safety data needed for future development of
     Registration Standards.

o    Where necessary, perform multi-media hazard and
     exposure evaluations and risk assessments.
     Pollutants and other substances designated as
     inter-media priorities will be considered where
     appropriate.

o    Promote safe handling of pesticides through the Label
     Improvement Program and completion of a farm safety
     program involving government, growers, and producers.

Second Level Objectives

o    Consider the use of Integrated Pest Management  (IPM)
     technology in making decisions on regulatory actions
     (e.g., emergency exemptions, registrations, RPARs)
     when technically appropriate.

o    Identify requirements for monitoring pesticide residues
     in order to predict hazards, assess the significance of
     potential problems, and develop exposure assessment
     models for predictive purposes.  Improve the scientific
     validity of pesticide monitoring data.

o    In conjunction with the Food and Drug Administration
     and EPA's Office of Enforcement, administer the laboratory
     audit program to check on the validity of scientific
     data submitted in support of registration applications.

PESTICIDES ENFORCEMENT

     The Regions and states should jointly define specific
priority use problems tailored to the needs of each state and
specific enforcement programs to deal with each priority
problem area.   These programs should be incorporated in state
grant agreements and supported by state and Federal resources.
Headquarters will provide national use priorities for
consideration by the Regions and states in their priority-
setting exercises.

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                             -42-


Headquarters Objectives and Activities

First Level Objectives

o    Provide legal and technical support to Regions in case
     development, prosecution, and settlement.

o    Conduct and improve Regional capability to conduct
     laboratory data investigations, providing full technical
     support for chemical residue and drift analyses.

o    Overview Regional pesticides enforcement and certification
     and training programs.

o    Manage, oversee, and evaluate the state Grants Program.

Regional Objectives and Activities

First Level Objectives

o    Establish and maintain enforcement grants-in-aid with
     states, territories, and Indian tribes, emphasizing pesti-
     cides use enforcement activities.

o    Establish and maintain certification and training programs
     with states and territories.

o    Initiate and prosecute appropriate civil actions.

Region-Specific Objectives and Activities

o    Work closely with Nebraska and Colorado to develop and
     implement EPA-approved plans for the training and
     certification of pesticide applicators.  (Regions VII
     and VIII)

o    Regions with non-participating states should expend
     every effort to includes those states in the enforcement
     grant program.  At present, those states include Alabama,
     Georgia, South Carolina, Ohio, Nebraska, Colorado, Wyoming,
     and Alaska.

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                             -43-
                   RESEARCH AND DEVELOPMENT
              OPERATING YEAR GUIDANCE FOR FY 1982


     Three major objectives will to be of primary importance
in the Office of Research and Development (ORD) as we proceed
to FY 1982.  These are:  (1) integrating research and develop-
ment into the mainstream of EPA's regulatory and enforcement
activities;  (2) enhancing ORD's capability to provide the
information needed for the Agency's future planning and
decision making; and (3) improving the quality of the
scientific and technical information that ORD provides
to the Agency.

     The remainder of this statement describes what action
will be needed in FY 1982 to meet the objectives.

INTEGRATING ORD PLANNING INTO THE MAINSTREAM OF THE AGENCY

     EPA has a joint research planning system in which committees
composed of research staff and representatives from Headquarters
and Regional Offices regularly participate in planning research
to be performed by ORD.  The Research Committee system is an
essential Agencywide tool for integrating research into
regulatory and enforcement activities.  Committee members
are directly involved in formulating ORD plans and reviewing
research in progress.  In FY 1982, the Committees should
refine their respective programs and build on this year's
progress for developing the FY 1983 program.  All offices
involved with the Committees should participate to the maximum
extent possible.  Likewise, the Research Committees will
assist the rest of the Agency in re-examining current approaches
to protecting public health and the environment in the most
cost-effective, reasonable way.  Regional participation in
the planning process is especially important and should be
incorporated into the Regional budget and work planning
process to provide manpower and travel resources to support
Regional representation on Research Committees.

     ORD's budget structure has been realigned for FY 1982 to
correspond to research committee subject areas.  As a result,
each Committee can now see clearly how much is being invested
in a particular topic of research and can determine the
relative priority of specific areas of inquiry within the
total program.  It remains top priority for each Committee
to define its research needs and priorities such that they
can be incorporated into budget year planning.

     The Committees' attention should move increasingly
toward reviewing ongoing research and evaluating the respon-
siveness of recently completed research.  This task should
be greatly aided by the fact that planning, budgeting, and
reporting systems are now aligned along Research Committee
lines.   Of particular use will be a milestone tracking system
which will keep Committee members informed as to when important
research outputs will be delivered.

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                             _44-


ENHANCING ORD's CAPABILITY TO ASSIST FUTURE AGENCY PLANNING AND
DECISION-MAKING

     ORD has an obligation to anticipate future problems
which may jeopardize environmental quality and to provide
the scientific and technical information needed to formulate
future policies.  To this end, the Office of Exploratory
Research (OER) in ORD should add a dimension of stability
and continuity to EPA's long-term research program.  This
will be done through academic "centers of excellence" and a
group to conduct strategic analyses and special studies.

     By FY 1982 approximately 15 percent of ORD's extramural
funding will be awarded through the centralized competitive
grant program.  At least 7 centers of excellence should be
operational by FY 1982, providing long term support to the
Agency.  Strategic analyses and special studies should provide
EPA with an improved understanding of likely future scenarios
and their environmental implications.  This will be done
through publication of the Environmental Outlook, sponsorship
of innovative research opportunities for EPA scientists,
"mini-assessments" of potential future problems/ and integrated
studies of specific regions or economic sectors.

     Links between OER and the Research Committees must be
strengthened during FY 1982.  Greater involvement of OER
staff with Research Committees will provide substantial
benefits in that:  1) grants awarded through the competitive
program can reflect the broad needs of the Committees; and
2) the Committees can be better attuned to the projected
long-range issues and problems that they may face in the
future.

IMPROVING THE QUALITY OF INFORMATION

     Improving the quality of scientific and technical infor-
mation that ORD provides is extremely important for FY 1982.
Three major approaches will be used in support of this objective:

     o    Rigorous peer review of all phases of research and
          development conducted by ORD.

     o    Evaluation, application, and adjustment of quality
          assurance procedures published during FY 1980 and
          FY 1981.

     o    Implementation of ORD's technical information policy,
          which streamlines the dissemination of research
          results.

     Peer review plans will ensure that EPA research meets
the highest standards of scientific quality, objectivity,
and credibility.  Prescribed reviews will include:

     o    Extensive review and rating by outside experts of
          all grant proposals administered through the centralized
          competitive grant program.

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                             -45-
     o    The review of all research results for publication
          in scientific and technical journals.  Research
          results not published in the refereed professional
          literature will be peer reviewed in accordance with
          ORD's technical information policy.

     o    Extensive use of the Agency's Science Advisory
          Board in reviewing health and environmental criteria
          documents on which Agency regulations are based.

     o    Ensuring that unnecessary overlap and duplication
          does not occur.  In the area of mobile source air
          pollution control, there should be close coordination
          with the Health Effects Institute.  The Research
          Program should identify studies which can best be
          designed and conducted by the Institute.

     ORD has responsibility for determining quality assurance
requirements for not only its own environmental measurements
but also those made by program and Regional Offices.  ORD
must assist the Agency in improving monitoring efforts to
establish more statistically representative and scientifically
valid measurements of environmental quality.  In FY 1982
three activities related to quality assurance will receive
priority attention.  First, ORD will provide training, technical
support, and performance audits.  Second, ORD will conduct
overview audits and evaluate the quality assurance activities
the program and Regional Offices are already conducting to
see if any adjustments are needed.  Third, ORD will develop
national performance standards and data acceptability criteria
for use by all EPA laboratories, grantees, and contractors.

     ORD will also implement a formal policy designed to
improve the transfer of technical information from ORD to
interested users.  Designed to streamline information transfer,
the policy contains the following major highlights:

     o    All project reports will be available from the
          National Technical Information Service (NTIS).

     o    All project reports are now summarized in abstracts
          containing the key findings of subject reports.
          This abstract is printed and distributed by ORD.

     o    A technical information plan is produced annually
          by each ORD organizational unit.  This plan identifies
          expected technical information products to be
          produced by ORD research during the year and contains
          estimates of when the products will be available.

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                             -47-
                POLICY AND RESOURCE MANAGEMENT
             OPERATING YEAR GUIDANCE FOR FY 1982


     EPA must develop alternative, more effective, and less
burdensome ways of controlling pollution.  To do so, we must
find more effective, equitable, and economical ways of solving
environmental and management problems.

     Now and in FY 1982 we must concentrate our efforts on
strengthening our ability to provide first-rate policy and
economic analyses to the Agency's top managers; on coordinating
diverse program activities to achieve common goals; on developing
innovative new approaches to pollution control; on posing
and resolving tough budget issues; on helping review, prepare,
and improve regulations; and on conducting program evaluations
and working with other offices and the states to make their
programs more effective.

     At the same time, we must develop and implement a success-
ful strategy for working more effectively with state and
local agencies, business organizations, and public interest
groups.

     The following are our Headquarters and Regional objectives
for meeting these broad goals.

Headquarters Objectives and Activities

First Level Objectives

o  The Office of Policy and Resource Management (OPRM) must
   help the Agency comply with the analytic and procedural
   requirements of Executive Order 12291 on Federal Regu-
   lation, the Regulatory Flexibility Act, and the Paperwork
   Reduction Act.

   Under Executive Order 12291, EPA must set up procedures for
   OMB review of regulations.  OPRM will revise the existing
   approach to developing new rules and reviewing old ones
   to incorporate the requirements of the new Order.  OPRM
   is now developing guidance for performing the cost and
   benefit analyses for new or revised regulations.

   Under the Regulatory Flexibility Act, EPA must develop
   guidelines for defining "small entity" and for analyzing
   the impacts of our regulations on small entities (including
   small businesses, small governments, and small organiza-
   tions).  It must establish procedures for implementing
   the Act in regulatory development.   It is developing a
   plan for the periodic review of all regulations that
   have a significant economic impact on a substantial number
   of small entities.   Under the Paperwork Reduction Act,

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                          -48-
EPA must develop procedures for producing an annual Infor-
mation Collection Budget (ICB).  It is also developing
guidance for determining the cost of information collection
to the regulated population.

The Office of Policy and Resource Management, working
with the program offices, will develop better methods of
regulatory decision-making.  This objective is critical
for EPA, and particularly for OPRM in FY 1981 and FY 1982,
as the further reduction of pollution becomes more expensive.
In addition to finding new approaches to pollution control,
we will also strengthen the Agency's ability to assess
what costs our regulations impose on industries and what
the benefits of those regulations are.

- OPRM will develop an approach to cost-effectiveness
  analysis for major classes of regulation and help the
  Agency implement this approach appropriately in future
  regulatory decision-making.

- OPRM will help program offices demonstrate and quantify
  the benefits of a limited number of major regulations.
  This experience should help OPRM write regulations which
  are more defensible and which it can "target" more
  closely on the most severe problems.

EPA needs to increase emphasis on market- and incentive-
based approaches to regulation such as the bubble policy.

These approaches will create economic incentives to find the
lowest cost means of reducing pollution.  They are important
as a way to encourage economic development, to increase
the rate of innovation in pollution reduction technology,
to eliminate overhead, and to reduce the cost of pollution
control.  To encourage more industries and communities to
take advantage of these new approaches, OPRM staff, working
with the appropriate Headquarters and Regional program
offices and state and local agencies, should:

-  Work to provide the technical assistance and resources
   to help states and localities incorporate regulatory
   reforms into their on-going programs and ensure that
   short-term costs associated with converting to these
   approaches do not discourage adoption and vigorous use
   of these reforms.  This should include their use of
   in the 1982 SIPs.

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                             -49-
      Design and implement programs to build the infrastructure
      needed to make regulatory reform work on a broad-scale,
      efficient basis.  OPRM will encourage the development
      of flexible "model" policies or rules that states and
      localities can easily adopt and administer if they
      wish and other actions to help states and localities
      act as laboratories for needed experimentation in this
      expanding field in FY 1982.  OPRM will also assist
      OANR in its efforts to implement innovative regulatory
      reforms after their adoption.

      Work with the Regions to help make sure these approaches
      are equally available in all parts of the country.

      Work with other EPA offices and with state and local
      agencies to develop and begin to implement other
      market-based incentives.

o  OPRM's legislative development efforts will focus on
   developing simple, effective legislative revisions where
   needed to improve the effectiveness of EPA's programs or
   balance national environmental and economic objectives.
   Among the major concerns in FY 1982 will be reauthorization
   of the Clean Water Act to the extent not completed in
   FY 1981.

o  The Office of Policy and Resource Management will take a
   lead role in diagnosing substantive program integration
   problems and will work with program offices, other Federal
   agencies, and state and local agencies to develop solutions.
   Areas OPRM will concentrate on include:

      Assisting in the development of an integrated toxics
      strategy.  OPRM will work closely with OPTS in leading
      the Toxics Integration Committee that is developing
      strategies for coordinating all programs' toxic-related
      activities.  The Committee will set interprogram priori-
      ties on regulating individual chemicals and groups of
      chemicals  an action that will affect all aspects of
      planning, research, information collection, and regulatory
      and enforcement actions.  It will also develop other
      approaches to integrating toxics activities, including
      trying industry-based or geographic approaches to regulation
      and control of toxic pollutants.

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                          -50-
   Supporting the Agency's efforts to design and implement
   new programs such as Superfund in order to ensure that
   the requirements for new programs are coordinated with
   one another and with existing programs in as logical and
   practical a way as possible.

The Office of Policy and Resource Management will contri-
bute to the development of clean energy policies 1E>y
encouraging the development of economically sound and
environmentally benign options and by pressing to ensure
reasonable environmental control of all energy sources.

   OPRM must give close management attention to permitting
   energy projects.  We will work to streamline and closely
   manage permitting associated with getting energy facilities
   on line.

   It will work closely with the Administration and the
   Department of Energy to ensure that the nation's
   commitment to increased coal use is met without undue risk
   to environmental quality.  The Agency has an important role
   to play in encouraging public acceptance of use of coal by
   showing that it can be burned cleanly.

-  It will work closely with DOE and industry to encourage
   the development and marketing of clean alternative
   fuels.  Higher prices of imported oil combined with
   deregulation of prices for other energy sources have
   stimulated development of fuels such as heavy oil and
   tight sands gas, both of which offer attractive alter-
   natives to imported oil.  These circumstances provide
   us with an excellent opportunity to encourage increased
   production of relatively clean fuels and in this way
   to act not just as a regulator but also as a proponent
   of clean energy alternatives.

-  It will develop an integrated plan for the regulation
   of synthetic fuels to reduce delays and uncertainty sur-
   rounding development of these new technologies while
   protecting the environment.  Rapidly emerging synfuel
   technologies will strain research, regulatory, and
   permitting capacity.  As co-chair of the Agency-wide
   Alternate Fuels Group, OPRM will work with ORD and the
   program offices to develop multi-media guidance for
   permit officials and industrial designers in 1981 and
   1982 and prepare to propose coordinated standards
   for the different technologies in 1983-1987.

The Office of Policy and Resource Management will implement
a streamlined, responsive budget development process.
Revisions to the budget development process will be imple-
mented to reduce inefficient use of paper and staff time

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                             -51-
   and make the budget more responsive to top management
   priorities by incorporating more front-end guidance from
   the Administrator and less cumbersome documentation
   requirements and decision-making procedures.

o  OPRM will strengthen its program evaluation effort and
   stimulate and lead an expanded evaluation effort in the
   programs, the Regions, and the states.  We must conduct
   systematic reviews of each Agency program, evaluate our
   present approaches to solving environmental and management
   problems, and assess whether Federal, state, and local
   roles are properly apportioned.  Such evaluation will
   provide EPA and state and local agencies with the infor-
   mation needed to make the modifications to their programs
   that are necessary to increase their effectiveness and
   drop unwarranted activities.

o  OPRM will help to strengthen the Agency's partnership
   with the states.

      OPRM will work with Headquarters offices, the Regional
      offices, and the states to strengthen the use of State/
      EPA Agreements as a top management tool for the Regional
      Administrators and key state officials during FY 1982.
      It will particularly work to improve the agreements so
      that they are truly bilateral agreements that benefit
      both the states and EPA and reflect the strengthened
      partnership that we anticipate.

      OPRM will work with other Headquarters offices, Regional
      offices, and state and local agencies to evaluate
      how effectively programs are delegated and to develop
      improved methods and tools which enable EPA to better
      delegate programs and the states to operate them.

o  OPRM will support Regional Management Analytic Centers
   (RMACs).  It will work with RMACs to develop inter-regional
   projects which most effectively address Regional, state
   and local problems.  OPRM will encourage interaction be-
   tween RMACs and interested offices throughout the Agency
   and make the results of analyses performed by RMACs avail-
   able to interested program offices.

Second Level Objectives

o  OPRM will emphasize decentralized responsibility to the
   Regions and states for decisions associated with regulatory
   reforms.  It will encourage development of more "generic"
   approaches to controlled trading which will eliminate the

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                             -52-
   need for EPA approval of each transaction.  It will also
   give states and Regions more direct responsibility for
   and opportunities to implement regulatory reforms.

o  OPRM will identify ways the Agency and the states can use
   environmental resources more effectively.  Many government-
   funded programs, environmental programs among them, are
   facing serious challenges.  Inflation has significantly
   reduced the purchasing power of grant dollars, and many
   states have introduced Proposition 13-type legislation
   that has reduced their ability to match Federal grant
   dollars.  At the same time, EPA's responsibilities,
   especially those with respect to TSCA, RCRA, and CAA and
   CWA amendments, have increased dramatically.  It appears
   that this trend will continue.  This situation is a grave
   concern, both to the states  who are finding themselves
   unable to support existing programs, much less to assume
   responsibility for new programs  and to EPA.  We must
   all work together now and through FY 1982 to develop ways
   to use EPA's existing direct operations and state grant
   funds as effectively as possible, to document the areas
   in environmental programs that are being most impacted by
   inflation, and to determine how best to help states take
   on new responsibilities in the future.

o  OPRM will develop a much improved strategic planning
   capacity.  The Agency must increase its capability to
   anticipate problems and do a better job of advance planning.
   In FY 1981 and 1982 OPRM will examine alternative approaches
   to managing our planning and budgeting processes so that
   it can better link resource investments with environmental
   objectives.  In addition, it will try to improve the
   data available to the Agency for planning by working with
   Regional Offices to improve the indicators available for
   determining the ambient status of the environment.

Regional Objectives and Activities

First Level Objectives

o  Take the lead in pressing the wide-spread adoption and
   implementation of regulatory reforms such as controlled
   trading if we are to realize their full benefits.  Specific
   top priority actions include:

      Commitment of staff to work with states, industry,
      and environmental groups in developing innovative,
      cost-saving and environmentally sound alternatives to
      our existing regulatory programs.One of the first
      areas the Regions should concentrate on is providing
      fast review of proposed Air State Implementation Plan
      (SIP) changes that incorporate these reforms.

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                                -53-
      Development of an effective technical assistance program
      that supports state efforts to design and implement con-
      trolled trading initiatives.

      Commitment of adequate funds to the states as appropriate
      through Section 105 or other grants that can be used in
      developing and implementing controlled trading initiatives
      at the state or local level.

   -  Work with industry to develop approaches to expand the
      benefits of controlled trading.

o  Concentrate on implementing procedures to expedite permitting
   for energy facilities as well as other permitting reforms.
   It is critical that environmental requirements for such
   facilities are properly met without unnecessarily delaying
   start-up of those facilities.

o  Work with Headquarters to improve data collection and
   analysis activities, particularly the materials developed
   for environmental profiles.Accurate,useful data are
   essential to planning and policy-making and to determining
   the effectiveness of program strategies.  EPA must give
   increased attention to improving the validity of its data
   and to presenting it in a way that conveys information
   easily.

o  Emphasize development of State/EPA Agreements that focus
   on major environmental and management issues of concern
   to them and the states and that are truly bilateral agree-
   ments that benefit both EPA and the states.

o  Develop and support the Regional Management Analytic
   Centers.

      Regional Administrators should place priority on first-
      rate staffing.

      The Centers must increase the communications they have
      with one another and work closely, or even jointly, on
      those projects of interest to more than one.

Second Level Objectives

o  Work with Headquarters to assess how direct operating
   resources can be used more effectively and to help states
   to use their grant funds.  Regional staff are in a particu-
   larly good position to determine whether and how program
   resources are contributing to achievement of environmental
   objectives and how they could be more effective.

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                             -54-
o  Play a more active, critical role in helping develop new
   regulations and evaluate and improve existing regulations
   and policy.  Input from Regional staff during the develop-
   ment and review of regulations is important to any success
   the Agency has in improving regulations and the regulatory
   process, since Regional staff are the people with front-
   line, practical experience in what it takes to implement
   a program.  Regions and states can better assess the
   practical implications proposed rules will have  whether
   they are reasonable, can be implemented, and can be
   understood by the people who will be responsible for
   carrying them out.

OBJECTIVES FOR STATE/EPA AGREEMENTS AND GRANT NEGOTIATIONS

o  Controlled Trading.  Expand efforts to creatively reduce
   the cost of air pollution control by fostering increased
   uses of bubbles, offset trading, and banking.  Strongly
   encourage states to pursue opportunities for pilot experi-
   ments, generic bubble rules, and offset trading and banking
   systems.

o  Consolidated and Streamlined Permitting.  Encourage the
   states to take the lead in this area since most permitting
   occurs there.

o  Energy Projects.  Address more energy/environmental
   problem-solving issues in SEAs.

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                             -55-
                LEGAL COUNSEL AND ENFORCEMENT
             OPERATING YEAR GUIDANCE FOR FY 1982
     During FY 1982 Agency enforcement units will develop
and implement several significant initiatives to address
the cross-cutting aspects of their various programs and to
foster more effective and efficient enforcement at the Federal
and state levels.  These cross-cutting initiatives are discussed
below.

o    Management Reform

     Agency enforcement units will develop criteria and
objectives for an improved program management system.  The
system will include a plan for more effectively integrating
currently available management tools, such as performance
standards, operating year guidance, projected program
accomplishments, budget commitments, State/EPA Agreement
commitments, Grant and Cooperative Agreement conditions, and
periodic Headquarters and Regional program reviews.  A more
effectively integrated management system will enhance our ability
to identify, define, and remedy program deficiencies and will
foster the exchange of particularly successful techniques among
enforcement programs. Regional Offices, and states.

o    Compliance Monitoring and Continuous Compliance

     Priority in enforcement should now be given to ensuring
the continuing compliance of sources that have installed
appropriate control equipment and achieved initial compliance.
In addition, we need to improve tracking and enforcement of
intermediate milestones incorporated in compliance schedules
or agreements.  Regions and states should jointly develop
compliance overview programs to detect and remedy patterns
of non-compliance.

o    Multi-media Compliance Approaches

     During the coming year, EPA will develop uniform procedures
for conducting multi-media compliance inspections, conduct
formal training programs for multi-media compliance inspectors,
develop national protocols for chain-of-custody and evidence
preservation as part of out quality control program, and create
an integrated data management system that will allow us to make
multi-media compliance determinations.  The need for developing
multi-media enforcement tools will be part of an overall Agency
effort to better integrate the regulatory programs of the
various media.  This is especially important for hazardous and
toxic pollutants.

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                             -56-
o    Integrated Enforcement Data System

     Agency enforcement offices will begin to integrate the
major data systems for compliance monitoring, litigation
tracking, Federal facility information, and hazardous waste
site tracking.  When completed in FY 1983, the system will
utilize a single integrated data base which will allow for
cross-media data retrieval and will eliminate duplication of
effort in system operation and maintenance and data input.
The empnasis of this project will be on managing information
and data, improving quality assurance, data production and
storage, establishing data standards, and providing improved
retrieval and analytical capabilities.

o    Consolidated Permits

     The Consolidated Permit Regulations provide for con-
solidated permit issuance procedures and centralized
administration for five permit programs:  the National Pollu-
tant Discharge Elimination System (NPDES); the hazardous
waste permit program under the Resource Conservation and
Recovery Act (RCRA); the Underground Injection Control (UIC)
program; the Section 404 Dredge and Fill program; and the
Prevention of Significant Deterioration (PSD) program.  In
FY 1982 this program will examine and implement reforms to
simplify the Consolidated Permit Regulations and provide
training to assist Regions and states to consolidate and
streamline their permitting activities.

o    Integrated Toxics Strategy

     The Agency's enforcement units are committed to fully
supporting implementation of the Agency's toxics integration
strategy.  The inter-media priority chemicals list should be
considered by Regions and states in establishing enforcement
priorities for all relevant programs (NPDES, PSD, 404, RCRA,
and UIC).

o    Energy-Related Permits

     Permits for energy-related facilities should be issued
in an expeditious manner for all media, with special emphasis
on offshore oil and gas operations and other facilities
designated as priority by the Permits Coordination Group and
the Regions.

o    Enforcement Responses to Emergencies

     Enforcement actions in emergency situations involving
substantial threats to public health or safety whenever or
wherever they occur are to receive overriding priority
attention.

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                             -57-
o    Strengthened Criminal Enforcement Program

     The Agency will improve its ability to investigate and
prosecute criminal enforcement cases, particularly with regard
to major environmental dangers such as midnight dumping.


o    State/EPA Agreements

     In negotiating the 1982 State/EPA Agreements, the Regional
Offices and states should focus on identifying enforcement
commitments which contribute to the solution of major multi-
media or program-specific environmental or management problems,
including state-specific problems, with maximum state partici-
pation and Federal assistance where needed.

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                             -59-
                        ADMINISTRATION
             OPERATING YEAR GUIDANCE FOR FY 1982
     The Office of Administration (OA) is responsible for
providing many management services to the rest of EPA that
are critical to programs' ability to function  grants,
personnel, contracts, support services, management of our
facilities, protection of the health and safety of employees,
and an information management/data processing capability.
Budget constraints and inflation are directly affecting many
of these areas at the same time there is increasing demand
for these management services.  Therefore, EPA needs to
develop new and more efficient ways of performing and providing
these services.  The actions the Office of Administration
plans to take in FY 1982 to be in a position to more effectively
provide these services follow.

Headquarters and Regional Objectives and Activities

o  Improve delivery and the perception of delivery of services
   as now exist in terms of quality and timeliness in order to
   develop OA credibility.  (HQ)

o  Set-up systems to consolidate Agency-wide (including
   Regions) activities in AA/A office for:  (HQ & RO)

   - fiscal reporting

   - information systems development and support

   - laboratory facilities and equipment management
     including acquisition

   - grants and financial administration

   - library and publications systems

o  Develop an accomplishment-oriented personnel assessment
   system that will:  (HQ)

   - allow better estimates of manpower requirements for
     task accomplishment

   - form the basis for a more quantitative personnel
     review technique with perceived higher motivational
     effect

o  Test the system above within OA.  (HQ)

o  Perform a comprehensive management review to determine
   areas of duplicative effort and establish a new, more
   streamlined management organization with its ancillary

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                          -60-
functions.  Test organizational structure in OA.  Recom-
mend action to Administrator in pertinent offices (R&D,
for instance).  (HQ)

Develop summary financial data reporting forms to provide
Administrator with periodic information relating to that
office's direct action concerns.  (HQ)

Simplify contract and grant administrative procedures
in order to expedite implementation of programs, reduce
contractor's  (and, therefore, EPA's) cost, but without
losing control.  If Federal regulatory procedures inhibit
this, move to have them changed.  (HQ)

In all these processes ensure that affirmative action,
civil rights, OSHA, union and other related activities
are adequately taken into account.  (HQ & RO)

Begin to implement the decisions made as a result of the
examination of our laboratory analytic services.  Special
attention will go to decisions that concern capital
investment choices.  (HQ & RO)

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                             -61-
         OPERATING YEAR GUIDANCE FOR FY 1982 FOR THE
              ADMINISTRATOR'S EXECUTIVE OFFICES
     The Administrator's Executive Offices include many
distinct and separate offices.  They are:

     - Immediate Office of the Administrator
     - Office of Administrative Law Judges
     - Office of Civil Rights
     - Office of Federal Activities
     - Office of International Activities
     - Office of Congressional Liaison
     - Office of Public Affairs
     - Office of Small and Disadvantaged Business
     - Office of Intergovernmental Liaison
     - Science Advisory Board
     - Office of Inspector General

     Many of the activities associated with these offices are
conducted in direct response to requests of the Administrator
and Headquarters program offices and do not lend themselves
to inclusion in the Guidance.  However, several offices 
the Office of Federal Activities, the Office of Public Affairs
the Office of Civil Rights, and the Office of Inspector
General  are responsible for ongoing activities that are
carried out in both Headquarters and the Regional Offices
and need to issue some guidance to help the Regions more
effectively carry out their responsibilities.  The likely
1982 priorities of these offices are included in this section
of the Operating Year Guidance.

OFFICE OF FEDERAL ACTIVITIES

     The Office of Federal Activities, pursuant to the mandates
of the National Environmental Policy Act (NEPA), Section 309 of
the Clean Air Act, and Executive Order 12088, will work to
ensure that EPA and other Federal agencies carry out their
activities in manner that protects the environment.

     The purpose of NEPA is to achieve responsible planning and
protection of our nation's natural resources in decisions made
by EPA and other agencies of the Federal government.  All
Federal agencies involved should routinely be brought into the
planning process early so as to produce faster decisions as
well as environmentally sound projects.  NEPA can improve
decisions on major projects by:

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                             -62-
     - identifying early which Federal agencies are involved;

     - consolidating environmental information in a single
       document;

     - identifying early major environmental problems that
       require alternative solutions.

     Pursuant to Section 404 of the Clean Water Act, Executive
Orders, Directives, and other policies, EPA will protect wetlands
and other environmentally critical areas.  It will also carry
out its responsibilities to protect the environment on Indian
reservations in a manner consistent with tribal self-determination
and national policies toward Indian lands.

     In addition, Executive Order 12088 mandates that EPA
assist Federal agencies in controlling pollution from their
facilities and activities by monitoring compliance, providing
technical assistance, reviewing budgetary plans, and resolving
disputes through the administrative mechanisms provided in the
Order.

     The major priorities the Office of Federal Activities
will emphasize in FY 1982 are listed below.

First Level Priorities

     o  EPA NEPA Compliance

       - Ensure that Agency decisions concerning wastewater
         treatment construction grants, new source discharge
         permits, and selected regulatory actions are environ-
         mentally sound and cost-effective and that EPA's
         compliance with NEPA is coordinated, timely, and
         efficient.

       - Identify the benefits and costs associated with the
         NEPA process as it is being implemented.

     o EIS/309 Review

       - Work with other Federal agencies in their planning
         to help them achieve environmentally sound decisions.

       - Give energy projects the highest priority for review.

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                             -63-
     o Protection of Special Areas

       - In undertaking Agency programs, place particular
         emphasis on review of actions affecting floodplains,
         wetlands, coastal zones, prime agricultural lands,
         wild and scenic rivers, endangered species, and
         historic and cultural resources and Indian lands.

     o Activities to Protect Aquatic Ecosystems

       - Review individual Section 404 permit cases,
         with emphais on pre-permit application,
         planning, and analysis.

       - Work actively to encourage and assist states
         in developing their own Section 404 programs.

     o Control of Pollution from Federal Facilities

       - Provide technical assistance to Federal agencies.

       - Review and evaluate annual olans of Federal agencies.

       - Resolve disputes regarding violations by Federal
         facilities.

OFFICE OF PUBLIC AFFAIRS

     The Office of Public Affairs has been significantly
changed during FY 1981.  The former offices of Public Awareness
and Press Services have been abolished and many of the functions
they performed consolidated into a smaller, more focused
Office of Public Affairs.

     The new Office provides the Agency with one centralized
point for coordinating all EPA public information policy and
activities, including public participation.  The reduced size
of this Headquarters office represents a reduction in overlap
and duplication in implementing the Agency's public information
activities.  Some of the specific functions previously performed
by the Office of Public Awareness will now be performed only
by the Regions or Headquarters program offices, while the
Office of Public Affairs ensures consistency with overall
Agency objectives.

     The Office of Public Affairs will support Agency
programs chiefly through press services.  The Office will
have one person assigned to each major program for coordination
of media efforts, technical advice on publications, and
policy input into grants and contracts issued by the program
which are geared to public information activities.  The new
Office will also help Regions by providing direction and
guidelines for Regional publications.

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                             -64-
     Program areas which can be expected  to require public
information office attention are:

     o Clean Air Act and Clean Water Act  - Both of these
       pieces of legislation will  be reviewed by Congress.
       EPA can expect an increased demand for public
       information and programs regarding the laws and
       their implementation through Federal,  state, and
       local efforts.

     o Hazardous Waste Siting - Public acceptance of
       hazardous waste facilities  depends on public
       understanding of the nature of the wastes that they
       are being asked to accept and the  protection afforded
       by EPA's regulations.

     o Regulatory Reform - Implementation of innovative
       regulatory reform efforts,  such as the bubble
       policy, will require public information efforts to
       help state/local agencies and businesses learn how
       to use them to save money.

     o Superfund Activities - A coordinated public information
       and community relation program is  being developed by
       Headquarters for implementation in the Regions.

     o Water Supply Contamination - Information activities
       to alert the public to drinking water contamination
       in their area and the EPA authorities (Safe Drinking
       Water Act, Resource Conservation Recovery Act, etc.)
       for dealing with it.

OFFICE OF CIVIL RIGHTS

     EPA will implement a program to recruit minorities and
women in all of its occupational categories in which there
are vacancies in order to improve the current underrepresent-
ation of those groups.

     For those actions that previously have resulted in formal
discrimination complaints, the Agency will eliminate that
backlog.  Any future complaints will be processed promptly
so that significant backlogs do not occur.

     The Agency will also develop procedures that will enable
it to comprehensively assess equal employment opportunity
with effective standards, evaluation criteria to measure
progress, and monitoring tools for standardized reviews.

OFFICE OF INSPECTOR GENERAL

     In October 1978, the Congress passed and President Carter
signed the Inspector General Act of 1978  (Public Law 95-452).
That Act created Offices of Inspector General in 12 Federal
Agencies including the Environmental Protection Agency.
EPA established its Office of Inspector General in January 1980

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                             -65-
     Araong other duties, the EPA Office of Inspector General
(OIG) is responsible for:

     - Conducting audits and investigations relating to EPA's
       programs and operations.

     - Improving the efficiency and economy of EPA's programs.

     - Reviewing existing and proposed legislation and regula-
       tions in order to make recommendations concerning their
       impact.

     Twice each year, the Office of Inspector General sends
a formal report to the Congress, through the Administrator
and Deputy Administrator, providing results of its audits
and investigations and describing progress in promoting
economy and efficiency in the administration of the Agency's
programs or in preventing and detecting fraud, abuse,
mismanagement,  and waste in the programs and operations of
EPA.

First Level Objectives

     The principal FY 1982 activities OIG will undertake are
broken out into three broad categories:  Project Look reviews,
audits, and investigations.

     o Project Look Reviews

       EPA's Wastewater Treatment Construction Grant Program
       annually represents more than 90 percent of the
       Agency's grant budget.  Problems for construction
       programs have included defective construction,
       substandard materials, improper costing of or unneces-
       sary change orders, collusion in bids, restrictive
       specifications, and bribes or kickbacks to public
       officials.

       Because allegations concerning EPA's construction
       grant program are on the increase, a coordinated
       effort is needed to identify possible waste, mis-
       management, abuse, and fraud.  To address these
       problems, the Inspector General conducts "Project
       Look"  intensive reviews of Construction Grant
       program expenditures and operations.  Under "Project
       Look" the OIG sends out a team composed of auditors,
       investigators, and engineers to perform intensive
       reviews  of selected grant projects.

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                             -66-


     o Audits

       The objectives of OIG audits are:

       - To determine whether the management control
         exercised by the grantee or contractor through
         its management system, accounting system, pro-
         curement system, and property control system
         are adequate to provide assurance that costs
         claimed are reasonable, allowable, and allocable
         to the sponsored project.

       - To review operations and report any noncompliance
         with applicable grant or contract conditions or
         EPA rules and regulations and, based upon the
         review, to provide recommendations for improvement.

       - To identify indicators of fraud, abuse, mismanage-
         ment, and waste or allegations of improprieties
         concerning EPA grants.

       The audit activities planned for FY 1982 will emphasize
       construction grant final preaward contracts (other
       than construction grant preawards), construction grant
       interims, and other final audits.

     o Investigations

       The OIG receives allegations from employees, grantees,
       Congress, and the public concerning a wide variety of
       irregularities.  The OIG has directed its investigative
       priorities to major fraud cases, such as conflicts of
       interest, kickbacks, or bribery of public officials,
       and away from cases of little consequence and of
       little administrative or legal significance.

Second Level Objectives

     o Audit the Agency's ADP systems as required by
       OMB Circular A-71 and the GAO Standards for
       Audit of Government Organizations, Programs,
       Activities, and Functions.

     o Provide audit cognizance for state and local
       agencies as required under Attachment P to
       OMB Circular A-102.

     o Provide oversight of those states that have been
       delegated authority for the Construction Grants
       Program under the Clean Water Act.

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