United States
Environmental Protection
Agency
Office of
The Administrator
Washington DC 20460
March 1987
EPA
Agency
Operating Guidance
FY1988
001R87100
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Agency
Operating Guidance
FY 1988
U.S Environment* Frottctton Afltney
Refton V, L*rar>
23t South Oear^rn
, Illintts ง0604
March 1987
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U.S. Environment! Protection
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PREFACE
The FY 1988 Agency Operating Guidance reflects the Agency's
FY 1988 Priority List, which follows, and the priorities of each
of the Assistant Administrators. The Guidance highlights the
changes in direction and emphasis since last year and provides
the Regions and States directions for planning and executing
environmental programs. It also includes the Strategic Planning
and Management System measures which will be used to track progress
in priority areas.*
The Guidance was compiled by the Office of Policy, Planning
and Evaluation with the Headquarters media program offices and
the Offices of External Affairs and Administration and Resources
Management preparing individual sections. Valuable input and
comments were received from the Headquarters program and staff
offices, Regions and States. Our sincere thanks to the many
individuals who helped develop the final document.
*Guidance and measures for programs affected by recent changes
to the Clean Water Act and RCRA measures are not included in
this document. They will be published shortly and forwarded
for insertion in this document.
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TABLE OF CONTENTS
I. AGENCY PRIORITY LIST
II. PROGRAM OPERATING GUIDANCE
A. Office of Air and Radiation
B. Office of Water
C. Office of Solid Waste and Emergency Response
D. Office of Pesticides and Toxic Substances
E. Office of External Affairs
F. Office of Administration and Resources Management
III. APPENDIX: STRATEGIC PLANNING AND MANAGEMENT SYSTEM
FY 1988 MEASURES
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AGENCY PRIORITY LIST FOR FY 1988
REDUCE RISKS FROM EXPOSURES TO PESTICIDES, TOXIC CHEMICALS AND
PATHOGENS.
a. Reduce risks from pesticides. Continue to give priority to
the re-registration process. Place appropriate pesticides
in Special Review. Continue the emphasis on ground-water
contamination. Strengthen performance of regional and state
enforcement programs and state certification and training
programs. Build technical capability in the regions to support
Agency programs addressing ground-water and other site-specific
pesticide problems.
b. Reduce risks from new and existing toxic chemicals. Emphasize
the review of categories of chemicals and the products of
emerging biotechnology. Use the National Human Monitoring
Program to identify, test, and control chemicals posing
significant risks. Strengthen performance of regional and
state enforcement programs, emphasizing enforcement against
serious violations of PCB regulations. Use TSCA to resolve
cross-media problems in an integrated manner.
c. Control drinking water contaminants. Improve enforcement
of drinking water regulations. Develop standards for
radionuclides, disinfection byproducts and other statutorily-
mandated contaminants. Develop health advisories for
agricultural chemicals and other drinking water contaminants,
and to support RCRA and Superfund decisions.
REDUCE EXPOSURE TO UNHEALTHY AIR QUALITY.
a. Control air toxics. Implement the comprehensive national air
toxics strategy. Continue to identify hazardous air pollutants
and develop federal control requirements for vehicle fuels and
stationary sources, especially hazardous waste and Superfund
sites. Strengthen state and regional enforcement programs.
Increase support to states to implement multi-year air toxics
program development plans. Provide assistance for accidental
release planning through the Chemical Emergency Preparedness
Program.
b. Reduce violations of the ozone standard. Implement the
national ozone reduction strategy. Enforce federal standards
for vehicles and fuels, and improve compliance with state
implementation plans. Tighten existing federal, state and
local emission controls and institute new controls where
necessary. Implement "reasonable extra efforts" programs in
the worst ozone areas.
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c. Reduce risks of exposure to unhealthful levels of indoor air
pollutants, especially radon from both soil and tap water.
Implement the indoor radon assessment and mitigation strategy.
Continue field studies to measure human exposure to air
pollutants. Ensure consistent Agencywide policy analysis,
risk assessments and strategy development for indoor air
pollution.
d. Promote effective remedial actions for asbestos. Strengthen
educational and technical assistance programs. Support
development of state contractor licensing and certification
programs. Develop state inspector training programs. Strongly
enforce asbestos NESHAPSs.
PREVENT GROUND-WATER CONTAMINATION AND REDUCE OTHER RISKS FROM
HAZARDOUS WASTES.
a. Protect ground water resources. Continue to develop and
undertake a comprehensive approach to ground-water management
in cooperation with the states. Implement the Wellhead
Protection Program.
b. Reduce imminent threats to public health and the environment
from abandoned hazardous waste sites. Use increased Superfund
removal authorities to stabilize National Priority List and
non-NPL sites.
c. Control hazardous waste releases to ground water. Make
permit decisions on operating land disposal facilities by
the 1988 HSWA deadline and ensure compliance. Establish
priorities and approve and monitor plans for closing land
disposal facilities. Respond to petitions to continue
underground injection of hazardous wastes and enforce UIC
Class I injection well bans.
d. Clean up significant releases of hazardous substances.
Accelerate use of corrective action authorities at environ-
mentally significant land disposal facilities. Streamline
the Superfund cleanup process and use enforcement efforts
to increase Potentially Responsible Party settlements.
Encourage state-lead projects and federal facility activity.
Pursue cost recovery to reimburse the CERCLA Trust Fund.
e. Prevent and clean up leaks from underground storage tanks.
Complete and enforce tank standards. Approve state UST programs
f. Develop adequate hazardous waste treatment capacity by
promulgating regulations, streamlining permit requirements,
and encouraging alternatives to land disposal.
g. Prevent ground-water contamination from injection wells.
Assure compliance with UIC permits. Control contamination
from Class V wells.
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IMPROVE PROTECTION OF AQUATIC LIFE AND HUMAN USES OF SURFACE WATERS.
a. Control the release of toxic discharges and hazardous wastes
to surface waters. Issue and enforce third-round NPDES permits
for major discharges and significant minors, with BAT and
water quality based requirements. Develop additional toxic
and hazardous waste controls. Screen, investigate and determine
control strategies for unregulated chemicals. Develop technical
guidance for assessing human risks from ingesting toxics-
contaminated fish and shellfish. Improve the coverage and
effectiveness of local pretreatment program requirements by
developing and enforcing categorical standards and local
limits for toxics and hazardous wastes not adequately regulated.
b. Reduce discharges of inadequately treated wastes from municipal
treatment facilities. Aggressively enforce compliance with the
statutory deadline under the National Municipal Policy, taking
judicial enforcement actions where necessary.
c. Reduce nonpoint source pollution. Implement the Agency's
Nonpoint Source Strategy to encourage state development of NPS
control programs for high priority surface and ground waters.
Work with other federal programs to ensure that they complement
state NPS control efforts.
d. Restore the integrity of near coastal waters. Implement an
integrated approach to control toxics and nonpoint source
pollution in near coastal waters, consistent with the
recommendations of the Near Coastal Waters Strategic Plan.
e. Protect wetlands. Aggressively implement the Wetlands Pro-
tection Strategy. Increase emphasis on use of advance
identification and strengthen enforcement for protection of
priority wetlands.
IMPROVE THE AGENCY'S ABILITY TO MANAGE RISK.
a. Develop risk assessment methods for human health effects.
Focus on methods development for non-cancer health effects.
Improve techniques for using animal studies to estimate risks
to humans. Develop statistical models to characterize dose-
response levels of toxic chemicals and to characterize
uncertainty. Determine Structure Activity Relationships to
determine toxic effects of untested chemicals based on physical
similarities to other chemicals for which effects are known.
b. Develop ecological risk assessment methodologies. Develop
integrated environmental risk methods through the use of
ecosystem function and structure information. Develop methods
to assess effects from exposures to complex mixtures without the
need for chemical-by-chemical analysis. Use statistical models
to characterize uncertainties associated with risk estimates.
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c. Develop total exposure methodologies. Improve monitoring of
exposures to human and ecological populations through development
of biological indicators and use of pharmacokinetic and
metabolism information. Improve exposure monitoring systems
and other analytical methods to better identify the total amount
of chemicals absorbed and retained in exposed populations.
d. Work with industry to ensure availability of cost-effective
risk reduction technology. Explore alternative treatment
technologies such as biodegradation, biotechnology and advanced
separation. Conduct pilot-scale evaluations of advanced
incineration and techniques for stabilizing wastes to prevent
releases into the environment. Conduct collaborative, full-scale
demonstrations with private sector on promising innovative
technologies .
EPA MANAGEMENT PRIORITIES
1. Risk Reduction; EPA's basic mission is to reduce the level
of risk to health and to the environment posed by pollution.
Toward that end, the Agency will focus its resources, and those
of society at large, where pollution causes the most damage.
2. Balance environmental gains against other goals; Environ-
mental protection actions should be designed to achieve the great-
est social benefit. The Agency will strive to manage its resources
to achieve the greatest overall benefits for the public.
3. Environmental federalism; We recognize that each level of
government has a proper role in public health and environmental
protection, and that the concerted and coordinated efforts of federal,
state, and local agencies will best serve the public interest.
4. Better environmental science: We will work to expand the know-
ledge available to manage health and environmental risks. This
priority involves improving the scientific basis for environmental
protection decisions.
5. Negotiation and consultation; In finding solutions, we
will expand the use of negotiated regulations and consultative
proceedings with a wide range of representatives from industry,
environmental organizations, state and local government, and
the general public.
6. Enforcement; We will enforce environmental laws vigorously,
consistently, and equitably to achieve the greatest possible
environmental results.
7. Human Resources; We will promote excellence and growth in
EPA staff at all levels.
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TABLE OF CONTENTS
Page
I. Executive Summary .................. . ......... ... 1
II. Air Quality Guidance ............................ 8
A. Air Toxics ............................... 8
B. Ozone Attainment ... ...................... 9
C. PM Attainment .......................... 31
D. Emerging Issues (Acid Rain, Stratospheric
Ozone Depletion, Indoor Air) ........... 37
III. Radiation Guidance .............................. 40
A. Indoor Radon ..... ........................ 40
B. Radiation Standards ...................... 41
C. Surveillance and Emergency Response ...... 46
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OFFICE OF AIR AND RADIATION
I. EXECUTIVE SUMMARY
This FY 1988 guidance updates the national goals, strategies, and
objectives developed for the air quality and radiation programs.
The guidance also describes the actions that the Environmental
Protection Agency (EPA) and State and local agencies must take in
FY 1988 to implement these goals, strategies, and objectives.
The FY 1988 guidance is based on overall EPA goals, the Admini-
strator's priority list and management priorities, and the
President's FY 1988 budget request.
A. Structure of the Guidance
The FY 1988 guidance for the national air quality and radiation
programs consists of four parts. The first part, Executive
Summary, identifies the updated national goals for each program,
describes the national strategies, and summarizes the changes
from FY 1987. The second part, Air Guidance, describes the high
priority components of the national program and lists the specific
actions that must be taken by EPA and by State and local agencies
to carry out the national strategy. The third part, Radiation
Guidance, presents the high priority components of that national
program and actions for implementing the national radiation
strategy.
The descriptions of the high priority components of the national
programs are divided according to the five major elements:
0 Federal Standards and Regulations
0 Planning and State Support
0 Enforcement
0 Monitoring
0 Program Assessment
The specific actions listed include two types, actions that
support one or more of the priorities on the Administrator's list
and actions that support priorities of the Office of Air and
Radiation (OAR). Actions that support the Administrator's
priorities are identified by an asterisk (*) in the left margin.
Actions that support OAR priorities are identified by a bullet
(o). Some actions have been continued unchanged from the FY 1987
guidance. Other actions have been modified or appear for the
first time. Modified actions are identified by a dash (-) in the
right margin; new actions are identified by a plus (+).
The fourth part of the guidance is an appendix that contains the
Strategic Planning and Management System (SPMS) measures for FY
1988. The SPMS measures included in the appendix reflect the
results of a complete reassessment of reporting and account-
ability needs. Although some of the SPMS measures for FY 1988
require information that has been reported in the past, the
overall framework for the measures and the measures themselves
are new.
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B. Major Goals for the Air Quality Program
In FY 1988 the EPA strategy for the national air quality program
will continue to be based on five major goals. The first three
goals are directed at addressing major environmental problems.
These goals are listed below in general order of national priority,
based on public health risk and feasibility of control. The order
of these priorities may vary from area to area depending on the
relative health risks presented by local pollution problems. The
fourth and fifth goals are more programmatic and cross-cutting in
nature. Examples of key activities are listed with each goal.
ฐ Reduce the risk of exposure to air toxics. In FY 1988 EPA will
continue to implement the national strategy, announced in June
1985, to address the significant public health problem caused
by toxic compounds in the air. As part of this implementation,
EPA will place increased emphasis on strengthening State and
local air toxics programs, including the compliance and
enforcement elements of the programs.
ฐ Achieve National Ambient Air Quality Standards (NAAQSs) set to
protect public health. In FY 1988 EPA will place the highest
national priority on aggressively carrying out programs to
implement the post-1987 ozone nonattainment policy and the
NAAQSs for size-specific particulate matter (PM^0). EPA will
also place high priority on meeting NAAQSs for other pollutants
where ambient levels of these pollutants present significant
risks to public health.
ฐ Determine the policy alternatives and strategy options
available to address emerging issues. In FY 1988 EPA will
continue to provide Federal leadership in developing national
policies and programs to address three major environmental
problems: acid rain, stratospheric ozone depletion, and indoor
air pollution.
ฐ Increase the capacity and improve the effectiveness of State
and local air quality agencies. In FY 1988 EPA will continue
to work toward a stronger, more effective partnership with
State and local agencies and with Tribal governments and help
them improve their capabilities to address air quality prob-
lems. In FY 1988 EPA will join with State and local agencies
to implement the five principles established in FY 1986 for
trie air grants program. This effort will include defining the
core components of control programs and establishing criteria
for disinvestment of low priority activities.
ฐ Develop and support programs to maintain improvements in air
quality. In FY 1988 EPA will continue setting national
technology-based standards and carrying out compliance programs
to ensure that gains made in improving air quality are not
lost. EPA will also give increased emphasis to prevention of
future air pollution problems through support of strong State,
Tribal, and local programs for preconstruction review of new
sources.
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In carrying out these goals, as well as the goals of the
radiation program, OAR will continue to use the Agency's commu-
nications strategy process to ensure that programs are conducted
openly, accurately, and fairly.
C. FY 1988 Strategy for the Air Quality Program
The FY 1988 operating guidance for the national air quality
program focuses on three priority problem areas: air toxics,
NAAQSs attainment, and emerging issues (acid deposition, stra-
tospheric ozone depletion, and indoor air pollution) corresponding
to the first three program goals. Under NAAQSs attainment, the
guidance emphasizes achieving the standards for ozone and PM^Q,
while allowing Regional Offices the flexibility to address other
pollutants (e.g., carbon monoxide) in areas where significant
violations of the primary NAAQSs for these pollutants still
occur. New or changed activities in the priority areas are
summarized below. General activities corresponding to the two
cross-cutting goals are also described.
1. Reduce Air Toxics Exposure
In FY 1988 EPA will refine and expand the basic elements of the
national air toxics strategy. The first element of the national
air toxics strategy is to expand the Federal regulatory program.
In FY 1988 EPA will change or increase activities in four areas.
First, EPA will place more emphasis on non-cancer health effects
in making decisions whether to regulate chemicals under section
112 of the Clean Air Act (CAA). Second, EPA will increase the
types of chemicals and source categories covered by National
Emission Standards for Hazardous Air Pollutants (NESHAPs). The
Agency will also continue to explore ways to accelerate the
development of NEdHAPs. Third, EPA will increase the regulation
of vehicle emissions and fuels. Fourth, EPA will further expand
the use of statutory authorities other than the CAA to control
air toxics.
The second element of the national strategy is to increase the
capabilities of State and local agencies to address air toxics.
In FY 1988 EPA will continue to assist State and local agencies
by identifying additional categories of high-risk sources that
may be candidates for State or local regulation. EPA will in-
crease the information made available to State and local agencies
for use in making regulatory decisions for high-risk sources.
In FY 1988 EPA will continue to negotiate multi-year air toxic
program development plans with State and local agencies and pro-
vide increased support in the development of these plans. EPA
will also begin to stress implementation of previous State and
local commitments and to evaluate the environmental effectiveness
of selected State and local programs. In addition, EPA will
review the compliance and enforcement programs of State and local
agencies to evaluate their etfectiveness in implementing delegated
NESHAPs and State and local requirements.
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The third element of the strategy is to detine and address urban
multi-source, multi-pollutant problems. In FY 1988 EPA will
increase the support available to State and local agencies for
characterizing this "urban toxic soup" and developing control
programs.
2. Achieve NAAQSs
Ozone attainment. Additional progress towards attainment of the
current NAAQSs for ozone will require both the continued imple-
mentation and enforcement of existing EPA, State, and local
measures to reduce emissions of volatile organic compounds (VOCs)
and implementation of a new national policy for post-1987
nonattainment areas, including the development of new control
measures. The new national policy is now under development and
will not be completed before this guidance is published. As a
result, some supplemental guidance may be necessary.
EPA will evaluate the ozone data collected by State and local
agencies during the 1987 ozone season and use the results of that
evaluation to identify areas witn deficient State implementation
plans (SIPs). Once the post-1987 nonattainment areas have been
identified, EPA will issue SIP deticiency notices to States.
During the balance of FY 1988 and the first part of FY 1989,
States will revise their SIPs in accordance with the post-1987
ozone policy.
During FY 1988 EPA will work with States to enhance the compliance
of VOC sources in ozone nonattainment areas. Special attention
will be given to resolving significant violators of VOC emission
requirements. EPA and States will also begin implementation of a
strategy addressing small VOC sources in nonattainment areas
where these sources collectively contribute significantly to the
nonattainment.
In FY 1988 EPA will propose or promulgate new and more stringent
Federal standards for both stationary and mobile sources of VOCs.
For example, EPA will promulgate New Source Performance Standards
(NSPSs) for seven VOC source categories and propose hydrocarbon
standards for light-duty truck emissions.
In FY 1988 EPA will continue the regular review of the adequacy
of the existing ozone NAAQSs , as required by the CAA. Evidence
now available indicates health and other effects greater than
those identified when the ozone NAAQSs were last revised in 1978.
attainment. The promulgation of primary and secondary NAAQSs
for PM^o in FY 1987 will trigger a major restructuring of current
programs for the measurement and control of particulates. As a
result, EPA and State and local agencies will have to undertake a
number of new activities during FY 1988, including the development
of SIPs for areas not meeting the standards. ^
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At the time the PM}Q NAAQSs are promulgated, EPA will use
particulate air quality data to classify all counties into one
of three groups. The classification: Group I, Group II, or
Group III, will be based on the probability of violating the
standard. The requirements for PM^g SIPs will vary, depending
on the classification of the area, from full control strategies
and demonstrations of attainment to revised preconstruction
review programs.
Other pollutants. Although in FY 1988 EPA will emphasize progress
towards attainment of the NAAQSs for ozone and PM^g, there are
areas where significant violations of the primary NAAQSs for
other pollutants, particularly carbon monoxide and sulfur dioxide,
still occur. For these areas, EPA will work with State and local
agencies to correct SIP deficiencies contributing to the viola-
tions, to improve source compliance, and to develop any addi-
tional control measures necessary. In general, EPA will target
its resources for NAAQS attainment based on the extent of NAAQS
violations, the size of the population exposed, and the feasibility
of control.
3. Address Emerging Issues
During FY 1988 EPA will continue to assess the severity and
extent of three major emerging issues: acid rain, stratospheric
ozone depletion, and indoor air pollution, and evaluate the
policy alternatives and strategy options available.
EPA will continue to participate in the planning and review of
acid rain research to ensure that policy information needs are
addressed. EPA will also continue the cooperative effort with
States to examine potential implementation issues that would
arise if an acid rain control program were initiated. In addi-
tion, EPA will make early use of the Agency's communications
strategy process to avoid unnecessary implementation controversy.
Early in FY 1988 EPA will announce a decision on the need to
regulate chlorofluorocarbons (CFCs) to reduce stratospheric ozone
depletion and carry out the follow-up actions necessary. During
FY 1988 EPA will also continue to attempt to develop an inter-
national cons9nsus on the nature and extent of the CFC problem
and on the actions needed to address the problem.
In FY 1988 EPA will continue to analyze the policy issues
associated with addressing indoor air pollution. EPA will also
continue to examine how existing EPA programs can be adjusted to
reduce total exposure, indoor and ambient, to unhealthtul air
quality.
4. Strengthen State and Local Agencies
Maintaining strong State and local agencies is key to reducing
air toxics exposures, achieving the ozone and PM^g NAAQSs, and
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addressing other air quality problems. In FY 1988 EPA will
continue to support state and local programs by identifying and
reducing obstacles to program effectiveness, providing direct
program assistance, facilitating information exchange, and main-
taining national monitoring and data management systems. EPA
will also work with Indian Tribes with serious air quality prob-
lems on Tribal lands to address these problems. Further, EPA
will explore means to address pollution problems on Tribal lands
where Tribes may lack authority for new source review and
compliance activities.
In FY 1988 EPA will continue to provide financial support to
State and local agencies and Indian Tribes through the section
105 air grants program. EPA will also continue to carry out
the performance-based grants policy signed by the Administrator
in May 1985. In the management of the grants program and the
implementation of the performance-based grants policy, EPA will
adhere to the five principles established in June 1986 by the
Assistant Administrator for Air and Radiation. Carrying out the
five principles requires clear definition of those key activities
that constitute the foundations of State and local programs and
establishment of a process for identifying disinvestments when
new priorities arise and no additional Federal, State, or local
resources are available. In FY 1988 EPA will work with State and
local agencies to expand the pilot efforts begun in FY 1987 to
address these issues.
5. Maintain Air Quality Improvements
EPA will continue efforts to protect gains in air quality and
prevent future air pollution problems. These efforts include
establishment of national technology-based emission limits for
stationary sources and vehicles; improvement of the effectiveness
of EPA, State, and local compliance programs; and support for
strong State and local programs to review and regulate new sources,
In carrying out these cross-cutting efforts in FY 1988, EPA will
emphasize activities that address sources of air toxics, VOCs,
and
D. Major Goals for the Radiation Program
In FY 1988 the EPA strategy for the national radiation program
will be based on the two major program goals listed below.
Examples of key activities are included with each goal.
0 Reduce the risk of exposure to unhealthful levels
of radiation. In FY 1988 EPA will help States build
self-sufficient programs to reduce levels of indoor
radon.
ฐ Maintain comprehensive surveillance and effective
emergency response capabilities. In FY 1988 EPA
will continue to maintain emergency response teams
to meet emergency situations.
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E. FY 1988 Strategy for the Radiation Program
There are a variety of sources of radiation exposure, and
statutory authority to deal with these sources. EPA has chosen
to emphasize two general categories contributing to radiation
exposure of humans: radon and other airborne radionuclides, and
the disposal of radioactive wastes. These categories have been
given priority because they represent the greatest health hazards,
statutory authority is available to remedy the problems, and the
radiation levels are amenable to reduction. With the exception
of radon, these categories are being pursued from the standpoint
of regulatory controls. The Agency also continues to exercise
its important federal guidance role in the radiation protection
community.
In addition to implementing regulatory and guidance programs,
the Agency will maintain a capability to pursue four objectives
of environmental assessment in order to provide a comprehensive
radiation protection program for the public. The objectives
include: (1) assess and quantify existing and emerging radiation
problems (e.g., radon), (2) assess and quantify the potential
impact of technologies under development, (3) evaluate and
respond to issues of serious public concern and identify the
organization(s) responsible for corrective action, and (4)
respond to radiological emergencies and aid in the development
and testing of State, local, and Federal emergency response
plans.
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1I AIR QUALITY GUIDANCE
A. Air Toxics
The objectives for the air toxics program are based on the air
toxics strategy (as it applies to routine releases*) announced
in June 1985. The basic approach taken in the 1985 strategy was
recently reaffirmed as part of the air toxics strategic planning
initiative (SPI) carried out in FY 1986. As a result of the air
toxics SPI, a detailed five-year implementation plan for the
strategy is being developed. Some changes to this guidance may
be needed to reflect the final air toxics strategy implementation
plan, scheduled for completion in FY 1987.
To assist in implementing the air toxics strategy, the Office
of Research and Development (ORD) will perform research to quantify
emissions trom municipal incinerators and document best technology;
develop more efficient and cost-effective control technologies for
air toxics, particularly VOCs; prepare health summaries or health
assessment documents and secure Science Advisory Board review as
needed; identify toxic components of urban air mixtures and
assess risks; determine total human exposure to VOCs and other
toxic air pollutants, including wood smoke and components of
automobile exhaust; and determine genetic, neurologic, immunologic,
pulmonary, carcinogenic, mutagenic, and physiological risks from
air toxics.
1. Federal Standards and Regulations
The Federal regulatory program has three major thrusts:
0 Implement section 112 of the CAA, including identification
of air toxics problems and selection of appropriate regulatory
strategies.
0 Assess toxic air emissions risks from motor vehicles and
fuels and regulate emissions as necessary, either directly
or through criteria pollutant control programs.
0 Use Federal authorities other than the CAA to regulate air
toxics.
Implement section 112. In the air toxics identification program
EPA will screen and rank about 100 chemicals per year for more
detailed assessment. About 10-12 of the pollutants ranked highest
will enter the more detailed health, source, and exposure assess-
ment process each year. EPA will also continue risk assessment for
multi-pollutant emission sources (e.g., hospital, commercial, and
Accidental releases of air toxics are covered in the Hazardous
Waste portion of the Agency Operating Guidance.
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industrial incinerators). More emphasis on non-cancer health
effects is anticipated during FY 1988. Decisions on the need to
regulate at the Federal level will be published for about 10
pollutants or pollutant mixtures per year. For pollutants or
source categories that do not cause nationally significant risk,
but may cause high localized risk, the assessment program will
provide health risk and control technology information to State
and local agencies for action under their own air toxics programs.
In FY 1988 EPA will propose Federal regulations for two source
categories of chromium and promulgate changes to the current
NESHAPs for asbestos. EPA will also promulgate new NESHAPs for
benzene (coke oven final coolers), for coke oven emissions
(charging, topside, and doors), and for perchloroethylene,
trichloroethylene, ethylene oxide, chloroform, methylene chlo-
ride, butadiene, ethylene dichloride, and carbon tetrachloride
(organic chemical manfacturing industry). A number of other
source categories that emit the eight organic compounds are under
consideration for NESHAPs. Proposals for a number of these
NESHAPs will occur in FY 1988 and FY 1889.
Regulate vehicle emissions and fuels. In FY 1988 EPA will continue
to develop new regulations for testing fuels and fuel additives
prior to registration, controlling sulfur in diesel fuel, controll-
ing refueling emissions and evaporation of gasoline (both also
with ozone control potential), and controlling emissions from
methanol fueled vehicles. EPA will also decide on banning lead in
gasoline.
The regulations on testing fuels and fuel additives prior to
registration are expected to be in effect by 1989-1990. Implemen-
tation of these regulations will result in additional information
on substances with a newly recognized potential for direct toxic
effects or for damaging vehicle emission control systems. The
availability of this new information may result in additional
rulemaking through the 1990's to control or prohibit specific
substances identitied in the registration process.
Use other statutory authority. The air toxics strategy commits
the Agency to increased use of Federal authorities in addition
to actions taken under section 112 and regulation of vehicle
emissions and fuels. EPA will emphasize implementation of other
provisions of the CAA which indirectly reduce air toxics. For
example, an NSPS for wood stove emissions that will be promul-
gated in FY 1988 will reduce particulate emissions, some of which
are toxic. Other NSPSs for particulate matter and VOCs will
similarly reduce toxic constituents.
The EPA will also use Federal statutes other than the CAA to
control air toxics. For example, the air program is developing,
under the Resource Conservation and Recovery Act (RCRA), regula-
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tions for toxic air emissions from seven types of hazardous waste
treatment, storage, and disposal facilities (TSDFs). The air
program is also considering the use of the Toxic Substances
Control Act (TSCA) to regulate chromium emissions from comfort
cooling towers. Final regulations under TSCA or the CAA for
comfort cooling towers are scheduled in late FY 1988 or early FY
1989. In addition, EPA is preparing a comprehensive strategy for
controlling solvent emissions. Development of proposals under
appropriate authorities: TSCA; tne Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA); the Safe Drinking Water Act (SDWA);
or the CAA will be underway in FY 1988. The Agency also will be
implementing decisions issued in FY 1987 on controlling new and
existing municipal waste combustors. Finally, EPA's Regional air
program staff will continue to coordinate with their counterparts
in the Regional hazardous waste program and provide technical
support to help address air toxics in the clean-up of Superfund
sites and the issuance of RCRA permits.
Key FY 1988 Headquarters Actions
(1) Continue the pollutant assessment and evaluation program.
Publish regulatory decisions for 10-12 potential hazard-
ous air pollutants. (OAQPS)
(2) Promulgate hazardous organic NESHAPs (eight organic com- -
pounds), NESHAPs for coke oven emissions (charging, top-
side, and doors), and NESHAPs for benzene emissions (coke
oven final coolers). Promulgate revisions to current
asbestos NESHAPs. Propose Federal regulations for two
chromium sources (electroplating and cooling towers).
(OAQPS)
(3) Continue to develop NESHAPs for 10 pollutants for which
Notices of Intent to List were published in 1985. De-
velop NESHAPs for other pollutants for which Intent to
List notices were published in FY 1936 and FY 1987.
(OAQPS)
(4) Promulgate NSPSs for residential wood stoves. (OAQPS) *
(5) Continue development of regulations under RCRA to control
air toxics emissions from seven types of TSDFs: surface
impoundments, landfills, storage tanks, waste piles, land
treatment facilities, containers, and transfer operations.
Promulgate fugitive and waste solvent regulations in sup-
port of RCRA land banning actions in FY 1988. Propose
regulations in early FY 1988 tor remaining sources.
(OAQPS)
(6) Decide on ban on lead in gasoline and implement follow-up
actions. (QMS)
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(7) Decide on a rule on evaporative vehicle emissions (fuel
volatility) and implement tollow-up actions. (QMS)
(8) Publish a Notice of Proposed Rulemaking (NPRM) on fuels
and fuel additive testing protocols. (QMS)
(9) Publish an Advance Notice of Proposed Rulemaking (ANPRM)
and an NPRM on diesel fuel quality. (QMS)
(10) Promulgate methanol vehicle emissions standards. (QMS)
Key FY 1988 Regional and State Actions
(1) Provide technical support in clean-up of Superfund sites on
The National Priority List to reduce risks from toxic air
pollutants during removal and remedial activities.
2. Planning and State Support
Strong and effective State and local air toxics programs are
essential to the implementation of the EPA air toxics strategy.
The EPA national strategy depends on acceptance by State and
local agencies of the following responsibilities:
1. Implementing and enforcing delegated NESHAPs.
2. Controlling high-risk point sources of local concern
that are not appropriate for Federal regulation.
3. Building the technical, regulatory, and administrative
capabilities needed to implement an effective program
through the development and implementation of multi-
year development plans.
4. Assessing the health impacts in high-risk urban areas
and reducing air toxic emissions that result from the
combined effects of numerous sources and pollutants.
NESHAPs enforcement and delegation are discussed in the enforce-
ment section on page 14. The other activities and responsibilities
are discussed below.
High-risk point sources. One of the major State responsibilities
under the State air toxics program enhancement effort is the
identification and regulation of high-risk point sources that
are not appropriate for Federal regulation. States will have the
primary responsibility for determining these sources. EPA will
assist in this process by continuing to identify, as part of
the pollutant assessment and NESHAPs decision-making process,
sources (cancer and non-cancer) that will not be regulated at the
Federal level. In some cases, sources with high residual risk
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after the imposition of NESHAPs may also be suitable for further
State investigation.
In FY 1988 EPA will continue to provide grant funds to
support high-risk point source evaluations and regulatory efforts
by States. EPA will also continue to provide grant funds for
"promoted initiatives" to support more detailed evaluations of
specific sources by the States. EPA will oversee State and local
implementation of the high-risk point source program and evaluate
the need to continue grants for specific promoted initiatives.
Once States have identified high-risk sources of concern, they
should decide on the need for control, and on the degree of
control required. EPA will provide information to the States
from which they can derive their own acceptable ambient limits
(AALs), best-technology decisions, or other bases for regulation.
This includes health assessment documents, source and exposure
documents, risk reference doses (RFDs), EPA risk assessment and
risk management actions via the Integrated Risk Information System
(IRIS) and the National Air Toxics Information Clearinghouse
(NATICH), data contained in the Interim Air Toxics Data Base,
information on other State regulatory approaches (AALs, etc.),
and operation of an air toxics control technology center.
Urban multi-source, multi-pollutant problems. The air toxics
strategy recognizes the need for assessment and mitigation of the
accumulation of toxic compounds in the air of many urbanized
areas. In FY 1988 EPA will provide continued grant support to
assist State and local agencies in developing and implementing
assessment activities in approximately 30 major urban areas and
to provide assistance for the demonstration of local control pro-
grams or mitigative actions in at least five such areas. In
addition to providing grant support for these State and local
activities, EPA will provide technical guidance and assistance in
carrying out the programs. These support activities include
ambient monitoring, emission inventory development, and modeling/
risk assessment guidance and assistance. EPA will continue to
present workshops in FY 1988 to transfer guidance and information
to the States.
The Agency will continue to take advantage of the development of
new ozone and particulate matter SIPs by the States to encourage
incorporation of toxic considerations into the process. Much of
the toxics control that has been achieved in the past is closely
related to VOC or particulate matter controls in SIPS. The SIP
guidance will recognize the potential dual benefits of criteria
and toxic pollutant reductions.
Enhancement of State and local air toxics programs. The strategy
sets a goal for all States of establishing quality air toxics pro-
grams that are adequate in size and capability to carry out state
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requireraents and those activities envisioned for them in the
strategy. The enhancement activity is the principal means to
accomplish these goals. In general, it consists of setting grant
priorities that promote the development of State and local pro-
grams that are responsive to both local air toxics concerns and
to national priorities; providing technical support to build
necessary State and local capabilities; and monitoring the evolu-
tion of air toxics programs and measuring their effectiveness.
Nearly all State and major independent local agencies have been
able to establish high quality multi-year development plans to
address air toxics. These plans contain specific performance
milestones established as part of grant negotiations. The multi-
year development plans are more flexible than SIPs because their
components are established and amended through grant agreements,
rather than through a regulatory process.
In FY 1988 Headquarters will stress implementation of previously
accepted commitments and integration of air toxics activities
with ongoing particulate matter/ozone SIP activities. In addi-
tion, Headquarters will issue guidance for reviewing the effec-
tiveness of State and local programs, complete a national report
describing the FY 1987 experience with multi-year development
plans, and provide the necessary technical support to accomplish
the stated objectives. Regions will continue to negotiate new
multi-year development plan commitments and submit them to Head-
quarters. Regions will also review the implementation of FY 1987
milestones, take appropriate new actions, and begin to evaluate
the environmental effectiveness of selected State and local
programs.
Key FY 1988 Headquarters Actions
(1) Identify nigh-risk point sources from EPA's assessment and
NESHAPs decisionmaking process and allocate program grant
funds for specific promoted initiatives. (OAQPS)
(2) Establish and operate an air toxics control technology +
center to provide direct engineering support (on an
as-requested basis) to State and local agencies in
solving problems of assessing and controlling stationary
sources. (OAQPS and ORD)
(3) Develop additional implementation and technical guidance
tor the high-risk point sources and urban multi-source
programs. Technical guidance will involve health docu-
ments, source information, emission factors, results
of EPA exposure and risk assessments, example programs
and practices, and modeling and monitoring guidance.
This information will be disseminated by workshops,
training courses, and written documents. (OAQPS)
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(4) Develop additional guidance for multi-year development +
plans, review plans for adequacy, and track progress by
issuing a national summary report. (OAQPS)
(5) Develop additional guidance to promote analysis of -
the interaction between VOC and particulate matter
programs and air toxics control. (OAQPS)
(6) Enhance the design and operation of NATICH, providing
a primary referral service for obtaining information
and expertise on hazardous air pollution sources,
emissions, control technology, health effects, exposure,
and ambient concentrations. (OAQPS)
(7) Involve State and local representatives, including the
State/EPA Committee, in early strategy development
discussions. (OAQPS and OEA)
Key FY 1988 Regional and State Actions
(1) Allocate program grants for high-risk point sources,
multi-year development plans, and urban toxics assess-
ment and mitigation. Negotiate appropriate commitments
by States and submit to Headquarters. (Regions)
(2) Continue screening activities to identify high-risk
point sources. Conduct evaluations and make decisions
regarding further control. (States)
(3) Upgrade new source review procedures to incorporate +
review of air toxics emissions. (States)
(4) Provide support to requesting State and local agencies +
making key program development and implementation
decisions. (Regions)
(5) Provide timely information and updates to NATICH regard-
ing State and local activities, helping to maintain
effective and current clearinghouse operation. Continue
to provide updates to the Interim Air Toxics Data Base.
(States)
(6) Consider the impact on air toxics in developing SIP
revisions for new PM^g standards and additional VOC
measures in ozone nonattainment areas. (States)
3. Enforcement
NESHAPs enforcement. To assist in the implementation of the air
toxics strategy, the compliance and enforcement program (1) will
ensure sources subject to existing and new NESHAPs are in compli-
ance, (2) will establish and implement a NSPS program for wood
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stoves, and (3) will overview State and local air toxic compli-
ance activities. EPA and the States will continue to give
priority to administrative, civil, and criminal enforcement of
NESHAPs. In implementing existing NKSHAPs, EPA and States will
continue to give priority to implementing the enforcement strate-
gies for vinyl chloride and asbestos demolition and renovation.
In FY 1988 EPA will promulgate regulations requiring renovation
and demolition contractors to be trained in asbestos removal and
disposal. Contractors will be required to maintain records of
their training. Compliance inspections of demolition and reno-
vations sites by EPA and State agencies will include checks of
contractor training records. In FY 1987, Headquarters will
develop a compliance and enforcement strategy that will be
implemented in FY 1988 for the benzene NESHAPs.
Certification of wood stove production lines will begin in FY
1987 and will continue in FY 1988. Headquarters will complete
implementation plans for the wood stove NSPS program in FY 1988.
Also, Headquarters will direct a national certification program
to be implemented by personnel located in the Regional Offices,
but dedicated to the wood stove NSPS program. These people will
be responsible tor assisting in wood stove certification, includ-
ing reviewing applications and test results, and monitoring a
percentage of the performance tests. In addition, Headquarters
will develop a parameter inspection enforcement strategy for the
Regional Offices.
Mobile source enforcement. The goal of the mobile source enforce-
ment program is to assure that regulations currently in effect are
implemented by tne affected industries. Regulations are in place
for the control of diesel particulates, evaporative emissions of
hydrocarbons, lead in gasoline, the granting of waivers for new
additives for unleaded gasoline, and the registration of fuels
and fuel additives. As a result of these regulations, the mobile
source toxics enforcement program pursues enforcement activity in
a number of air toxics related areas, including lead in fuel,
alcohol, and emission control component tampering. A heavy-duty
vehicle recall program will be initiated in FY 1988.
The mobile source program will have to increase its activity in
the 1988-1994 period. Most of the rules listed above either are
not yet effective (e.g., stringent, technology-forcing standards
for particulates from heavy-duty engines come into effect with
the 1991 and 1994 model years) or require additional mobile
source enforcement activity in the future. In addition, the
mobile source enforcement program will have to address the
enforcement of new rules currently under development.
National air audit system. As part of the national air audit
system, the Regions will review the compliance and enforcement
programs of State and local agencies to evaluate their effective-
ness in addressing the air toxics problem. The review will
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include both enforcement of delegated NESHAPs and of State-
developed air toxic regulations. This review will include
assessing how well the States and EPA Regional Offices are
integrating their air toxics regulations and programs into an
overall compliance and enforcement effort.
Key FY 1988 Headquarters Actions
(1) Develop implementation plans for the wood stove NSPS
program and a wood stove parameter inspection enforcement
strategy. (OAQPS)
(2) Review applications and certify eligible wood stove +
production lines. (OAQPS)
(3) Develop guidance for review of State and local compliance +
programs for delegated NESHAPs and State and local air
toxics regulations. (OAQPS)
(4) Implement lead pnasedown. (QMS)
(5) Implement evaporative hydrocarbon standards. (OMS)
(6) Implement car/light-duty truck diesel particulate standards.
(OMS)
(7) Implement heavy-duty diesel particulate standards. (OMS)
Key FY 1988 Regional and State Actions
(1) Implement the enforcement and compliance strategy for +
the benzene NESHAPs. (Regions and States)
(2) Review State and local agency air toxics compliance and +
enforcement programs for delegated NESHAPs and State and
local regulations. (Regions)
(3) Ensure compliance with NESHAPs, in accordance with the
timely and appropriate guidance. Continue to implement
EPA's enforcement strategies for vinyl chloride and
asbestos demolition and renovation. (Regions and States)
(4) Promote recommendations tor improving performance in the +
delegated asbestos programs project, including improved
asbestos demolition inspections and violation detection
techniques. (Regions)
(5) Implement the wood stove parameter inspection enforcement
strategy. (Regions)
4. Monitoring
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In FY 1988 EPA will increase resources and activities to monitor
air toxics in the ambient air. This will include ORD activities
to develop and evaluate additional monitoring methods and quality
assurance procedures and to expand the Toxic Air Monitoring System
(TAMS). Guidance and technical assistance will be provided on
sampling and analysis of air toxics; development and/or upgrading
of air toxics monitoring programs via manuals, guidelines (analy-
tical methods, quality assurance procedures, network design,
siting and data analysis); and workshops. Grant funding will be
provided to support the ozone related non-methane organic compound
measurement program and to assess urban multi-pollutant toxics
problems. EPA will work with States to maximize these resources
to collect data on ambient air toxics.
Key FY 1988 Headquarters Actions
* (1) Expand the TAMS to four sites in each of five cities.
(ORD)
* (2) Provide technical assistance. (OAQPS)
a. Continue to develop sampling and analytical methods,
and explore new methods for potentially toxic
compounds.
b. Develop and/or upgrade technical manuals and guide-
lines and hold workshops.
* (3) Acquire and analyze State and local air toxics pollutant
data. Produce final report of the Interim Air Toxic
Volatile Organic Chemical Data Base and complete the con-
version of this data base into the Aerometric Information
Retrieval System. (OAQPS)
5. Program Assessment
The air toxics program includes a number of activities to provide
oversight and assessment of both the basic strategy and its
implementation projects. The mobile source programs continue to
focus on assessing the effectiveness of various enforcement and
control strategies on the mitigation of air toxics related to
motor vehicles. The information generated through the fuels
registration process should have defined most of the issues
related to fuels and additives by 1992/1993. In addition, the
mobile source program continues to examine the effects of new
technologies used to control regulated pollutants in terms of
their effects on currently unregulated pollutants (e.g., toxics),
especially as they may be emitted under conditions not currently
controlled by the Federal Test Procedure (e.g., under temperatures
outside the 69 to 86ฐF specified for the standards); the quanti-
fication of emissions of other substances already known to be
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emitted (e.g., formaldehyde) from motor vehicles; and the poten-
tial for achieving toxics control by the application or improve-
ment of already established control mechanisms (e.g., better
operation and maintenance of in-use vehicles through vehicle
inspection and maintenance (I/M) programs). The results of these
activities are expected to be a better definition and control of
the contribution of mobile sources to the air toxics problem
(currently identified as 60 percent of the problem) by the
mid-to-late 1990's. The Federal enforcement activities will be a
primary conduit for concrete information and data on the results
of these control strategies. They will assist in quantifying the
progress being made in achieving the emissions reductions contem-
plated by the vehicle emission standards and fuels regulations
and redirecting the focus of the program into areas of most
serious concern.
Key FY 1988 Headquarters Actions
(1) Continue activities to update understanding of the +
air toxics problem and assess the Air Toxics Strategy
and its implementation as related to the program goals
and effectiveness measures. (OAQPS and"OMS)
(2) Develop a national report regarding the overall effec-
tiveness of the high-risk point source program based on
the reviews of individual State activities, including
recommendations for any appropriate changes in policy
and/or support. (OAQPS)
(3) Review multi-year development plans for adequacy and +
issue a national report that identifies approaches that
have had the greatest success and summarizes progress,
needs, and issues. (OAQPS)
(4) Operate the fuels registration program. (OMS)
(5) Assess effects of new technologies for effects on
currently unregulated pollutants. (OMS)
(6) Assess the potential for achieving toxics emissions con- +
trol by the application or improvement of already estab-
lished control mechanisms. (OMS)
Key FY 1988 Regional Office and State Actions
(1) Provide general oversight of State and local toxics +
programs and provide periodic information and reports
concerning State and local activities, including the
status of program development and specific regulatory
actions. (Regions)
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(2) Review initial implementation of multi-year development +
plan commitments for indications of program weaknesses,
guidance needs, and environmental effectiveness. Submit
summary reports to Headquarters. (Regions)
B. Ozone Attainement
In FY 1988 EPA will carry out various programs to address new
information on the health and welfare effects of ozone and
continuing ozone nonattainment problems in numerous urban areas.
These include programs to complete the review of the NAAQSs
to more fully assess the magnitude of the nonattainment problem
and progress in its control, to develop and implement new Federal
control measures, to ensure effective implementation of existing
controls and commitments, and to implement a national policy to
address ozone nonattainment beyond December 31, 1987. These will
require substantial effort on the part of EPA Headquarters and
Regional Offices and, most signiticantly, by the State and local
air agencies with affected areas.
1. Federal Standards and Regulations
In FY 1988 EPA will continue the review of the existing ozone
ambient standards. Also in FY 1988, EPA will implement addi-
tional Federal measures to control vehicle and stationary sources
emissions of VOCs.
NAAQSs revision. During FY 1988 work on the review of the NAAQSs
for ozone will be nearing completion. The proposal of revised or
reaffirmed standards is expected in early FY 1989. A growing
body of scientific data indicates that the health and welfare
effects associated with ozone are more serious than envisioned in
1979 when the standards were last revised and that the current
standards may provide little or no margin of safety. ORD will
continue activities to determine the health effects of long-term
exposure to ozone and the economic impacts to commercial crops
and forests.
Motor vehicle controls. The control of refueling emissions can
be achieved by requiring the adoption of Stage II controls by the
States as part of their SIPs or by requiring that vehicles be
manufactured with appropriate controls. A combination of both
approaches is also feasible. The EPA Administrator is consider-
ing this issue. Specific implementation activity will be defined
after a decision is made.
Emission standards are in place for the control of evaporative
emissions from major classes of motor vehicles. However, the
efficacy of control technology used to meet these standards is
suspect when gasolines currently available in the marketplace are
used. EPA is studying the problem and the alternatives for the
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control of the excess evaporative hydrocarbons emitted, including
the control of gasoline's evaporation characteristics. No emis-
sion reductions from these actions are expected before 1989.
EPA expects that additional hydrocarbons emission reductions can
be achieved from light-duty trucks if the emission standards
applicable to these vehicles are tightened. EPA is currently in
process of revising these standards, with a proposed rule
expected during FY 1988.
NSPS development. EPA will maintain ongoing efforts to assess
and develop NSPSs for key VOC source categories on the Agency
priority list. The focus will be on several categories involving
the synthetic organic chemical manufacturing industry (SOCMI) and
surface coating.
Key FY 1988 Headquarters Actions
* (1) Continue on schedule the review process for the ozone -
NAAQS. (OAQPS)
* (2) Promulgate seven NSPSs for VOC source categories (poly-
meric fabric coating, petroleum refinery wastewater
treatment, SOCMI reactor processes, and four polymer
manufacturing categories).
* (3) Implement refueling controls development, following +
decision on control alternative. (OMS)
* (4) Control gasoline evaporation. (OMS)
* (5) Propose light-duty truck hydrocarbon standards. (OMS)
2. Planning and State Support
The ozone program in FY 1988 will require both continued
implementation of existing measures to control emissions of
VOCs and implementation of the new national policy for post-
1987 nonattainment areas. As the statutory attainment deadline
of December 31, 1987 passes, emphasis will shift to the post-
1987 nonattainment areas and to the new or focused Federal and
State efforts that will be needed to address problems in these
areas. However, it is still important that existing SIP commit-
ments be met to provide for attainment, where possible, con-
tinued progress in other areas, and maintenance of emission
reductions that have been achieved.
Fully implement existing SIP requirements. Previously approved
ozone SIPs contain commitments to prepare and implement regula-
tions and programs that are essential to attainment of the NAAQSs.
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During FY 1987 and FY 1988, EPA and States will need to concen-
trate on completing fully any remaining commitments for imple-
menting these regulations and programs, consistent with national
policies, guidelines, and schedules in these SIPs. The EPA
Regional Offices and States will need to carefully review and
document the progress toward meeting the ozone NAAQS in nonattain-
ment areas. These activities will occur primarily in extension
areas (i.e., those areas with approved plans for attainment by
December 31, 1987) and areas where earlier attainment was pro-
jected, but where the SIPs were subsequently found to be inade-
quate to provide for such attainment. For the areas that cannot
attain by the end of 1987, these activities will be further
augmented through the four-part national ozone policy discussed
below.
Post-1987 attainment: SIP calls. EPA will review the avail-
able air quality monitoring data to determine those areas that
have not attained the ozone standard by the end of 1987. Par-
ticularly for areas that are "marginally" nonattainment, air
quality data for he most recent ozone season (i.e., 1987) will be
needed on an expedited time frame to support these determinations.
EPA will issue guidance outlining the process and schedules for
Regional Offices and States to follow in submitting the data by
late 1987 or early 1988. After determining the areas still
violating the ozone NAAQS after 1987, EPA will issue SIP defici-
ency notices to States for those areas in early 1988. Over the
following 12 months (i.e., the balance of FY 1988 and first part
of FY 1989), States will need to revise their SIPs consistent
with the post-1987 policy. The requirements for the States and
the SIP revisions due in one year will vary depending on the
nature and severity of the ozone problem. Implementation of
parts one and two and at least portions of part three of the
national policy will be required in all areas. All part three
measures and part four requirements may be needed in areas
experiencing the worst ozone problems.
The major activities for EPA in FY 1988 will be completion of the
guidance for use by States in revising their SIPs under the post-
1987 policy and the implementation of various Federal activities
in the policy. For States, the major activities will focus on
preparing revisions to their SIPs to implement parts one and two
and the necessary elements of parts three and tour of the policy.
Both EPA Headquarters and Regional Offices will work closely
with States during the preparation of the revised SIPs.
The following discussions describe specific requirements antici-
pated by the current draft of the post-1987 policy. The policy
will continue to evolve during the next several months. Changes
in some of the requirements described below may occur as the
policy is completed.
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Post-1987 attainment; part one requirements. Part one calls
for a series of steps to improve the effectiveness of the post-
1982 policy programs and regulations to reduce further the VOC
emissions in nonattairiment areas. EPA will complete the pre-
paration of guidance and begin developing technical support
(workshop material/ training courses, technical memorandums,
etc.) aimed at improving the implementation of these existing
programs and achieving the projected emission reductions. In
preparing their post-1987 SIP revisions, States will need to
commit to improve existing programs through participation in
training courses and use of other technical support related to
ozone control. States will also need to (1) review their pro-
grams and regulations and ensure they are consistent with
national guidance and policies; (2) work with EPA to expand
stationary source compliance programs; (3) put in place pro-
cedures for evaluating periodically individual rule effective-
ness; and (4) refine monitoring networks wnere necessary to
support modeling and attainment demonstrations. EPA will work
with States in identifying rule inconsistencies or problem
areas that should be addressed in the SIP revisions.
Deficiencies in State and local vehicle I/M programs that result
in not achieving the emission reductions called for in the SIP
have to be corrected. States and localities are expected to
remedy such deficiencies as they discover them through their pro-
gram monitoring and audit activities. Regional Offices, in con-
cert with EPA Headquarters, will be expected to bolster State and
local action as required by the specific circumstances related
to each program. Remedial action is expected to be expeditious
since making existing control requirements work as designed is
one of the most effective control measures.
Post-1987 attainment; part two requirements; Within part two,
EPA will continue implementation of selected national motor
vehicle-related control measures (see "Federal Standards and
Regulations" above). The EPA will also develop guidance for new
stationary source measures required for all areas receiving SIP
calls. This guidance will take the form of (1) control technique
guidelines (CTGs) or similar documents describing reasonably
available control technology (RACT) for the selected existing
source categories and (2) policy changes and implementation
instructions for new source review. Guidance will also be pre-
pared to describe how the CTGs or other control information
should be applied. ORD will continue efforts to identify and
improve control technologies for VOC emissions. The EPA Regional
Offices will work with States to ensure that appropriate rules
and procedures are modified or added to accommodate necessary new
source review changes. States will need to add or modify their
regulations to incorporate the additional RACT measures and the
new source review changes into their SIPs.
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Post-1987 attainment; part three requirements. In FY 1988 part
three of the national policy will require States to initiate the
necessary modeling activities and evaluation of additional measures
that may be needed. Detailed modeling analyses to demonstrate
attainment will be required within one year for areas with high
ozone levels. The demonstration analyses for other areas would
be given an additional two years for completion. The demonstra-
tion analyses will have to select from the "part three menu" of
measures those needed to show attainment. The EPA will review
controls in State regulations throughout the country as a basis
for the development of the "part three menu" of measures. States
will be expected to revise their SIPs, in accordance with the
ozone policy, to incorporate improved I/M programs that will
achieve feasible additional emission reductions from in-use
motor vehicles. These program will have to be implemented in
addition to improving existing program operations to the level
required to meet current SIP requirements. Specific guidance
on enhancement of I/M programs will be provided as part of the
ozone policy and the calls for revisions to SIPs for nonattain-
ment areas.
Post-1987 attainment; part four requirements;
Areas that cannot demonstrate attainment of the standard in the
near-term with parts one, two, and three will have to include the
requirements of part four in their SIP revisions. In future
years under part four, EPA will develop additional measures that
States must consider for implementation. States will also need
to continue to review and document their progress toward attain-
ment, instituting programs to track and report on key emissions
changes. The EPA will review the States' efforts and determine
whether the requirements of part four are being satisfied.
Key FY 1988 Headquarters Actions
(1) Develop and issue guidance outlining the activities and +
schedules for Regional Offices and States to follow in
expediting submittal of air quality data for the 1987
ozone season. (OAQPS)
(2) Assess and determine the areas not attaining the ozone +
NAAQS by December 31, 1987. (OAQPS)
(3) Coordinate among Regions the preparation of SIP defi- +
ciency notices for continuing nonattainment areas.
(OAQPS and OMS)
(4) Complete the guidance for use by States in revising SIPs
to implement the post-1987 policy. (OAQPS and OMS)
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(5) Develop various technical guidelines to assist States
implementing specific regulatory parts of the post-1987
policy. (OAQPS and OMS)
(6) Audit I/M and tampering control programs. (OMS)
(7) Assess operating problems of I/M and tampering programs
as they arise. (OMS)
(8) Support development of State I/M and tampering programs
through the development of technical information and
assistance. (OMS)
Key FY 1988 Regional Office and State Actions
(1) Review and document progress toward meeting the ozone +
NAAQS in nonattainment areas. Document the implementa-
tion status of existing SIP commitments. (Regions and
States)
(2) Expedite submittal of monitoring data for the 1987 ozone +
season. (Regions and States)
(3) Issue SIP deficiency notices to States following con-
sultation with EPA Headquarters and analysis of SIPs. +
(Regions)
(4) Initiate SIP revisions to implement the post-1987 policy. +
(States)
(5) Work with States in analyzing SIP deficiencies and +
developing appropriate remedies for inclusion in SIP
revisions. (Regions)
(6) Audit I/M and tampering control programs. (Regions)
(7) Develop and implement enhanced vehicle inspection -f
programs. (States)
3. Enforcement
Stationary sources. A major focus in FY 1988 of the traditional
stationary source compliance and enforcement program will be
efforts to address the ozone nonattainrnent problem. The EPA will
work extensively with State and local agencies to enhance the
compliance of sources subject to the VOC air quality regulations
in ozone nonattainment areas. EPA will concentrate on four ele-
ments of the compliance and enforcement program: the timely and
appropriate guidance, the Federally-reportable violations guid-
ance, the compliance strategy for small VOC sources, and VOC
compliance workshops and inspection manuals. Together, these key
I
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elements will provide EPA Regional Offices and State and local
agencies with the tools to accurately assess compliance problems
within specific nonattainment areas, to determine which viola-
tions are to be reported to EPA, to identify the relative roles
and responsibilities of EPA and States in returning significant
violators to compliance, and to determine the need for further
action, including criminal enforcement.
Special attention in FY 1988 will be focused on identifying and
resolving significant violators of VOC emissions requirements.
During FY 1987 EPA, working jointly with STAPPA/ALAPCO, will
develop a strategy addressing selected categories of small VOC
sources located in ozone nonattainment areas where small sources
contribute significantly to nonattainment. Implementation of
this strategy will begin in FY 1988. The strategy will focus on
a limited number of VOC categories, including service stations--
stage 1, coaters of miscellaneous metal parts, dry cleaners,
graphic arts, and coaters of fabric and vinyl. The strategy will
not require inspection of all small sources in selected VOC
categories. EPA's strategy will identify two non-traditional
approaches: compliance promotion and targeted inspections.
Compliance promotion is a method to ensure that small sources
know and understand the VOC compliance requirements. The tar-
geted inspection program will inspect a random sample (about 30
inspections per selected category) to provide compliance infor-
mation and to establish an enforcement presence.
Mobi 1 e sources. The enforcement program for mobile sources con-
sists of a Federal program aimed at: (1) control of emissions
from motor vehicles by manufacturers, (2) control of lead and
other catalyst poison content of gasoline, (3) prevention of
tampering with emission control systems, and (4) bolstering and
assuring that States and localities carry out their own in-use
vehicle emissions control programs. Direct Federal enforcement
of regulations applicable to motor vehicles will continue in FY
1988 using the full range of authorities provided by the Clean
Air Act, i.e., pre-production certification, assembly line
testing, tampering investigations, and recall of in-use vehicles.
The program will focus on sources of evaporative hydrocarbons
and in-use compliance with hydrocarbon standards by light-duty
trucks, a rapidly growing segment of the vehicle population.
Enforcement will start a modest effort aimed at heavy-duty trucks
and vehicles at high altitude. The Federal program will also
enforce regulations applicable to lead in gasoline, as well as
continue to control the introduction of new additives and fuels
through the enforcement of fuels and additives registration and
fuel additive waivers. The enforcement of lead related regula-
tions will be focused on facilitating State and local action to
control fuel switching. Control of tampering will be continued
by focusing Federal efforts on significant violators of the
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Federal prohibitions (which do not apply to individual owners)
and by supporting State and local program development and en-
forcement actions (which can be directed at individual owners).
Finally, Federal actions will also be aimed at assuring that
States achieve full compliance with the requirements of their I/M
programs.
Key FY 1988 Headquarters Actions
(1) Evaluate and ensure consistent implementation of the
timely and appropriate guidance and the Federally report-
able violations guidance. Complete the post-1987 enforce-
ment policy and revise current national guidance. (OAQPS)
(2) Manage the Compliance Data System. Continue to inventory
VOC sources, emphasizing the identification of small VOC
sources that significantly contribute to ozone nonattain-
ment. (OAQPS)
(3) Develop VOC compliance workshops and VOC inspection
manuals. Provide technical support and expertise, as
needed, to the Regional Offices and States in conducting
inspections and addressing significant violations. (OAQPS)
(4) Continue pre-production certification, assembly line
testing Selective Enforcement Audits, and recall programs.
Focus on sources of evaporative hydrocarbons and in-use
compliance with hydrocarbon standards by light-duty trucks.
(OMS)
(5) Start enforcement (recall) for heavy-duty trucks and +
vehicles at high altitude. (OMS)
(6) Enforce regulations applicable to lead in gasoline. (OMS)
(7) Enforce fuels and additives registration and fuel additive
waivers requirements. (OMS)
(8) Support State and local enforcement action to control fuel
switching and tampering. Focus Federal efforts on signi-
ficant violators of the Federal prohibitions on tampering.
(OMS)
(9) Assure that States achieve full compliance with the re-
quirements of their vehicle inspection programs. (OMS)
Key FY 1988 Regional Office and State Actions
(1) Implement the small VOC source compliance strategy. +
(Regions and States)
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* (2) Implement the guidance on defining a Federally reportable
violation and the timely and appropriate response guidance.
Resolve, consistent with EPA policies, violations ot SIP
regulations by VOC sources. Identify and resolve signifi-
cant violations. (Regions and States)
* (3) Assure that appropriate violations are entered into the
Compliance Data System consistent with the new guidance
on defining a Federally reportable violation. Where com-
pliance schedules tor sources have been established, track
these schedules to assure timely compliance. Assure that
the system contains acceptable compliance status informa-
tion for these sources. (Regions and States)
* (4) Implement the new EPA Federal Facilities Compliance
Strategy by providing appropriate technical assistance and
taking expeditious actions when violations occur at Federal
facilities. (Regions)
* (5) Develop and implement in-use vehicle emissions control
programs. (States)
* (6) Develop and implement tampering and fuel switching control
programs. (States)
* (7) Assure that States achieve full compliance with the
requirements of their vehicle inspection programs.
(Regions)
4. Monitoring
The measures required in ozone SIPs are clearly more effective
and defensible if based on a strong data base. The data base
needed to develop defensible SIPs includes ambient concentrations
of ozone, non-methane organic compounds (NMOCs), and oxides of
nitrogen (NOX). Meteorological measurements and emission estimates
for VOCs, and the resulting information, is used to determine
attainment status, to estimate the reduction in emissions needed
to attain the ozone NAAQS, and to help track whether reasonable
further progress is being made toward attainment of the NAAQS.
Minimum data base recommendations for ozone SIPs were identified
in a January 1981 Federal Register notice. Minor changes are
being made to these recommendations. The changes suggest sampling
for NMOC at (at least) two sites and analyzing the data by gas
chromatographic (GC) sum of species or by using a cryogenic pre-
concentration approach. As before, at least three ozone moni-
toring sites will be needed for smaller urban areas with marginal
ozone problems. However, five or more are strongly recommended
for larger urban areas with ozone concentrations at or above
0.14 ppm. NOX monitors should be co-located with each NMOC
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monitor. Inventory and meteorological measurements should be
sufficient to support a city-specific EKMA (i.e., "Level III")
modeling analysis. ORD will continue programs to simplify and
validate regional and urban ozone models.
EPA anticipates that NMOC monitoring will be necessary every year
for the foreseeable future. Current plans call for monitoring
to be performed in each urban nonattainment area on a three-year
cycle (i.e., every third summer in a given city until the ozone
NAAQS is attained). During FY 1987, 20 major centers having
populations greater than one million and ozone levels at least
as high as 0.15 ppm were targeted as candidates for NMOC monitor-
ing. During FY 1988, approximately 20 additional cities will
need to monitor for NMOCs as part of the three-year cycle.
During FY 1988, State and local agencies will also need to assure
that NOX data collected at NMOC sites are of high quality, and
that high quality ozone data are collected from at least the
minimum recommended number of sites in each city.
During FY 1988 a program begun in FY 1987 to update and improve
VOC and NOX emission inventories will need to be continued. In
FY 1987, this program focused on the largest and worst urban
areas. Plans for FY 1988 are to update inventories in the
smaller cities having more moderate ozone levels. At a minimum,
emissions from TSDFs and puolically-owned treatment works (POTWs)
should be identified and incorporated into the inventory, Mobile
source emissions should be updated using the most current version
of the MOBILE model.
During FY 1986 EPA developed revised guidance for the submission
of reasonable further progress (RFP) reports that States will
need to periodically prepare to track progress towards attaining
the ozone standard. The revised guidance applies to each area
that will receive a post-1987 ozone SIP call. The first report
will be due one year after the State submits to EPA its revised
SIP for post-1987 nonattainment areas. In FY 1988 States should
work to develop this program, including activities to (1) iden-
tify the key sources/source categories whose progress towards
compliance will be tracked in the RFP process, and (2) develop
the baseline data that will be needed to track progress and
satisfy RFP reporting requirements in the future.
Key FY 1988 Headquarters Actions
(1) Disseminate the results of summer 1987 NMOC and NOX +
monitoring, including the resulting NMOC/NOX ratio data,
to Regional Offices/States to allow use of these results
in preparation of "post-1987" SIP analyses. (OAQPS)
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(2) Coordinate activities to ensure the availability of a
central, contractor-operated laboratory to analyze NMOC
samples and return sampling cannisters to the field.
(OAQPS and ORD)
(3) Provide technical assistance and consultation to those
Regional Offices wishing to set up a Regional laboratory
for analyzing NMOC samples. (OAQPS and ORD)
Key FY 1988 Regional Office and State Actions
(1) Select appropriate sites and conduct monitoring for NMOCs
and NOX at these sites during June-September 1988 in all
cities identified as needing monitoring data during FY
1988. (Regions and States)
(2) Update VOC and NOX emission inventories for designated
cities, incorporating latest available stationary source
emission factors and mobile source models. (States)
(3) evaluate existing ozone monitoring networks to ensure
they meet or exceed minimum recommendations. (Regions
and States)
(4) Review air quality data identifying the five highest
1987 ozone concentrations at each monitoring site in
every Metropolitan Statistical Area (MSA) with a 1984-86
ozone design value greater than 0.12 ppm within 60 days
of the end of the ozone season for each area. (Regions
and States)
(5) Evaluate ozone and NOX ambient data to ensure they meet
published quality assurance requirements. (Regions and
States)
(6) Begin or continue assembling data bases and instituting
programs to meet RFP reporting requirements. (States)
5. Program Assessment
The EPA will work with States through the existing National Air
Audit System to complete a detailed review of one or more VOC
regulations per year to determine effectiveness of the VOC con-
trol program. The EPA Regional Ottice and the State will
jointly report on the results of this review, and the State
should then take appropriate actions to remedy identified prob-
lems. Although EPA will develop and discuss with States in FY
1988 the guidance and procedures for conducting these reviews,
the reviews themselves will probably not be initiated until
after the SIPs are revised and submitted to EPA.
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In FY 1988 EPA will increase auditing of State new source review
and I/M programs. The EPA will also expand its overview of
State and local enforcement activity, particularly in regard to
larger VOC sources and sources with significant violations.
Audits of I/M and tampering control programs will be continued
to assure that they meet the requirements for achieving emis-
sion reductions required by the SIP. Additionally, Federal
surveillance and enforcement programs for fuel switching,
tampering, in-use vehicle emissions, control technology assess-
ment, and fuel and fuel additive use will provide information
on the effectiveness of control programs, and will lead to
corrective actions if required.
Key FY 1988 Headquarters Actions
(1) Implement enhanced auditing and enforcement of new source +
review and I/M programs. (OAQPS and OMS)
(2) Complete guidance for rule effectiveness evaluations. +
(OAQPS)
(3) Continue tampering and fuel switching surveys. (OMS)
(4) Continue in-use vehicle emissions surveillance and moni-
toring, for both properly used and maintained vehicles
and representative in-use vehicles of all classes. (OMS)
(5) Operate fuels registration and surveillance program.
(OMS)
Key FY 1988 Regional Office and State Actions
(1) Distribute/review with States guidance on rule ettec- +
tiveness evaluations and implement for one or more
regulations. (Regions)
(2) Coordinate enhanced compliance/auditing programs within +
the Region. (Regions)
(3) Audit and analyze I/M and tampering control program
effectiveness. (Regions)
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C. PM^g Attainment
In FY 1987 EPA expects to complete decisions that will require
major restructuring of current programs for the measurement and
control of ambient particulate levels. This change in the
national program will require substantial efforts by EPA, States,
and local air pollution control agencies over the next several
years. Many of the actions that State and local agencies will
need to undertake are due for completion during FY 1988.
1. Federal Standards and Regulations
The starting point for this major restructuring will be the
changes to the NAAQSs for particulates and to the associated EPA
regulations for implementing the NAAQSs.
NAAQS revision. The EPA efforts over the past several years to
review and revise the NAAQSs for particulate matter will be com-
pleted by mid-1987. The basis for both the primary (health) and
secondary (welfare) standards will change from total suspended
particulates (TSP) to a size-specific component (PM^Q). The
levels for the primary and secondary PM^g NAAQSs are expected
to be identical. The establishment of PM^g standards also
requires changes in the current emergency episode levels and the
significant harm level for particulate matter, the applicability
and level of review thresholds for prevention of significant
deterioration (PSD), and State reporting requirements.
SIP and monitoring regulations. At the time the PM^g standard
is promulgated, EPA will revise existing regulations governing
SIPs and the particulate monitoring programs (40 CFR Parts 51,
52, and 58). A guideline document, "PM^g SIP Development Guide-
line," will accompany the regulations. This guideline, along
with the regulations, will specify the changes in SIPs, demon-
strations of SIP adequacy, new source review requirements, and
modifications to the ambient monitoring network that will need
to be developed by the States and submitted to EPA for approval.
The requirements that States will have to meet in response to
the NAAQSs depend upon the severity of the anticipated problem.
EPA will conduct workshops during FY 1987 to review with States
these requirements.
New source performance standards. EPA will consider the effec-
tiveness of NSPSs in controlling PM^g emissions as part of future
reviews of the standards required by section lll(b)(l)(B) of the
CAA.
2. Planning and State Support
During FY 1988 State and local air pollution control agencies
will need to devote significant efforts toward the completion
of a number of regulatory planning and analytical steps culmi-
nating in the submission of SIPs for attaining and maintaining
the NAAQSs.
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SIP submission. The promulgation of the revised NAAQSs, the
revision of the SIP and monitoring regulations, and the issuance
of the SIP development guidelines in 1987 will set Ln motion a
series of actions that States will need to undertake. At the
time the PM^g standards are promulgated, EPA will assess and
classify all counties with particulate air quality data into one
of three groups. Both ambient PM^g data and TSP data will be
reviewed in determining these categorizations. A probabilistic
model employing TSP and PM^g data for the most recent three-year
period (1984-1986) will be a key element of the classification
scheme.
Counties demonstrating a 95 percent or greater probability of
violating the annual or 24-hour PM^g NAAQS will be classified as
Group I. These counties are the ones most likely to require
major changes in their existing TSP SIPs. Counties demonstrating
a probability between 20 percent and 95 percent will be classi-
fied as Group II. This includes counties where the nonattainment
probabilities drop below 95 percent or rise above 20 percent
because of PM^g data in the "gray zone." (The "gray zone" is a
ฑ20 percent zone of uncertainty placed around the standard be-
cause of the uncertainty existing in the PM^g measurements
collected with particular PM^g instruments.) For Group II
counties, EPA believes there is enough uncertainty about the
attainment status of the area that the Agency will allow time for
States to monitor air quality and analyze the adequacy of the
existing SIP before a revised control strategy is required. The
only immediately required revisions to State regulations will be
those implementing the preconstruction review (permit) require-
ments. For the remaining counties (i.e, Group III), EPA will
assume that the current TSP SIP is fully adequate with no addi-
tional SIP revisions or commitments required, except those for
preconstruction review.
Once the counties are classified, specific schedules identified
in the guideline come into play requiring individual State sub-
missions. States will need to complete the SIPs for Group I
areas within nine months of the NAAQSs promulgation. These SIPs
will have to include full control strategies and to demonstrate
attainment as expeditiously as practical, but not later than
three years (for the primary standards) from approval of the SIPs.
The control strategies will have to be supported by complete,
updated emissions inventories and appropriate modeling results.
These SIPs must also provide for future maintenance of the NAAQSs
and implementation of the preconstruction review requirements for
the PSD and other new source review requirements, consistent with
40 CFR Part 51.165.
The SIPs for the Group II areas must also be submitted within
nine months of the promulgation of tne standards. These "commit-
tal" SIPs must include enforceable schedules and appropriate mile-
stones, as well as revisions to implement the preconstruction re-
view requirements for PSD and 40 CFR 51.165. Required commitments
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include: (1) the collection of ambient PM^Q data at the levels
specified in the ambient monitoring regulations (40 CFR Part 58),
(2) the analysis and verification of ambient PM^Q data and the
reporting of 24-hour PM^Q exceedances, (3) notification of the
EPA Regional Office of a nonattainment problem whenever the
annual arithmetic mean or the number of 24-hour exceedances vio-
late the NAAQSs, and (4) a determination whether the measures in
the existing SIP will assure attainment and maintenance of the
primary PM^Q standard and submittal of any necessary revisions
to EPA.
For Group III areas, States will need to submit within nine months
revisions to existing preconstruction review regulations required
under PSD and 40 CFR 51.165. EPA will approve the current TSP SIP
as adequate to maintain the PM^Q NAAQSs at the time it approves the
preconstruction review regulations.
Requirements for analysis in group II areas. Beyond the submis-
sion of the committal SIPs required for Group II areas, the
States will need to evaluate the adequacy of the existing SIPs
and determine the need for further revisions. A State will be
allowed up to three years from the date of the NAAQSs promulgation
to collect air quality data, unless the NAAQSs are violated. At
the end of the 37-month period following promulgation, all avail-
able PM^Q ambient data will be examined to determine if attain-
ment can be demonstrated consistent with Appendix K of 40 CFR
Part 50 or EPA1s "Guidance on Exceptions to Data Requirements for
Determining Attainment of Particulate Matter Standards."
As part of the review in Group II areas, States will need to make
several determinations concerning the existing TSP control
strategy and its implementation. First, States must determine if
attainment can be demonstrated with modeling techniques. Second,
States must determine if the existing TSP strategy has been fully
implemented. Third, States must determine whether sources are
substantially in compliance with existing regulations. Finally,
States must determine if start-up, shutdown, and malfunction
regulations are adequate. States will also need to assess the
likelihood of PM^Q emissions increasing significantly, the proxi-
mity of actual emissions to allowable emissions, and the quantity
and impact of emissions from sources that are not operating or'
operating at reduced capacity.
Rural fugitive dust policy. At least for the time being, EPA
will continue to follow the rural fugitive dust policy established
in 1977. Consistent with that policy, rural areas violating the
PM^Q NAAQS because of rural fugitive dust will be categorized as
Group III areas. These rural areas must be identified by a lack
of major industrial development or absence of signiticant indus-
trial particulate emissions and low urbanized population. EPA
will publish alternative fugitive dust policies during FY 1987
and seek public comments. EPA may subsequently revise the cur-
rent policy requiring SIPs for certain of tlie rural fugitive dust
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areas. Submissions in such cases are not expected to be required
before FY 1989.
Emission trades. States will not be required to automatically
review partTculate emission trades in response to the PM^g NAAQS.
However, emission trade agreements should be considered along
with other particulate emission limits during the development of
the PM^o control strategy.
Key FY 1988 Headquarters Actions
(1) Provide necessary interpretation and clarit ication on P
implementing regulations and guidelines as requested by
individual Regions and States. (OAQPS)
(2) Keep abreast and prepare periodic national reports on the
status of State progress toward the development and
submission of PM^g SIPs to EPA. (OAQPS)
(3) Review regionally forwarded PM^g SIPs for consistency with +
requirements of the CAA, EPA implementing regulations, and
guidelines for SIP development and approval, including
required changes in regulations for preconstruction review.
(OAQPS)
(4) Expedite EPA Headquarters review and decisions on the ade- +
quacy of State-submitted PM^g SIPs and complete necessary
rulemaking actions consistent with EPA policy. Convene
necessary meetings of the PM^g advisory committee to re-
solve national issues that surface during review of PM^g
SIPs. (OAQPS)
(5) Complete action on review of rural fugitive dust policy +
and issue final requirements for affected areas. (OAQPS)
Key FY 1988 Regional Office and State Actions
(1) Provide technical and financial support to assist States
in developing PM^g SIPs. Address requirements in the PM^g
implementing regulations and in the guideline for SIP de-
velopment and submission, revision of preconstruction re-
view provisions, collection and analysis of data, and re-
view of existing control strategies as part of the
Regional/State grant negotiations and agreements for FY
1988. (Regions)
(2) Complete development and submit to the EPA Regional Office +
on schedule, required SIPs and/or regulations for PM^g in
Group I, II, and III areas, including required regulations
for preconstruction review. (States)
(3) Implement the commitments identified within the committal +
SIPs for Group II areas. (States)
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(4) Commence review and rulemaking actions on State-submitted +
PM10 SIPs. (Regions)
(5) Identify and document inadequacies within State-submitted +
PM^o SIPs and notify States of necessary corrective
actions for SIP approval. (Regions)
(6) Respond to violations of PM^g NAAQS identified in Group +
II areas, including required notifications to EPA.
(States)
3. Enforcement
While the PM^g SIPs are under development and review, the Regions
and States will need to continue to ensure the compliance of
stationary sources subject to the existing control regulations in
TSP SIPs. EPA will include in the review of the PM^g SIP
submittals the enforceability of the SIPs and individual regula-
tions. If needed, EPA will work with the States to correct
identified deficiencies that may hinder enforcement of the SIPs.
Key FY 1988 Regional Office and State Actions
(1) Review enforceability of PM^g SIP submittals. (Regions) +
(2) Continue to inspect sources subject to existing TSP SIP
requirements, consistent with the EPA Inspection Frequency
Guidance. Address and report violations according to
previously issued EPA policies and guidelines on enforce-
ment actions. (States)
(3) Maintain the continuing compliance of sources with +
existing TSP SIPs during the preparation and review of
the PMiQ SIPs. (States)
4. Monitoring
Consistent with 40 CF'R Part 58, each State will need to establish
a PM^g ambient air monitoring network following promulgation of
the PMiQ NAAQSs. In FY 1988, EPA will focus on accomplishing
three major elements of the PM^g a^-r monitoring program: (1) the
development and approval of State and Local Air Monitoring System
(SLAMS) and National Air Monitoring System (NAMS) networks for
PM^g; (2) the operation of an adequate network of PM^g samplers;
and (3) the timely reporting of PM^g data produced by these
network operations.
Each State, within six months after the effective date of promul-
gation of the Part 58 PMjg regulations, is required to submit a
SLAMS network and a NAMS network description. Regional Offices
are responsible for the review and approval of the SLAMS networks,
OAQPS is responsible for review and approval of the NAMS network
description.
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The relative priorities for the purchase and siting of
samplers described in the SLAMS and NAMS networks are shown
below.
0 First priority
0 Second priority
0 Third priority
Completion of the NAMS networks
Completion of the networks in Group I
areas outside the NAMS urbanized areas
Completion of the networks in Group II
areas outside the NAMS urbanized areas
In determining which Group II areas to address, primary considera-
tion will be given to the magnitude of the probability of non-
attainment of the PM^o standard and the population density of the
Group II area. In attempting to meet deficiencies in Group II
areas, consideration should be given to meeting these needs
through redistribution of samplers currently located in Group III
areas. It may be appropriate to establish monitoring in certain
fugitive dust areas where the Regional Office and State -believe
measures to improve air quality may be warranted, As mentioned
earlier, fugitive dust areas initially will be placed in Group
III, pending review of the current policy.
Decisions on PMig SIP adequacy are heavily dependent on analysis
of collected ambient PM^g data. Therefore, timely reporting of
the data to the national air data bank (within 120 days after the
end of the quarterly sampling period) will be an important
requirement of the FY 1988 program.
Key FY 1988 Headquarters Actions
(1) Track State/Regional submittal of NAMS PM^Q network des-
criptions. Review, evaluate, and take follow-up action in
order to conditionally or finally approve the NAMS networks.
( OAQPS )
(2)
Track the progress and adequacy of PM^g data submittal.
Issue periodic progress reports. In conjunction with
Regions, take action to obtain delinquent PM^g data.
(OAQPS)
Key FY 1988 Regional Office and State Actions
(1)
(2)
Submit SLAMS and NAMS network descriptions to Regional
Offices within the required six months following promulga
tion of the PMio NAAQSs. (States)
Review and approve SLAMS network descriptions. Assist
States in expediting needed corrections or changes.
( Regions)
I
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(3) Assess NAMS network descriptions for completeness, and +
for compliance with Part 58. Submit to OAQPS for review
and approval. (Regions)
(4) Implement networks in accordance with the negotiated +
schedules contained in the approved network descriptions.
Operate samplers at the required sampling frequency and
submit timely data to EPA. (States)
(5) Provide technical and financial support to assist States
in establishing the PM^o monitoring networks. Negotiate
within the grant agreement commitments and funds for the
purchase and operation of PM^o samplers in required areas.
Give priority tirst to NAMS, then Group I areas (outside
urbanized areas), and finally Group II areas (outside
urbanized areas). (Regions)
5. Program Assessment
Source-specific SIP revisions submitted during the transition
period from TSP to PM^o will be reviewed for their impact on the
PM^Q NAAQSs. Requests to redesignate a TSP nonattainment area to
attainment will be reviewed on the basis of previously issued
guidance for TSP redesignations. EPA will track State progress
toward the preparation and submission of PM^Q SIP revisions
and monitoring network descriptions. EPA will track comple-
tion of specific SIP and monitoring items as part of the
Strategic Planning and Management System.
D. Emerging Issues
In FY 1988 EPA will determine the policy alternatives and
strategy options available to address acid deposition, strato-
spheric ozone depletion, and indoor air pollution.
1. Ac i d Ra i n
Identify policy implications of research results. In FY 1988 EPA
will continue to emphasize the review of research results from
the National Acid Precipitation Assessment Program (NAPAP).
EPA's air program will actively participate in the research
planning and evaluation processes of NAPAP and ORD to ensure that
policy information needs are being adequately addressed by the
national research program.
Evaluate critical implementation and policy issues. EPA will
continue a cooperative effort with States to examine potential
implementation issues associated with the enactment of an acid
rain control program. In FY 1988 EPA will emphasize the develop-
ment of specific options for resolving these issues.
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2. Stratospheric Ozone Depletion
Meet EPA regulatory commitments. In FY 1987 EPA will focus on
developing a national and international consensus on the nature
and magnitude of the CFC problem, including negotiation of an
international protocol and a decision on domestic regulation.
In FY 1988 these efforts will continue and implementation efforts
supporting domestic regulation and international protocols will
be initiated, as appropriate.
3. Indoor Air
In FY 1988 OAR will produce a report delineating the state of
knowledge concerning the nature and magnitude of exposures to
indoor air pollution, the associated risks to the public health
and welfare, and the causes of and solutions to the problem. The
report will delineate an EPA policy and program strategy for
mitigation of these risks and an evaluation of alternative
actions the Federal government can take. The report will form
the basis of a report to Congress (pursuant to the Radon Gas and
Indoor Air Quality Research Act of 1986) due in the fall of FY
1989.
In cooperation with major national private sector organizations
representing architects, ventilation engineers, building owners
and managers, and public health professionals, OAR will produce
a state-of-the art document on the causes, consequences, and
solutions to indoor air pollution problems in non-residential
buildings. The report will be a first step in EPA's strategy to
mitigate what has become known as the "sick building syndrome."
The report will contain practical steps for mitigation at each
stage of the process in which a building is designed, con-
structed, occupied, maintained, and remodeled.
In cooperation with the organizations representing the State and
local governments, and public sector interests, OAR will produce
a guide to sources of information and services for indoor air
pollution. This guide will be periodically updated and serve as
the basis for communications between the public and private sec-
tors. The guide will be organized for use by the general public
seeking help on indoor air problems.
Key FY 1988 Headquarters Actions
(1) Evaluate the ORD and NAPAP research outputs and incor-
porate results into revised policy alternatives. (OPD)
(2) Integrate and evaluate State and EPA issues related to
implementation of an acid rain control program, seek re-
view by State and Regional Offices, and incorporate re-
sults into revised policy alternatives. (OPD)
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(3) Publish a decision on the need for regulatory actions to
reduce CFCs. (OPD)
(4) Report to Congress on indoor air, EPA's program strategy,
and an evaluation of alternative actions for the Federal
government to mitigate risks to the public health and wel-
fare. The report is pursuant to the Radon Gas and Indoor
Air Quality Research Act of 1986. (OPD)
(5) Complete a state-of-the-art report on the sick building
syndrome, and practical measures that can be taken during
all phases of building construction and operation to miti-
gate and prevent indoor air quality problems. The report
will be produced as a joint cooperative effort between EPA
and major private sector organizations. (OPD)
(6) Complete an inventory and guide to resources, expertise,
and services in indoor air quality to serve as the foun-
dation to communications and as a guide to the public on
where to go to get assistance. (OPD)
Key FY 1988 Regional and State Actions
(1) Assist in the evaluation of State and EPA acid rain pro-
gram implementation issues analyses. (States/Regions)
(2) Assist in the development of acid rain program implemen-
tation options. (States/Regions)
(3) Identify acid rain research needs of States and Regional
Offices and provide these to the Multi-Media Energy
Research Committee. (States/Regions)
(4) Develop Regional strategies for addressing indoor air
quality. Delineate Regional initiatives for FY 1989.
(Regions)
(5) Establish a Regional indoor air task force to assist
Headquarters in development of an indoor air strategy
for support to State and local governments. (Regions)
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III. RADIATION GUIDANCE
A. Indoor Radon
Radon is a naturally-occurring radioactive gas estimated to
cause between 5,000 and 20,000 iung cancer tatalities annually.
The Agency's Radon Action Program, instituted in FY 1986 to
address the hazard of elevated radon levels in homes and other
structures, will continue through FY 1988 and beyond.
1. Federal Responsibilities
Congress has not designated a lead agency for addressing the
indoor radon issue, but has recognized EPA's role in the passage
of the Radon Gas and Indoor Air Quality Research Act of 1986.
Currently, EPA and the Department of Energy (DOE) are pursuing
complementary functions based on their respective areas of
experience, expertise, and mandates. The DOE activities focus on
basic research into radon production and migration and on ele-
vated radon levels in homes due to certain energy conservation
practices. EPA efforts are largely directed towards problem
assessment, diagnostic and mitigation capability development, and
information dissemination. Most importantly, in meeting the
Agency's goals regarding radon, the Office of Radiation Programs
(ORP) will foster the development of self-sufficient programs in
the States and private sector. ORP will also ensure that the
radon program addresses potential problems on Tribal lands.
2. Planning and State Support
In FY 1988 ORP will continue to provide technical assistance
related to radon to the States. This support includes providing
geologic consultation, design and analytic support for surveys
to identity high-radon areas, and diagnosis of elevated levels
of radon in homes (40 homes in three or four States). The Radon
Measurement Proficiency (RMP) program will continue to operate
--providing information to consumers as to manufacturers and
distributers of radon detection devices that give acceptably
accurate readings. The total number of firms expected to parti-
cipate will limit the number of rounds in this program to two
for the year, as in FY 1987. Final measurement protocols are
to be issued. The three-day diagnosis and mitigation training
course will be updated and a new video tape will be made avail-
able to the States. Continued efforts are to be made in FY 1988
to encourage consideration of construction techniques that should
reduce the level of radon in new homes. ORP will continue to
provide training and develop and disseminate to the public new
fact sheets and other information about radon and EPA's Radon
Action Program.
3. Monitoring
As part of the Radon Action Program, the design and pilot testing,
and data handling system connected with a national survey are
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expected to be completed by ORP in early FY 1988. Field work
will then begin and continue throughout the balance of the
year and for some time thereafter. This survey is structured
to provide the basic statistical data on the overall distribu-
tion of radon levels throughout the country. The survey will
help the Agency decide where to focus its limited resources in
order to assist those States, local governments, and Indian
Tribes who have the most serious radon problems and the least
capability to address the problems themselves. The survey will
also provide much of the information necessary for the Agency
to prepare a report to Congress on the location of high levels
of radon in homes, schools, and workplaces. This report is
reguired by the aforementioned 1986 Act.
Key FY 1988 Headquarters Actions
* (1) Complete design and pilot testing of the national radon +
survey and initiate field work. (ORP)
* (2) Provide report to Congress, as required by the Radon Gas +
ana Indoor Air Quality Research Act of 1986. (ORP)
* (3) Provide design and analysis support for State surveys.
(ORP)
* (4) Continue the RMP program. (ORP)
* (5) Issue final protocols for measurement techniques. (ORP)
* (6) Update diagnosis and mitigation training course and
prepare new videotape. (ORP)
Key FY 1988 Regional Office and State Actions
* (1) Provide technical assistance, mitigation/prevention
demostration projects, and training to build State
capability. (Regions)
* (2) Respond to State and public inquiries and participate in
public meetings and technical conferences. (Regions)
* (3) Train State staffs, initiate surveys, ana provide radon
information to constituents. (States)
B. Radiation Standards
The control and disposal of radioactive substances in an
environmentally sound manner is a complex task that requires the
collective efforts of the DOE, the Nuclear Regulatory Commission
(NRC), individual States, and private industry, as well as EPA.
The Agency's principal role in this effort is to establish envi-
ronmental standards and guidance that limit exposure to various
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categories of radioactive material thereby minimizing public
health risks.
1. Federal Standards and Regulation
Radioactive waste. Because of the different types of waste being
considered and different potential control options and costs, the
problems nave been treated separately in the development of
standards for disposal of high-level wastes, low-level wastes
(including natural and accelerator produced materials), and
residual radioactivity at decommissioned nuclear facilities.
The high-level waste standard was promulgated in FY 1985 and is
currently being incorporated into DOE and NRC regulations. ORP
developmental work on a regulation for trie land disposal of low-
level waste will continue through FY 19ซB, with promulgation
scheduled for FY 1989. The inclusion of measures for the protec-
tion of groundwater resources is an important consideration in
this effort. In another elfort, ORP is developing the low-level
radioactive waste disposal portion of the Office oE Water (OW)
regulation for ocean disposal. This regulation will greatly aid
in protecting aquatic life and human uses of the oceans. The
substantive cooperative involvement with this OW effort will
continue into FY 1988 (OW promulgation likaly by the fourth
quarter of the year). ORP will also complete work during this
period on an extensive series of criteria and technical support
documents essential to implement tnis rule. On another front,
risk assessment and other technical work necessary to prepare
generic guidance and source-based categorical standards for
residual radioactivity will continue in FY 19B8. When promul-
gated, tnese regulations will apply to some 20,000 nuclear
facilites. The objective is to ensure an adequate level of
public satety as these facilities are decommissioned and released
for other uses.
Under a remand by the Tench Circuit Court of Appeals, work will
be completed in FY 1988 on a supplement to EPA standards for in-
active uranium mill tailings sites issued under the Uranium Mill
Tailings Radiation Control Act (UMTRCA). This new standard will
provide for groundwatar protection at 24 sites where DOE is
charged with taking remedial action under Title I of the Act.
Other Federal radiation standards and guidance. In response to a
court order, ORP promulgated in FY 1986, under tne Clean Air Act,
a MESHAP for radon-222 emissions from mill tailings at licensed
uranium mills. Currently, ORP has underway the development of a
series of documents to complete the "reserved" sections of the
previously issued NESHAP for DOE and other Federal facilities,
and the NESHAP for NRC licensed facilicies. Included are: record-
keeping requirements, models, and various criteria. Most of
these items will be completed by late FY 1988. Also, a series of
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guidance documents (essential for implementing all radionuclide
NESHAPs issued to date) are in preparation and this effort will be
completed in FY 1988. Beyond FY 1988, the emphasis will shift to
providing the essential elements of an etfective and continuing
implementation program.
In FY 1988 a decision will be made, based on a risk assessment
(Florida Field Studies) and a study of control techniques, on
whether to begin development of standards for radionuclide
emissions from pnosphogypsum piles.
EPA is responsible for advising the President on radiation
matters that directly or indirectly affect public health.
Included is development of guidance tor ali Federal agencies
in the formulation of their radiation standards. Federal radi-
ation protection guidance for radiofrequency (RF) radiation is
in preparation and scheduled for promulgation in early FY 1988.
This landmark guidance will be implemented by other Federal
agencies, such as the Federal Communication Commission (FCC), and
the National Telecommunications and Information Administration
(iMTIA), -- many of whom have formally expressed the need for its
development. The guidance will also serve as a useful information
oase for the communications industry and the public.
Protective Action Guides (PAGs) for radiation emergencies are
under development. "Plume," and "Ingestion," and "Relocation"
PAGs are scheduled for completion in FY 1988. when completed,
they will be added to the Manual of Protective Action Guidesa
document essential to tne Federal government and the States in
drafting their nuclear emergency response plans.
2. Implementation and Enforcement
The high-level waste standards will be implemented by DOE and NRC
through incorporation into their rules and procedures. ORP has
provided substantive input to these rule development efforts, has
reviewed the proposed rules, and expects tne tinal versions in FY
1987 or early FY 1988. EPA has no enforcement responsibilites
ror high-level waste disposal, but will begin in FY 1988 to track
DOE and NRC compliance. Also, on a continuing basis, ORP will
respond to requests for interpretation of EPA's standards and
their application in specific cases. The approach regarding
implementation of the UMTRCA groundwater standard in FY 1988 will
be essentially the same.
Implementation of ocean disposal of low-level waste will begin
in FY 1988. This will require ORP to work closely with OW to
develop specific permit review procedures. ORP will then, in
cooperation with the relevant Region(s), review permit applica-
tions and provide recommendations to OW on the low-level waste
disposal aspects.
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NESHAPs tor five source categories emitting airborne radionuciides
are currently in effect and will require various levels of imple-
mentation. The five rules encompass DOE and other Federal facil-
ities, NRC licensees, uranium mines, uranium mills, and elemental
phosphorus plants. It is estimated that some 17,QUO individual
facilities may ultimately be subject to these rules. Implementation
will thus require a continuing effort through FY 1988 and the years
beyond. FY 1988 is a transition year wherein NESHAPs implementation
will move from "initiation" stages to an ongoing program. This
program will emphasize assistance to the Regions and training of
Regional and State personnel, as well as provision of needed
regulatory data bases ana other elements essential to ensuring
effective and continuing implementation.
NESHAPs implementation will involve reviewing requests for: (1)
approval to construct new or modified facilities, (2) waivers
of emission testing, and (3) delegation to the States. (Uranium
mills will not involve waivers, but instead reviews of requests
for extensions and exemptions.) During the initial stage of
NfiSHAPs implementation, the work load will be shared by ORP and
the Regions. The relative distribution of responsibilities will
be based on: (1) the type and complexity of the facilities
involved, and (2) the technical/staff resources and workload of
the Regions. During tnis stage, ORP Headquarters will take the
lead on most DOE facilities; the Regions on facilities such as
elemental phosphorus plants. Ultimately, however, much of the
burden of implementation will be shifted to the Regions and the
Stateswith ORP overseeing the process and providing the guidance
and assistance where necessary.
The NESHAPs for DOE and other Federal facilities, as well for NRC
licensees, can be implemented in full only when all reserved
parts of the rule are completed. The reserved parts include DOE
and NRC recordkeeping, exemption criteria, screening models, and
sampling/analytical criteria. In addition, for any of the five
NESHAPs to De implemented, a series of guidance documents must be
developed. These include guidance for the EPA Regions and State
governments. Although the amount of effort involved in completing
all of these items is considerable, work in both key areas is
underway and major portions will De concluded in FY 1988.
Implementation of the radiofrequency guidance will be initiated
in FY 1988. This will involve a cooperative effort with the
FCC, NTIA, Department of Defense (DOD) and numerous other Federal
agencies who regulate or operate radiofrequency equipment and
facilities. EPA guidance will be incorporated into the procedures
of these agencies and ORP has received indications from many of
them that they will need EPA implementation assistance. Subse-
quent interpretation of the guidance and its application in
specific cases is also expected. EPA has no enforcement respon-
sibility, but overview of compliance will be conducted as
necessary.
I
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Continued implementation support of an advisory and overview
nature will be provided to various Federal agencies responsible
for implementing other EPA radiation guidance promulgated prior
to FY 1988. Some examples are: Guidance on Occupational Expos-
sure (applicable to 1.3 million workers) and on Diagnostic X-Rays
(for medical purposes).
3. Monitoring
Many of EPA's radiation standards and guidance are implemented
by other agencies, who are responsible for any monitoring, site
inspections, or other compliance related actions. For the radio-
nuclide NESHAPs, however, ORP will review the need for any initial
test or permanent on-sita monitoring to support compliance efforts,
4. Program Evaluation
For standards and guidance promulgated pursuant to the Atomic
Energy Act, ORP will monitor the performance of other Federal and
State agencies responsible tor their implementation. By use of
such means, ORP is aoie to identify problems with implementation
of specific regulations that need resolution and to identify
areas in which future fiPA standards or guidance may need to be
developed. ORP will continue to foster resolution of problems
through meetings, workgroups, negotiations, and other coorperative
interagency efforts. Also, to the greatest extent possible, ORP
will continue to involve the Regions in workgroups and in efforts
to identify problems with nuclear facilities.
One possibility for regulatory development in FY 1988 is an
amendment to 40 CFR 191 for high-level waste providing an alterna-
tive standard tor the disposal of radioactive wastes at DOE's
Hanford facility. ORP has reviewed DOE's draft environmental
impact statement (EIS) on Hanford ana anticipates a formal request
for such a standard. ORP will follow developments regarding this
matter and take appropriate action should a request oe received.
Key FY 1988 Headquarters Actions
(1) Meet approved schedule on development of low-level
waste ^tandara (towards early FY 1989 promulgation).
(ORP)
(2) Complete assistance on OW ocean disposal regulation,
including series of criteria/technical support docu-
ments. (ORP)
(3) Meet approved schedule on development of residual
radioactivity generic guidance and categorical
standards. (ORP)
(4) Issue groundwater standard under UMTRCA. (ORP)
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(5) Complete "reserved" sections of airborne radionuclide
NESHAPs for DOE facilities and NRC licensees. (ORP)
(6) Complete guidance documents and initiate implementa-
tion of all NESHAPs for radionuclides. (ORP)
(7) Promulgate radiofrequency guidance. (ORP)
(8) Meet approved schedule on development of Protective
Action Guides. (ORP)
Key FY 1988 Regional and State Actions
(1) Work with Headquarters in initiating the implementation
of NESHAPs for radionuclides. (Regions)
(2) Participate in tracking the compliance of taciiities
and the processing of industry requests under NESHAPs.
(Regions and States)
(3) Continue to review EISs for radiation facilities, such
as uranium mines and mills and waste disposal taciiities.
(Regions)
(4) Provide information to the media and to the public
explaining radiation issues and Agency actions.
(Regions)
C. Surveillance ana Emergency Response
1. Federal Responsibilities
The Agency conducts radiological surveillance to maintain a
capability to inform State and local governments and the general
public of any radiation release to the environment it believes
is a potential health hazard. Such releases can come from acci-
dents at nuclear facilities or from nuclear testing, whether they
be domestic or foreign. Such releases can also come from natural
sources or as inadvertent by-products of non-nuclear commercial
activities.
The Federal government has the responsibility to develop and
maintain the comprehensive emergency response framework and
capability through which appropriate actions can be taken at the
Federal, State, and local level to meet emergency situations.
The technical expertise and management overview capabilities of
the Federal Emergency Management Agency (FEMA), EPA, DOE, NRC and
other agencies are required to provide the technically sound and
coordinated approach necessary in such situations.
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Under the Superfund Amendments and Reauthorization Act (SARA),
the Agency has responsibility for material removal and other
remedial actions required at sites contaminated with radio-
nuclides. ORP and the Regions provide extensive support to the
Office of Solid Vfeste and Emergency Response for Agency responses
at these sites. This includes review of contractor prepared work
plans, remedial investigations/feasibility studies (RI/FSs), and
other documents; analytical support; and technical assistance in
the field. Regional and ORP Headquarters involvement varies
according to need on a site-by-site basis.
2. Planning and State Support
The primary goals regarding the Agency's radiological emergency
response capability are: (1) to maintain all personnel and equip-
ment in a state at readiness, and (2) to upgrade the system where
necessary to improve its performance. With the Agency's Emergency
Response Plan now revised and made consistent with the Federal
Response Plan (completed in FY 1986), active tests of the EPA
plan and emergency capabilities will continue in FY 1988. Also,
emergency response teams at ORP field facilities in Montgomery,
Alabama and Las Vegas, Nevada will be tested periodically by
participation in exercises conducted by FEMA. The Agency receives
some 35 notifications annually of incidents at nuclear facilities
requiring varying levels of response.
Through EPA's Regional Radiation Representatives, a continuing
area of focus will be maintenance of emergency preparedness
capability for nuclear facilities. Included in FY 1988 are
participation in Regional Assistance Committees; testing and
critique of 20 to 30 emergency response plans; and review of
updated State, local, and site-specific emergency response plans,
as required. In addition, the Regions will continue to distribute
information to State and local governments and to the public in
their area in the event of a nuclear incident or other potential
radiological health hazards.
3. Monitoring
EPA's Environmental Radiation Ambient Monitoring System (ERAMS)
is the only national multi-media surveillance system providing
timely measurements of ambient radiation levels in air, drinking
water, surface water, and milk. Its 268 sampling locations are
found in every State. They are generally operated by State and
local personnel and in accordance with EPA procedures. ERAMS
operations will continue in FY 1988 during which an average of
2,150 environmental samples will be collected and analyzed each
quarter.
In FY 1988 ORP will emphasize improving the responsiveness of
ERAMS through assessment and, where necessary, refinement of its
design and procedures. Also, ORP will change its overall approach
to maintaining ERAMS. Beginning in FY 1988, ORP will service,
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replace, or upgrade sane 20 percent of the field equipment each
year. This approach is needed to assure the continued readiness
of the system by providing the benefits of routine maintenance
and phased replacement.
Key FY 1988 Headquarters Actions
(1) Maintain and upgrade the Agency's comprehensive emer-
gency response cabability. (ORP)
(2) Provide timely and appropriate responses to notifica-
tions of radiological emergencies. (ORP)
(3) Maintain and upgrade ERAMS equipment design and pro-
cedures. (ORP)
(4) Phase out the Three Mile Island field office. (O.RP)
(5) Provide technical support for Agency actions at con-
taminated sites under SARA. (ORP)
Key FY 1988 Regional and State Actions
(1) Participate in and support ERAMS. (Regions and States)
(2) Test and upgrade emergency response plans. (States)
(3) Review and critique emergency response plans. (Regions)
(4) Participate in, and critique, emergency response
plan exercises. (Regions)
(5) Provide technical guidance and information to the States
and the public. (Regions)
(6) Provide technical radiation support tor site investi-
gations under SARA. (Regions)
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TABLE OF CONTENTS
PAGE
I. EXECUTIVE SUMMARY 1
1
A. Program Priorities 3
B. Performance - Based Assistance
II. DRINKING WATER GUIDANCE 5
A. Public Water System Supervision Program 5
B. Underground Injection Control Program 8
III. GROUND-WATER PROTECTION GUIDANCE 11
A. Ground-Water Direct Assistance Programs 11
B. Ground-Water Protection Strategy 12
IV. SURFACE WATER AND WETLAND PROTECTION GUIDANCE
[This section will be published in April.]
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FY 1988 OFFICE OF WATER AGENCY OPERATING GUIDANCE
I. EXECUTIVE SUMMARY
The Office of Water portion of the FY 1988 Operating Guidance
provides national direction to EPA, States and the regulated
community in carrying out programs mandated under Federal water
protection statutes. These statutes include: the Safe Drinking
Water Act (SDWA), the Clean Water Act (CWA) and the Marine Pro-
tection, Research and Sanctuaries Act (MPRSA). The Agency and
the States also implement programs to protect ground-water
quality through authorizations under several different statutes.
The Office of Water (OW) uses a management accountability system
to set priorities, define performance expectations, and track and
assess Regional and State performance. The Office of Water
Accountability System (OWAS) includes the OW portion of the
Guidance, the accompanying SPMS measures, the OW program evalua-
tion guide with quantitative and qualitative measures, and the
OW midyear Regional evaluations. In addition, the Regions will
provide the OW Assistant Administrator with their projected
operating strategy and plan for FY 1988, including an overview
of Regional and State priorities and their relationship to
national priorities, before FY 1988 commitments are made to set
the context for negotiation of those commitments. The Regions
will present their plans at the time of the senior management
review for the FY 1987 midyear evaluation.
Part I of this Guidance outlines the major program priorities for
water programs in FY 1988 and the water program policy for
Regional negotiation of FY 1988 grant assistance to the States.
Parts II and III contain specific program guidance and priority
activities for the Drinking Water and Ground-Water Protection
programs. Part IV, the guidance for the Surface Water and Wet-
land Protection programs, will be issued in April to provide
directions for implementing the Clean Water Act Amendments.
Activities that support Agency priorities are marked in the left
hand margin by an asterisk (*); those activities supporting OW
priorities are marked by a bullet (ฐ). Additionally, activities
with associated SPMS measures are denoted by [SPMS] appearing at
the end of the activity.
In line with tne Agency format, activities modified from the FY
1987 Operating Guidance are indicated by a dash (-) in the right
hand margin. New activities are indicated by a plus sign ( + ).
A- Priorities for FY 1988
In FY 1988 and beyond, the Water program will focus on seven
major program priorities, consistent with the Agency's FY 1988
Priority List and the Administrator's Management Priorities.
The priorities continue trends and developments of the water
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programs from FY 1987 and previous years and reinforce the
directions legislated by the Safe Drinking Water Act Amendments
of 1986 and the Clean Water Act Amendments of 1987.
Control Drinking Water Contaminants
The Safe Drinking Water Act Amendments provide EPA with new
enforcement authorities and responsibilities and require an
accelerated standard-setting process. One of our highest
priorities is to protect the public from contaminated drinking
water, and our efforts in FY 1988 will focus on stronger
enforcement of existing drinking water standards, development of
new standards for statutorily-mandated contaminants, and
monitoring for unregulated contaminants to determine the need
for additional standards.
Protect Ground-Water Resources
The Water Program will continue in FY 1988 to undertake a
comprehensive approach to ground-water management in collabora-
tion with the States. The Safe Drinking Water Act Amendments
provide EPA and the States with additional authorities and prog-
rams to ensure protection of ground water. In FY 1988, the
Ground-Water Classification Guidelines will be implemented as
official Agency policy and will provide a benchmark for all EPA
programs involved in ground-water protection and clean-up
authorities to provide strong enforcement of UIC requirements ^B
and to develop the Class V well injection control program.
activities. Additionally, EPA and the States will be implementing
the wellhead protection program. EPA will also use its new
Protect Wetlands
We will focus in FY 1988 on aggressively implementing the Wet-
lands Protection Strategy. This will include maintaining the
current central Section 404 program activities; increasing
emphasis on advance identifications in priority wetland areas;
enhancing State roles in wetlands through State capacity build-
ing, including using Section 401 certification; improving
consistency across Federal agencies on wetlands policy; and
building the information base for decisions on wetlands in the
future.
Restore the Integrity of Near Coastal Waters
Consistent with the Near Coastal Waters Strategic plan, we will
focus in FY 1988 on implementing an integrated approach to
control toxics and nonpoint source pollution in near coastal
waters. This could include (1) use of selected comprehensive
estuarine management studies to apply the lessons of the Chesa-
peake Bay and Great Lakes through local management, and plan
implementation systems and (2) integrated approaches to control
toxics, including setting and enforcing more stringent control
limits in NPDES permits on a basin-wide basis and developing non
point source controls.
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Control the release of toxic discharges and hazardous wastes to
surface waterฅ
A high priority for surface water programs in FY 1988 is to
protect human health and the environment by controlling toxicity
in all waters where designated uses are not being attained due to
the presence of toxic discharges from either point or nonpoint
sources. Water program efforts in FY 1988 will focus on working
with the States in conducting comprehensive integrated assess-
ments of State toxic control programs for surface waters
covering standards, control priorities, permitting, binding
legal authorities, and monitoring, and, as part of these assess-
ments, developing State-specific action plans. Other surface
water toxic control efforts will include issuance and enforcement
of third-round water quality-based permits with whole effluent
toxicity controls as needed and improvement of coverage,
effectiveness, and enforcement of local pretreatment program
requirements.
Reduce discharges of inadequately treated wastes from municipal
wastewater treatment facilities
FY 1988 is the year of the July, 1988 deadline for municipal
compliance. The Water Program will aggressively enforce compli-
ance with the statutory deadline under the National Municipal
Policy, taking judicial enforcement actions against major POTWs
where necessary and seeing them through to completion.
Prevent uncontrolled discharges of pollution to surface waters
Water program managers must be aware of and deal with unpermitted
discharges of pollution to surface waters to ensure that our
pollution control efforts are successful. EPA will encourage
State development of nonpoint source control programs where
needed and work with other Federal programs to ensure that they
comply with State NPS control efforts. Water program managers
must use their NPDES and Section 404 authorities to deal with
unpermitted discharges in wetlands to ensure protection of
these valuable resources. EPA and States also must be prepared
to deal with and track down pollution spills and other unpermitted
discharges.
B. Water Program Performance-Based Assistance Policy
The EPA Policy on Performance-Based Assistance explicitly links
EPA assistance to effective State performance. Performance-based
assistance programs are built on commitments jointly negotiated
prior to grant award. Work programs must provide for early
warning of missed commitments and a mechanism to respond to them.
The overall approach is to use the assistance process to provide
a context for agreeing jointly on how and to what extent Agency
and state Priorities will be met. The water program performance-
based assistance policy applies to all State and local assis-
tance programs under the Clean Water Act, Safe Drinking Water
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Act, and related appropriations. Funding priorities should
be based on the Agency priority list, the individual program
priority activities detailed in the following text, and
achievement of State SPMS and OWAS commitments. All water
program assistance agreements in FY 1988 are to be consistent
with the policy outlined in this section.
Negotiation of Work Programs
Regions arid States are to tailor their work programs to the
priority activities listed in the following sections of this
guidance, recognizing the individual Region/State circum-
stances and priorities and the level of program assistance.
Regional Offices may issue written guidance tailored for
each State to incorporate national, Regional, and State
priority activities into the work program negotiation pro-
cess. Work programs must contain realistic commitments for
every national SPMS measure. It is critical that the work
program clearly identify both the performance expectations
and the plan for EPA's evaluation ot State performance. The
States should be encouraged to provide a comprehensive work
program that includes activities outside those paid for
under the assistance agreement.
Oversight of Program Performance
Oversight will be designed to give an early indication of
State progress and problems in meeting the work program
commitments. Regional Offices must monitor and evaluate
program performance both informally and formally, maintaining
continuous dialogue with the States to give early warning of
emerging issues. Regions must conduct a minimum of one
on-site mid-year evaluation, culminating in a report of
findings and follow-up activities. Regional reports should
include comments from the State on the report's findings. A
copy of the mid-year evaluation for each State is to be
available for Headquarters review upon request.
Actions to Reward Accomplishments and Correct Problems
Follow-up actions to evaluate findings are meant to find the
most effective way to maintain and improve program perfor-
mance. Regional Offices should encourage good performance
by publicizing accomplishments and reducing the extent,
level, and scope of oversight. Where appropriate, financial
incentives should be provided. Likewise, where performance
problems exist, the Regional Office is to initiate a series
of escalating actions to resolve the problem in a quick and
fair manner. Where performance problems persist, actions
should include the use of the grant mechanism as outlined in
40 CFR Part 30 and Subpart A of 35. Corrective measures are
to be based on the severity and persistance of the performance
problem, in line with the performance expectations laid out in
the original work program.
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II. DRINKING WATER GUIDANCE
The Safe Drinking Water Act was amended on June 19, 1986, result-
ing in major changes to program implementation for both the
Public Water System Supervision (PWSS) and the Underground Injec-
tion Control (UIC) programs. The 1986 amendments significantly
increased the number of drinking water standards to be promulgated
in the next three years, gave EPA new administrative enforcement
authorities, and increased the scope of the existing public
notification requirements. The FY'88 program activities reflect
the new initiatives and direction established in the 1986 amend-
ments .
A. PUBLIC WATER SYSTEM SUPERVISION PROGRAM
The goal for the PWSS program continues to be the elimination
of all violations of the National Primary Drinking Water Regu-
lations. The first priority for FY'88 is to eliminate all
significant noncompliers of these regulations. Every community
water system which is in significant non compliance (SNC) will
be targeted for EPA and/or State compliance efforts. For FY '88
these efforts will include the exercise of the new administrative
enforcement authorities granted to EPA under the 1986 amendments
to the Safe Drinking Water Act.
Compliance/Enforcement Activities
* Regions and States will continue to emphasize elimination (-)
of violations of the NPDWRs. Regions and States should
use the full range of available tools, and escalate actions
as needed, to achieve compliance -- training, plan review,
sanitary surveys, technical assistance, site inspections,
enforcement, etc. States and Regions should take into
consideration degrees of contamination, populations at risk,
acuteness of risk, etc., in employing those compliance tools
and apply them strategically to obtain the maximum value
for each action, and to establish a strong enforcement presence.
* Regions and States should emphasize the exercise of their
administrative, civil, judicial and criminal enforcement
authorities, and take appropriate follow-through on enforce-
ment actions to bring water supplies into compliance.
Regions and States should ensure that all SNCs are either
returned to compliance or are addressed in a timely and
appropriate fashion. The primacy agent's goal should
be that 100% of the SNCs are returned to compliance or
are appropriately addressed (according to guidance and
State/EPA enforcement agreements) within the prescribed
time frame. [SPMS]
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Those Regions and States with few SNCs should focus on
those non-SNC violators which are considered to deserve
the most attention. EPA's Compliance Strategy should be
used in identifying those systems or groups of systems.
Regions and States should ensure that all noncomplying
systems are at risk of an enforcement action. Although
first priority should be on SNCs, noncomplying systems
which do not meet the SNC definition should not be ignored.
These systems should understand that they are in violation
and are subject to enforcement actions. States and Regions
should agree to enforcement actions against some number
of non-SNCs.
Regions and States will, at a minimum, conduct quarterly
compliance meetings to discuss and verify progress made
in compliance and enforcement activities, particularly
against SNCs. Any SNC that a State has not addressed
in a timely and appropriate fashion shall receive immediate
follow-up action by the Region.
* Regions and States are to negotiate targets for the percent (-)
change in micro/turbidity/TTHM SNCs during the year. The
goal for the national average is a 10% overall decrease in
the number of microbiological MCL or monitoring, turbidity
MCL or monitoring, or TTHM monitoring SNCs over any 12
month period. Individual States and Regions should negotiate
State targets based upon that State's current compliance
status and capabilities in improving compliance. [SPMS]
0 Regions and States are to ensure that compliance of Federal (-)
facilities is an integral part of their compliance and enforce-
ment programs; the A-106 process should be followed in all
situations. To enable EPA to identify Federal facility
compliance automatically, States and Regions should ensure
that Federal facilities are correctly coded in FRDS.
0 Regions and States are to ensure that their approach to (-)
noncompliance resolution is consistent with ODW1s revised
compliance strategy.
0 Regions and ODW shall continue the existing special com- (-)
pliance initiatives (e.g. the Oceanic Islands, the Caribbean,
and the Alaskan Remote Villages Initiatives), and should
begin such new initiatives as warranted.
Data Management
* States are to report accurate violation and enforcement (-)
data (in acceptable format for FRDS input) to Regions within
60 days after the end of each quarter. Regions are to ensure
that data are submitted for inclusion in FRDS arid available
for extraction within 90 days after the end of each quarter.
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* Regions will continue to conduct data verifications of State (-)
violation reports. Regions will follow up on those States
for which previous audits revealed reporting inconsistencies
to ensure that the recommendations made are being implemented
and that there have been improvements in the quality of the
reporting.
0 Regions will report information on Federal administrative (+)
enforcement actions to HQs via a national tracking system
to be established in FY'87.
Program Development
* States will begin to incorporate in their laws and regula- (-)
tions the first phase of the revised National Primary Drinking
Water Regulations for VOCs and monitoring rule for unregulated
contaminants, in the fourth quarter FY'87. This will be
completed by December 19, 1988.
* In the second quarter of FY'88, States will begin to incor- (+)
porate in their laws and regulations requirements for fil-
tration and disinfection of surface water supplies, and MCLs
for microbiological contaminants. This will be completed
by June 30, 1989.
* HQs will promulgate MCLs for synthetic organic and inorganic (+)
chemicals in the third quarter FY'88.
* HQs will promulgate MCLs for radionuclides in the second (+)
quarter FY'88.
0 States will begin to incorporate in their laws and regula- (+)
tions the 41 new MCLs or treatment requirements as specified
in the Safe Drinking Water Act Amendments of 1986, in the
fourth quarter FY'88. This will be completed by December 19,
1989.
HQs will modify 40 CFR 142 to incorporate all of the new ( + )
implementation requirements created by the SDWA Amendments,
and to specify State reporting requirements, by the fourth
quarter FY'88.
0 Regions (Program offices and Regional Counsel) will provide ( + )
assistance to States, as needed, in preparing for and in
modifying State statutes and regulations as required by
the SDWA Amendments and Federal regulatory changes.
Regions will conduct reviews of proposed and actual State
modifications as needed.
Otner
* States will ban, by June 19, 1988, the use of lead materials (+)
(State/local level) and develop adequate enforcement programs
to ensure adherence to the lead ban requirements.
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Regions and States will expand their oversight requirements ( + )
for non-transient, non-community water systems as EPA phases
in additional monitoring arid MCL requirements for these
systems over the next few years. Headquarters will provide
guidance during the 1st quarter FY 1988.
States and Regions will provide technical assistance and in- ( + )
formation on public health risks associated with radon.
Regions will conduct special reviews of selected State PWSS (-)
programs where there is concern about a State's ability, or
effort, in implementing the primacy program.
Regions will continue to coordinate sampling and information ( + )
dissemination on the Pesticides Survey.
HQ will publish regulations and guidance regarding primary ( + )
enforcement responsibility for Indian Tribes. Regions will
act quickly on tribal applications for development grants.
ORD will provide human health assessments to support ODW's (+)
need for quantitative risk assessments of drinking water
contaminants, will analyze public comments on eight drinking
water health assessment/criteria documents, and will finalize
documentation for 30 health advisories initiated in FY '86.
B. Underground Injection Control Program
The major goal of the Underground Injection Control (UIC) program
in FY 1988 will be to assure the effective implementation of direct
implementation and primacy programs. Objectives for FY 1988 are
to assure that: (1) programs conform to applicable regulations
and program descriptions; (2) reporting is accurate and used for
management purposes; and (3) EPA and primacy States take timely
and appropriate action to resolve instances of significant non-
compliance. A major Headquarters activity will be to develop
appropriate restrictions of the injection of hazardous waste.
The priority activities this year are listed below.
Compliance and Enforcement:
* Regions ana States will maintain a strong field presence
by conducting field inspections and surveillance, in
accordance with priority established in the UIC
Compliance Strategy. [SPMS]
* Regions and HQ will continue support for enforcement
cases begun in FY 1987 and prior years. [SPMS]
* All suspected Class IV wells will be investigated promptly ( + )
and all necessary steps taken to ensure proper plugging
and abandonment of Class IV wells.
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Regions and States should respond to all violations, and (+)
must escalate actions consistent with national guidance
on timely and appropriate enforcement actions for all
Significant Noncompliers (SNCs). [SPMS]
Regions will oversee State primacy programs, conduct
intensive reviews in selected States, negotiate
enforcement agreements, and take enforcement action
where the State has not or cannot respond to signi-
ficant violations in a timely and appropriate
manner.
Regions ana States will ensure compliance with all formal
enforcement actions (including coordinated use of both
civil and criminal enforcement authorities) through tracking
and prompt follow-up when deadlines are missed. [SPMS]
Regions will continue to report information on Federal
administrative enforcement actions to Headquarters pursuant
to the national tracking system established in FY 1987.
[SPMS]
The Regions and States will inspect Federal Facilities as (+)
part of their inspection plans, and will pursue compliance
at Federal Facilities according to the Federal Facilities
Compliance Strategy. The Regions should coordinate with the
States on review of the A-106 plans.
Regions and States will ensure that all injection wells ( + )
have mechancial integrity and bring violators to compliance
in a timely manner. [SPMS]
Permitting:
Regions and States are to continue to review and make (-)
permit determinations for new and existing injection
wells based on the following priority order, in
accordance with UIC regulations. Regions and States
will use their discretion to set a higher priority for
injection well operations which threaten to contaminate
groundwater. [SPMS]
a. new Class II wells.
b. existing Class II salt water disposal wells.
c. Class I and III wells.
d. Class V wells which may endanger USDWs.
Class II:
Regions and States will continue to monitor and review
mechanical integrity of injection wells authorized by
Rule to determine compliance with the UIC regulations.
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headquarters will conduct a series of activities to
determine whether the current regulations are adequate
to protect underground sources of drinking water (USDWs).
Regions and States will work vigorously to complete ( + )
the five-year cycle on mechanical integrity tests. [SPMS]
Regions and States will work vigorously to complete (-)
the five-year cycle on file reviews.
For States which have completed their first five-year ( + )
cycle of permit reviews, the Regions will individually
determine the program necessary to demonstrate a
continuing effective compliance evaluation program
based on guidance to be issued in FY 1987.
Regions and HQ will review alternative methods for
demonstrating mechanical integrity of wells for
which no current method is yet acceptable.
Hazardous Waste;
* Regions will coordinate with States and Federal RCRA ( + )
programs to implement the corrective action requirements
of the 1984 Hazardous and Solid Waste Amendments for
(HSWA) Class I hazardous waste wells. [SPMS]
* Headquarters and Regions will implement the UIC waste (+)
restriction determinations promulgated under the UIC
regulatory to implement the requirements in the 1984
HSWA amendments for Class I harzardous waste wells.
Class V;
0 Headquarters will begin the implementation of (+)
recommendations from the Class V Report submitted in
FY 1987.
Other:
ORD will continue field evaluation of techniques for ( + )
determining the mechanical integrity and adequacy of
construction of injection wells. Work to develop
technological alternatives for regulating Class V
wells will begin at the request of ODW.
Regions will develop and oversee Indian land programs (+)
consistent with the Indian direct implementation program
regulations promulgated in July,1987.
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GRQUND-WATER PROTECTION GUIDANCE
In 1984, EPA issued a Ground-Water Protection Strategy which
provides a framework for coordinating the Agency's programs
related to ground-water resources. This national focus has been
expanded and strengthened by the enactment of a new assistance
program, authorized in the Safe Drinking Water Act Amendments of
1986, which is targeted directly to ground-water resources. The
Well-head Protection Program has the principal purpose of
protecting wells which supply public water systems. This program
has been designed to both complement and be integrated with the
States' ground-water protection strategies support by Section 106
grants.
A. Ground-Water Direct Assistance Programs;
Wellhead Protection (WHP) Program
This program provides grants to support State activities to pro-
tect wellhead areas of all public water supplies within each
State's jurisdiction from contaminants that may have adverse
effects on public health.
* States which participate in this program will develop pro- {+)
grams for controlling sources of well contamination. (Ongoing)
* HQ will assist the Regions in developing and conducting orien- (+)
tation sessions for State personnel on the WHP program and
will provide oversight, including program and grant policy,
for this program. (Ongoing)
* Regions will provide all necessary consultation and technical (+)
assistance to the States in the development of their programs.
(Ongoing)
* Regions will review States approaches in delineating wellhead
areas, including hydrogeological assessments. (Ongoing) (+)
* Regions will approve WHP applications with HQ concurrence on
first year applications for quality control and policy reso- ( + )
lution. (Ongoing) [SPMS]
* Regions will negotiate an annual work plan with the States/ (+)
Indian Tribes for their wellhead protection projects.
* hQ and Regions will ensure that Indian Tribes are accorded ( + )
the same treatment as States, as required by EPA rule.
(Ongoing)
* HQ and Regions will interface with all Federal agencies to ( + )
ensure compliance with State approved programs. (Ongoing)
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* ORD will assist HQ in developing technical resource documents (+)
and other information to aid States in protecting public
water from contaminants which may enter wellhead areas.
(Ongoing)
Sole Source Aquifer (SSA) Designation
In FY 1988, EPA will continue to focus on the designation of sole
source aquifers.
* Regions will offer technical assistance and other support (+)
measures needed by prospective petitioners in interpreting
EPA's petition requirements. (Ongoing)
* Regions will receive the petitions for SSA designation, for- (+)
mally accept completed petitions, provide the technical ex-
pertise necessary to review these petitions, and review envi-
ronmental impact statements (EIS) of facilities within SSA
designated areas. (Ongoing) [SPMS]
* Regions will carry out the requirement for public comments on (+)
the petitions, including all public hearings. (Ongoing)
* Regions will act upon or send to HQ recommendations on desig- ( + )
nation generally within six months of petition acceptance.
(Ongoing) _
* HQ will review Regions' actions on petitions involving more ( + ) ^B
than one Region. (Ongoing)
* Regions will publish final determination in the Federal (+)
Register. (Ongoing)
**** ADDITIONAL GUIDANCE BASED ON CWA AMENDMENTS PERTAINING TO ****
NON-POINT SOURCE/GROUND-WATER WILL BE FORTHCOMING
B. Ground-Water Protection Strategy
The Ground-Water Protection Strategy centers around four main
areas of dctivity.
1 State Ground-Water Protection Activities - Priority Activities
Collaboration between the Federal and State governments is a prin-
cipal feature of the Ground-Water Protection Strategy. States
have the responsibility for the protection of ground-water re-
source. All states are expected to have developed/adopted a
state-wide ground-water protection strategy by the end of FY 1987.
* States will develop program and/or processes to implement (+)
their strategies. (Ongoing)
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* Regions will manage 106 grants to States, provide assistance
to States in the development of programs for their ground (-)
water protection strategies, and conduct seminars for the ex-
change of information on how States are solving specific pro-
blems. (Ongoing)
2. Sources of Ground-Water Contamination - Priority Activities
The Strategy calls for efforts to determine the extent of prob-
lems caused by ground-water contamination sources not covered
by Federal statutes and to provide assistance to States on appro-
priate responses.
* HQ will implement a ground-water monitoring strategy to (+)
provide a framework for crosscutting ground-water monitoring
issues and for commmon data sharing systems. (Ongoing)
* Regions and HQ will develop Technical Information Publications
(TIPs) on sources of ground-water contamination not covered (-)
by Federal regulations, such as agricultural chemicals.
(Ongoing)
3. Guidelines for Ground-Water Protection - Priority Activities
In FY 1987, EPA issued guidelines based on a three-tiered classi-
fication system taking into account the value and relative vul-
nerability of the resource.
* Regions will fully implement the ground-water classification (-)
guidelines and assist Regional programs and States in imple-
menting the guidelines. (Ongoing)
* Regions and HQ will work with States that have ground-water (-)
classification systems or other ground-water protection
systems to help achieve the equivalence of the State systems
to EPA's so that the State system can be applied To EPA
programs in lieu of EPA's approach. (Ongoing)
4. EPA Ground-Water Focus and Coordination - Priority Activities
EPA established ground-water offices in Headquarters and the
Regions. Using the strategy and other mechanisms EPA will
assure coordination among ground-water programs.
* Hu with Regional input will continue to develop and implement ( + )
indicators which measure the effectiveness of Agency efforts
in protecting the nation's ground water. (Ongoing)
* Regions will provide assistance to both RCRA and Superfund (-)
staffs in reviewing and establishing appropriate ground water
monitoring plans for specific permits or sites. (Ongoing)
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HQ will continue to work with other EPA offices to incorporate (-)
the guidelines into EPA regulations and policy statements in
order to improve the consistency in treatment of ground-water
across EPA programs. (Ongoing)
HQ will expand its efforts with other Federal agencies, e.g., ( + )
the USDA, on issues of common concern, such as pesticides and
fertilizers in ground water. (Ongoing)
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FY 1988 OSWER Operating Year Guidance
TABLE OF CONTENTS
TOPIC PAGE
I. Executive Summary 1
II. Program Guidance - Superfund 5
1. Introduction 5
2. Program Priorities 6
A. Stabilize Actual or Potential Threats 6
from Releases of Hazardous Substances
i. Increased Limits 6
ii. Removal/Remedial Program Consistency 7
iii. Alternatives to Land Disposal 7
iv. State-lead Removals 8
v. Contracting Strategy 8
vi. Administrative Orders for Immediate Removals 9
vii. Emergency Response Notification System 9
viii. Reportable Quantities 9
ix. Temporary Emergency Measures 10
x. Oil Spills 10
B. Ensure that Environmental Threats Posed by 10
Uncontrolled Hazardous Waste Sites are
Addressed Quickly and Effectively.
i. Cleanup Standards 10
ii. Alternative Treatment Technologies 11
iii. Delegations 12
iv. Streamlining the Process 12
v. Remedial Contracting Strategy 13
vi. Community Relations 13
vii. Information Management 14
viii. Revision of HRS 14
ix. Management Improvements 14
x. Response Claims 15
xi. Health Assessments/Toxicological Profiles 15
xii. Mandatory Schedules/NPL Listing 15
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C. Maintain a Strong Enforcement Program 16
i. Increase PRP Response through the Settle- 16
ment Process
ii. Increase PRP Response through Section 106 19
Administrative Orders
iii. Increase Recovery of Costs into 19
the Trust Fund
iv. Increase Imposition of Civil and Criminal 20
Penalties
v. Address Contractor Indemnification 21
through Regulatory Action
D. Facilitate Federal Facility Response Actions 21
E. Increase State Participation 22
3. Appendix - Key Supplemental Guidances/Regulations
III. Program Guidance - Chemical Emergency Preparedness 23
Program, Community Right to Know, and Prevention
1. Introduction 23
2. Program Priorities 23
A. Implement New Emergency Planning and Community 23
Right to Know Authorities
i. Roles 23
ii. Preparedness Priorities 24
iii. Prevention Priorities 24
3. Appendix - Key Supplemental Guidances/Regulations
IV. Program Guidance - Resource Conservation 26
and Recovery Act
1. Introduction 26
2. Program Priorities 27
A. Expedite and Improve Operating Permits 27
i. Meet Permitting Deadlines 27
ii. Permits for New and Expanded Treatment 27
Capacity
iii. Corrective Action 28
8. Close Facilities Threatening Human Health and 29
the Environment
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C. Develop Effective Regulations 29
i. Emphasize Development of Effective, 29
Enforceable Regulations
ii. Develop a Simplified System for the 30
Future
D. Monitor Compliance and Enforce Regulations 30
i. Inspections 31
ii. Enforcement Actions 31
E. State/Federal Partnership 32
F. Information Management Activities 32
3. Appendix - Key Supplemental Guidances/Regulations
V. Program Guidance - Underground Storage Tank 33
Program
1. Introduction 33
2. Program Priorities 36
A. Prevent and Reduce Groundwater Degradation 36
by Developing a National UST Program
B. Clean Up Leaking USTs By Implementing the 37
Federal LUST Trust Fund
3. Appendix - Key Supplemental Guidances/Regulations
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OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
I. EXECUTIVE SUMMARY
The Office of Solid Waste and Emergency Response (OSWER) Operating
Year Guidance for FY 1988 outlines the goals, objectives and
program priorities for implementation of the hazardous waste
programs. The guidance delineates those key activities associated
with the Resource Conservation and Recovery Act (RCRA) as amended
by the Hazardous and Solid Waste Amendments of 1984 (HSWA) and
the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) as amended by the Superfund Amendments and Reauth-
orization Act (SARA) of 1986. It is worth noting that the CERCLA
bill was awaiting passage at the time of publication of the FY
1987 Operating Year Guidance; therefore, the FY 1988 Operating
Year Guidance delineates the requirements of the new law in
substantial detail.
One of the Agency's priority activities, as identified in the
FY 1988 Agency Priority List, is the prevention of groundwater
contamination and reduction of other risks from hazardous waste.
This is also a main goal of the Office of Solid Waste and
Emergency Response. While our programs continue to evolve, due
to statutory requirements and implementation experience, our
major goals remain unchanged. The goals in the OSWER FY 1988
Operating Year Guidance are identical to those in FY 1987: reduce
risks to human health and the environment from improper past
disposal of hazardous wastes; ensure protection in the future;
use resources and expertise effectively; and institutionalize
effective management systems and delegate to Regions and States.
The FY 1987 OSWER Operating Year Guidance reflected the philosophy
of the new managers of our hazardous waste programs. The FY 1988
submittal builds upon those premises set forth and highlights
those activities deemed crucial to effective implementation of
programs. Those key objectives can be summarized as follows:
ฐ Meet Congressionally Mandated Deadlines
We now have the authority to implement several laws that stipulate
a wide variety of mandatory activities: RCRA, CERCLA and the
Emergency Planning and Community Right-to-Know Act (Title III of
SARA). In addition to stipulating deadlines, these laws have
given us expanded authorities to more effectively prevent, reduce
and clean up releases. This is particularly evident as we implement
the new Title III requirements, which are geared towards promoting
awareness of chemical hazards and development of State and local
preparedness programs. However, we have less discretion than in
the past to choose among programmatic activities since our actions
are driven mainly by statute. The range of mandatory activities
varies from promulgation of regulations to issuance of operating
permits to schedules for deciding whether to list sites on the
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National Priorities List. In order to plan a strategy geared
towards fulfillment of these statutory requirements, we must
efficiently use all resources and authorities, and delegate
whenever feasible.
ฐ Continue to Delegate Responsibilities to Regions, States and
Localities and Increase Citizen/Community Involvement
This shift in emphasis is one which has been occurring over
time, but has been enhanced by factors such as:
0 Adherence to statutory requirements, particularly those
under the new Superfund that mandate participation in
programmatic and enforcement activities by States, citizens
and communities
0 Promulgation of key regulations and guidance that will lead
to significant implementation efforts at the State level,
such as: the land disposal restrictions, small quantity
generators, Subtitle D revised criteria and retrofitting
surface impoundments
0 Development of statutorily-mandated programs that will
mainly be implemented/enforced at the State and local level,
such as the Underground Storage Tank and Leaking Under-
ground Storage Tank Programs and the Chemical Emergency
Preparedness Program. We have placed a high priority on
these programs since they reflect our goals of planning and
prevention, as well as our aim to correct past problems and
prohibit them in the future.
0 Understand the Fate and Transport of Hazardous Waste and
Lay the Foundation for an Integrated Technology Performance/
Risk-Based Program in the Future
We will continue our work with the Office of Research and
Development and other Headquarters offices in order to improve our
understanding of the overall hazardous waste system as it affects
all environmental media. This knowledge will be crucial in
order to determine optimum, cross-media solutions to environmental
problems. This research will also aid us as we evaluate and
address issues such as adequate capacity, pursuit of alternate
treatment technologies and encouragement of waste minimization.
We face a dilemma as we attempt to provide permanent remedies
and utilize a risk-based approach, while concurrently seeking to
move projects to completion and meet statutory deadlines.
0 Ensure Corrective Actions Through Increased Response by
Potentially Responsible Parties and Effective Compliance
Monitoring and Enforcement
We will aggressively address threats from uncontrolled waste
sites by increasing the PRP and State role in clean-up actions.
These increased efforts can be attributed, in part, to the
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new authorities delineated in the Superfund Amendments and
Reauthorization Act of 1986. While the amendments generally
codified existing enforcement and settlement practices, they
also provided some new tools for promoting PRP settlements. We
will attempt to increase PRP response through various mechanisms
such as encouraging "DeMinimus" settlements, use of non-binding
preliminary allocation of responsibility and mixed funding. We
will also continue to actively pursue cost recovery and Section
106 actions.
Similarly, we will utilize our RCRA authorities to address
facilities with immediate releases as well as ensure compliance
with requirements such as groundwater monitoring and closure/
post-closure. We will consistently enforce schedules of compliance
and issue orders to compel corrective action. The land disposal
restrictions program will also necessitate a strong enforcement
presence commencing in FY 1988, with the dioxin and solvent
containing waste ban, and continuing through the California
List, first third of listed wastes, etc. The Underground Storage
Tank enforcement program will be two-fold in FY 1988: Continuing
to enforce the interim prohibition and then enforce the new
requirements once effective. Clearly, OSWER programs will be
placing an increased emphasis on enforcement and compliance
monitoring in FY 1988.
0 Strive to Utilize OSWER and Agency Authorities Most Effectively
In Order to Achieve Environmental Results
The Office of Solid Waste and Emergency Response recognizes the
dynamic nature of its programs as well as the need to coordinate
within OSWER and between other Agency programs. Within OSWER,
we will attempt to utilize our RCRA and CERCLA authorities in
ways that are most optimal in given situations. As we strive to
effectively manage for environmental results, the best tools
should be used to complement each other when appropriate. During
FY 1988, as in FY 1987, several issues will be addressed with a
cross-OSWER focus, including:
0 RCRA/CERCLA compliance with the land disposal restrictions
program;
0 RCRA/CERCLA compliance with the CERCLA Off-site Policy;
0 Use of various corrective action authorities/procedures;
0 Use of RCRA/CERCLA authorities to address Federal
facilities; and
0 Listing of RCRA sites on the National Priorities List.
Further guidance on such activities can be found in OSWER documents
such as the FY 1988 RCRA Implementation Plan and the draft National
RCRA Corrective Action Strategy.
Similarly, OSWER will continue to work with other Agency offices
in order to develop and implement effective programs. Particular
attention will be given to the multi-media focus on groundwater
protection. Activities related to the protection of this resource
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will consider, where appropriate, the Agency's groundwater
protection policy and strategies. We will continue to work with
the Office of Water to place emphasis on integrating RCRA
permitting, corrective action and enforcement actions with
water program activities at POTWs treating hazardous waste.
Other cross-media efforts include Title III activities with the
Office of Pesticides and Toxic Substances, and air emissions
at TSDFs with the Office of Air and Radiation.
Lastly, we will increase emphasis on Federal facilities, ensuring
compliance with requirements of SARA and RCRA. We will assist
them with prioritization of work through the A-106 process and
through issuance of guidances/regulations. Similarly, as resources
permit, we will work with Tribal Governments. OSWER will also
continue to coordinate with other Federal agencies to address
complex environmental issues such as mixed waste and health
assessments.
The OSWER FY 1988 Operating Year Guidance outlines the priorities
of the Assistant Administrator and also reflects the related
Agency Priority List activities. We have divided the guidance
into the following sections for ease of reading: Superfund;
Chemical Emergency Preparedness; RCRA; and Underground Storage
Tanks. At the request of several Regions, we have included a
list of key supplemental regulations/guidances at the completion
of each section.
I
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II. SUPERFUND
1. Introduction
The basic authority under which the Agency addresses threats
from uncontrolled hazardous waste sites is the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA) as amended by the Superfund Amendments and Reauthori-
zation Act of 1986 (SARA). This guidance reflects current program
goals. The Superfund Comprehensive Accomplishments Plan (SCAP)
will also reflect program goals as it delineates projected Regional
activities. Program goals and policies will continue to evolve
as the Headquarters/Regional SARA implementation workgroups
complete their efforts.
The Superfund Program will continue to pursue five broad objectives
in FY 1988, each of which includes several priority activities:
A. Stabilize Actual or Potential Threats from Releases of
Hazardous Substances'
This will encompass response through removal actions, an area in
which we have been given increased authority for short-term
emergency clean-up actions. In addition, we will implement
regulations pertaining to reportable quantities and release
notifications, as well as continuing our responses to major oil
discharges.
B. Ensure that Environmental Threats Posed by Uncontrolled
Hazardous Waste Sites are Addressed Quickly and Effectively
The new Superfund amendments will be implemented, and major
activities will include: meeting clean-up standards and mandatory
schedules; considering treatment and permanent remedies; promulgating
contractor indemnification, State participation, citizen and
community involvement regulations; and using expanded removal
authorities and technical support capabilities. Lastly, we will
attempt to continue our emphasis on project management and project
completion, which has become more difficult as requirements have
increased.
C. Maintain a Strong Enforcement Program
Here we will seek to increase PRP response through use of new
and existing authorities and procedures. We will continue to
seek recovery of costs into the Trust Fund as well as attempting
to increase settlements.
D. Facilitate Federal Facility Response Actions
The amendments also confirmed that all Federal facility response
actions are applicable to CERCLA requirements. In addition, it
prescribed specific activities and processes for Federal facilities.
This will clearly require increased EPA coordination and oversight.
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E. Increase State Participation
The Superfund amendments enhance the State role in all phases
of response actions. We will see increased State participation
in areas such as selection of remedy and participation in PRP
negotiations.
2. Program Priorities
A. Stabilize Actual or Potential Threats from Releases of
Hazardous Substances
SARA articulates a number of changes for the removal program that
will result in broadened authorities and more extensive clean-ups
and responses to threats to public health and the environment
posed by releases from uncontrolled hazardous waste sites and
spills of hazardous substances and oil.
i. Increased Limits (-)
SARA increases the statutory limits on removal actions to $2
million and 12 months. SARA also provides for an additional
waiver of the statutory limits which allows removal actions to
continue beyond $2 million and 12 months, if the response action
is "otherwise appropriate and consistent with the remedial action
to be taken." The removal program will use the higher limits and
new waiver to:
1) Address larger contamination problems at NPL and non-NPL
sites where appropriate;
2) Design more efficient removal actions, particularly at
NPL sites; and
3) Facilitate the use of alternative technologies to achieve
more permanent solutions.
Regional Administrators will be delegated the authority to approve
removal actions costing up to $2 million. The delegation applies
to both NPL and non-NPL sites, except for any non-NPL removal
action that involves an issue which is precedent-setting or could
expand the current scope of response under CERCLA. These removal
actions will require OSWER concurrence. Examples include: certain
sites involving bays or estuaries; mining sites; dioxin contamin-
ation; radon in homes; pesticides in groundwater; and hazardous
substances in building materials.
OSWER approval is required if removal actions continue beyond the
$2 million statutory limit and if the $2 million limit is exceeded
due to a finding of continued emergency. Legal determinations
of the three statutory emergency criteria must be approved in
EPA Headquarters for both NPL and non-NPL sites. Statutory
exemptions for removal actions to continue beyond the $2 million
limit at NPL or proposed NPL sites may be delegated to the Regions
on a site-by-site basis. Only the first operable unit at the
NPL or proposed NPL site is considered for continued removal
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action under this new exemption criterion.
ii. Removal/Remedial Program Consistency (-)
As in the past, the removal program will strive to ensure that
removal actions are consistent with future remedial actions at
those sites where additional clean-up measures are required. SARA
formalizes this practice by stating that removal actions must
"contribute to the efficient performance of any long-term remedial
action" to the extent practicable.
In an important new initiative, the Agency will be conducting
"Expedited Response Actions" (ERAs) at selected clean-up sites
to encourage efficient coordination of removal and remedial
resources. Under this concept, the program may conduct short-term
response work under removal authority using services available
through remedial contractors, the U.S. Army Corps of Engineers, or
other contract support. This arrangement may result in savings
of both time and cost at sites where prompt action is essential,
the appropriate remedy is clear and obvious, and clean-up is
expected to lead to deletion or a determination that no further
action is needed. Guidance on the conduct of ERAS will be issued
during FY 1987.
The removal program will continue to work on implementation of
the compliance policy, which requires removal actions to attain
or exceed applicable or relevant and appropriate Federal public
health and environmental requirements to the greatest extent
practicable considering the exigencies of the situation. Other
Federal guidelines and State standards will also be considered
where appropriate.
iii. Alternatives to Land Disposal (-)
The removal program will focus on the use of alternatives to
land disposal through adherence to the CERCLA Off-site Policy
and Office of Emergency and Remedial Response (OERR) Alternative
Technology Guidance, which strongly encourages a preference for
alternative technologies over land disposal. The removal program
will also comply with the land disposal restrictions program.
The transition to alternative treatment and disposal technologies
will parallel the framework of the RCRA amendments, which call
for an evaluation of alternatives to land disposal.
The Regions, in conjunction with other Agency programs, will
perform an analysis of disposal options which includes
consideration of the following factors:
1) The time-critical nature of the response;
2) The degree to which the options attain or exceed applicable
or relevant and appropriate Federal public health and
environmental requirements;
3) Engineering reliability/feasibility;
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4) Cost;
5) Administrative/managerial feasibility; and
6) Environmental impacts.
Funding for the demonstration of alternative technologies
may be provided under CERCLA 104(b) authorities, which
allow the Agency to undertake "such planning, legal, fiscal,
economic, engineering, architectural, and other studies or
investigations" as it deems necessary to plan and direct
response actions. Costs associated with the use of 104(b)
authority do not count against the statutory limit and may
be incurred by either the removal or remedial program.
iv. State-lead Removals
We will address the implementation of State-lead, non-time-
critical removals at NPL sites through Multi-site Cooperative
Agreements. By this mechanism, States may participate in the
removal program and receive funding for actions that EPA would
have otherwise undertaken. This would enable States to assist
in stabilizing NPL sites prior to the initiation of remedial
action.
v. Contracting Strategy (+)
In order to accomplish the expanded removal goals established
by SARA, a diversified contracting strategy will be implemented.
The four zone Emergency Response Clean-up Services (ERGS) will
be separated into seven zones to provide quick turnaround emergency
response support in a nationwide network of contractors. In
addition, up to nineteen Region-specific contracts will be procured
to provide services where a longer response time is allowed.
Further, several site-specific contracts will be procured in
instances where the immediate threat can be stabilized for an
amount of time sufficient to pursue a competitive contract (nine
months).
The program anticipates that this diversified approach will
enhance competition and could lead to as many as 37 contracts
supporting the removal cleanup effort. These cleanup contracts
will support Superfund removal cleanups and a minimal cleanup
program for leaking underground storage tanks as provided for in
the new RCRA Subtitle I LUST Trust Fund.
In addition, two technical assistance contracts will provide
support nationwide to the removal clean-up effort. These Technical
Assistance Team contracts will assist EPA removal program field
personnel in: investigatory activities; oversight of clean-up
contractors; oversight of responsible party removal clean-up
efforts; cost tracking; training of State and local responders;
oil spill prevention inspections; engineering and design support;
and any other areas needing special analytical or technical
expertise.
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vi. Administrative Orders for Immediate Removals
Removals for the purpose of site stabilization or for response
to emergencies may be fund-financed or conducted by responsible
parties. The Regions should contact Potentially Responsible
Parties (PRPs) and consider whether private party response is
appropriate, in lieu of fund-financed response. The Agency will
issue administrative orders in appropriate circumstances before
initiating fund action, as long as the site does not pose an
unreasonable risk of harm to the public health/ welfare or the
environment. But in order to issue a Section 106 order, we need
to make the determination that the site may pose an imminent and
substantial endangerment.
The Regions should consider issuing administrative orders in
situations where there is at least one week between the time
that the OSC determines that a removal action is warranted and
the time that actual on-site response must begin. In the event
of non-compliance with an administrative order, the Region should
be prepared to quickly initiate a fund-financed response and
seek fines or treble damages from the responsible parties.
Further detail is provided in the policy entitled, "Issuance of
Administrative Orders for Immediate Removal Actions,"
February 21, 1984.
vii. Emergency Response Notification System (-)
In FY 1986 and FY 1987, the Office of Solid Waste and Emergency
Response has initiated for Headquarters and the Regions PHASE I
of a national Emergency Response Notification System (ERNS) for
collection of data on releases of oil and hazardous substances.
Release notification information is being documentated by all EPA
Regions on a standardized incident report form containing 87 common
data elements. This data is transmitted either electronically
or in hard copy form to the National Response Center (NRC) database
located at the Transportation Systems Center (TSC) in Cambridge,
MA. During FY 1987, all Regions will be provided with an IBM/AT
computer, which will enable them to capture incident notification
data, transmit the data electronically to the TSC, and generate
their own analyses and management reports. Analyses and reporting
on a national basis will be done at Headquarters using the entire
NRC data base. During FY 1987, OSWER will pursue development of
PHASE II of the project where information contained in the initial
report will be verified and response data will be included in
conjunction with the CERCLIS data system.
viii. Reportable Quantities (-)
The Office of Solid Waste and Emergency Response will develop
final reportable quantities (RQs) for potential carcinogens and
radionuclides, and will propose new listings promulgated by the
media programs directly affecting the CERCLA section 101(14)
hazardous substance list. In addition, the Office of Emergency
and Remedial Response will propose RQs for the approximately 250
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new extremely hazardous substance listings which are not currently
on the CERCLA section 101(14) hazardous substance list. OSWER will
also finalize the continuous release reduced reporting regulation as
well as the federally permitted release interpretive rule. All RQ
adjustments have a statutory deadline for promulgation by April 1988.
SARA adds new civil penalties and increases existing criminal
penalties for failure to notify the NRC of releases equal to
or in excess of the reportable quantities. Releases equal to or
exceeding an RQ which are not properly and promptly reported may
be subject to administrative penalties. Criminal penalties will
be applied in cases where the failure to report is willful and
egregious or results in, or threatens, significant environmental
contamination or a hazard to human health.
ix. Temporary Emergency Measures (+)
OSWER will also promulgate regulations under Section 123 of SARA
on the reimbursement to local governments of expenses for carrying
out temporary emergency measures to prevent/mitigate injury to
health or the environment associated with the release or threatened
release of a hazardous substance. Reimbursement is to be limited
to $25,000 per response action and is restricted to actions that
would not normally or routinely be performed by the local juris-
diction. SARA requires these regulations to be promulgated no
later than one year from the date of enactment.
x. Oil Spills (-)
Regions should maintain their present level of on-scene response
to major oil spills as defined in the National Contingency Plan.
Further, the Regions should continue to provide on-scene oversight
of private party clean-ups of major oil spills. Where States or
local governments are known to have the capability and commitment
to respond to spills, including major discharges, they should be
encouraged to the maximum extent possible to provide response.
Technical assistance should be provided to the U.S. Coast Guard in
coastal oil spills when the Coast Guard specifically requests it
or when the RRT is activated.
Spill Prevention Countermeasure and Control (SPCC) activities should
be conducted only as resources permit. In some situations, it may
be possible to perform SPCC functions in conjunction with spill
response activities. Each Region should review and update its
strategy for SPCC inspections and plan reviews for the coming year.
B. Ensure that Environmental Threats Posed by Uncontrolled^
Hazardous Waste Sites are Addressed Quickly and Effectively
i. Clean-up Standards (+)
Several efforts are underway to develop implementation guidelines
for Section 121, the clean-up standards section of SARA, including
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workgroups and guidance development which will address needed
changes to Remedial Investigation/Feasibility Studies (RI/FS),
Records of Decision and considerations related to soil clean-ups,
and compliance with the applicable or relevant and appropriate
requirements of other Federal and State environmental statutes.
The Section 121 standards apply equally to Fund-financed remedial
actions taken under Section 104 and private party response
actions taken under Section 106.
ii. Alternative Treatment Technologies. (-)
During FY 1988 the Agency will aggressively implement the results
of several efforts directed towards increasing the use of alter-
native treatment technologies, particularly in removal and remedial
activities. These technologies will continue to be used to imple-
ment the Hazardous and Solid Waste Amendments directives on
reducing land disposal of wastes. Demonstrations of alternative
technologies at Superfund sites will be a priority activity. FY
1987 will see the increased availability of alternative treatment
technology studies and reports, treatment capacity studies,
and other technology transfer studies.
SARA also calls for the use of permanent solutions and treatment
technologies or resource recovery to the maximum extent practicable
in carrying out remedial actions. This new emphasis will involve
more frequent use of treatability testing and technology demon-
stration during the remedial process. The Regions should actively
support and help implement the OSWER/Office of Research and Develop-
ment (ORD) hazardous waste Technology Transfer Task Force strategy,
and the OSWER/ORD SITEs Program. Superfund will build on experience
gathered in the SITE program and will continue to use removals as
opportunities for applying new treatment technologies and techniques.
Guidance will be developed and the National Contingency Plan will
be revised to assist Regions in satisfying the preference for
treatment technologies. Ongoing RI/FSs will be modified to
ensure that at least one treatment alternative is analyzed in
detail and discussed in the Record of Decision. New RI/FSs will
examine a range of treatment alternatives. Treatment will be
the principal element of most final source control remedies.
The Regions should use the expertise of the Emergency Response
Team (ERT) when considering the use of innovative technology for
removal and remedial site activities. The ERT will provide
preliminary design, site lay-out, set-up support, operational
oversight, engineering evaluation and analytic support. ERT
will also expand its training, technical support and information
services programs.
In FY 1988, analytical support for Superfund will be affected by
two factors: 1) need for flexibility to be able to respond to
changing program requirements; and 2) provision of additional
support systems to the Regions. There will be continuing emphasis
on maintaining adequate capacity to meet program needs, minimizing
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turnaround times, and improving data quality. The Agency will
consider an emphasis on short-term field labs handled through the
on-site contractor. Expanded and decentralized analytic support
will be provided to the Regions, via ESAT contracts and access to
SMO information systems, to meet the growing and changing require-
ments of both RCRA and CERCLA. These resources will supplement
the analytic services available through the Regional Environmental
Services Divisions (ESDs), Contract Laboratory Program and other
technical support contracts.
iii. Delegations (-)
The Regions will continue to be delegated decision authority for
actions that do not: 1) Set major national precedents; or 2) Involve
fund-balancing or public interest exceptions. However, some level
of consultation for remedy selection will be requested during the
early phases of implementing SARA.
Each Region is responsible for reviewing the clean-up status of
its NPL sites and initiating technical reviews for those that
meet the criteria for deletion from the NPL. OSWER has initiated
a Green Border review of the delegation of authority to Regional
Administrators for publishing Notices of Intent to Delete in the
Federal Register. Total delegation of deletion authority is
anticipated in early FY 1988.
iv. Streamlining the Process (-)
During FY 1988, Regions will continue to attempt to streamline
the remedial process by implementing management initiatives
identified in FY 1986 and FY 1987. Overall emphasis in the
program will continue to shift from initiation activity to site
completions which meet SARA requirements. It is clear that many
of the new requirements will hinder our goal of "speeding up the
process."
One OSWER initiative is the Expanded Site Inspection, which provides
the Regions with additional sampling data at an earlier stage of the
remedial planning process in order to improve site characterization
prior to the expenditure of significant resources. This will also
provide a better basis for the planning and implementation of remedial
investigations. Headquarters has developed revised contractor work
assignment procedures to facilitate the implementation of phased
RI/FS to take advantage of alternative analytical capabilities.
In addition, Regions will be given additional staffing authority
to improve the management of both remedial and removal contracts.
In funct .ons related to contract administration, Regions will
seek to balance the use of program resources with those available
to other Regional management units. Another significant initiative
involves the implementation of the "Project Management Concept."
This will improve technical consistency and accountability by
assigning responsibility for all actions at a given site to a
single contractor/firm. Other initiatives include the performance
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of the aforementioned expedited response actions (ERAs) and dele-
gation of additional responsibilities to Regional project officers.
v. Remedial Contracting Strategy
During FY 1988, the remedial program will begin full implementation
of the Alternative Remedial Contracts Strategy (ARCS). A key
component of the new strategy will be the incentives for superior
performance. Similar to the current REM contracts, the new
contracts will have an award fee component to allow Regions to
balance the fee on individual projects based on site-specific
performance. However, in addition to the award fee, a major new
incentive provision will be included. Specifically, a firm's
ability to become eligible for additional work through the execu-
tion of options for additional LOE hours will be closely tied to
their performance on ongoing projects.
The initial contract, which will provide support to Regions III and
V, should be awarded during the first and second quarters of FY
1988. At this time, we envision awarding a minimum of three
contracts for Region III, and four contracts for Region V. Con-
tractors will work primarily in the assigned Region with limited
flexibility to support other Regions on an exception basis. The
scope and size of the contracts and the technical evaluation
criteria will be designed to ensure a broad spectrum of competition
from both large and small firms. The Regions will handle both
the contract officer and project officer responsibilities for
these contracts.
In addition to the ARCS concept, the Regions will continue to per-
form the award fee determinations for the REM contracts consistent
with national and Regional protocols established during FY 1987.
vi. Community Relations
Experience to date has reinforced the importance of two-way
communications based on informal, personal contact with Regional
project officers and site residents. In FY 1988, the Regions
will continue to expand their community relations activities, in
terms of "risk" discussions, as well as conducting more community
relations activities in the early and late phases of the remedial
process. Guidance will be developed on making presentations to
the public on site clean-up alternatives.
The Regions will continue to implement the basic community relations
program. SARA now mandates several activities that in the past
were carried out as a matter of policy, including public meetings
and public notification on the feasibility study. In addition,
EPA Headquarters will continue production of generic fact sheets (on
subjects such as clean-up alternatives) and provide training in
such areas as risk communication, facilitation, and community
relations skills. Regions will focus on site-specific fact
sheets. Responsiveness summaries will continue to play a major
role in feedback to the public on their reactions to site remedies.
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Th e greatest change in the community relations program will be
the provision of technical assistance grants to communities
located near NPL sites. The purpose of the grants is to help
the public interpret information on possible site hazards,
technical decision documents and response actions at a specific
facility. Headquarters, together with the Regions, will develop
and issue grant regulations during FY 1987.
vii. Information Management (-)
Given the increased number of sites with ongoing removal and
remedial activity, we will be placing greater emphasis on site-
specific management. In FY 1988, Regions will have full respon-
sibility and accountability for maintenance of most national
data. Regions should use the information management infrastructure
that they built during FY 1987 to collect and enter data, ensure
data quality and otherwise maintain and support the national
CERCLIS system as it will serve as the medium for most Superfund
program reporting and evaluation.
Also, the Regions should be using the variety of available auto-
mated tools available through CERCLIS, the PC's and the Prime
minicomputer. These tools were developed as part of the Superfund
Management Advisory Committee's ADP system enhancement activities.
viii. Revision of Hazard Ranking System (+)
In FY 1988, OSWER intends to promulgate revisions to the Hazard
Ranking System (HRS), which is utilized to rank potential cand-
idates for the National Priorities List. The revision of the
HRS will necessitate training for Regional and State personnel.
OSWER will issue guidance on the revised HRS and revised data
collection requirements for site inspections.
ix. Management Improvements (-)
The use of Data Quality Objectives (DQOs) will help ensure that
the program is collecting data of sufficient quantity and quality
to support decisions on clean-up. These guidelines will also
help to reduce the cost and duration of remedial work.
Regions will continue to place emphasis on program reviews of
States having lead responsibility under single or multi-site
Cooperative Agreements. Under the Management Assistance Program
(MAP), Regions will review State compliance with the terms and
requirements of cooperative agreements and will provide appropriate
training to the States.
It is an OSWER priority to enhance its workforce through various
approaches such as individual development plans, training and
rotations. The Office of Solid Waste and Emergency Response
will continue to implement the "Office of Solid Waste and Emer-
gency Response Training Strategy" in FY 1988.
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Functional curricula such as the OSC/RPM curriculum will be
utilized to increase the programmatic and technical capabilities
of on-scene coordinator's (OSC's) and remedial project managers
(RPM's). Such efforts will continue to be geared toward pro-
fessional development of EPA and State staffs as well as in
improving our overall effectiveness.
x. Response Claims (-)
During FY 1987, we will be promulgating regulations governing
response claims by private parties. The rulemaking will establish
procedures and criteria for prior authorization of private party
response at NPL sites.
xi. Health Assessments/Toxicoloqical Profiles (-)
Under SARA, a health assessment must be completed at every site
on the NPL (including RCRA sites) according to schedules prescribed
in the act. OSWER has jointly developed a procedures manual with
the Agency for Toxic Substances and Disease Registry (ATSDR) to
facilitate the completion of these assessments. Topics to be
covered in the manual include: 1) overview of the remedial process;
2) the scope of ATSDR's health assessment activities; 3) prior-
itization of sites; and 4) the coordination process between EPA
and ATSDR. While ATSDR will assess the risk to public health
from existing exposure, EPA will continue to perform the broader
public health evaluation and endangerment assessments associated
with selecting the remedial approach.
In addition, OSWER will continue to work with the Office of
Pesticides and Toxic Substances to develop and utilize the
toxicological profiles as required under SARA.
xii. Mandatory Schedules/NPL Listing (-)
Regions will continue to conduct preliminary assessments and site
inspections in accordance with mandated schedules and citizen
petitions. By January 1, 1988, every site in CERCLIS, as of
October 17, 1986, must have a completed preliminary assessment
and a decision must be made as to whether the site requires a
site inspection or whether no further action is needed at the
site. OSWER plans to meet this deadline, as well as the deadlines
for site inspections, RI/FS starts, and remedial action starts.
OSWER will continue to issue policy and process guidance to
Regions to assist in the NPL candidate evaluation and rulemaking
process. In FY 1987, OSWER will develop and disseminate the
first annual SARA publication which will be comprised of a
national list of completed removal actions at NPL and non-NPL
sites. This publication will serve as a vehicle to provide
greater visability to Superfund accomplishments.
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* C. Maintain a Strong Enforcement Program
Both the original Superfund law and the 1986 amendments place an
important emphasis on a strong enforcement program. During
FY 1988, OSWER will attempt to increase potentially responsible
party response through use of Section 122 settlement procedures
and Section 106 administrative orders as well as to increase
cost recovery efforts and impose civil and criminal penalties
where appropriate while the 1986 Superfund amendments do provide
some important new authorities for ensuring private party clean-upf
the amendments generally codify existing enforcement activities.
The following discussion highlights the activities that will
be undertaken and the tools that will be used:
* i. Increase PRP Response Through the Settlement Process
A fundamental goal of the Superfund enforcement program is to
encourage PRPs to enter into negotiations and to reach settle-
ments with EPA for conducting response actions. All of the
activities discussed below (except non-binding preliminary of
allocation agreements) are ongoing activities conducted pursuant
to the original Superfund law or existing program policy. However,
many of these activities or tools have been modified in various
ways by the 1986 amendments. EPA plans to create incentives for
encouraging PRPs to enter into settlements for conducting
response actions in the following ways:
PRP Searches (-)
SARA emphasizes the importance of reaching negotiated settlements
with PRPs. To facilitate an overall effort to reach such settle-
ments, EPA plans to enhance existing efforts to identify responsible
parties and to identify such parties earlier in the enforcement
process, preferably before the site is listed on the NPL. EPA
also plans to utilize the new authority in SARA to hire civil
investigators to conduct PRP searches. To ensure negotiations are
conducted in a timely fashion, PRP searches should be undertaken
thoroughly and early in the enforcement process.
Notice Letters, Information Exchange, and Subpoenas (-)
SARA provides for procedures which modify our current EPA policy
and procedures relating to notifying PRPs of their potential
liability and exchanging information about a site with PRPs.
The Superfund amendments authorize EPA to issue "special notices"
for informing PRPs of their potential liability and for requesting
and providing information when such procedures will facilitate
negotiations. Such notices are followed by a moratorium on
certain EPA actions for a specified period of time. The amendments
also authorize EPA to issue subpoenas to obtain information
when PRPs do not promptly respond to information requests.
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SARA provides for an increased emphasis on the use of "special
notices" and on information exchanges with PRPs to facilitate
the settlement process. EPA plans to utilize SARA's "special
notice" procedures in most cases and to exchange infor-
mation with PRPs early in the process.
EPA efforts will include greater emphasis on identifying and
notifying a greater number of PRPs and providing such PRPs with
as much relevant information as possible. Relevant information
will include the names and addresses of other PRPs/ the volume
and nature of substances contributed by each PRP, and ranking by
volume of substances at facilities when this information is
available.
In addition, EPA plans to aggressively utilize the new subpoena
authority where appropriate to ensure information exchange
necessary to facilitate settlements.
PRP Conduct of Remedial Investigation/Feasibility Study (-)
SARA enhances existing Agency policy and authorities established
under the original law which allowed PRPs to conduct the RI/FS.
The Superfund amendments clarify that PRPs are authorized to
conduct response actions (including RI/FS) and allow EPA to
provide PRPs with an opportunity to conduct the RI/FS. EPA will
place particular emphasis on encouraging PRPs to undertake the
RI/FS.
The use of special notices early in the process would trigger
the moratorium on EPA initiation of the RI/FS and should give
PRPs a realistic opportunity to assume responsibility for
conducting RI/FS. In addition, the amendments require EPA
oversight of the PRP's RI/FS. Revisions to the Agency's RI/FS
oversight guidance is expected in FY 1987 and will provide for
consistently applied oversight of such work. This guidance
will include a discussion of when to utilize the civil penalty
authorities under SARA for noncompliance with any order, decree,
or settlement agreement, including agreements with PRPs for
conducting RI/FS.
PRP Conduct of Re me d i a1 De s i qn/Re me d i a 1 Ac t ion (-)
Similar to the discussion above, SARA also enhances existing
Agency policy which allowed PRPs to conduct RD/RAs. EPA
plans to increase efforts to encourage PRPs to enter into
negotiations and reach settlement agreements for conducting
RD/RAs. An increased number of PRP-conducted remedial designs
and remedial actions is expected during FY 1988. PRPs are being
encouraged to begin discussions on RD/RAs during the feasibility
study. In addition, use of the "special notice" procedures
will trigger the moratorium on EPA conduct of such actions,
thereby providing a discrete timeframe for the PRPs to submit
a proposal for undertaking or financing RD/RAs.
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Non-bindinq Preliminary Allocation of Responsibility. (+)
SARA provides new authority not contained in the original law
relating to the development of non-binding preliminary allocation
of responsibility among PRPs. The Superfund amendments authorize
the President to use NBARs if they would facilitate settlements
and require the President to develop guidelines for such NBARs.
EPA plans to develop guidelines for and use NBARs to facilitate
allocation of responsibility among PRPs where appropriate.
It is anticipated that pilot NBARs will be developed in FY 1987
and guidelines for using NBARs will be in place by FY 1988.
NBARs will be used at sites where PRPs express an interest in
using such NBARs, where there are many PRPs, and where it is
believed NBARs will facilitate settlements.
"DeMinimis" Settlements
SARA modifies existing procedures for reaching "De Minimis"
settlement with certain PRPs. The Superfund amendments authorize
EPA to expeditiously reach final settlements with PRPs if the
settlement involves a minor portion of the response costs and
the waste sent to the site by the PRP is minimal in comparison
to other hazardous substances at the facility. In addition,
settlements may also be entered into with landowner PRPs if
the landowner did not conduct or permit the disposal, did not
contribute to the release, and did not buy the property with
actual or constructive knowledge that the property was used
for waste disposal. The statute authorizes such settlements to
be entered into as administrative orders or consent decrees.
EPA will continue to encourage the use of "De Minimis" settlements
where appropriate. Currently there are several "De Minimis" pilot
projects underway and Agency-wide guidance should be in olace by
FY 1988.
Releases From Liability/Covenants Not to Sue (-)
SARA modifies existing Agency policy relating to entering into
covenants not to sue with PRPs. The Superfund amendments author-
ize EPA to provide PRPs, in certain circumstances, with covenants
not to sue for liability under CERCLA (including future liability).
This provision generally adopts EPA guidance set forth in the
Interim CERCLA Settlement Policy and could be an important tool
in encouraging PRPs to conduct permanent remedies that fully
meet the clean-up standard requirements of the Superfund amendments
Covenants not to sue have been entered into in the past based
upon the guidance set forth in the settlement policy.
EPA plans to continue entering into covenants not to sue where
appropriate to facilitate the overall goal of maintaining an
effective enforcement program. During FY 1987, EPA will be
amending the interim settlement policy, including the provision
relating to covenants not to sue. Guidance should be fully
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III. CHEMICAL EMERGENCY PREPAREDNESS PROGRAM, COMMUNITY RIGHT
TO KNOW, AND PREVENTION
1. Introduction
FY 1988 will be the third year of the Chemical Emergency Pre-
paredness Program (CEPP) which was announced in June 1985 as
part of the Agency's Air Toxics Strategy. The overall program
goals are to promote community awareness of chemical hazards and
assist in the development of State and local preparedness programs
and response capabilities. In FY 1986 and FY 1987 the program
objectives were: to develop the list of extremely hazardous
substances and accompanying guidance; build program infrastructure
at the Federal, State, and local levels; begin program imple-
mentation; and establish data bases to better understand the
causes of chemical accidents. In FY 1987 CEPP Implementation
was enhanced by the new reguirements of Title III of SARA (October,
1986): a State and local emergency planning structure, and
industry reporting reguirements (community right to know) and
participation in the planning process.
2. Program Priorities
A. Implement NewEmergencyPlanning and Community Right To (+)
Know Authorities
In FY 1988, the Regions, coordinating through RRTs, will accelerate
program assistance to States and through States to communities
to meet the emergency planning and community right to know require-
ments of Title III. Further, in FY 1988, the program will continue
its two pronged approach to prevent chemical accidents, i.e.
gathering information on causes of accidents and ways to prevent
them, and influencing professional organizations and private
industry to begin initiatives in these areas.
i. Roles
The role of EPA Headquarters is to provide overall coordination
of program development and implementation and provide additional
guidance, program oversight and assessment and support to Regional
Offices. In particular, Headquarters will coordinate Federal
training and technical assistance resources to Regions. Federal
interagency coordination at the national level will take place
primarily through the National Response Team and directly with
key agencies such as U.S. Coast Guard, FEMA and OSHA. OSWER
will coordinate closely with the Office of Pesticides and Toxic
Substances which has the lead for Section 313 of Title III
(Emissions Inventory) and trade secrets Section 322. This office
also provides technical support to OSWER on other Title III
activities.
EPA Regions will be responsible for overall preparedness and
prevention program implementation within their Region. Regions
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-24-
will provide active assistance to States in implementation
of their Title III responsibilities, working closely with
the State Emergency Response Commissions established under Section
301. In this role, Regional staff will provide training and
technical assistance to States and through States to local
personnel and assess program implementation. The Regional
Response Team (RRT) will provide the primary forum for coordin-
ating activities in the Regions, particularly in the area of
training and technical assistance. As with Headquarters, Regional
staff will ensure close coordination with key agencies such as
Coast Guard, FEMA and OSHA. EPA RRT Co-chairs will work with
their Coast Guard Co-chair and member agencies to build RRT
preparedness capabilities to implement the NRT/RRT preparedness
initiative through RRT workplans and to manage the additional
RRT preparedness resources provided to key Federal Agencies
through the interagency budget.
Title III mandates major State and local responsibilities for
preparedness and community right-to-know. State and local
implementation is critical to program effectiveness. The State
role is to provide program leadership in the State, to ensure
the development of the emergency planning structure and imple-
mentation of State and local Title III responsibilities, and to
provide training and technical assistance to communities. The
local government role is to take the lead in carrying out community
right-to-know, emergency planning, preparedness and response
functions.
ii. Preparedness Priorities (-)
Preparedness efforts will build upon the CEPP with the new
authorities and requirements of Title III. Program priority
will continue to build State program leadership and focus
joint Federal/State assistance in priority areas designated
in CEPP State implementation memoranda. Emphasis will be
on assisting States in meeting Title III deadlines, assisting
States and communities in managing community right-to-know
information and on simulations and exercises to evaluate con-
tingency plans, preparedness, and response operations. Regions
will continue to coordinate preparedness activities with the
RRTs.
iii. Prevention Priorities ( + )
In FY 1988, the Accidental Release Information Program will
continue to gather information from facilities which have had
frequent and/or large chemical releases or releases with major
public health or environmental impact. The purpose of this
activity is not only to increase our knowledge but. to focus
corporate management attention on prevention of potential
problems. In addition, Headquarters and the Regions will
conduct a limited number of chemical process safety audits,
often jointly with OSHA, NRC, other Federal agencies and the
States. A primary focus of this activity will be to train
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implemented by FY 1988.
Mixed Funding (-)
SARA provides explicit authority that allows mixed funding at
Superfund sites; this modified existing procedures for such
settlements. Mixed funding refers to situations where both the
fund and PRPs pay for a portion of total costs of response at
a Superfund site. The Agency's Interim CERCLA Settlement Policy
authorized mixed funding, but the Agency has not yet issued
separate guidance.
EPA will continue to provide mixed funding where appropriate,
especially in cases where settling parties agree to perform the
clean-up and where there are financially viable recalcitrants to
pursue. Guidance will be issued on circumstances where mixed
funding is appropriate. Procedures for providing such funding
in FY 1987 will also be issued.
ii. Increase PRP Response through Section 106 Administrative
Orders
Another tool for ensuring private party clean-up is the use of
administrative orders authorized under Section 106 of CERCLA.
Under the original Superfund law, the Agency is authorized to
issue administrative orders to require PRPs to conduct response
actions. This basic tool has not been altered by the 1986
amendments. As under current policy, the Agency plans to continue
issuing administrative orders when negotiations with PRPs for a
voluntary settlement fails to produce a workable agreement.
During FY 1988, the use of administrative orders will continue
to be an important method for assuring private party cleanup for
both removal and remedial actions. In addition, administrative
orders at sites which will not be the subject of further fund-
financed clean-up are the highest priority for referrals for
injunctive relief.
iii. Increase Recovery of Costs into the Trust Fund
An essential component of an effective enforcement program is
the ability to recover costs of conducting response actions from
PRPs when fund money has been used under Section 104 of CERCLA
to conduct such responses. An effective cost recovery program
not only helps to preserve adequate fund resources for those
sites where PRPs are truly unknown or unable to pay, but it is
also an important tool for providing an incentive for PRPs to
conduct their own actions in the first instance. The ongoing
cost recovery efforts will be enhanced by the following
provisions contained in the 1986 amendments.
Cost Recovery Settlements (+ )
EPA plans to develop and utilize procedures for settling cost
recovery cases administratively. The Superfund amendments
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authorize Federal agencies, including EPA, to settle claims
for cost recovery under Section 107 of CERCLA if the claim is
less then $500,000 and has not been referred to the Department
of Justice. In addition, Federal agencies can settle such claims
that are greater than $500,000 with concurrence from DOJ.
The Agency will focus its efforts on both administrative and
civil action cost recoveries. EPA is in the process of devel-
oping and will use special procedures for settling such claims
administratively, including procedures for obtaining DOJ concur-
rence on claims greater than $500,000. The Agency plans to
continue the general policy of initiating cost recovery actions
for removals within one year of completion and for remedial
actions within 18 months of signing the Record of Decision. In
addition, the Superfund amendments permit the use of arbitration
to settle these cases and we expect such regulations to be prom-
ulgated by FY 1988.
Use of administrative procedures for settling cost recovery
claims together with an aggressive civil action program will
result in increased cost recoveries into the fund.
Administrative Record (+)
The Superfund amendments require the Agency to establish an
administrative record as the basis for selecting a response
action. We are also required to develop procedures and promul-
gate regulations for developing the record. Judicial review of
the adequacy of response actions is generally limited to the
administrative record. The courts are required to uphold EPA's
remedy decision unless the objecting party can demonstrate,
based on the administrative record, that EPA's decision was
arbitrary and capricious or not in accordance with the law.
The Agency expects interim guidance to be in place during FY
1987 and anticipates promulgating final regulations for devel-
oping an administrative record during FY 1988. The development
and maintenance of administrative records for response actions
is a high priority. The regulations will ensure that proper
administrative records are developed. A proper administrative
record is important in ensuring that the Agency is able to defend
its decisions regarding remedy selection and in allowing the
Agency to recover the full costs of such actions from responsible
parties.
iv. Increase Imposition of Civil and Criminal Penalties (-)
EPA plans to increase the use of civil and criminal penalties
where appropriate. The amendments authorize increased penalties
for civil and criminal violations of CERCLA and provide new
authority to assess civil penalties administratively. These
penalties are authorized for various violations of CERCLA including
failure to provide notice of releases under Section 103, failure
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APPENDIX
OERR KEY SUPPLEMENTAL REGULATIONS/GUIDANCE
Document
National Contingency Plan
HRS Revision
State Involvement
Local Reimbursements
RQs for Radionuclides
RQs for Carcinogens
RQs for Extremely Hazardous Substances
(non-carcinogens)t
RQs for Extremely Hazardous Substances
(carcinogens and chronic)t
Response Claims
Technical Assistance Grants
Natural Resources Damage Claims/
Arbitration Procedures
OSHA Worker Protection Regulations
BOAT Soil and Debris Regulations
(HSWA/Land Ban)
Internal Delegations
Section lll(o) Procedures
(Notify State/Localities on Claims)
Expected Publication (Final)
4/17/88
4/17/88
4/17/88
9/25/87 (Interim Final)
4/20/88
4/20/88
5/3/88
8/30/88
9/30/87
12/31/87
8/31/87
1/17/88
11/8/88
3/17/87
1/15/87 (Federal Register
Notice)
t If RQs are not promulgated by April 30, 1988, RQs become
1 pound for all the extremely hazardous substances.
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APPENDIX
SUPERFUND ENFORCEMENT
KEY SUPPLEMENTAL REGULATIONS/GUIDANCE
Document
Notice Letter Guidance
RI/FS Guidance
NEAR Guidance
DeMinimus Settlements Guidance
Settlement Policy
Covenance Not to Sue Guidance
Mixed Funding Guidance
Cost Recovery Procedures Man8ual
Arbitration of Small Claim Regulations
Administrative Record Regulations
State Involvement Regulations
Contractor Indemnification Regulations
Federal Facility Guidance
Expected Publication (Final)
9/87
4/86
9/87
12/87
12/87
12/87
9/87
9/87
10/87
4/88
4/88
12/88
8/87
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-21-
to comply with an order or request under the information gathering
and access authorities of Section 104, and failure to comply
with an order, decree or settlement agreement under Sections
122 or 120.
v. Address Contractor Indemnification through Regulatory ( + )
Action
Another important provision in the Superfund amendments addresses
contractor liability issues. At present, it is difficult to
secure affordable and adequate liability insurance coverage for
response action contractors (RACs) involved in Superfund clean-up
actions. The Superfund amendments and EPA policy address this
problem through discretionary indemnification of such contractors.
The Superfund amendments give EPA discretionary authority to
indemnify RACs against liability (including the expenses of
litigation settlement) for negligence arising out of the RAC's
performance in carrying out response action activities under
CERCLA with certain limitations. The Agency expects interim
guidance to be in place during FY 1987 and to promulgate final
regulations covering such indemnification during FY 1988.
Indemnification will apply to all EPA approved RACs and their
subcontractors working under the Superfund program for EPA,
another Federal agency, the States, or PRPs if certain conditions
are met. Such indemnification will be provided only as a
supplement or substitute for insurance or responsible party
indemnification and will be limited to liability related to
Superfund clean-up activity releases.
D. Facilitate Federal Facility Response Actions (-)
An important goal of the Superfund amendments is to ensure that
Federal facility response actions are consistent with CERCLA.
Consequently, the amendments confirm that CERCLA is applicable
to such facilities and provides for substantial EPA involvement
in clean-up at such facilities.
Interagency Agreements (+)
The Superfund amendments establish a process that EPA and other
Federal agencies must follow in initiating and completing various
response activities. This includes a requirement for EPA to
coordinate and oversee investigatory activities at Federal facil-
ities and requires EPA and other Federal agencies to enter into
interagency agreements governing remedial actions at NPL sites.
Guidance governing EPA's role in such activities should be avail-
able prior to FY 1988 and our emphasis will be on entering into
actual agreements with Federal agencies governing response
activities. In addition, the Agency plans to issue the Federal
Facilities Program Manual for Implementation of CERCLA/SARA in
FY 1987 which will include a discussion on interagency agreements.
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SARA also provides that EPA and the responsible Federal agency
jointly select the remedy at a site. However, in situations
where EPA and the Federal agency do not agree on the remedy,
EPA has final authority to select the remedy. The Agency has
developed a dispute resolution process to deal with situations
where disagreement exists on the final remedy. This process
is discussed in the revised executive order which delegates
CERCLA authorities to various Federal agencies.
Docket (+)
The Superfund amendments require EPA to establish a special
Federal agency docket. This docket will include information on
Federal hazardous waste facilities submitted under Section 3016,
Section 3005, or Section 3010 of the Resource Conservation and
Recovery Act or reported under Section 103 of CERCLA. The
development of the docket should be completed in FY 1987 and the
emphasis in FY 1988 will be on managing the docket.
E. Increase State Participation (-)
While CERCLA and existing Agency policy do provide for State
involvement in the Superfund program, the Superfund amendments
enhance and formalize the States' role in all Superfund response
activities. For example, the amendments require the Agency to
promulgate regulations for substantial and meaningful State
involvement in the initiation, development, and selection of
remedies for fund-financed, enforcement, and Federal facility
sites. The amendments also require the President to notify
States of negotiations with PRPs and to provide an opportunity
for State partipation in such negotiations, and establish a
process for State challenges to remedial action decisions.
The Agency strongly encourages and plans to promote State involve-
ment in all response actions. This will include the following
activities in FY 1988: the promulgation of regulations for State
participation in Federal-lead remedial actions at NPL sites as
part of the revisions to the National Contingency Plan, a series
of policies and guidance documents covering State enforcement
activities at State-lead enforcement NPL sites, and an emphasis
on State participation in all Superfund Implementation workgroups.
The Agency will also encourage States to provide similar oppor-
tunities for EPA review and consultation at State-lead sites.
Similarly, the Agency will place special emphasis on encouraging
the Regions to coordinate closely with States at State-lead
sites, including the sharing of information on technical and
enforcement progress toward cleanup. Close coordination will
ensure that settlements and remedies will be acceptable to both
sides; it will also allow proper EPA oversight of State expendi-
tures of Superfund money used by the States for various
enforcement activities. ^ซ
i
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State inspectors.
In FY 1988, Headquarters will complete the study required by ( + )
Title III on emergency systems, focusing on filling the data
gaps identified in the FY 1987 interim report to the Congress.
An integral part of the program will be maintaining liaison
with national and international organizations to share
information on chemical accidents and to identify innovations.
The Agency will also work closely with professional
organizations such as AIChE, ASSE, and others to fill the
gaps identified through the information collection effort.
This program is closely linked to the Superfund program in
that it is focused on preventing or mitigating the effects
of releases and on enhancing Federal-State-local-private
preparedness for response to environmental releases of
hazardous substances.
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APPENDIX
KEY SUPPLEMENTAL REGULATIONS/GUIDANCES
Document Expected Publication (Final)
Section 302 Extremely Hazardous 4/87
Substances/Threshold Planning
Quantities
Sections 311-312 Emergency and 7/87
Hazardous Chemical Inventory
Forms and Community Right to
Know Reporting Requirements
National Response Team Emergency 3/87
Planning Guide
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IV. RESOURCE CONSERVATION AND RECOVERY ACT
1. Introduction
The basic authority for the national waste management program
is the Resource Conservation and Recovery Act (RCRA). It was
amended and strengthened in 1984 by the Hazardous and Solid
Waste Amendments (HSWA). RCRA established a "cradle to grave"
approach to the management of hazardous waste. The major goal
of this system is the protection of human health and the
environment. HSWA significantly expanded both the scope of
coverage and the detailed requirements of RCRA and strengthened
the program for non-hazardous wastes (Subtitle D).
Two major goals will drive the effective development, implemen-
tation and enforcement of the national hazardous waste program
in FY 1988: 1) improvement of the existing system for managing
hazardous waste; and 2) prevention of future degradation of the
environment. The FY 1988 RCRA Implementation Plan (RIP) will
provide detailed implementation guidance and direction to the
Regions and States; it identifies specific program goals, high
priority activities and policies that must be reflected in State
and Regional planning documents.
The specific program priorities for FY 1988 target six categories:
A. Expedite and Improve Operating Permits
We will meet land disposal permit deadlines, provide capacity
by issuing permits to facilities offering alternatives to land
disposal, and address cleanup (corrective action) of prior or
continuing releases through appropriate permit or enforcement
actions.
8. Close Facilities Threatening Human Health and the Environment
We will minimize the post-closure escape of hazardous constituents
into the environment and take corrective action to remedy existing
environmental problems at closing/closed facilities.
C. Develop Effective Regulations
We will continue to stress development of effective, enforceable
regulations as well as make regulatory "fixes" in order to improve
the system. We will propose comprehensive corrective action regula
tions to establish a basic framework as well as develop regulations
for, among others location standards, Subtitle D wastes and
concentration - based listings.
D. Monitor Compliance and Enforce Regulations
We will maintain monitoring and enforcement with an emphasis on
groundwater protection. In addition, we will monitor and enforce
corrective action requirements in permits, orders and decrees and
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land disposal restrictions.
E. State/Federal Partnership
EPA and States must continue to work closely together on program
delegations and implementation oarticularly where States have
not yet received HSWA authorization. EPA and the -States will have
joint permitting and enforcement responsibilities until 1990.
F. Information Management Activities
We will seek to make improvements geared towards more effective
utilization of our data systems. These efforts will be evident as
the RCRIS conversion becomes effective during FY 1988.
2. Program Priorities
A. Expedite and Improve Operating Permits
i. Meet Permittin_g_p_eadlines (-)
The top priorityfor the Regions and States inFY 1988 will be
meetingthe November 8,1988 deadline for permit decisions on
operating land disposal, facilities as well as_J:he November 8, 1989
deadline _fojL _pe_rmitting of incineratio_n_facilities_. In addition,
for all facilities other than land disposal or incinerators,
call-ins must be completed by May 1988. Interim Status terminates
on November 8, 1992 unless the owner/operator submits a permit
application by November 8, 1988. Processing of these permits is
a low priority in FY 1988 except: in States without a heavy work-
load for land disposal facilities or incinerators; for facilities
causing health or environmental problems, and for facilities pro-
viding alternative treatment capacity.
Facility management plans (FMPs) are the mechanism to develop
a strategy to move facilities through the permitting process
in a timely fashion. Regions and States should continue to
use a team approach to coordinate permitting and enforcement
actions at a facility. Agency/permittee meetings, documented
as part of the regulatory record, should be used to facilitate
the permitting process.
i i. Permits for New and Expanded Treatment Capacity (+)
The more stringent procedural and technical requirements of HSWA,
in particular, the land disposal restrictions program combined
with the minimum technological requirements and corrective action,
will increase the need for permitting new and expanded capacity.
The permitting of facilities with alternate treatment technologies
will become a major focus of the program.
Streamlining the permit program offers the best hope for expediting
the permit process for new facilities. In addition, resolving
regulatory impediments to the issuance of permits for mobile
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treatment units and to modifications in existing permits (major/
minor permit modifications) will assist in speeding the permit
process. Permit modifications should be a high priority when
they increase capacity or address restricted wastes.
EPA Headquarters is working toward implementation of waste min-
imization techniques that may play a critical role in helping to
abate capacity shortfalls and for assuring the public that effective
efforts are being made to manage waste responsibly.
Community involvement continues to be an important component of
the permitting process. The Regions and States should make every
effort to notify and inform the local community of all significant
permit actions. These efforts will allow EPA and the States to
obtain the most complete information on the facility and avoid
litigation that delays the final stages of the permit process.
* iii. Corrective Action (-)
Corrective action activities may be conducted during interim
status, permitting and closure stages. EPA will focus on
corrective actions at operating land disposal facilities and
incinerators in the permit pipeline and other facilities that
pose the greatest overall threat to human health and the
environment. After considering this overriding priority, the
priorities in descending order are: off-site commercial
disposers/treaters; others in the permitting pipeline, including
land disposal, incineration and alternate treatment facilities;
and closing land disposal facilities.
Before an operating permit is issued, the Agency or State
should undertake a RCRA Facility Assessment (RFA) to determine
whether there may be releases. All operating land disposal
facilities are to have received RFAs by September 1987. At
facilities subject to operating permits, corrective action
steps after the RFA may be required through a schedule of
compliance in an operating permit. EPA and the States must
review and approve documents submitted by these facilities in
a timely manner. This is a resource-intensive effort, yet
necessary in order for facilities to complete each milestone
and keep on track for cleanup.
The Agency's goal should be to ensure that all permits have
enforceable schedules of compliance for corrective action
activities. If necessary, enforcement orders can be used in
advance of permit issuance to compel corrective action in the
case of immediate threats or to get corrective action investiga-
tion activities underway prior to permit issuance. The choice
of using an order or permit to secure various steps of corrective
action at facilities seeking permits should be made a part of
the FMP process.
During FY 1988, Federal facilities should adhere to corrective
action rules and policies. Regions should work with the Federal
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agencies on their A-106 reports and comment on adequacy of funding
for priority RCRA permits and closures.
* B* Close Facilities Threatening Human Health and the Environment
The objectives of the closure/post-closure programs are to
minimize the post-closure escape of hazardous constituents into
the environment and to take corrective action to remedy existing
environmental problems at closing/closed facilities, including
storage and treatment facilities with contamination. Sections
3008(a) and (h) and 3004(u) of HSWA and various State authorities
provide flexible tools for ensuring the environmental integrity
of these facilities.
The Agency is focusing upon closure of regulated units via the
closure plan approval process and the issuance of enforcement
orders or post-closure permits to obtain corrective action at
environmentally significant facilities. Priorities for post-
closure activities should be based on need for corrective
action. If enforcement orders are used as the first step
to compel action, they can later be incorporated into post-
closure permits when appropriate. Regions and States should
continue to use the FMP process to refine their multi-year permit/
closure strategies.
C. Develop Effective Regulations
o i. Emphasize Development of Effective, Enforceable Regulations
During FY 1987 and continuing into FY 1988, the Agency, in
particular cooperation with Regions and States, will place a
priority on ensuring that new regulations are effective and
enforceable. Examples of new regulations that will need special
focus are the technical and procedural standards for corrective
action, the Subtitle D criteria, and the location standards.
Section 3004(u) of HSWA requires corrective action for releases
of hazardous wastes or constituents from any solid waste management
unit (SWMLJ) at a treatment, storage and disposal facility (TSDF)
subject to a RCRA permit. Permits must also contain assurances
of financial responsibility for complying with corrective action.
While a number of guidances have been issued to assist the Regions
and States as they undertake corrective action, the scope of the
program requires a more comprehensive approach than now exists.
The Agency will be developing a regulatory framework to define
both the procedural and substantive requirements for the program.
This major rulemaking will provide the States, the regulated
community and other parties the opportunity to participate in
setting program standards and provide a solid legal foundation
to implement those standards.
In addition, the regulations will tighten closure standards,
will provide appropriate consistency between RCRA and CERCLA
cleanups, and will revise existing regulations for regulated
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unit corrective action.
During FY 1988, new programs will be evolving that will require
considerable attention and coordination among the Agency and the
States. These programs include the land disposal restrictions
program, the minimum technology requirements, a more sophisticated
corrective action program, waste minimization, Subtitle D, and
the control of air emissions from waste treatment and disposal
facilities (e.g., municipal waste combustion). A strong Federal
and State outreach program will be needed if the regulated community
is to comply with these new programs.
EPA will continue its efforts to develop and distribute clear
and useful guidance. EPA Headquarters will seek a better system
for obtaining Regional and State input with regard to what guidances
are developed and how they can be made more useful.
i i. Develop a Simplified System for the Future
Even with corrections in the current regulatory program, the
existing approach to regulating hazardous waste presents problems
because of its complexity and inconsistencies. The Agency will
focus on laying a foundation for an integrated technology performance/
risk-based future system. Traditionally the RCRA program has
relied on a technology-based performance approach, e.g., secondary
containment for hazardous waste tanks regardless of the permeability
of the soils in which they are located. During FY 1988, EPA will
continue to move toward combining this approach with one that
seeks to identify the situations or wastes posing the greatest
risks to human health and the environment. Limited program
resources can then be targeted on abating or eliminating these
risks.
Among the issues that will be examined by the Agency, States and
the regulated community are: ensuring consistency among different
disposal methods, regulating wastes and products consistently,
developing a concentration-based approach to listing of hazardous
waste, examining the delisting approach, encouraging waste min-
imization, and identifying incentive-based private sector approaches.
D. Monitor Compliance and Enforce Regulations
Safeguarding human health and the environment requires compliance
with RCRA requirements. Therefore, ensuring that compliance is
achieved is a priority of the Regions and States. In FY 1988,
the Agency will continue to emphasize land disposal facility
compliance with groundwater protection, closure/post-closure and
financial responsibility requirements.
In addition, the base program covering administrative and technical
standards for TSDFs will be substantially augmented by new require-
ments having broad and interrelated effects. Numerous land
disposal facilities, previously governed by generic interim
status standards, will be subject to facility-specific permits
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and closure plans. Corrective action studies will be underway
at land disposal and other environmentally significant facilities.
Land disposal restrictions are likely to result in substantial
modification of waste treatment and disposal practices.
The more stringent technological requirements for land disposal
facilities and the retrofitting requirements for surface impound-
ments will also contribute to the major transition in waste manage-
ment practices. In addition to inspecting and enforcing these
significant new requirements at treatment, storage and disposal
facilities, the Agency will place increased emphasis on targeted
handlers subject to land disposal restrictions.
Handlers that pose an immediate threat to human health and the
environment are the highest priority for compliance monitoring
and enforcement actions. Other activities for FY 1988 include the
following:
i. inspections
Inspection priorities are established by statute and Agency
policy. Under the HSWA requirements, EPA will inspect all
Federal, State and local treatment, storage and disposal
facilities annually and that the remaining TSDF's be inspected
by EPA or the state at least once every two years. As a matter
of Agency policy, certain categories of handlers will be inspected
more frequently than required by law. For example, all operating
and closing land disposal facilities are to be inspected in FY
1988. Also, the CERCLA Off-site Policy requires that TSDF's
receiving Superfund wastes be inspected within the six month period
prior to acceptance of the waste.
In addition, the land disposal restrictions necessitate a substantial
increase in the number of inspections of targeted handlers. Other
inspections of major importance include those needed to support
case development and those undertaken to oversee compliance with
conditions of orders and permits.
ii. Enforcement Actions
Enforcement action will be taken against handlers that pose
an immediate threat to human health or the environment.
Such enforcement actions may require corrective action for
releases to human health or the environment or may compel a
return to compliance with statutory or regulatory requirements.
Enforcement actions will also be pursued against the following:
0 Owners and operators of facilities likely to receive
Superfund wastes if the facilities are not in compliance
with RCRA requirements or have unaddressed releases of
hazardous waste or hazardous constituents.
0 High Priority Violators of the pre-HSWA program, as defined in
SPMS and the Enforcement Response Policy, particularly disposal
facilities in violation of groundwater monitoring, closure/
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post-closure and financial responsibility requirements.
0 Facilities in significant violation of requirements for
corrective action in permits or orders.
0 Owners and operators of hazardous waste management
facilities with environmentally significant releases.
0 Targeted handlers subject to land disposal restrictions.
E. State/Federal Partnership
RCRA has always required close coordination between EPA and the
States. Under HSWA the States and EPA must work in even closer
coordination to achieve a joint working relationship to implement
the HSWA provisions until States are authorized to administer
the Amendments. In FY 1988, the Regions and the States should
have as a priority, where capability is demonstrated in the base
program, capability assessments and HSWA authorizations. A
major effort should be made to enhance the State/Federal partnership
through agreement on program goals and methods of implementation.
F. Information Management Activities (-)
In FY 1988, the Agency and the States should continue to have as
a priority an improved data management system. Information is
needed to determine where the greatest environmental benefits
can be obtained and where accomplishments have occurred. To
date EPA and the States have not done a good job characterizing
the extent and severity of the problems and the progress made in
addressing them. This data can ensure that priorities for taking
action maximize environmental results. The new RCRIS system
will be a key component of the FY 1988 information management
activities.
The Regions and States should play a critical role in obtaining
this data and ensuring its quality. The types of information
to be acquired should include: an accurate list of facilities
subject to RCRA requirements, including land ban requirements
such as the constituent-based California list and the operating/
closing status of areas of the facility; a list of newly HSWA-
regulated entities, e.g., SQGs and burners/blenders; the amount
and type of waste generated for the biennial report; information
on wastes going to different media and different types of facil-
ities; accurate tracking of compliance monitoring and enforcement
activities, including schedules of compliance and returns to
compliance. During FY 1988 both Headquarters and the Regions
will have to review and act upon a large number of waivers and
petitions. A useful and accurate tracking system must be developed
to meet this need.
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V. UNDERGROUND STORAGE TANK PROGRAM
1. Introduction
The Office of Underground Storage Tanks (OUST) was established
at EPA in 1986 to respond to the requirements of Subtitle I, an
amendment to the Resource Conservation and Recovery Act.
Some state and local governments currently operate regula-
tory programs or emergency response programs that address the
problem of leaking underground storage tanks. However Congress
has now called for concerted government action on a national
scale to reduce a growing problem of groundwater pollution
from leaking underground storage tanks, and to prevent such
pollution in the future.
In 1986, Subtitle I of RCRA was amended by the Superfund Amend-
ments and Reauthorization Act. The two major changes to Subtitle
I were to establish a trust fund providing federal funds for
corrective action and enforcement for leaking underground storage
tanks, and to require that owners and operators of underground
tanks maintain evidence of financial responsibility.
During FY 1987, there is significant work to be done in developing
implementation plans and detailed guidance for this new program.
The Operating Guidance provides broad guidance for purposes of
priority-setting by Headquarters and Regional offices and States.
This will be followed by supplemental guidance and planning
documents that address in more detail the trust fund, the State
program approval process, enforcement issues, and targeted
federal program implementation in the field. Regions and States
will be invited to participate actively in this planning process
during FY 1987.
In FY 1988, as in FY 1987, the overriding priorities of the UST
Program are to: (A) prevent and reduce groundwater degradation
by developing a national UST program; and (B) clean up leaking
USTs by implementing the Federal LUST Trust Fund. Program
activities that support these objectives are as follows:
Promulgate UST National Standards and Requirements
Since a national regulatory program must be based first and fore-
most on a set of national standards and requirements, the comple-
tion of national standards continues to be the highest priority
activity for OUST in FY 1988. Proposed regulations covering
technical standards, financial responsibility, and state program
approval will be published for public review and comment during
FY 1987. Depending on responses to these proposed regulations,
public hearings may be held during FY 1987 or FY 1988. The final
regulations will be published in FY 1988, and will become effective
three months after the date of promulgation. Guidance materials
to supplement the new regulations will also be published in FY 1988.
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Support Development of State UST Programs
The second most important ingredient of an effective national
regulatory program/ after establishing national technical standards,
is to have as many effective State programs as possible. States
with effective programs approved by EPA thus become the implementing
arra of the national UST program, tailoring national requirements
to reflect the unique environmental characteristics and governmental
structure of each state.
During FY 1987 and FY 1988, EPA's focus is on preparing its staff to
review draft State program approval applications in late FY 1988
or early FY 1989, and on assisting and encouraging States to
develop State authorities and funding mechanisms for new UST
programs where needed.
During FY 1988, the final UST regulations will be published, and
EPA then begins the State program approval process. The Regions
will have the lead in the approval process, with participation
and assistance from OUST. Since it is unlikely that EPA will
receive many State applications during FY 1988, the Regions will
be busy providing review and comment on draft applications and
otherwise assisting states in developing their programs. This
activity will be the highest priority activity for the Regions
in FY 1988.
Regions will continue to negotiate and oversee State grants,
which will require an increase in State funding match from 15%
to 25% in FY 1988. It should be noted that Congress intended that
Federal grant funds in the Underground Storage Tank Program be
used as "seed" money to assist States with development of State
programs. There are no plans for substantial long-term Federal
funding of State-run programs. However, EPA will assist States
in finding ways to pay for their programs, and will be providing
information on alternative State funding mechanisms in FY 1987.
EPA will also be developing a variety of implementation tools
for use by States, and will provide a forum for States to share
information and experience concerning UST programs.,
Begin Targeted Federal UST Program
Establishing a "national" regulatory program for underground
storage tanks does not mean establishing a "federal" program,
administered and enforced by EPA, in every State. Instead, EPA's
goal is to assist States in establishing adequate State-run
programs. However, in the absence of State interest in operating
an UST program, EPA is required by law to operate a Federal
program in such States, and will implement one. In the future,
EPA will also develop UST programs on Indian lands through coop-
erative agreements with Indian tribes.
In FY 1987, OUST will work with the Regions to develop a strategy
for a federal program in those States with no plans for a State
program, and on Indian lands. During FY 1988, the Regions will
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-35-
begin to implement a targeted Federal UST program, based on the
strategy developed this year. Implementation of targeted Federal
enforcement activities will be a priority effort in FY 1988.
Continue to Administer LUST Trust Fund Program
The Superfund Amendments and Reauthorization Act of 1986 amended
Subtitle I of RCRA to establish a Leaking Underground Storage
Tank (LUST) Trust Fund, which provides funds for corrective action
and enforcement. Thus, designing Trust Fund procedures and
beginning to allocate funds for either State or Federal clean-ups
is a priority effort for FY 1987. Supplemental guidance will be
issued during FY 1987 which will describe Trust Fund procedures
and priorities. Headquarters offices, such as OARM, OECM, OGC
and OERR, and the Regions will be very involved in program plan-
ning for the Trust Rund.
During FY 1987, the Regions will also be negotiating State coopera-
tive agreements under the Trust Fund, and may carry out enforce-
ment actions or conduct Federal emergency clean-ups, as necessary.
Federal clean-ups are expected to occur only in a limited number
of cases in which an imminent hazard is present. During FY 1988,
the implementation of the Trust Fund by OUST and the Regions
will continue to be a priority.
There are two activities that were priorities in FY 1987 but will
no longer be priorities in FY 1988: (1) implementation of noti-
fication requirements; and (2) enforcement of Interim Prohibition
requirements.
Implement Notification Requirements (-)
During FY 1987, notification continues to be a priority activity
for the UST Program, and OUST and the Regions will continue to
assist the States with notification activities. Regions will work
with States to identify classes of non-compliers, and Regions and
those States with appropriate authorities will be enforcing the
Federal notification requirements as needed. States will be
completing the initial processing of notification forms, and
must (under a Congressional deadline of July 1987) submit to the
Regions a summary of their State inventory of regulated tanks,
based on notification data. OUST will provide a format for
this inventory summary.
By FY 1988, the initial notification phase of the program should
be complete. Notification data should be updated periodically
by the States, but maintaining the State notification systems
should now be considered a minor activity. Regional compliance
monitoring and enforcement of the notification requirements will
begin phasing out as State programs are approved and State enforce-
ment is begun in FY 1988 and FY 1989.
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-36-
Enforce Interim Prohibition Requirements (-)
In FY 1987, compliance monitoring and enforcement during the
Interim Prohibition phase is a priority activity. The Regions
will develop grants and cooperative agreements with States to
enforce Interim Prohibition requirements. OUST, working with
OWPE, will develop enforcement guidance to support the Regions
in implementing the Interim Prohibition. OSWER will establish
an enforcement task force, co-chaired by OUST and OWPE and
including representatives from OERR, OECM, OGC and the Regions,
whose purpose is to set compliance monitoring and enforcement
priorities for the implementation of Interim Prohibition require-
ments, and for the development of a new targeted Federal UST
program, as previously discussed.
During FY 1988, compliance monitoring and enforcement of Interim
Prohibition requirements will continue until final regulations
become effective. Once final regulations are in place, the
Interim Prohibition will cease to exist, and EPA will begin to
enforce the new requirements under a targeted federal program.
2. Program Priorities
A. Prevent and Reduce Groundwater Degradation by Developing a ^^
National UST Program. ^1
OUST WILL: 1. Promulgate final regulations covering technical
requirements and standards, financial responsi-
bility requirements, and state program approval
irements ana standards, rinanciai responsi-
ty requirements, and state program approval
irements.
requirements.
2. Provide technical guidance and assistance to
regions, and information to the regulated
community and the public.
REGIONS WILL: 1. Begin the State program approval process, and
assist States by providing review and comment
on draft state applications.
2. Provide assistance to states to encourage the
development of adequate state programs that
will be fully implemented over time.
3. Begin implementation of a targeted federal UST
program, enforcing new federal regulations as
needed in the absence of state programs.
4. Provide technical guidance and assistance to
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-37-
STATES WILL:
States, and information to the regulated
community and the public.
1. Operate and enforce existing State UST programs
in States with programs already in place.
2. Develop or change State authorities or require-
ments for UST programs, in order to meet the
new Federal standards.
3. Develop draft applications for State program
approval.
4. Increase State funding match for grant to 25%,
and for Trust Fund to 10%.
B. Clean up Leaking USTs by Implementing the Federal LUST Trust
Fund.
OUST WILL:
REGIONS WILL:
STATES WILL:
1. Continue to administer the LUST Trust Fund
program.
2. Develop methodologies and provide guidance
for corrective action.
1. Continue to negotiate and oversee State
cooperative agreements under the Trust Fund.
2. Continue minimal federal clean-up and enforce-
ment activities, as needed, under joint
direction of OUST and OERR. (Federal clean-
ups are expected to occur only in a limited
number of cases.)
1. Conduct clean-ups financed by Federal Trust
Fund, including enforcement actions, corrective
actions, and cost recovery.
The following two charts summarize the priority activities, plus
other somewhat less important activities, that will be expected
of OUST, Regions and States, during FY 1987 and FY 1988.
It is our intent to communicate all FY 1988 priorities and
goals for the Underground Storage Tank Program in this document.
Publication of separate UST State Grant Guidance would thus be
redundant and unnecessary. Information on grant amounts and
allocation will be forwarded to the Regions under separate cover
when that information becomes available. Regional Offices are
responsible for negotiating grant agreements with States in order
to ensure relevance of national guidance to individual State
-------
-38-
situations, progress in State program development/ and account-
^hi 1 i t~v for nt-Anl- fund f^vnemdi fiirpR.
ability for grant fund expenditures.
I
-------
-39-
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APPENDIX
KEY SUPPLEMENTAL REGULATIONS/GUIDANCES
to be finalized during FY 1987
LUST Trust Fund Program Guidance: procedures and prior-
ities, fund allocation, general program plan, etc.
State Program Approval Guidance: guidance on what con-
stitutes an "approved" State program, and on what basis EPA
will make that determination.
Enforcement Guidance on implementing Interim Prohibition
requirement.
Strategy for implementing a Targeted Federal UST Program.
to be finalized during FY 1988
UST Technical Standards
Financial Responsibility for Underground Storage Tanks
UST State Program Approval
-------
APPENDIX
KEY SUPPLEMENTAL REGULATIONS/GUIDANCES
Document Expected Publication (Final)
Hybrid Closure Guidance 7/88
Clean Closure Guidance 9/87
RCRA Facility Assessment Guidance 12/87
Corrective Measures Guidance 4/88
Land Treatment Unit Closure Guidance 3/87
Land Disposal No Migration Petitioners 11/87
Guidance
FY 1988 RCRA Implementation Plan 4/87
Guidance on Closure of Surface 11/87
Impoundments by Removal or
Decontamination
Alternate Concentration Limits 4/87
Guidance
Land Disposal Restrictions Inspectors 3/87
Checklist
Land Disposal Restrictions Enforcement 3/87
Strategy
Interim Guidance on Public Involvement 3/87
in Section 3008(h) Actions
RCRA Section 3008(h) Model Order 4/87
Enforcement Response Policy (revision) TBA
-------
TABLE OF CONTENTS
I. EXECUTIVE SUMMARY 1
II. PESTICIDES GUIDANCE 3
III. TOXIC SUBSTANCES GUIDANCE 12
-------
OFFICE OF PESTICIDES AND TOXIC SUBSTANCES
I . EXECUTIVE SUMMARY
The 1988 Pesticides and Toxic Substances program guidance is
designed to continue the same major program emphasis contained in
the 1987 guidance. We will maintain the priority the Agency has
assigned to reducing risks from pesticides, although we are
making substantial changes in our approach to pesticide reregistra-
tion. We will continue to assign a high priority to the toxic
substances program, although we are no longer assigning superordinate
priority to the existing chemicals program but are giving equal
priority to the new and existing chemicals programs. Finally we
have added to the 1988 guidance the program objectives and key
activities necessary to carry out the requirements of the Superfund
Amendments and Reauthorization Act (SARA) Title III community
right-to-know and emergency planning amendments and the recently
enacted Asbestos Hazard Emergency Response Act.
The 1988 pesticides reregistration program will involve a signi-
ficant redirection of effort and change in process in order to
accelerate the acquisition of complete, scientifically acceptable
data bases supporting the reregistration of existing pesticides.
Currently, only selective data are called-in prior to development
of a registration standard. These data usually require a long
time to develop and/or are of special interest, such as that
associated with groundwater contamination. Existing data are
reviewed in detail for adeauacv and all missing or inadequate
studies are called-in when the registration standard is developed.
Under the new process, all data will be called-in before we begin
development of a registration standard, including replacements
for data which may be in EPA files but are inadequate by current
standards. A major feature of the revised data call-in program
will be evaluation by registrants of the adequacy of existing
data and research information. This evaluation will be performed
under EPA oversight and guidance. Using the regulated industry
to perform some parts of the review, and calling-in all missing
or inadequate data before a final registration standard is
developed, will speed review of the universe of pesticide
active ingredients and permit a more efficient process.
In the toxic substances program, we are assigning equal priority
to the new chemical review and existing chemical programs.
Sustained growth in the number of new chemical submissions, and
continuing recognition of the value of section 5 of TSCA
in allowing EPA to assess and control risks of chemicals
before they enter the marketplace, led us to this change. The
number of chemical submissions grew from 1,774 in 1985 to over
2,100 in 1986 with 2,600 expected in 1988. This growth caused
us to make a substantial resource shift in 1987 from the existing
chemical review program to the new chemical review program.
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Activities under Title III of the Superfund Amendments and
Reauthorization Act will be started in 1987 and continued in
1988. Principle headquarters activities will include continuing
to meet the section 313 toxic emissions inventory requirements
and revising criteria for identifying extremely hazardous chemicals
Regional activities will involve assistance to manufacturers in
reporting hazardous chemicals and assistance to States and commun-
ities in interpreting information reported and in preparing
emergency response plans. In 1988 we will also begin an enforce-
ment program to ensure that many activities comply with the
reporting requirements of Title III of SARA.
The Asbestos Hazard Emergency Response Act (AHERA), signed
by President Reagan on October 22, 1986, will accelerate
efforts to reduce asbestos hazards in schools. EPA
must promulgate a series of regulations by October 1987 which
provide a framework for addressing asbestos hazards in schools.
In 1988, after the new rules are established, the Agency will
help States implement accreditation programs for contractors,
inspectors and abatement planners, and will assist schools to
develop and implement adequate asbestos management plans.
Existing asbestos technical assistance and direct support
activities will be modified to assist States to meet the require-
ments of the Asbestos Hazard Emergency Response Act. The modi-
fications will include the development of new guidance documents,
enhanced technical counseling in the Regions, improved training
through asbestos information centers, and grants to States for
inspector certification programs.
Aside from new requirements arising from the SARA Title
III ammendments and the Asbestos Hazard Emergency Response Act,
there are no major changes to the guidance as it pertains to
regional and State programs. In the pesticides program we will
continue the priority we assign to strengthening regional and
State programs, particularly by building more technical capability
to address complex issues such as groundwater contamination
(addressing interim results of the groundwater survey). Revised
Worker Protection Standards will be effective in 1988 and both
the States and regions will be mounting education programs to
make growers and farmworkers aware of the provisions of the new
rule. We will also continue, of course, the high priority we
assign to reviewing and revising State pesticide applicator
certification and training programs. We anticipate completing
the review of certification programs in 1987. In 1987 and 1988
after discussion between the States and Regions, certification
plans and programs will begin to be revised; in 1988 the regions
will begin to review State certified applicator training programs.
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II. PESTICIDES GUIDANCE
The pesticides Program will continue to emphasize the reduction
of risks through the Generic Chemicals Review program, of existing
pesticides. In 1988 we will move to accelerate the review of in
use pesticides, largely through the initiation of a comprehensive
data call-in program that will provide more nearly complete data
bases when registration standard development begins.
A. Program Goal; Protect Health and the Environment from Any
Unreasonable Adverse Effects from Pesticides Currently in Use.
The principal programs in this area are Data Call-in, Registration
Standards, Special Reviews, pesticides applicator Certification
and Training, and State and regional enforcement to reduce pesticides
misuse. The Data Call-in program, by which existing pesticides
data bases are updated to meet today's standards, will undergo a
major shift in 1988 to calling-in all data required to evaluate
in-use pesticides, rather than depending upon the registration
standard process to initiate the development of most such data.
The 1988 program includes continued development of Registration
Standards, review of studies submitted in response to data call-in
and earlier registration standards, and completion of Final
Regulatory Standard and Tolerance Reassessments (FRSTRs). The
1988 program also includes Special Reviews of the risks and
benefits of pesticides suspected of causing unreasonable adverse
effects on human health and the environment. The need for Special
Reviews may be identified during the establishment of a registration
standard, during review of called-in data, during review of data
supporting applications for the registration of new chemicals,
during the revision of existing registrations, or by referrals
from other sources. Pesticides Certification and Training will
be given greater emphasis in 1988 as will Pesticides Enforcement.
1. Program Objective: Continue the review of previously
registered chemicals currently being used.
a. Key Program Activities:
(1) During 1987, the in-use pesticides review and reregistration
program will develop procedures to call-in all data required
to evaluate comprehensively existing pesticides before
registration standard development begins. (Currently data
call-in is used to call-in selective data, principally data
* requiring a long time to develop and data of special interest,
such as that associated with groundwater contamination.)
A major feature of the comprehensive DCI program will be
evaluation by registrants of the adequacy of existing data
bases with EPA oversight and guidance. The new DCI program
will be developed in 1987 and in operation in 1988. (HQ)
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(2) The Registration Standard program will produce both interim
registration standards (in current format including data
* requirements) and Final Regulatory Standards and Tolerance
Reassessments (FRSTRs) after data bases are complete.
The number of each type to be produced will depend upon
the availability of complete data bases, and the need
to produce interim standards for special cases such as
worker protection problems. (HQ)
(3) We will continue the program begun in 1986 to improve the
rate of compliance with registration standard data and label
requirements, with Headquarters issuing suspension and
cancellation notices for enforcement by the regions and
States. (HQ/RGNS)
(4) In 1988, the product chemistry data called-in during
1987 will yield data that requires evaluation to develop an
up-to date data base essential for regulating inerts, impuri-
ties, and contaminants (e.g., dioxin and DDT) of toxi-
cological concern in pesticides. (HQ)
(5) The current strategy to review selected inert ingredients
of toxicological concern in new and existing pesticide
active ingredient will be continued in 1988. (HQ)
(6) Studies generated by Data Call-in and required by Registration
Standards will continue to be reviewed as received in 1988 if
they meet the criteria for early review:
product chemistry and acute toxicity data necessary to
approve label changes
tiered test data
data flagged in accordance with flagging criteria im-
posed by EPA or submitted in accordance with the adverse
effects provision of FIFRA ง 6(a)(2) which requires
registrants to report information indicating potential
adverse effects.
studies identified during the establishment of a standard
as critical to resolving a health or safety problem.
The Agency will rigorously enforce the 6(a)(2) provision. (HQ)
(7) The sampling and analysis phase of the survey to sample
pesticides in groundwater, designed in 1986 and begun in
* 1987, will be essentially complete in 1988. This statistically
based, stratified survey for about four dozen pesticides is
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-5-
being supported by both the Office of Pesticide Programs and
the Office of Drinking Water. The regions will help gather
pesticide usage and groundwater vulnerability data, and
develop communication strategies concerning the results of
the survey. (HQ/RGNS)
(8) Headquarters will continue to develop measures to prevent
groundwater contamination by pesticides and will pass these
measures on to the regions. The regions will provide this
information to the States and aid them in educating users
as to the proper use of pesticides with groundwater res-
trictions. Whenever studies of groundwater problems unique
to a geographic area are conducted by headquarters, the
regions and States will be involved. (HQ/RGNS)
(9) Work will continue in accordance with the National Pesti-
cide Monitoring Plan to develop further a national
information clearinghouse on pesticide monitoring activities
and to provide guidance to the monitoring community on
priority pesticide monitoring needs. A computerized data
bank will be developed in 1987 to capture monitoring
activities' characteristics. The regions will be asked to
canvas their States to provide data for forming the data
bank. (HQ/RGNS)
2. Program Objective; Restrict or ban the use of pesticides
posing unreasonable adverse effects to human health and
the environment.
In approximately 25% of the Registration Standards estab-
lished to date, public health or environmental problems have
been identified requiring the comprehensive evaluation of
pesticide risks and benefits through the Special Review
process. Candidates for Special Review are also identified
in the course of reviewing data submitted in response to data
call-in or registrations standards, data supporting appli-
cations for the registration of new chemicals or for the
revision of existing registrations, or by referrals from
other sources.
a. Key Program Activities
(1) Special Reviews initiated in 1988 will continue to employ
revised risk criteria that more realistically reflect
actual exposure and hazard. Opportunity will be avail-
* able for public participation in the evaluation process.
Formal hearings are expected to be required on proposed
Agency cancellation/suspension actions on suspect chem-
icals. (HQ/RGNS)
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(2) Where feasible, alternatives to cancellation for mitigat-
ing unreasonable risk will be pursued, such as restriction
to use by certified applicators, modifications to the
terms and conditions of use, improved pesticide labeling
(e.g., requirements for protective clothing and equipment,
reentry intervals, warnings, directions for emergency
treatment, etc.) to reduce risk. The Agency will also
promote use of closed-system containers, childproof
packaging, and safe container disposal practices.
(HQ)
(3) In 1987, EPA will develop a Management Action Plan for
Indemnification and Disposal of Pesticides. This plan
will include specific instructions for named pesticides
and generic instructions for future pesticides disposal
situations. This plan will be implemented in 1988.
(HQ/RGNS)
(4) The Special Review process will continue to focus on
review of clusters of similar use pesticides such as wood
preservatives, termiticides, and grain fumigants, when
appropriate. We will also begin to examine the problem
of stimulating industry innovation in high-risk classes
such as fungicides. (HQ)
(5) The program will cooperate closely with the Toxic
Substances program on high priority chemicals where
TSCA data may be available or TSCA data gathering
authorities may be useful, such as certain inert
ingredients used in pesticides. (HQ)
3. Program Objective: Reduce the incidence of pesticide mis-
use.
a. Key Program Activities:
(1) In 1988, all States will observe the top national
pesticide use priority of enforcement of suspension
and cancellation actions. In addition, the Regions
will direct the States to consider other high-
priority use araas, such as groundwater contamination,
chemigation, aerial drift, and the proper use of
restricted use pesticides such as wood preservatives
and 1080 collars, when utilizing the formal priority-
setting process that establishes enforcement priori-
ties within each State. The Regions will encourage
the States to increase the level of such use in-
spections (at the expense of other types of in-
spections, such as marketplace surveillance), con-
ducted under Federal/State cooperative enforcement
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agreements. The Regions will receive additional resources
in 1988 to provide technical support to the States and
the regulated community in use areas such as those noted
above. Where appropriate, the Regions will promote
coordination between agricultural and environmental
agencies in their States in the area of pesticide
use. (RGNS)
(2) State applicator certification/recertification and train-
ing programs will be strengthened with greater financial
support, by updating State applicator certification
plans, by reviewing State training programs, and by
assisting in the development of new or revised training
materials, especially in specific areas where such train-
ing materials do not exist or are inadequate. Information
on existing State fee programs for certification and
trainina will be distributed as one way of encouraging
State fee systems. (HQ/RGNS)
(3) The Agencv will determine how regulations need to be
amended to clarify issues such as "maintaining an
applicator's competency". (HQ/RGNS)
(4) Federal oversight of State programs will be maintained
to assure nationwide consistency in the pesticide com-
pliance monitoring program, and to ascertain whether
timely and appropriate enforcement action is being
achieved. The current FIFRA penalty policy will be
revised. (HQ/RGNS).
(5) The Agency will operate Federal compliance monitoring
and enforcement or certification and training programs
in instances where States are unwilling or unable to
conduct their own programs. (RGNS)
(6) Federal case development support will be maintained for
referrals of State enforcement actions and in EPA-
operated maintenance programs. (RGNS)
(7) The Agency seeks to integrate criminal enforcement into
the overall compliance monitoring/enforcement programs.
Accordingly, regions should identify and refer to the
Office of Criminal Investigation (OCX), cases or
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incidents that concern knowing/willful violations re-
suiting in injury to human health or major environ-
mental harm, that involve egregious repeat offenders,
or that involve data fraud or pesticide misuse. These
cases are further limited to those which occur in
States for which EPA has primary enforcement responsi-
bility, or which are referrals from States. Activities
to integrate the programs should include cross-referrals
within the regions between OCI and the program office.
The regions will also provide technical and program
support to criminal investigations and prosecutions,
as necessary. (RGNS)
(8) Revisions to the FIFRA and TSCA Enforcement System
(FATES), which contains all enforcement data, will be
continued, with input from the Regions, to increase
its efficiency and usefulness. (HQ/RGNS)
(9) Small business outreach efforts will be continued
in the area of compliance with FIFRA. (HQ/RGNS)
(10) We will develop cooperative enforcement and certif-
ication and training programs with Indian Tribes to
address problems of pesticide use and misuse. (HQ/RGNS)
(11) EPA will maintain, principally through the Federal/
State cooperative enforcement agreements, compliance
monitoring programs at Federal facilities. OPTS will
implement the new Federal Facilities Compliance Strategy,
when it becomes final, by providing appropriate tech-
nical assistance and taking action when violations
occur at Federal facilities. The Regions will cooperate
with their respective Regional Federal Facilities
Coordinators by providing information and reports on
their Federal facility compliance monitoring programs.
(HQ/RGNS)
Program Objective: Conduct research and develop methodologies
to support existing pesticide risk reduction efforts.
a. Key Program Activities:
(1) The research program will emphasize the development of
methodologies and techniques needed to evaluate health
and environmental risks associated with existing pest-
icides. These important tools are critical to both the
testing and regulation of existing pesticides. (HQ)
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(2) Models for evaluating environmental concentrations
of pesticides and for determining health risks will
continue to be developed and validated. Hazard
assessment methodologies which are critical in risk
analysis of chemicals will also be developed. (HQ)
B. Program Goal: Prevent Unreasonable Risks From New Pesticide
Active Ingredients And Products And Encourage Use of Safer
Products (New Or Old).
The Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)
provide for Agency control of the terms and conditions under
which new pesticides may be legally used in the United States,
through pre-market reviews of their potential human and
environmental effects. Registrations permit pesticide use
under specific limitations, and Tolerances specify maximum
pesticide residues permitted on food and feed products.
Exceptions may be made to registration requirements under the
Special Registration program which provides for unregistered
uses for experimental purposes or in emergency situations,
and for registrations by the States for special local needs.
1. Program Objective; Provide careful review to assure that
new pesticides do not add unreasonably to total risk.
a. Key Program Activities:
(1) The program will continue to be alert for applications
for new chemical or new use registrations which indicate
a possible need for intensive risk/benefit analysis.
Agency forums such as the Scientific Advisory Panel
will be used to review difficult science issues. (HQ)
(2) Current monitoring efforts will be redirected to focus
more effectively on special problems such as groundwater
contamination, and guidance for monitoring, predicting,
and preventing pesticide contamination of groundwater
will be provided to registrants. (HQ)
(3) Methodologies for assessing risks posed by new products
of biotechnology will continue to be refined in 1988.
(HQ)
(4) The safety of farm workers and families will continue
to be promoted. A Notice of Proposed Pulemaking for
Worker Protection Standards will be published in 1987
and a final rule oromulgated in 1988. The regions and
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States will assist in the dissemination of education
materials to make growers and farmworkers aware of the
provisions of the new rule. State grant guidance will
contain priorities for enforcing the new rule. (HQ/RGNS)
(5) In support of the Agency's goal of pesticide safety,
the program will undertake to expedite the availability
of fundamentally new products to displace riskier, older
products. (HQ)
(6) Integrated Pest Management (IPM) technology will be en-
couraged, and where appropriate, IPM alternatives will be
considered in risk/benefit decisionmaking. (HQ)
(7) Improvements in information management and automation
support will continue in 1988, with the goal of support-
ing pesticide program decision making with rapid and
comprehensive access to relevant information, and
more efficient processes for creating, storing, using
and updating important regulatory decisions and support-
ing technical assessments. Changes to data base systems
and content will address regional as well as headquarters
needs. These improvements will also provide the public
with more meaningful information on the properties
and effects of pesticides. (HQ)
(8) Internationally consistent pesticide tolerances, and greater
efficiency in the use of resources expended in tolerance-
setting will be sought through the Codex Alimentarius
program of the U.N. World Health Organization. (HQ)
(9) New approaches to the protection of endangered species
and other wildlife from pesticide hazards, initiated in
1987, will be continued. One approach under consideration
would rely on generic labeling and the use of bulletins
distributed by field operations of USDA and Interior
Department agencies. The bulletins would provide
detailed instruction on the conditions under which
pesticides are prohibited as a result of concern for
endangered species. A plan for gathering ecological
effects monitoring data from existing State and Federal
programs is being developed. The pesticides program
will also continue to work to develop requirements for
ecological monitoring by registrants. (HQ)
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(10) Experimental use permits, emergency exemptions and
special local need registrations issued under Sections
5, 18 and 24(c) of FIFRA respectively, will be monitored
to prevent unwarranted circumvention of Section 3
registration requirements. Headquarters will provide
the lead in monitoring, such as audits of State activi-
ties, with support provided by the regions as appropri-
ate. (HQ/RGNS)
Program Objective: Insure the integrity of data submitted
to FPA.
a. Key Program Activities;
(1) The Agency will perform both full-scale audits of a
sample of completed test studies that have been sub-
mitted to EPA and in-process audits of studies being
conducted. (HQ)
(2) Ensuring compliance with Good Laboratory Practice (GLP)
requirements is a high priority for the Agency. In
cooperation with FDA, Regions II, III and V will perform
GLP inspections at testing facilities. Headquarters
(NEIC) will perform GLP inspections in other regions.
(HQ/RGNS)
(3) We will implement the mandatory Agency-wide Quality
Assurance (QA) program which ensures that all environ-
mental measurements are of known and documented quality
and meet the requirements established by the responsi-
office or laboratory. Each program office, region, and
EPA laboratory must maintain a QA program consisting of
a QA program plan and appropriate updates, Data Quality
Objective (DQO's) for specific environmental data-
generative activities, and QA Project Plans for all
monitoring projects; and must provide for periodic audits
to assess compliance with approved QA plans. (HQ)
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III. TOXIC SUBSTANCES GUIDANCE
The 1988 Toxic Substances program will continue to emphasize
the reduction of risks to public health and the environment
through a program of review and regulation of both existing and
new chemicals in conjunction with regional and State implement-
ation in the field. New to the toxic substances guidance in
1988 are program goals and objectives to carry out. the require-
ments of Title III of the Superfund Amendments and Reauthorization
Act (SARA) and the recently enacted Asbestos Hazard Emergency
Response Act.
A. PROGRAM GOAL : Prevent Risks From New Chemical Substances
In 1988, EPA will operate a careful but efficient premanu-
facture review program that is responsive to the workload demands
generated by industry's submission of notices. These new
chemical reviews will be coordinated with other programs to
ensure that decisions under TSCA are consistent with policy across
the Agency and that future environmental problems (e.g., air,
water, or disposal) are effectively prevented. New actions to
be implemented in 1988 include biotechnology rulemakings, a user
fee rule and a comprehensive hazard based significant new use
rule.
1. Program Objective: Subject all new chemicals to a meaningful
review, taking action on those that pose an unreasonable risk.
a . Key Program Activities :
(1) EPA will conduct reviews on all new chemical notices
within the respective statutory deadline, including
any notices for biotechnology products that fall
under TSCA's purview. We will take prompt action on
new chemicals which present unreasonable risks. (HQ)
(2) The new chemical review process will continue to
include attention to all media concerns so that future
environmental problems can be prevented, and will
continue to identify new chemicals that meet the
Agency's acute hazards criteria and thus should be
subject to reporting under Title III of SARA. (HQ)
(3) A new rule implementing a fee for reviewing new chemical
notices will take effect in 1988. The rule will propose
a fee of $100 for PMNs submitted by small business
concerns and for PMNs qualifying for low volume and
test market exemptions. All other PMNs will have a fee
of $2,500. (HQ)
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Proqram Objective: Protect society from potential risks
which may occur from biotechnology.
a. Key Program Activities:
(1) The biotechnology rulemakings to establish review
and reporting procedures under TSCA will be implemented.
They will require under section 8, the reporting of
releases of living organisms; under section 5, review
of any significant new uses for pathogens; and, under
section 5(h)(3), definition of research and development
for exemption purposes. (HQ)
(2) EPA will work through the regions to ensure that State
and local agencies are aware of biotechnology pre-
manufacture issues relevant to their areas. The
sharing of biotechnology PMN data must be consistent
with TSCA CBI procedures. (HQ/RGNS)
Program Objective: Protect society against risks which may
develop as new chemicals are commercialized.
a. Key Program Activities:
(1) During 1988 the emphasis on putting in place more
efficient follow up mechanisms will continue. The
general hazard-based criteria Significant New Use
Rule (SNUR) will be promulgated in 1988. New chem-
icals which meet the criteria will be automatically
added to the list of those for which SNUR procedures
must be followed (i.e., reporting to EPA before the
chemical is manufactured in greater quantities than
originally planned or for significant new uses).
(HQ)
(2) Implementation of the acrylate category SNUR and the
acrylate listing SNUR will also enhance the efficiency
of the follow-up program. The acrylates category
SNUR will establish protective equipment and record-
keeping requirements for all new acrylate substances
produced after the rule is promulgated. The acrylates
listing SNUR will establish these same requirements
for new acrylate substances that have already under-
gone PMN review or new acrylates that do not meet
the criteria.
(3) We will continue to issue chemical specific signif-
icant new use rules, when warranted, to require
notification of EPA if the chemical is to be used in
a different manner than described in the PMN. (HQ)
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B. PROGRAM GOAL; Reduce Significant Risks from Existing Chemicals
The 1988, we will maintain a strong Existing Chemicals program
Changes in the approach to existing chemical problems will include
frequent senior level involvement in existing chemical reviews
to focus resources on the most significant problems, continued
coordination with other offices and other agencies to facilitate
integration of related actions, and continuation of the chemical
category approach. The program will be focused toward intermedia
chemical problems where TSCA authorities, TSCA data, and staff
expertise can be effectively applied to priority Agency existing
chemical problems.
1. Program Objective: Identify and evaluate the potential risks
of suspected existing chemicals.
(1) In 1988, the program will provide information to other
EPA offices, States, and other agencies, as a result of
the Comprehensive Assessment Information Rule (CAIR)
and inventory update reporting. Under the CAIR rule,
manufacturers are required to report various types of
information for specific chemicals. Chemicals may be
added quickly to the list by publishing a Federal Register
Notice. In addition, the program will continue to
screen incoming data from section 4 test rules, section
8 reporting and other sources (like the new chemicals
program) to highlight information that requires more
detailed review. Incoming data will be routinely disse-
minated to other EPA programs, States and other agencies.
(HQ/RGNS)
(2) The program will continue to address petitions under
TSCA section 21, taking steps to keep regions and other
interested groups abreast of TSCA actions. (HQ/RGNS)
(3) Section 4 test rules will address Interagency Testing
Committee (ITC) designations but will also continue to
respond to critical data needs of EPA programs. (HQ)
(4) Baseline and trend data on human exposure to chemicals
will be made available to other program offices, States
and other agencies when requested. These data are
developed through the National Human Monitoring Program
(NHMP) which includes the Adipose Network and a Blood
Network. Data from these networks will be used to
identify chemicals for Section 4 test rules, to develop
baseline/trend data necessary to support regional and
State evaluation of local concerns, to set priorities
for existing chemical assessments, and to monitor
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environmental results. (HQ/RGNS)
Program Objective: Initiate and promulgate regulatory
actions under TSCA to reduce risks to human health and the
environment from existing chemicals. (Risk management
actions on PCBs and asbestos are addressed under separate
objectives).
a. Key Program Activities:
(1) In 1988, approximately 10 risk management actions are
planned. Risk management actions include section 6
rules, section 9 referrals, section 5 significant new
use rules and chemical advisories. The regions will
serve on workgroups, as appropriate to ensure that
their issues are addressed. (HQ/RGNS)
(2) The regulatory investigation of risks associated with
exposure to formaldehyde emissions from wood products
used in the construction of mobile and conventional
homes will be completed. Regulatory options for
reduction of risk are being developed in consultation
with other EPA programs, regional offices, HUD and
CPSC. (HQ/RGNS)
(3) OPTS, in consultation with other EPA program offices,
the regions and other Federal agencies, developed a
crossmedia strategy for addressing exposure to methy-
lene chloride and several other chlorinated solvents.
We will assess control measures from several Agency
statutes, including TSCA. (HQ/RGNS)
Program Objective: Initiate and promulgate regulatory actions
under TSCA to reduce risks to human health and the environ-
ment from PCBs.
a. Key Program Activities:
(1) OPTS will implement the PCB Spills Clean-up Policy
Statement establishing nationwide standards for PCB
cleanup operations when PCBs have been illegally
disposed of by spill, leak or other uncontrolled
discharge. In addition, PCB recordkeeping amendments
to require maintenance of PCB clean-up records will
be put in final form. (HQ)
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(2) OPTS will put in final form amendments to the 1984
PCB rule which covers inadvertently generated or
uncontrolled PCBs in response to a consent agreement
to resolve the judicial challenge. (HQ)
(3) In accordance with a consent agreement, OPTS will put
in final form amendments to the PCB transformer fires
rule which places restrictions on continued use of
PCB transformers. (HQ)
(4) OPTS will continue review of PCB exemption requests.
Exemptions from prohibitions may be granted where they
will not pose an unreasonable risk to health or the
environment and have met the good faith efforts test to
find a substitute for PCBs in the activity. (HQ)
4. Program Objective: Insure integrity of data submitted to EPA.
a- Key Program Activities
(1) We will perform full-scale audits of completed test
studies that have been submitted to the Agency and in-
process audits that are being conducted. (HQ)
(2) Ensuring compliance with Good Laboratory Practices (GLP)
requirements is a high priority for the Agencv. In
coordination with FDA, the regions and headquarters will
perform (GLP) inspection at testing facilities. (HQ/
RGNS)
(3) We will implement the mandatory Agency-Wide Quality
Assurance (QA) program which ensures that all environ-
mental measures are of known and documented quality
and meet the requirements established by the responsible
office or laboratory. Each program office, region, and
EPA laboratory must maintain QA programs consisting of
a program plan and appropriate updates, Data Quality
Objectives (DOO's) for specific environmental data-
generative activities, and QA Project Plans for all
monitoring projects, and must provide for periodic
audits to assess compliance with approved QA plans.
(HQ/RGNS)
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5. Program Objective: Conduct research and develop methodologies
to support existing chemicals risk reduction efforts.
a. Key Program Activities:
(1) The research program will emphasize the development
of methodologies and techniques needed to evaluate
health and environmental risks associated with
existing chemicals. These important tools are
critical to both the testing and regulation of
existing chemicals. (HQ)
(2) Short-term testing will be conducted to fill
critical data gaps for regulatory decision making
on important chemical classes. (HQ)
(3) We will continue to develop assessment methodologies
based upon structural characteristics and physical-
chemical properties. These will be used to screen
classes or categories of both new and existing
chemicals for potential risks and to prioritize
chemicals within a category. (HQ)
(4) The research program will continue to develop models
to define exposure pathway for toxic chemicals;
methods to extrapolate data from animals to humans;
and models and methodologies for predicting quanti-
tatively the toxic activity of chemicals. (HQ)
(5) Finally, data and models will be developed to
predict the release of and exposure to new and
existing chemicals via research in environmental
engineering and technology. (HQ)
6. Program Objective: Improve compliance with all toxic
substances regulations.
a. Key Program Activities:
(1) Because of confidential business information concerns
the Agency will continue to have the responsibility
to conduct Federal compliance monitoring programs
for TSCA section 5, 8, 12, and 13. Compliance with
TSCA section 6 and future activities under the
Asbestos Hazard Emergency Response Act will continue
to be a joint responsibility of EPA and the States.
(RGNS)
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(2) Hazard assessment and information collection in-
spections under TSCA section 5 and 8 will be
conducted by regions and/or headquarters (NEIC).
(HQ/RGNS)
(3) EPA will continue to provide Federal case develop-
ment support for all enforcement actions, including
those resulting from State inspection activity
(until the enactment of State laws). Enforcement
and ligigation priorities will include laboratory
data cases, PMN cases, and PCB disposal,. In cases
involving settlement with conditions, the regions
will insure the conditions are met. (RGNS)
(4) Federal PCB inspections will decrease by approxi-
mately 20% in 1988. Resources saved will be shifted
to PCB case development to help eliminate the case
development backlog. (RGNS)
(5) The Agency seeks to integrate criminal enforcement
into the overall compliance monitoring/enforcement
programs. Accordingly, Regions should Identify and
refer to the Office of Criminal Investigation (OCI)
cases or incidents that concern knowing/willful
violations resulting in human death or major environ-
mental harm, that involve egregious repeat offenders,
or that involve data fraud. Activities to integrate
the programs should include cross-referrals within
the regions between OCI and the program office. The
regions will also provide technical and program
support to criminal investigations and prosecutions,
as necessary. (HQ/RGNS)
(6) Compliance assistance will receive continued at-
tention in 1988. Compliance assistance involves
alerting the regulated community (including Federal
facilities) of EPA regulatory actions, and providing
advice and direct assistance to industry in its
efforts to comply with TSCA rules. These tasks are
particularly important between the time EPA issues
a proposed or final rule and the time a final rule
becomes effective and enforceable. Outreach and
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interaction before EPA begins compliance monitoring
for a new rule will increase the capacity of industry
to comply and result in more effective use of EPA
compliance monitoring resources. (RGNS)
(7) Headquartersr with input from the regions, will con-
tinue to revise the FIFRA and TSCA Enforcement
System (FATES) to increase its efficiency and use-
fulness. (HQ)
(8) EPA will continue to send draft enforcement response
policies, compliance monitoring strategies, and
inspection guidance to the Regional Offices and, as
necessary, to the States, for comment before publi-
cation. (HQ/RGNS)
(9) We will continue to emphasize small business
compliance issues in developing TSCA compliance
monitoring strategies. (HQ/RGNS)
(10) EPA will conduct compliance monitoring programs at
Federal facilities. OPTS will implement the new
Federal Facilities Compliance Strategy, when it
becomes final, by providing appropriate technical
assistance and taking action when violations occur
at Federal facilities. The regions will cooperate
with their respective Regional Federal Facilities
Coordinators by providing information and reports
on their Federal facility compliance monitoring
programs. (HQ/RGNS)
(11) We will actively participate in regional reviews of
Federal facility A-106 pollution abatement plans and
provide comments on Federal agency projects proposed
for the toxic substances program. Comments will
focus on project adequacy in terms of engineering
timing, cost, and overall impact on the environment
if not funded. The regions will conduct these
reviews in accordance with instructions provided by
their respective Regional Federal Facilities
Coordinator. Regional program staff will coordinate
their comments with program counterparts in the
States during the initial review period (i.e.,
January-March). The regions will also assist the
Regional Federal Facilities Coordinators in identi-
fying Federal facilities that fall within the toxic
substances program priority areas selected annually
for the A-106 process by the Headquarters program
office. (HQ/REGNS)
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B. PROGRAM GOAL; Address Hazards from Asbestos
In 1988, the Asbestos Action Program will continue to empha-
size technical assistance to schools. Action will continue
under the Asbestos Hazards Emergency Response Act to assist
local education agencies in asbestos inspection, control and
abatement. Grants to states for asbestos inspection
certification will be initiated.
1. Program Objective: Strengthen the asbestos-in-schools
and public and commercial buildings program.
a. Key Program Activities:
(1) Technical assistance activities will be continued.
Activities include (1) operation of the TSCA Assistance
phone line, (2) guidance to school officials and public
and commercial building owners and managers, and (3)
dissemination of information materials. The role of
the Regional Asbestos Coordinators and inspectors, hired
under the American Association of Retired Persons
(AARP) Senior Environmental Employment Program, will
continue as an integral element of the technical
assistance program as they provide assistance on both
abatement and compliance issues. (HQ/RGNS)
(2) Five Regional Training and Information Centers were es-
tablished in 1985 and 1986 to provide information con-
cerning the identification and abatement of asbestos
hazards and to educate and train people in proper
asbestos identification and abatement techniques. The
centers will be operated in 1988, with two receiving a
final allotment of Federal funds. (HQ/RGNS)
(3) EPA grants to states for contractor certification pro-
grams will shift to inspector and perhaps school manag-
ment plan developer accreditation programs in 1988.
These programs help ensure adequate training qualifi-
cations and certification of those involved in asbestos
hazard identification, assessment and abatement. (HQ/RGNS)
(4) Compliance with the worker protection rule for public
employees not covered by the current OSHA rule will
continue to be a major priority in 1988 for both the
regions and the contractor. We also anticipate that
inspection activities will be directed toward compliance
with the contractor certification requirements imposed
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by Congress through the ASHAA program, asbestos abate-
ment worker training rules to be proposed by OSHA and
EPA, and the requirement of the recently enacted Asbestos
Hazard Emergency Response Act (AHERA). Wherever TSCA
enforcement cooperative agreements are in place, the
States will conduct compliance monitoring inspections
in support of the asbestos worker protection rule.
(RGNS)
(5) The Agency will promulgate the Section 6 rule to ban
certain asbestos products and to phase out the use of
asbestos in other products over a 10 year period. The
final rule will address the extensive comments raised
on the proposed rule. Publication is planned in June
1988. (HQ)
(6) We will continue to refine guidelines to assist the
public in identifying those situations in which asbestos
containing materials present a serious risk. (HQ)
(7) Field studies to examine the efficacy of various
asbestos abatement technologies, and the feasibility
of air monitoring before, during, and after abatement
will continue in 1988. Because of the insidious
environmental characteristics of asbestos, control
technologies must be thoroughly investigated prior to
public recommendation or endorsement by EPA. (HQ/RGNS)
(8) Monitoring and field follow-up will be required for 1986
and 1987 school asbestos abatement projects which received
loans and grants under the Asbestos School Hazard Abatement
Act. (HQ/RGNS)
2. Program Objective: implement the provisions of the Asbestos +
Hazard Emergency Response Act (AHERA).
While most of the action required of EPA by AHERA will take
place in fiscal year 1987, a number of activities will con-
tinue in 1988.
a. Key Program Activities
(1) EPA will promulgate by October 22, 1987 AHERA
regulations on asbestos inspections, circumstances
which require response actions, appropriate response
actions, the implementation and completion of these
actions, periodic surveillance, operations and plan-
ing by schools. (HQ)
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(2) EPA will assist the States and local education agencies
(LEAs) in implementing new regulatory standards on
asbestos inspection, control and abatement in schools
to reduce or eliminate asbestos hazards. (HQ/RGNS)
(3) EPA will assist the States as they implement
accreditation programs, developed from EPA model
plans, for asbestos contractors, inspectors and
management plans submitted to them by individual
schools. (HQ/RGNS)
(4) EPA will provide technical assistance to help LEA's
develop appropriate asbestos management plans by
1989 and to complete them in a timely manner. (RGNS)
(5) EPA will complete, by October 1987, a study of asbestos
hazards in public and commercial buildings and recommend
what AHERA school rules, if any, should also be applied
to these buildings. (HQ/RGNS)
(6) EPA will provide an interim report to Congress on the
availability of liability insurance for schools and
contractors by April 1, 1988 with a final report due
October 1, 1990. (HQ)
D. PROGRAM GOAL: Support Agency Priorities Under Other Statutes
The TSCA program will be more focused on intermedia problems
where TSCA authorities, data, and chemical expertise can assist
the Agency in making regulatory decisions under other statutes.
This means we will place a strong emphasis on working jointly
with others to achieve coordinated regulatory and enforcement
strategies on priority cross media problems as well as on educating
others as to the features of TSCA, the data and staff expertise
that can be effectively used to accomplish integrated approaches
to complex chemical problems.
1. Program Objective; Continue to assist others in assessing
chemical risks
a- Key Program Activities:
(1) The Chemical Assessment Desk project will be continued
in 1988. The Chemical Assessment Desk provides consul-
tation to EPA program offices, regional offices, and
other Federal agencies on chemical toxicity and exposure
potential. Responses to questions are based on available
OTS information and evaluations plus information from
other EPA programs. The Chemical Assessment Desk essenti-
ally operates as a central point for obtaining all inform-
ation currently known about a chemical. At the end of
1986, the pilot project included regions 1, 4, 8, and 9.
(HQ/RGNS)
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(2) Regions will work with their counterparts in other media
offices to ensure that TSCA information gathering authori-
ties are used to their fullest to support other program
initiatives. Every effort will be made to use TSCA
authorities in a manner which increases the regions
overall effectiveness. The toxics staff will promote
this throuqh outreach activities within the regional
office. (RGNS)
(3) OTS will provide rulemaking support and data analyses
for the approximately 50 inert substances. This action
supports the OPTS inerts strategy. (HQ)
(4) The Graphical Exposure Monitoring System (GEMS) will
continue to be used throughout EPA, other agencies,
some States and Canada during 1988. GEMS is an inter-
active computer system used to estimate a chemical's
properties and environmental fate from the structure
of organic molecules. GEMS has been demonstrated to
all regions and most regions have established user
accounts so they can more readily use GEMS to assess
local situations. (HQ/RGNS)
(5) We will continue to use the structure activity
relationship (SAR) technique developed by OTS to
predict a chemical's toxicity for other programs. SAR
is a good screening tool when data on the chemical
are not available. (HQ)
2. Program Objective: Assist the public and educate other
offices as to TSCA requirements and features
a- Key Program Activities:
(1) The region will continue to educate industry as to
applicable TSCA requirements, including the TSCA
inventory, and respond to questions from the public
on TSCA. (RGNS)
(2) We will continue outreach efforts through regional/
program office briefings with the goal of making TSCA
authorities available to assist in risk assessments.
The TSCA Assistance Office (TAG) serves as a broker
for unpublished or inaccessible data which can be
invaluable for other EPA programs as well as States
and regions. (HQ/RGNS)
(3) we will work to increase awareness of Title III SARA
activities and other new programs being implemented
by OTS. This includes holding public meetings and
developing mechanisms to further the ability of States
and regions to have input into OTS activities. (HQ/
RGNS)
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E. PROGRAM GOAL: Meet the Requirements of the Title III
Emergency Planning and Community Right-to-Know amendment.
Title III of the Superfund Amendments and Reauthorization
Act (SARA) of 1986 requires a substantial program of emergency
planning, community right-to-know, and emissions inventory
provisions aimed at increasing the public's awareness of human
health and environmental risks. OPTS has the lead responsibility
for the emissions inventory component of section 313, for trade
secret review and processing under section 322, and will continue
to provide technical support to the Office of Solid Waste and
Emergency Response (OSWER) under other sections of SARA.
1. Program Objective: Implement the Toxic Emissions Reporting
Requirements of section 313 of SARA.
a. Key Program Activities:
(1) Implementation of the emissions inventory reporting
will begin. The design of the emissions inventory
data base will be completed as well as mechanisms for
public access. Emphasis will be placed on review and
processing of the emissions inventory forms in order
to ensure the quality and utility of data collected.
(HQ)
(2) Technical support to submitters as well as concerned
citizens groups will be expanded. Support will encom-
pass explanations of reporting requirements, assistance
in completion of form elements, and associated resource
expertise. (HQ/RGNS)
(3) Trade secret review and claims process will be ini
tiated. (HQ)
2. Program Objective: Provide technical support to OSWER
a. Key Program Activities:
(1) Support will be provided for revising and expanding
technical guidance for emergency planning and community
right-to-know programs. This will include revisions
to chemical profiles, new criteria for hazard identi-
fication, supplemental information on accidental re-
leases, etc. (HQ)
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3. Program Objective: Provide enforcement for Title III
a. Key Program Activities:
(1) The enforcement program will integrate SARA Title
III reporting requirements into other inspections per-
formed under TSCA sec. 5 and 8. We will also target
additional inspections specifically for Title III
purposes. All such inspections will be performed by
the regions and/or headquarters (NEIC). HQ/RGNS)
F. PROGRAM GOAL: Meet the Requirements of Section 110 of the
Superfund Amendments and Reauthorization Act. Section 110
of SARA requires that EPA and the Agency for Toxic Substances
and Disease Registry prepare, by April 17, 1987, a priority-
ordered list of the 100 or more hazardous substances, found
at Superfund National Priority List sites. The list is to
contain those substances which the Agencies consider to pose
the most significant potential threats to human health due
to their known or potential toxicity and the potential for
human exposure. By October 17, 1988 toxic substances must
be added to the list.
1. Program Objective: Meet the requirements of section
110 of SARA
a. Key Program Activities:
(1) EPA will assist ATSDR in continuing effort, begun
in 1987, in developing toxicological profiles for
each substance proposed to be included on the list.
(HQ)
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OFFICE OF EXTERNAL AFFAIRS
I. EXECUTIVE SUMMARY
The Office of External Affairs (OEA) is the Agency's focal point
for communicating the Agency's program activities and policies to
the public, Congress, other Federal agencies, the media, the
regulated community and special interest groups. OEA and its
counterparts in the regional offices have the ultimate
responsibility for ensuring that the Agency's business is
conducted as openly and candidly as possible.
OEA provides a number of support functions for the EPA regional
offices. Vital to this support is OEA's work with the regional
offices in designing and implementing Agency wide communications
processes to ensure accurate and useful information to EPA's
constituencies.
Within the Office of External Affairs (OEA), the Office of
Federal Activities (OFA) is responsible for establishing
effective liaison and coordination between EPA and other Federal
agencies on environmental issues. OFA also assures, to the
extent possible, that other Federal agencies carry out their
activities in an environmentally sound manner, that EPA's
programs comply with the goals and requirements of the National
Environmental Policy Act (NEPA) and related environmental
legislation, and that coordination of the implementation of EPA's
Indian Policy of November 8, 1984, is provided.
This guidance presents national goals and objectives for the
Federal Activities Programs for FY 1988. The guidance also
identifies the action that EPA and, where appropriate, States
must take to implement these goals and objectives. The guidance
consists of three parts. The first part provides an overview of
Federal Activities Programs, summarizes the four major goals
which shape the four major programs, and highlights major changes
in emphasis or direction. The second part describes program
objectives for each goal/program and lists the specific actions
that must be taken to carry out the national strategy. This part
also identifies general priorities/directions for FY 1989 which
will be used in the formulation of national program strategies
and budget requests. The third part details the specific
performance measures that will be used in tracking our success in
addressing FY 1988 objectives.
A. Communications Goals for FY 1988
EPA Communication Processes; Agency-wide implementation of
the communication strategy process has yielded significant
benefits in two areas. First, it has brought to the
attention of EPA program managers the importance of
considering the impacts of major agency actions at the same
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time as the actions are being planned. Second, as a result
of better planning the Agency has improved the quality of
information being provided to those who are most concerned
with specific Agency actions. To build upon this progress,
the Agency will continue to refine the communication
strategy process and institutionalize the EPA Annual
Communications Plans. These plans will enable better long-
range planning for our communications projects and a clearer
identification of their resource implications. In addition,
the communications plans will serve as a useful vehicle for
highlighting and addressing priority Agency activities.
Improving the effectiveness of the Agency's communication of
risk issues and improving risk minimization practices will
be a major theme of EPA's FY 1988 communications plans.
Delivering EPA's Message; To date, the focus of the
Agency's communications strategy process has been mainly
upon improving communications planning for internal, Agency-
initiated actions. This focus is now being shifted. In the
coming fiscal year OEA and the regional offices will take
the initiative by seeking out and responding to the
information needs of major external constituencies. While
providing these constituencies with what they need, the
Agency will also emphasize its own messages such as the
search for environmental protection actions which achieve
the greatest social benefit in balance with other goals.
The first step in this initiative will be to link a network
of the Agency's best communications resources individuals
identified by each regional and program office for their
exceptional writing skills and extensive knowledge of policy
and technical issues. OEA's speaker services staff will
actively market the information developed by these
individuals, along with material developed for other
purposes (for example, Congressional testimony, speeches,
etc.) to specific high-priority Agency target audiences.
In addition, OEA's speakers services staff will make
available to the EPA communicators network potentially
useful and effective information produced elsewhere in the
Agency. This active outreach program should further
improve appreciation of our programs by key external
constituencies. It will also serve to achieve greater
exposure for information already being developed by the
Agency for other purposes.
Environmental Federalism; The State/EPA Committee has
become an important conduit for interactions between
representatives of state environmental departments and
Agency managers. Increased involvement of regional offices
in the State/EPA Committee will further the Agency goal of
allocating environmental responsibilities to the most
appropriate level of government. In addition, a greater
emphasis upon effectively packaging and transferring
technical information and assistance to those who need it
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most will help to improve the effectiveness of environmental
management at all levels. A revitalized community
involvement program will allow the sharing of information
and experiences across the Agency to improve efforts to
involve and inform local communities which are or may be
impacted by Agency activities. National networks of private
sector organizations will play a large role in this
information exchange and public outreach.
Youth Program; It is very much in the Agency's interests to
increase understanding of environmental management issues
among the nation's youth. Young people, both as individuals
and as future industry employees, will help to determine the
future quality of our air, land, water and natural
resources. For example, early training in the proper
handling of pesticides and other potentially toxic
substances can help to avoid the types of actions which
cause environmental damage and require expensive clean-up.
The most effective way for the Agency's youth program to
work is by developing cooperative partnerships with the
states and private sector. Fiscal Year 1988 will see major
efforts within the Agency to coordinate youth program
activities within headquarters and the regional offices.
B. Federal Activities Goals for FY 1988
In addition to Agency responsibility for communications
activities, OEA administers four national programs which
contribute toward accomplishment of the fundamental EPA mission
and its major goals:
1. Environmental Review Program. Goal: Prevent future
environmental problems from major Federal projects and
activities by providing effective EPA input through
participation and review in accordance with the provisions
of Section 309 of the Clean Air Act and of the National
Environmental Policy Act (NEPA).
2. NEPA Compliance Program. Goal: Protect and enhance
environmental quality through ensuring compliance by EPA and
delegated States (as appropriate) with the goals and/or
requirements of the National Environmental Policy Act (NEPA)
and related laws and directives.
3. Federal Facilities Compliance Program. Goal: Ensure
the Federal Government shows leadership in environmental
control practices through Federal facility compliance with
air, water, toxic, and hazardous waste requirements.
4. Indian Program. Goal: Ensure environmental protection
on American Indian reservations through focused
implementation of EPA's authorities and programs on the
special environmental problems of Indian lands and people.
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Each of the OEA programs managed by OFA supports more than one of
the points in the Administrator's Management Plan. Because of
their multi-media and crosscutting nature, these programs are
implemented in close coordination with the media programs at both
Headquarters and Regional levels, and help address many of the
subjects on the FY 1988 Agency Priority List.
Collectively, these programs cut across all environmental media
and consider a broad range of impacts on environmental values and
natural resources, as well as public health. In this regard,
OFA's program goals and objectives serve both as independent
goals for focusing Federal Activities resources and as key
elements in supporting the goals of the major media programs.
For example, the Federal Facilities Compliance and Indian
Programs both address such Agency priorities as compliance with
air quality standards, groundwater protection, and hazardous
waste site clean-up, where these are significant issues with
respect to Federal Facilities or Indian lands. For these two
programs, most of the resources and implementation
responsibilities are in the media programs, with Federal
Activities personnel playing a key coordinating and catalytic
role.
Federal Activities functions also serve as EPA's primary focal
point for working with other Federal agencies to ensure that they
carry out their project-related activities in an environmentally
sound manner. The Environmental Review Program provides EPA with
a unique opportunity to anticipate and prevent future
environmental problems associated with Federal actions, by
affording the opportunity to influence decisions, often where it
is too early in the planning cycle for direct application of EPA
regulatory authorities. EPA's NEPA Compliance Program plays a
similar role internally by encouraging consideration of the full
range of environmental impacts in EPA's project and regulatory
planning. By focusing on the full range of potential
environmental impacts in evaluating Agency actions, such as the
award of sewage treatment construction grants and issuance of new
source NPDES permits, EPA can assure that environmental effects
can be identified and minimized.
The Federal Activities programs have a key role in reducing
damage to sensitive environmental areas such as wetlands,
riparian zones, and near coastal waters. This is achieved
through the preparation or review of environmental impact
assessments dealing with the projects or activities of EPA and
other Federal agencies.
C. Changes in Program Direction
The FY 1988 Guidance represents no major change in direction from
the current Guidance. Rather, the new Guidance reflects
incremental changes in emphasis or approach which track the
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continuing evolution of these programs. An increased emphasis on
early public participation is a noteworthy change.
1. MAJOR PROGRAM GOAL; PREVENT FUTURE ENVIRONMENTAL PROBLEMS
FROM MAJOR FEDERAL PROJECTS AND ACTIVITIES BY PROVIDING
EFFECTIVE EPA INPUT THROUGH PARTICIPATION AND REVIEW IN
ACCORDANCE WITH THE PROVISIONS OF SECTION 309 OF THE CLEAN
AIR ACT AND OF THE NATIONAL ENVIRONMENTAL POLICY ACT (NEPA).
FY 1988 Guidance
a. In FY 88, the Environmental Review Program (ERP) will orient
its Federal project review activities towards prevention of
environmental problems related to the Administrator's
priority areas of reducing risks from exposure to pesticides,
reducing exposure to unhealthy air quality, prevention of
ground-water contamination, reducing risks from hazardous
wastes, improving protection of surface waters, and improving
protection of wetland systems.
ERP staff at Headguarters and Regional levels will place high
emphasis on specific liaison activities with Federal agencies
to ensure that they are aware of EPA regulatory or
programmatic policies and initiatives dealing with the
priority environmental problems. Federal agencies,
especially at the field level, will be encouraged to become
constructively involved in promoting regulatory compliance
with and participation in EPA initiatives for the resolution
of these environmental problems. This activity, in
conjunction with the project-specific liaison described
below, is intended to ensure that where possible EPA's
programmatic goals are not compromised through the actions
and projects of other Federal agencies.
ERP reviewers at both the Headguarters and Regional levels
will focus their pre-Environmental Impact
Statement/Environmental Assessment (EIS/EA) activities on
early involvement with those classes of Federal projects that
have the potential for the greatest environmental impacts in
the priority areas. For these high priority projects, EPA
will seek to provide input to agencies' project development
processes to ensure consideration of the full range of
alternatives and appropriate use of assessment methodologies.
Early participation or consultation in Federal agency
planning processes should surface, and lead to correction of,
potential problems at the earlier stages of project planning.
ERP reviewers at the headquarters and regional levels will
conduct follow-up liaison on all project reviews where EPA
has identified significant environmental problems. The
purpose of follow-up is to explain EPA's concerns and to
obtain positive agency responses to EPA's specific
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recommendations. Where necessary to resolve significant
environmental problems, the reviewers will elevate projects
to higher EPA management levels. Provide staff assistance
and technical expertise in developing EISs which EPA
voluntarily prepares for ocean disposal site designations.
b. Key Program Activities
In setting Region specific review priorities and goals for FY
88, reviewers should give special consideration to projects
with potential problems that fall within the six priority
areas. Accordingly, at a minimum, reviewers should:
* (1) Emphasize reviews of Federal land management agencies'
vegetation and pest management programs and other agencies'
use of registered pesticides in sensitive environmental areas
to reduce risks from exposure to pesticides and to toxic
chemicals.
* (2) Carefully review Federal transportation and energy
projects (including outer continental shelf oil and gas
activities) to ensure consistency with plans and policies for
air standards attainment and maintenance programs.
* (3) Emphasize review of potential ground water impacts from
major construction and energy related projects and injection
well activities and ensure that maximum impact mitigation is
utilized.
* (4) Carefully review all NEPA analyses related to siting,
relocating, and clean-up of hazardous waste facilities to
ensure full consideration of long-term, cross-media impacts.
* (5) Work with the Federal agencies to maintain and improve
water quality with particular efforts to ensure that non-
point source related activities of other Federal agencies
support State objectives and that Federal lands are managed
to minimize or eliminate non-point source pollution, [from
proposed activities]
* (6) Emphasize reviews of Federal construction and land
management projects impacting wetlands and other sensitive
areas to ensure that, first, these impacts are avoided and
second, that unavoidable impacts are mitigated in accordance
with Federal policy.
2. MAJOR PROGRAM GOAL; PROTECT AND ENHANCE ENVIRONMENTAL
QUALITY THROUGH ENSURING EPA COMPLIANCE WITH THE GOALS AND/OR
REQUIREMENTS OF THE NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)
AND RELATED LAWS AND DIRECTIVES.
FY 1988 Guidance
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a. The objectives of the NEPA Compliance Program are to: (1)
help improve EPA decision-making in order to avoid
unanticipated environmental impacts, with an emphasis on
identification of alternatives and the full range of
potential impacts, including impacts on natural resources and
possible intermedia transfer of pollutants, and
identification of mitigating measures to avoid or minimize
adverse impacts; and (2) ensure that EPA complies with the
requirements and procedures of other relevant environmental
laws and directives. It should be noted that environmental
impact assessment lessens the possibility of intermedia
transfer of pollutants and therefore relates directly to the
more specific Agency priorities.
The interdisciplinary experience developed in the course of
NEPA compliance (primarily for water media programs) is
increasingly involved in assisting other EPA program areas.
In FY 88, the NEPA Compliance Program will continue to be
directed to ensure that EPA's regulatory and other
programmatic actions comply with the goals and/or
requirements of NEPA and other related laws. The program
will be used to promote improved decision-making for complex
and controversial projects through comprehensive
environmental impact analyses, impact mitigation and public
involvement. Emphasis will be placed on those activities
with the greatest potential for adverse public health or
natural resource impacts and intermedia pollution transfers.
A major area of activity will be required to support NEPA
requirements for off-shore oil and gas permitting. In
addition to those programs for which formal NEPA analysis is
required, the NEPA compliance program will also continue to
assist agency programs, especially those with potential
intermedia or natural resource impacts, in carrying out
review processes that are functionally equivalent to NEPA.
Assistance will also be provided for compliance by EPA with
the requirements and directives of other Federal statutes and
Executive Orders affecting such environmental values as
wetlands, floodplains, coastal zones, historic preservation,
and endangered species.
b. Key Program Activities
In addition to EPA's continuing responsibilities for NEPA
analyses for construction grants, new source NPDES permits,
and related special or generic studies, the following
activities will be afforded special emphasis in FY 88 as
resources allow:
* (1) Assist in site-specific evaluations, e.g., working with
CERCLA staff in the development of feasibility studies for
remedial actions and RCRA staff on permitting activities,
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emphasizing the analysis of alternatives, cross-media
impacts, mitigation, and public involvement. (Regions)
(2) Improve communication with other Federal agencies
responsible for implementation of environmental laws and
Executive Orders with which EPA programs must comply, in
order to evaluate problem areas and facilitate Agency
compliance. (OFA, Regions)
(3) Continue to provide oversight and assistance to Agency
programs in complying with the requirements of other Federal
environmental laws and relevant Executive Orders affecting
wetlands, floodplains, agricultural lands, coastal zones,
wild and scenic rivers, fish and wildlife, endangered
species, historic and archaeological sites, etc. (OFA,
Regions)
(4) Evaluate the effectiveness of NEPA compliance activities
on selected projects for which FNSI/EAs or EISs were issued,
with an emphasis on accuracy of impact prediction, actual
installation of proposed mitigation measures and
effectiveness of implemented mitigation measures. (OFA,
Regions)
3. MAJOR PROGRAM GOAL: ENSURE THE FEDERAL GOVERNMENT
DEMONSTRATES LEADERSHIP IN ENVIRONMENTAL CONTROL PRACTICES
THROUGH INCREASED UP-FRONT FEDERAL FACILITY COMPLIANCE WITH
AIR, WATER, TOXIC AND HAZARDOUS WASTE REQUIREMENTS.
FY 1988 Guidance
a. The purpose of the Federal Facilities Compliance Program is
to help ensure that Federal facilities are brought into
compliance in the most cost-effective and timely manner
possible. In FY 1987, the revised Federal Facilities
Compliance Strategy was issued following a coordinated Agency
wide effort lead by OFA and OECM and involving all media
program offices in Headquarters and the Regions. The
Strategy establishes a comprehensive and proactive approach
to achieving and maintaining high rates of compliance at
Federal facilities. It provides the basic framework for all
EPA media programs to follow to ensure that Federal
facilities are fully integrated into EPA and State compliance
monitoring and enforcement activities. The Strategy serves
as the primary guidance document for the Federal Facilities
Compliance Program with the OFA Operating Guidance setting
annual priorities and activities for implementation of the
Strategy.
The approach set forth in the Strategy and in this FY 1988
Operating Guidance is most closely aligned with three of
EPA's Management Priorities: Environmental Federalism,
Negotiation and Consultation, and Enforcement. This guidance
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recognizes that coordination and cooperation among EPA, the
States and other Federal agencies is a necessary element for
achieving our mutual goal of environmental protection. It
provides for increased EPA technical assistance to Federal
agencies to help "ensure their cost effective and timely
compliance" as required by Executive Order 12088. With
Federal facilities, negotiation and early involvement and
consultation continue to be the most practical mechanisms
available for effective and long-term solutions to
environmental compliance problems. The new Strategy calls
for the use of mutually negotiated bilateral Compliance
Agreements in the first instance for the resolution of
violations at Federal Facilities. Lastly, the obligation of
Federal Facilities to comply with environmental requirements
is generally the same as private parties and EPA and the
State will take all actions necessary to ensure that
violating Federal facilities are returned to compliance in as
timely a manner as possible. The Strategy outlines EPA's
enforcement response procedures, requires Federal facility
adherence to all media program "timely and appropriate"
response time-frames, and establishes a formal dispute
resolution process under Executive Order 12088 for cases
where agreement cannot be reached in a timely manner.
In FY 1987, the top priorities for the Federal Facilities
compliance Program are:
(1) To improve the effectiveness of the A-106 planning
process and the A-106 projects more closely to identified EPA
media program priorities;
(2) To provide timely and improved technical assistance to
Federal agencies to help ensure their compliance with all
environmental regulations, particularly, those related to
newly reauthorized statutes (e.g., CERCLA/SARA, RCRA/HSWA,
SDWA); and
(3) To improve the overall identification and tracking of
compliance status of the Federal facility universe.
b. Key Program Activities;
(1) Increase technical assistance and training for Federal
facilities as required by Executive Order 12088.
a) Conduct periodic (e.g. monthly, bimonthly, or quarterly)
meetings with key Federal agency personnel to disseminate
information on new regulatory requirements.
(Headquarters, Regions)
b) Hold an annual multi-media workshop for Federal facility
environmental personnel in each Region. Special
workshops or seminars on new or reauthorized statutes
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(e.g. CERCLA) should also be presented as needed and
where resources allow. (Headquarters, Regions)
c) Make periodic coordination visits to significant Federal
facilities to provide program assistance and review major
A-106 projects. (Regions)
d) Develop Compliance Management Plans for the top three
Federal facilities identified in each Region to address
existing and potential compliance problems on a multi-
media basis. (Regions)
(2) Improve the identification, tracking and compliance
monitoring of Federal facilities.
a) Review and coordinate annual Regional/State inspection 4-
plans to ensure Federal facilities are being
inspected at least as frequently as the minimums
established in media program guidance. Also ensure that
Federal facilities are receiving the same percentage of
program oversight inspections as is done for other
sources. (Regions)
b) Review and update media program lists of majors and +
minors to ensure all Federal facilities are properly
classified and receiving required inspections.
(Headquarters, Regions)
c) Ensure that results of all Federal facilities inspections
are received from EPA Regional program offices and
State agencies in a timely manner through State/EPA
enforcement agreements or other means as appropriate.
(Regions, States)
d) Track the compliance status of all Federal facilities +
inspected during the fiscal year and report this
information to OFA quarterly on an agency-by-agency
basis. (Regions)
e) Update Regional lists and track the compliance status of
facilities identified as significant minors in each
media program and those Federal facilities identified as
the most environmentally significant on a multi-media
basis. (Regions)
f) Work with Regional program offices and Environmental
Services Divisions to conduct multi-media inspection ~
of Federal facilities where appropriate. Provide an
updated list of the ten Federal facilities identified as
the prime candidates for multi-media inspections during
FY 88. (Regions)
g) Accompany Regional media program staff on program and/or
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oversight inspections as appropriate and where resources
allow. (Regions)
(3) Improve the effectiveness of the A-106 Federal Agency
Pollution Abatement Planning Process. (Headquarters, Regions)
a) Coordinate the review and update of Federal agency A-106
plans with EPA Regional program staff and State agency
personnel as appropriate. (Regions)
b) Identify Federal facilities included in selected media +
' program priority areas and work with Federal agencies to
address any related compliance problems through the A-106
process or other means where appropriate. Report this
information to OFA as required by annual SPMS measures.
(Headquarters, Regions)
c) Conduct visits to priority A-106 projects to provide
technical assistance, review progress and participate in
pre-design meetings where resources allow. (Regions)
(4) Increase emphasis on returning Federal facilities to
compliance in a timely manner following the procedures
outlined in the revised Federal Facilities Compliance
Strategy and related media-program guidance.
a) Coordinate the negotiation of all Compliance Agreements
with Federal facilities, in cooperation with the media
program offices, within the established media-specific
"timely and appropriate" response timeframes. (Regions)
b) Escalate unresolved issues related to specific Federal
facilities violations to OFA for dispute resolution
through E.G. 12088 where necessary. (Headquarters,
Regions)
(5) Improve State/Federal relationships affecting Federal
Facility Compliance.
a) Continue efforts to have each State identify
counterparts to the Regional Federal Facilities
Coordinator through the State/EPA enforcement
agreements. (Regions, States)
b) Initiate actions through the State/EPA agreements to
ensure that delegated or authorized States inspect the
required numbers of Federal facilities and report the
results of inspections and enforcement actions to EPA in
a timely manner. (Regions, States)
c) Conduct at least one annual meeting with the States in +
each Region to identify and discuss patterns of non-
compliance at Federal facilities and to review Federal
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agency A-106 pollution abatement plans. (Regions,
States)
(6) Coordinate regularly with Regional Federal agency
staff and major installation personnel to ensure
development of environmental management and auditing
programs which will enable timely implementation of
requirements related to newly-authorized environmental
statutes (e.g. HSWA, SARA, and SDWA).
a) Help ensure timely Regional review of all Federal
agency assessments and plans submitted for abandoned
hazardous waste sites under SARA and correction action
plans for SWMUs under HSWA. In cooperation with
Regional program staff, develop a comprehensive
strategy for Regional review of Federal agency
documents submitted for all non-NPL hazardous waste
sites. (Regions)
4. MAJOR PROGRAM GOAL: ENSURE ENVIRONMENTAL PROTECTION ON
AMERICAN INDIAN RESERVATIONS THROUGH FOCUSED IMPLEMENTATION
OF EPA'S AUTHORITIES AND PROGRAMS ON THE SPECIAL
ENVIRONMENTAL PROBLEMS OF INDIAN LANDS AND PEOPLE.
FY 1988 Guidance
a. The objectives of EPA's Indian program are to: (1) directly
apply EPA's authorities and programs on Indian reservations;
(2) develop and enhance tribal institutional capabilities to
assist in the implementation of EPA's authorities and
programs on reservation lands; and (3) eliminate legislative
and regulatory barriers to program implementation (ranging
from partial participation of the tribe to full delegation of
programs to tribal governments). This program reflects the
fact that EPA retains program authority on Indian
reservations even where that reservation is geographically
located "in" a "delegated" State; our responsibilities remain
the same as in "non-delegated" States. It also aims to
ensure that the Agency's priorities are carried out on
reservation lands as well as on non-reservation lands. As
resources allow, regions should make funding available to
tribal governments, recognizing that it may be some time
before adequate resources become available.
In FY 88, EPA will continue to develop its programs along the
lines outlined in the interim Strategy for Implementation of
the EPA Indian Policy, within the constraints of available
resources. Direct program activity by Agency or reservation
lands will increase and, as the statutes are amended,
regulatory programs may begin to be delegated to Tribal
governments. Regions will maintain good communication with
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major Tribes, and will continue to provide technical
assistance to Tribal governments as they assess their
environmental problems and needs, and as they continue to
build up the institutional capability to deal with
environmental problems.
Innovative and alternative institutional options will receive
a high priority where they provide an effective means to
address environmental problems in terms of cost and
environmental results. The information base on environmental
problems on reservation lands will be updated and expanded to
additional reservations and will assist in focusing Agency
priorities on the most significant issues. OFA will continue
in its role of program coordinator, providing guidance,
direction, and oversight, as appropriate.
b. Key Program Activities
(1) Increase the level of direct programmatic involvement on +
Indian reservations to address the most critical air, water,
and hazardous/radioactive waste problems consistent with the
overall goals and objectives of the media programs.
(Regions)
(2) Develop on a selective basis several Tribal/EPA
agreements analogous to State/EPA agreements identifying
priority environmental problems and measures to address them.
(Regions)
(3) Continue to provide direct technical assistance to
Tribal governments including assistance on problem
identification and infrastructure development. (Regions)
(4) Continue to strengthen external liaison with Indian
Tribal organizations and relevant Federal agencies.
(OFA/Media Programs/Regions)
(5) Strengthen outreach and liaison with Tribal governments,
providing information and opportunity to participate in EPA
programs, as appropriate. (Regions)
(6) Maintain and, as appropriate, update the data base
developed during the FY 86 Survey of Environmental Conditions
on Reservation Lands. (Regions)
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TABLE OF CONTENTS
TOPIC PAGE
I. EXECUTIVE SUMMARY 1
II. OPERATING GUIDANCE 5
A. HUMAN RESOURCES MANAGEMENT 5
1. Employee Involvement/Communication 5
2. Managerial Excellence 6
3. Workforce Planning 6
4. Career Managanent 7
5. Training/Development Activities 7
B. STATE/EPA DATA MANAGEMENT 9
1. Objectives 9
2. EPA Regional Offices 10
3. EPA Program Offices 10
C. SUPERFUND FINANCIAL MANAGEMENT 11
1. Resource Control 11
2. Cost Management 13
3. Cost Documentation 14
4. Cost Recovery Support 15
5. Internal Control 16
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OFFICE OF ADMINISTRATION AND RESOURCES MANAGEMENT
I. EXECUTIVE SUMMARY
The FY 1938 Operating Year Guidance for the Office of Admin-
istration and Resources Management (OARM) is comprised of three
programmatic objectives new to the Guidance development process.
These activities are not, however, new to EPA. Rather, they
continue and improve upon work already underway in OARM and
across the Agency.
One activity, Human Resources Management, directly implements
EPA's Management Priority to promote excellence and professional
growth in EPA staff at all levels. The two additional activities,
State/EPA Data Management and improved Superfund Financial Manage-
ment support Agencywide goals to work collectively with State
and local governments to assure environmental protection action
and resources are fully effective and designed to achieve the
greatest social benefit.
OARM's key programmatic objectives discussed in the FY 1988
Guidance are summarized below.
ฐ HUMAN RESOURCES MANAGEMENT
The Administrator's priority emphasis on human resources manage-
ment reflects the Agency's commitment to investing the time and
resources needed to promote excellence and professional growth
in EPA employees at all levels of the workforce. The FY 1988
Guidance addresses broad areas of human resources management
essential to a quality workforce: employee involvement/commu-
nication; managerial excellence; workforce planning; career
management; and training/ development activities.
- Employee Involvement/Communication - Our workforce is our
greatest resource. EPA managers at all supervisory levels
should tap into the creativity and broad experience of
employees to improve work quality and productivity and to
foster and maintain a climate of open communication based on
trust and professional respect.
Managerial Excellence - Strengthened quality of our EPA
Management team is a major Agency goal. Managers should fully
integrate concepts and characteristics of the FAME program
(Framework for Managerial Excellence) with their employee
recruitment, selection, development, evaluation, and rewards
processes.
Workforce Planning - To meet projected program requirements we
need the highest quality applicants available. EPA managers
should assess and plan for the quality as well as quantity of
the workforce needed to get the job done well.
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Career Management - In FY 1988, each EPA organization should
give employees the opportunity to participate in career manage-
ment activities designed to promote the highly skilled and
motivated workforce needed to meet the still emerging and
changing needs of the Agency.
Training/Development Activities - Managers should identify
employee training and development needs, then ensure appro-
priate opportunities are available to foster professional
growth.
0 STATE/EPA DATA MANAGEMENT
One of the principal rationales for EPA policy regarding environ-
mental federalism includes the recognition that more effective
environmental protection results when Federal requirements are
implemented in a fashion which responds to the diversity of
local conditions. If we are to delegate program responsibility
to States without sacrificing accountability, we must have timely
and reliable data to monitor State progress in implementing and
enforcing environmental statutes.
Using recent EPA experience in joint Region/State pilot efforts,
the Agency has structured an initiative to strengthen the methods
and technology we use to manage and share data with States. This
effort will improve the Agency's ability to respond to government-
wide priorities regarding electronic collections, telecommunica-
tions and information management. In addition, it will enhance
the Agency's ability to share information among programs, reduce
duplicate State data reporting and produce significant savings
by both EPA and the States. Most important, it will result in
data management policies and systems that support, rather than
hinder, efforts to achieve our common goal of overeill risk reduc-
tion .
The program objectives that we will undertake to build the trust
and cooperation needed to build an effective State/EPA partnership
are:
Quality Data - EPA Regions will ensure that States provide
complete, accurate data to meet EPA reporting requirements,
and ensure that these data are entered into EPA's national
data bases in a timely way by either the State or the Region.
State Access - EPA will provide direct, on-line State access
to all EPA data bases that contain data reported by the State.
This will enable States to review and validate their data in
EPA's data bases.
State-Reported Data - EPA will establish policies and manage-
ment practices that assure the integrity of State-reported data
when EPA handles, edits, and interprets these data.
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ฐ SUPERFUND FINANCIAL MANAGEMENT
The Guidance for the Superfund Financial Management Program pro-
vides national direction to EPA Regional Offices in administration
of financial management policies and procedures which affect the
Superfund program. It also provides a framework within which the
Regions should work with States and other Federal agencies to
develop their Superfund financial management programs.
This Guidance identifies financial management initiatives which
support technical programs mandated unde-r the recently enacted
Superfund Amendments and Reauthorization Act (SARA) of 1986. SARA
authorizes an expansion of the Superfund program from $1.6 billion
to $8.5 billion, creating a commensurate need for effective and
efficient administration of the financially complex program.
The Guidance for FY 1988 is directed towards ensuring effective,
efficient, and consistent administration of the financially com-
plex Superfund program, while simultaneously supporting EPA's
management priorities in the specific areas of environmental
federalism, negotiation and consultation, enforcement, and
human resources. The major Superfund financial management
objectives for FY 1988 center on:
- Building Regional, State, and other Federal agency
capability to administer the financial management
of Superfund consistently and effectively;
Promoting and establishing an effective administrative
financial management infrastructure to encourage
program/financial office interaction;
- Developing and instituting effective, efficient, and con-
sistent accounting practices throughout EPA Headquarters,
Regions, States, and other Federal agencies; and
Developing accounting processes and techniques to produce
responsive and reliable management information in support
of program operations, enforcement, negotiation, and
consultation.
The strategy for accomplishing the FY 1988 objectives and for im-
proving operations within the established financial management
areas involves five major project initiatives, as follows:
Resource control initiatives will establish mechanisms to
ensure that resources are available for planned activities;
Cost management initiatives will ensure that charges are
necessary and reasonable given the services provided, and
that the services provided were those requested;
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Cost documentation initiatives will ensure that reliable
and accurate site-specific cost records will be available
for cost recovery support;
Cost recovery support initiatives will ensure that proper
amounts are collected for the Fund; and
Internal control initiatives will ensure that all Superfund
financial management operations achieve an improved level
of accuracy and consistency across Regions, States, and
other Federal agencies.
Together these initiatives will provide the financial management
foundation critical to effective management of the Superfund pro-
gram nationwide.
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II. OPERATING GUIDANCE
A. HUMAN RESOURCES MANAGEMENT
EPA is its people. The quality and performance of our employees
will determine whether or not we meet the complex and changing
needs of our environmental mission. With the assessment and
report by the National Academy of Public Administration (NAPA)
in 1983-84, EPA asked employees for their views on their work and
the management of the Agency. While their responses confirmed a
universal dedication to the EPA mission and willingness to work
hard, they also pointed to a number of areas seriously in need of
improvement. With the NAPA findings, we began a long-term effort
to change the way we manage our human resources, so that we may
continue to attract and retain the best people and produce the
highest quality environmental results.
The Administrator's priority in human resources )nanagement re-
flects the Agency's commitment to investing the time and resources
needed to promote excellence and professional growth in EPA
people at all levels. This guidance addresses broad areas of
human resources management essential to a quality workforce:
employee involvement/communication; managerial excellence; work-
force planning, career management, and training/development
activities.
1. Employee Involvement/Communication
Since the first NAPA Report in 1984, EPA's management has streng-
thened efforts to involve its employees in major program and
management decisions facing the Agency. The creation of the EPA
Human Resources Council, with advisory committees made up of
scientific/technical, support, and managerial employees from
across our media and our geographic locations attest to our
belief that our people are the best source of ideas and innovative
ways of getting the job done.
As we move into FY 1988, EPA will increase emphasis on employee
involvement in order to tap into the creativity and broad experi-
ence of our workforce. All EPA managers and supervisors should
encourage employees to participate in decisions that affect
their work and to offer ideas and suggestions that will improve
work quality and productivity. Then, they should be willing
to listen and consider implementing those that make sense. They
need to look at organizational structure and try to reduce the
number of levels so that decisions are made at the lowest practi-
cal level, closest to the actual work.
Meaningful employee involvement requires that managers and super-
visors communicate well with employees at all levels as profes-
sionals and as people. Managers and supervisors should develop
and articulate to their employees a clear and simple statement
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of their program and "human resources management goals-both what
is to be done and how to do it. Organizational goals should be
translated into individual commitments through meaningful and
measurable performance standards. They should work to foster
and maintain a climate of open communication based on trust and
professional respect, and give frequent and constructive feedback
to employees about their performance.
On the broad level, the use of cross-program task forces, multi-
disciplinary positions, and rotational assignments attest to
EPA's belief that environmental and management issues are so
complex that communication among people and groups with different
perspectives is not only desirable, but essential. In individual
organizations, local human resources "mini-councils," informal
newsletters, all-employee meetings, "brown bag" lunches with
senior officials, and staff team-building sessions aire examples
of activities which have worked well in EPA.
2. Managerial Excellence
One of the hallmarks of our Agency for the past few years has
been our investment in strengthening the quality of our management
team, to assure that managers at all levels are able to lead and
manage complex organizations, complex missions, and employees
with diverse and specialized backgrounds. Under the FAME (Frame-
work for Managerial Excellence) program, EPA has initiated a
comprehensive program to address the skills, abilities, and
personal characteristics that the Agency should look for in
recruiting employees to management positions. OARM has expanded
on those characteristics to determine appropriate training and
development activities which will allow EPA to "grow" highly
effective managers from within, and has mapped out criteria the
Agency should use to appraise managers and to reward managerial
excellence.
Full integration of the FAME competencies and effectiveness
characteristics into the selection, development, evaluation and
rewards processes is a major Agency goal. Current managers and
supervisors should aim for full participation of new managers
and supervisors in training such as the "Framework for Supervision"
and "Keys to Managerial Effectiveness" courses. They should
also encourage incumbent managers and supervisors to take as
many as forty hours of managerial training each year, through the
EPA Institute, commercially available packages, the Federal
Executive Institute, or other sources. Managers should support
the SES Candidate Program by encouraging their people to apply
and considering Candidates when filling SES vacancies. Similarly,
the Presidential Management Intern Program should be considered
as an excellent pool of management talent available to EPA organ-
isations .
3. Workforce Planning
All managers should take steps to plan for the quality of their
workforce as well as the quantity of FTE needed to do the work.
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OARM has developed a methodology to help each organization to
assess its human resources needs over the next 3-5 years, based
on program priorities, legislation, state delegations, and resource
levels. Getting the right person in the right job at the right
time requires identification of job tasks in the future, analysis
of the knowledges, skills and abilities needed to do the job, and
an inventory of current staff capabilities. The results of these
analyses will generate alternative courses of action for recruiting,
career management, training and development, and EEO/affirmative
action efforts.
To meet projected program requirements with the best quality
applicants available and achieve our EEO objectives, OARM has
advanced a much more targeted recruitment program for the Agency,
which will allow EPA to focus on hard-to-fill scientific and
technological needs, while assuring that recruiters are trained
to market and present the Agency and its various programmatic
needs in the best possible light to applicants.
4. Career Management
Agency commitment to greater employee involvement, managerial
excellence and workforce planning will lead to a larger, overarch-
ing goal: to have a highly skilled and motivated workforce, one
that is in tune with scientific and technological advancements,
and that is trained and developed to meet the still emerging and
changing needs of the Agency. EPA has already made significant
progress in this area with the implementation of the Career
Management System. The system is designed to improve employee
career planning within the context of the organization's needs.
In FY 1988, each organization should provide employees the
opportunity to participate in career management workshops, DIS-
COVER, and other career management activities. Development and
training experiences will be outlined in yearly career management
plans agreed upon by the employee and supervisor. A significant
percentage of positions should be announced and filled both as
lateral assignments and merit promotions using the Career Manage-
ment System Vacancy Announcements. Employees' participation
in professional societies and associations will occur as funds
are set aside by managers in their operating budgets.
5. Training/Development Activities
Managers should use workforce planning products and career
management activities to provide a systematic approach to
identifying individual employees' training and development needs.
Managers and supervisors should assure that appropriate growth
opportunities are available, and employees should participate
in these training and development experiences.
The Agency has instituted many programs to accomplish
these goals, including model career paths for chemists and
physical scientists, a rotational assignment program, and
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other training and development information which can be easily
accessed through in-house automated systems. Many EPA managers
and supervisors have already begun to reap the benefits of
rotational assignments to, from, and within their organizations.
The EPA Institute should be integrated into training and
development activities wherever possible, by supporting
staff in developing and delivering courses, encouraging staff
to attend Institute courses, including the "Managing Office
Relationships" and "Pitfalls" courses designed specifically
by and for support staff.
Summary
This guidance is directed at managers across the Agency, but
recognizes the organizational and program differences among our
Headquarters, Regions and Laboratories. OARM encourages managers
to be flexible in choosing the kinds of human resource management
activities that will best meet the needs of their employees and
their mission.
Each of the objectives outlined above should come to fruition
during FY 1988. We challenge supervisors and managers: make
these things happen for your people. We urge all managers, at
all levels, to invest the time, energy and resources necessary
to make your organization, and our Agency, a model of human
resources management in the Federal sector.
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B. STATE/EPA DATA MANAGEMENT
EPA's commitment to environmental federalism requires that we
strengthen the methods and technology we use to manage and share
data with state environmental and health agencies. If we are to
delegate program responsibility to States without sacrificing
accountability, we must have timely and reliable data to monitor
state progress in implementing and enforcing Federal environmental
statutes.
In addition to being the source, State agencies are also the
initial and primary users of the data required by EPA to manage
delegated programs. Thus, our ability to obtain these data, as
well as the ultimate success of the State-EPA partnership, depends
on our success in devising data management policies and systems
that support, rather than hinder, State efforts to achieve our
common goal of overall risk reduction.
1. Objectives
Over the past two years, EPA and pilot States in each of the EPA
Regions have worked to improve the management and sharing of
data. These pilots have applied a variety of methods and tech-
nologies, tailored to the unique needs of individual States, in
pursuit of three specific objectives:
0 To assure that complete, accurate data are provided in
response to all EPA reporting requirements, and that
these data are entered into EPA's national data bases
in a timely way by either the State or the Region.
ฐ To provide direct, on-line access that allows States to
retrieve and validate State-reported data contained in
EPA data bases.
0 To establish policies and management practices that
assure the integrity of State-reported data when EPA
handles, edits, and interprets these data.
These three objectives represent Phase I of a longer term effort
to strengthen State/EPA data management and sharing. A Phase II
pilot is now being launched in the State of Georgia to develop
improved methods for applying State and EPA data resources and
improved information technology to support risk reduction deci-
sions across media lines. In addition, the Georgia Phase II
pilot will examine cost-effective approaches to addressing new
State data management responsibilities under Title III of the
Superfund Reauthorization Amendments.
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2. EPA Regional Offices
During FY 1988, each EPA Region is to undertake one additional
State data management project, while maintaining support for the
State data management project begun during FY 1987. Regions
should also begin working with the FY 1987 pilot State to intro-
duce Phase II data management improvements. Especially in those
Regions where no additional Phase I State projects are feasible,
Regions should also concentrate on training and procedural
improvements required to institutionalize effective State/EPA
data management practices.
Each Region should give particular attention to assuring that
State/EPA agreements, enforcement agreements, and grant agree-
ments reflect Agency policy regarding State/EPA data management.
Finally, all Regions should begin efforts to improve the data
resources and technology available to Regional Office staff to
address risk reduction decisions across media lines in concert
with State agencies.
3. EPA Program Offices
EPA Program Offices should review existing and planned data
systems that involve State-reported data or that are intended for
use in overseeing State agency performance, to assure that these
systems are designed and managed consistent with the Agency's
State/EPA data management policy. Plans and budgets should be
developed to accomplish these changes over a reasonable period of
time, consistent with the Agency's priority on achieving effective
Environmental Federalism.
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C. SUPERFUND FINANCIAL MANAGEMENT
The FY 1988 objectives, initiatives, and high priority activities
to be conducted to improve Superfund financial management are
identified in this section of the Guidance. Each of the major
initiatives is summarized, followed by the priority activities
necessary to accomplish each initiative.
Administration of the financially complex Superfund program re-
quires the establishment and maintenance of effective, efficient
and consistent financial management practices in three major areas:
0 Traditional Financial Services - which covers basic ser-
vices such as issuance of paychecks, processing travel
vouchers and contractor invoices, preparation of regular
reports, maintenance of financial systems, and issuance of
general policy;
ฐ Site-Specific Accounting - which covers the additional
effort required to deal with unique Superfund process and
procedural complexities involved in reporting and
accounting site-specifically; and
0 Cost Recovery Support - which covers requirements to
gather, present, and support cost documentation needed in
cost recovery actions against responsible parties.
The initiatives discussed below are directed towards ensuring that
each of these critical Superfund financial management functions is
performed effectively.
Specific Superfund financial management program initiatives cover
the areas of:
0 Resource Control;
0 Cost Management;
0 Cost Documentation;
0 Cost Recovery; and
0 Internal Control.
Each of these initiatives and related priority activities are dis-
cussed in more detailed sections below.
1. Resource control initiatives will be directed towards
ensuring that the Agency's traditional financial ser-
vices, processes, procedures, and systems are upgraded to
provide the financial foundation necessary for the
Superfund program. Simultaneously, the financial infor-
mation resulting from these efforts must be made readily
available to the program officials, including the site-
specific information which is often needed for effective
Superfund program management. The initiatives include a
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number of priority activities directed towards establish-
ing mechanisms which will ensure accurate charging prac-
tices, timely obligations processing, and tracking of
obligations/outlays. OARM plans to complete these
initiatives during FY 1987, so that regional offices can
use the products during FY 1988.
The intended result of these initiatives is a reliable and
consistent system for tracking important cost, measures
such as work years, personal compensation and benefits,
travel, equipment, support, contracts, Intereigency
Agreements (lAGs), and Cooperative Agreements (CAs) from
the budgeting through the actual outlay process. Site-
specific allowances for Remedial Design (RD) and Remedial
Action (RA) activities and centralized Document Control
Registers (OCRs) will strengthen both the budget planning
and budget execution functions. These initieitives will
ensure that On-Scene Coordinators (OSCs) and Remedial
Project Managers (RPMs) can be more confident that charges
billed to a site represent the actual services provided.
Resource Control Priority Activities
In order to fulfill the requirements of these initia-
tives, the following activities should be performed:
0 Each region should create a unit within the finan-
cial office to provide the expertise to perform re-
gional Superfund financial management functions;
0 OARM/OSWER will continue to track actual costs
against site-specific allowances for RDs/RAs;
0 OARM will continue to maintain systems to ensure
accurate charging practices and timely obligations/
outlays processing and tracking;
0 Regions should continue to maintain centralized DCRs;
0 Regions should initiate briefings and discussions
with States/other Federal agencies to implement the
resource control initiatives;
0 Regions should implement the joint OSWER/OARM recom-
mendations for providing improved administrative
support to OSCs and RPMs;
0 Regions should implement programs to ensure that
time-charging practices are in line with Agency
standard procedures. OARM will issue by
September 1987 the comprehensive program and policies
to be followed;
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0 Regions should offer technical assistance to Statas
and other Federal agencies in establishing account-
ing and cost documentation systems consistent with
EPA's resource control measures; and
0 Regional financial programs should provide financial
analysis to assure that removal program managers have
sufficient information to prepare action memoranda
which include accurate site budgets.
2. Cost management initiatives have been developed to help
ensure that charges are necessary and reasonable and are
in line with site-specific accounting and reporting re-
quirements. These initiatives involve the enhancement
and more timely production of Financial Management
System (FMS) reports to facilitate improved overall
cost management, generation of reliable site-specific
cost data and reports, and calculation of supportable
indirect costs.
Cost Management Priority Activities
The foundation for effective cost management is timely
and accurate site-specific reporting by all organizations
and staff involved in the Superfund program, and the
subsequent timely consolidation and output reporting
of these data by the Agency's FMS and other financial
subsystems. To fulfill the requirements of this initia-
tive, the following activities will be performed:
0 OARM will continue to enhance FMS reports to improve
reporting for effective site-specific cost management;
ฐ Regions should review contractor charges/invoices
and daily reports to ensure that all site charges
are reasonable and necessary;
0 Regions should continue to work with Superfund con-
tractors, States, and other Federal agencies to en-
sure the accurate and timely reporting and process-
ing of site-specific costs;
0 OARM will continue to develop and issue on a fiscal
year basis Agency approved annual indirect cost
rates;
0 Regions should invest necessary resources to develop
accurate site-specific budgets and to closely moni-
tor actual costs, including indirect costs;
0 Regions should use Agency approved annual indirect
cost rates developed by OARM to determine site-specific
costs for both project ceiling and cost recovery
purposes; and
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Regions should review financial files managed by
recipients of CAs and lAGs to ensure that documenta-
tion is available to support all Superfund charges.
Cost documentation initiatives will ensure that charges
are accurately reflected in the Agency's FMS and can be
supported in litigation. One key activity will be the
development and distribution of a manual defining stan-
dard cost documentation requirements and procedures for
EPA, States, and other Federal agencies. Following stan-
dard processes will ensure that reliable and accurate
site-specific cost records are available for cost re-
covery support, strengthen management information, and
improve data quality.
The establishment and maintenance of Superfund site-
specific financial files will ensure easy retrieval of
cost recovery data. OARM will continue to maintain
Superfund site-specific financial files and will consider
automated alternatives for storage and retrieval of
Superfund financial transaction records.
Cost Documentation Priority Activities
The priority activities in this area carry through on
previous years' initiatives to implement the negotia-
tion, cost recovery, and supportable cost areas of the
Superfund program. Specific activities include:
0 OARM will develop and issue by August 1987 a manual
defining cost documentation requirements and
procedures for EPA, States and other Federal
agencies ;
0 Regions should maintain Superfund site-specific fin-
ancial files consistent with OARM Superfund cost
documentation procedures;
0 Regions should work with States and other Federal
agencies to ensure the consistent implementation of
cost documentation policies and procedures;
0 OARM will develop and issue by August 1987 criteria
for acceptable State and Federal agency Superfund
financial management systems;
0 Regions should work with States and other Federal
agencies to implement acceptable Superfund financial
management systems ;
0 Regions should conduct reviews of the Superfund
financial management systems of States and Federal
agencies with Superfund agreements with EPA;
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0 OARM will continue system development for subsequent
implementation of an automated storage and retrieval
system for Superfund financial management site-
specific files.
Cost recovery support initiatives will ensure that proper
amounts are reported and collected for the Fund. Key to
this initiative will be the development during FY 1987 of
a stand-alone document to explain the Agency's financial
management procedures and controls. Also, the establish-
ment of an automated billing and receivables system
capable of calculating interest will be necessary to
carry out the interest-charging mandates of SARA.
Central to the success of these initiatives will be the
ability to improve the integrity of the case settlement
process to ensure case closing information is immediately
transferred to the regional financial offices so that
collections can be recorded properly and receivable
amounts can be accurately reported to management.
Cost Recovery Support Priority Activities
Several specific activities will support the initia-
tives, including:
0 OARM will continue policy development support and
issuance of documentation codifying cost recovery
financial policies;
0 Regions should establish systems to ensure that case
closing information is immediately transferred to the
financial office so receivables and collections
can be accurately recorded;
0 Regions should actively pursue parties that do not
pay owed balances and report to Headquarters when
collections cannot be made;
0 Regions should ensure that they expeditiously deter-
mine potential responsible party (PRP) ability to pay
through analysis of their financial capabilities and
that they then process claims as quickly as pos-
sible ;
0 OARM will develop policies and procedures and design
an automated system that carries out the interest-
charging mandates of SARA by September 1987; and
0 Regions will implement procedures that support the
calculation and collection of interest from responsible
parties.
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5. Internal control initiatives will ensure that all Super-
fund financial management operations achieve an improved
level of accuracy and consistency across regions, States,
and other Federal agencies. Transaction testing will
ensure process improvement and provide a quantitative
indication of the degree of improvement.
Internal Control Priority Activities
The activities supporting these initiatives will focus
on reviews and assistance to ensure consistency and
accuracy. Specific activities will include the following:
0 OARM will design and develop by September 1987 a
quality assurance program to ensure integrity of
Superfund financial management processes;
0 OARM and OSWER will design and develop by
September 1987 a comprehensive internal control
program to ensure that Agency policies and procedures
are implemented correctly;
0 Regions should implement the integrated OARM/OSWER
internal control program;
0 Regions should conduct reviews of State and other
Federal agency internal control procedures for
Superfund financial transactions and provide sugges-
tions for improvement as appropriate; and
0 Regions should establish the capability for their
financial offices to perform transaction testing of
Superfund financial documentation.
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Region V, Library
230 South Ctearbom
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U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street ,y
Chicago, Illinois 60604 ^
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