United Sidles        Of lice of Planning      April 1979
           Eiwuonmenial Protection    and Management
           Agency          Washington DC 20460
<>EPA     EPA Agency Guidance
           Fiscal Year 1980/81
                            OOHB79102

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         EPA AGENCY GUIDANCE
        FISCAL YEARS 1980/81
U,S, ENVIRONMENTAL PROTECTION AGENCY
           WASHINGTON, D,C,


             APRIL, 1979

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                        FOREWORD
      This Agency Guidance  culminates an  intensive  review
of  EPA's plans  and priorities  for  the  1980 and 1981 fiscal
years.  It gives specific  direction on issues in the 1980
operating plan  and serves  as a basic agenda  for the 1981
budget.

CHANGES FROM LAST YEAR

      Past users of the Gu.ide%nce viil note that its
contents differ from last  year's in several  respects.

Media Focus

      Last year's Guidance  contained lengthy, detailed
descriptions and directions for specific Decision  Units.
This  approach resulted in  a lack of coordination among
Decision Units, and shifted attention away from common
Agency purposes and assumptions.   This year's Guidance
takes a broader perspective, focusing on the principal
issues, assumptions, and priorities within each of the
media.

Extension to Headquarters

     This document completes last  year's extension of the
Guidance to Headquarters programs.  Headquarters plans
for FY 1980 and FY 1981, with discussions of changes from
last year and possible alternatives for  the  future, appear
in each program's Guidance.  For media with  research
programs,  Headquarters plans also  include, for the first
time, a Research section describing EPA's present
priorities for Research and Development.

Cross-cutting Guidance

     While one section of  the Interdisciplinary Guidance
is devoted to interdisciplinary R&D (like last year), two
additional sections have been added.  These  sections deal
with Federal Activities and Environmental Profiles.  They
apply to all Agency programs and should be considered
supplementary guidance for all media.
                           111

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Length

     Preparation of last year's Guidance imposed an
excessive workload on the programs, and the document
was too long.  This year's Guidance has been shortened
substantially.

Four Parts of the Package

     Last year's Guidance marked the first appearance
of separate Policy Guidance and State Guidance documents.
This year, there is also a separate Research and Develop-
ment Guidance, compiled from the Research section of each
program's Headquarters Plan.  These three publications
supplement the Agency Guidance (this document) and provide
information about EPA's plans and priorities to audiences
(e.g., States, R&D labs, the general public) that do not
wish or need to review the entire Guidance package.

PROJECTED PROGRAM ACCOMPLISHMENTS (PPA's)

     The Guidance defines the scope of the Agency's
Regional programs.  The Agency will use PPA's as a guide in
developing budget justifications.  A listing of selected
PPA's for FY 1980 will be preprinted on the Operating Plan
forms that will be part of the Planning Manual.  We will
provide these forms to the Regions at the same time as the
Regional resource targets.

     The ZBB forms may require quantified end-of-year
output projections based on these PPA's.  Regions should
submit them as part of the Regional Operating Plans;
projected output levels should be negotiated with appro-
priate Headquarters program offices before final approval
of the Operating Plans.  The selected PPA's will be
consistent with the Guidance and correspond to those
activities contained in the workload analysis.  Each
Regional and Headquarters office will be required to
submit an end-of-year accomplishment report, which will
feed back into next year's Agency Guidance, workload
analysis, and OMB budget submission.

     Paul Elston's March 13, 1979 memorandum to the
Assistant Administrators and Regional Administrators on
Agency reporting requirements discusses the steps we will
take during the rest of this fiscal year to reinstitute
                           IV

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reporting in the Agency.  The content of a future formal
reporting system has not yet been determined.  Therefore,
there may be some overlap between the PPA's in the Agency
Guidance and the measures to be incorporated  in a new
reporting system.  PPA's may or may not be included  in such
a system for FY 1980 and 1981; by themselves, they do not
constitute the reporting system.  Considering this,  any
reference to PPA reporting or frequency of reporting in
the Agency Guidance should be temporarily suspended  until
decisions are made on a new reporting system  for FY  1980
and FY 1981.

MONITORING

     There has been considerable activity during FY  1979
to improve the Agency's monitoring activities, and improved
monitoring continues to be a priority for FY  1980 and 1981.
Specifically, one has identified a number of  issues  that will
affect how we conduct monitoring.   The issues that are being
addressed include:

     o  how to develop methods, and how to develop capabili-
        ties in the Regions and States, for analyzing toxic
        pollutants;

     o  how to improve the quality of the collection
        and analysis of samples and the quality of other
        data the Agency collects;

     o  developing and using better statistical methodologies
        for analyzing environmental data;

     o  defining the role of biological monitoring and
        health data collection;

     o  how to obtain resources for needed laboratory
        equipment;

     o  identifying ways of preventing overlap and
        redundancy in monitoring programs; and

     o  improving planning and resource allocation for
        monitoring throughout the Agency.

     Individual programs do prescribe in this Guidance
actions to improve the monitoring activities  in their
specific media and in some cases prescribe actions to be
taken in the same areas the Select Work Group is considering

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 (e.g., improving quality assurance of data).  Policies on
 monitoring that the Agency adopts as a result of the Select
 Work Group on Monitoring's Review will be fully circulated
 so that program managers can incorporate them into their
 programs at all levels.

 WHAT HAPPENS NEXT

      This Guidance is the basis for the FY 1980 Operating
 Plans which must be submitted for each Decision Unit.
 These plans should follow the priorities laid out in the
 Guidance and give reasons for any significant differences.
 The Guidance also provides the basic policy information
 necessary for constructing and reviewing descriptions of
 the FY 1981 Decision Units.   In early June, Media Task
 Groups will review these Decision Unit descriptions for
 consistency with the Guidance.

      The Program Analysis Division will issue the EPA
 Planning Manual soon.  That  document will give further
 details on the character and timing of Media Task Group
.reviews and ranking responsibilities.  Media Task Groups
 may also want to meet before their ranking sessions to
 review analyses of issues identified in the Administrator's
 Analytic Agenda and earlier  Task Group meetings.
      Our principal objectives in this year's planning and
.^budgeting cycle are to simplify the budget process, while
^expanding our analysis of significant issues and encour-
 aging the Agency to look at the assumptions behind itts
 .actions as well as their consequences.   The success of
 this Guidance will be measured by the extent to which it
 serves these  goals.
                            VI

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                  EPA AGENCY GUIDANCE
                  FISCAL YEARS  1980/81
TABLE OF
CONTENTS

FOREWORD	iii

ADMINISTRATOR'S/DEPUTY ADMINISTRATOR'S
      POLICY GUIDANCE  	    3

ASSISTANT ADMINISTRATORS' OVERVIEWS

     AIR, NOISE AND RADIATION	11

     WATER AND WASTE MANAGEMENT	16

     TOXIC SUBSTANCES	20

     ENFORCEMENT	35

     RESEARCH AND DEVELOPMENT   	   42

     PLANNING AND MANAGEMENT  	   48

MEDIA GUIDANCES

     AIR

          MEDIA OVERVIEW	55

          HEADQUARTERS PLANS

               Abatement  and Control 	   62
               Enforcement	   65
               Research and Development   	   69

          REGIONAL GUIDANCE

               Abatement  and Control 	   79
               Enforcement	   90

          PROJECTED PROGRAM ACCOMPLISHMENTS   	   92
                         VII

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WATER QUALITY

     MEDIA OVERVIEW	107

     HEADQUARTERS PLANS

          Abatement and Control 	 122
          Enforcement	147
          Research and Development  	 156

     REGIONAL GUIDANCE

          Abatement and Control	 164
          Enforcement ..... 	  . 192

     PROJECTED PROGRAM ACCOMPLISHMENTS  	 200

DRINKING WATER

     MEDIA OVERVIEW	227

     HEADQUARTERS PLANS

          Abatement and Control 	 231
          Enforcement	233
          Research and Development  	 236

     REGIONAL GUIDANCE

          Abatement and Control	 247
          Enforcement	250



SOLID WASTE

     MEDIA OVERVIEW	255

     HEADQUARTERS PLANS

          Abatement and Control 	  262
          Enforcement	266
          Research and Development  	  267

     REGIONAL GUIDANCE

          Abatement and Control	  271
          Enforcement	274

     PROJECTED PROGRAM ACCOMPLISHMENTS  	  276
                    Vlll

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TOXIC SUBSTANCES

     MEDIA OVERVIEW	281

     HEADQUARTERS PLANS

          Abatement and Control 	 289
          Enforcement	293
          Research and Development  	 297

     REGIONAL GUIDANCE

          Abatement and Control 	 307
          Enforcement	322

     PROJECTED PROGRAM ACCOMPLISHMENTS  	 324

PESTICIDES

     MEDIA OVERVIEW	329

     HEADQUARTERS PLANS

          Abatement and Control 	 334
          Enforcement	337
          Research and Development  	 340

     REGIONAL GUIDANCE

          Abatement and Control 	 346
          Enforcement	351

     PROJECTED PROGRAM ACCOMPLISHMENTS  	 354

RADIATION

     MEDIA OVERVIEW	361

     HEADQUARTERS PLANS

          Abatement and Control 	 364
          Research and Development  	 365

     REGIONAL GUIDANCE	368

     PROJECTED PROGRAM ACCOMPLISHMENTS  	 372
                    IX

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NOISE

     MEDIA OVERVIEW	 377

     HEADQUARTERS PLANS

          Abatement and Control	 379
          Enforcement	-  . 385

     REGIONAL GUIDANCE	388

     PROJECTED PROGRAM ACCOMPLISHMENTS  	 391

ENERGY

     MEDIA OVERVIEW	 397

     CONTROL TECHNOLOGY 	 398

     HEALTH EFFECTS 	 406

INTERDISCIPLINARY

     MEDIA OVERVIEW	413

     FEDERAL ACTIVITIES 	 415

     OTHER ACTIVITIES	427

MANAGEMENT

     OVERVIEW	435

     HEADQUARTERS AND REGIONAL GUIDANCE

          Personnel	  . 438
          Contracts Management  	 441
          Resources Management  	 444
          Planning, Evaluation, and Analysis   .  . 449
          Agency Support Services 	 455
          Legal Services	457
          Administrator's  Staff Offices 	 458

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 ADMINISTRATOR'S POLICY GUIDANCE



             1980/1981
DOUGLAS M, COSTLE, ADMINISTRATOR






BARBARA BLUM, DEPUTY ADMINISTRATOR

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             ADMINISTRATOR'S POLICY GUIDANCE
     EPA and State and local agencies can be proud of what
they have accomplished over the last two years.  We have
won strong legislative mandates, and we are making good
progress in implementing them.  EPA is better  integrated,
and we have begun the process of strengthening our State
and local relationships.  We are making good progress in
developing effective controls for toxics.  In  area after
area we are recognized front-runners in the Administration's
reform efforts.  The air and the water are getting cleaner.
The people, the President, and the Congress support our
work: they respect both our professionalism and our
ability to get a tough job done.

     This Guidance addresses the future.  But  before we
go on to define what lies ahead, we wanted to  note how far
EPA has come.  The Agency has been working hard and well.
Congratulations and our thanks.

     In this Agency Policy Guidance we identify what we
feel the Agency's priorities should be for the next
several years.  Our Assistant Administrators follow with
more detailed guidance for each of their areas of respon-
sibility.  We have worked closely with them in developing
these program guidances.

     Broadly stated, the Agency's priorities are as
follows:

     o  To reduce public exposure to dangerous
        pollutants;

     o  To protect sensitive ecological systems;
        and

     o  To improve management of our environmental
        programs.
REDUCE PUBLIC EXPOSURE TO DANGEROUS POLLUTANTS

     Over the last several years we have come to understand
more of the connections between the thousands of chemicals
our society has put into our environment and a great many
of the diseases that afflict modern man.  EPA has been
given lead responsibility for identifying, evaluating,
and controlling environmental pollutants.  Doing so is one

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                           _ 4 -

of our chief objectives.  We are approaching the problem $
every point — when a chemical is produced, shipped, used,
or ultimately disposed of.  Our Toxics, Air, Water,
Pesticides, Drinking Water, Radiation, Hazardous Waste,
and spills programs must all give the toxics problem
greater priority.  In doing so we expect that all action
on individual pollutants should generally be governed by
the principle of addressing first those that present the
greatest health risks.  A major part of that effort has
been the development of an integrated strategy for toxic
substances, a strategy which we will continue to develop
and refine throughout 1980 and 1981 through vigorous
implementation of the Toxic Substances Control Act.

     As another element of an Agency-wide toxics strategy,
we will develop an Agency cancer policy.  The policy
will provide a framework for continuing decision-making
in our pesticides, toxics, and drinking water programs
and for emerging carcinogen regulations under the Agency's
air, water, and hazardous waste programs.

     Finally, our urban strategy is a key part of this
effort because it is based on attacking the unhealthy
environmental conditions of cities.  We expect the
Assistant Administrators and you to continue to implement
our existing urban initiatives and to develop innovative
solutions for urban problems.

PROTECT SENSITIVE ECOLOGICAL SYSTEMS

     Increasingly during the past two years, we have
focused the Agency's efforts on dealing with pollutants
as they affect public health.  Ultimately, however, we
must protect the environment that supports us and all
other life.  While continuing to clean up our air and
water, we need to give much more attention to particularly
sensitive environmental systems such as wetlands.  Though
natural systems like wetlands and fisheries are usually
described as renewable — on the assumption that they can
regenerate themselves when depleted or damaged -- we are
beginning to learn how fragile they truly are as we begin
to understand sensitive ecological relationships.  Once a
groundwater supply is contaminated with toxics, for
example, it may take centuries for natural restoration
(or millions of dollars for clean-up) if it is ever to
support healthy natural life or to be used for drinking
water.

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                           - 5 -

IMPROVE MANAGEMENT OF OUR ENVIRONMENTAL PROGRAMS

     We have made a major commitment to finding better,
more effective ways of regulating.  There are almost fifty
reform efforts in progress across the Agency now.  We are
beginning to see the results of this commitment, and we
expect a great many more initiatives to move into
implementation stages over the next several years.  We
will continue to look for complements to traditional
regulation, such as offsets and the bubble, our reporting
requirements, sunset, and procedural simplifications.  We
want your active help in finding better ways to carry out
our responsibilities.  Specifically, we want to continue
to:

     o  Integrate EPA programs -- We have made a good
        start in our efforts to consolidate our grant
        and permit programs.  The integration of programs
        in water quality, drinking water, solid waste,
        hazardous wastes, and underground injection can
        serve as a good model for other program areas.

     o  Strengthen Federal/State/local partnerships --
        Establishing the State/EPA Agreements and
        encouraging appropriate delegation should streng-
        then and improve environmental programs at all
        levels.   We also need to retain and improve our
        ability  to assess performance at all levels.  We
        want to  work for passage of an Integrated Environ-
        mental Assistance Act as a legislative base for
        increasing management flexibility between us and
        the States as well as in State programs.

     o  Improve  coordination with other Federal agencies —
        We must  make greater use of the IRLG and Regulatory
        Council  mechanism to assure coordinated and
        concerted action among all Federal agencies.  We
        must work particularly closely with the Department
        of Energy in developing environmentally and health
        sensitive energy policies.

     o  Reform and refine our management practices —
        In this  area we are emphasizing the completion of
        Civil Service reforms recently enacted.  We must
        also put in place the planning,  zero-based
        budgeting accountability system for the Agency.

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        In addition, we are reassessing our monitoring
        with an eye to the quality, utility and compati-
        bility of our information systems.

     o  Improve regulatory reform — We are giving major
        emphasis to the development of more flexible, less
        costly alternatives to our traditional regulatory
        approaches, such as the "bubble" concept and
        "banking" of offsets in nonattainment areas.  We
        want to continue improving the quality of our
        regulations.  One of the most important elements
        to the latter is continued strengthening of the
        Steering Committee; we want to enlarge the role
        of the Regions in this process.

     o  Strengthen the Agency's research capacity and
        programs -- We want to improve our ability to
        forecast environmental problems and solutions,
        particularly in the long term.  We need to expand
        the data base for our regulatory decision-making.

     Finally, there are a number of cross-cutting issues
we want to flag.  We expect:

     o  a strong commitment to improving public partici-              "
        pation;

     o  a determined affirmative action program; and

     o  continued attention to the Administration's
        urban programs.
                        *****
     The 1980-1981 planning years present a great challenge
to us as managers.  We must continue to move this Agency
toward protecting public health and the environment more
fully.   We expect that each participant in this planning
will consider how his or her program can contribute to
these initiatives.

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     The following sections of this Guidance set forth our
priorities in greater detail.  They serve as the basis for
FY 1980 Federal and State program implementation and as
the policy framework for program and resource recommen-
dations to the President for FY 1981.
                                  Do
                                  Admini
M. Costle
rator
                                   Barbara Blum
                                  Deputy Administrator

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ASSISTANT ADMINISTRATORS' OVERVIEWS
      AIR, NOISE, AND RADIATION



      WATER AND WASTE MANAGEMENT



      TOXIC SUBSTANCES



      ENFORCEMENT



      RESEARCH AND DEVELOPMENT



      PLANNING AND MANAGEMENT

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         OFFICE OF AIR, NOISE, AND RADIATION

     Overview Statement of Priorities and Goals

      David G. Hawkins, Assistant Administrator


PUBLIC PARTICIPATION AND INFORMATION

     Each OANR program plan should include resources and
should plan for effective participation,  Limited resources
should also be available for case-by-case assistance to
participants in a small number of major rulemaking and/or
permit proceedings.

     I would also like OANR offices to work with Regional
Offices to develop effective public participation programs
for their activities.

     Finally, each office should review existing public
information materials in its area of responsibility.
Program plans should provide for major improvements in
our information base and should include a system for
keeping our public information materials current.  Please
work with our Office of Public Awareness representative
in this effort.  Our laws, particularly the Clean Air
Act, are complex but their purposes and effects can be
simply explained.  We must make more of an effort to do
so.

AIR

     High priority must be given in 1980 to completing all
actions required as a result of State implemention plan
submissions in 1979.  Most plan approvals, disapprovals,
and promulgations should be completed in 1979, as should
the schedules for implementing the plans.  However, some
such actions may not occur until 1980.  We must have in
place systems for tracking State progress in implement-
ing their approved plans.  We need to emphasize and
develop ways of assuring that the States assume their
responsibilities under the plans including all new source
review responsibilities.  It is especially important that
we encourage States to implement the program for Prevention
of Significant Deterioration.

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                         -  12  -

     During 1980 programs for visibility protection and
Prevention of Significant Deterioration for pollutants
other than TSP and SC>2 should be ready for implementation.
States should be urged to assume responsibility for these
programs as well.

     The next major round of SIP revisions will be in 1982
for those areas where EPA has granted extensions beyond
the 1982 deadline.  Our guidance requires that for ozone
these areas base their revised plans on an air quality
model.  It appears that the most appropriate technique for
protecting future air quality in this round of SIPs will
be the relatively complex dispersion models which account
for photochemical reactions.  We should give high priority
in 1980 to the acquisition of data required for these
models and to validating them.  The 1981 program plan
should provide for the use of these models in all areas
where required in a time frame that permits technical
review and public participation on development of control
strategy A.o assure meeting the Clean Air requirements.

     The general problem of lack of confidence in air
quality o ita also must be addressed in 1980.  Emphasis
must be given to the establishment of technically sound
sites and procedures for National Air Monitoring Stations
fNAMS) and State Local Air Monitoring Stations (SLAMS) as
required by our monitoring regulations.  Participation by
State/local laboratories in quality assurance programs
should be mandatory.  If the programs require additional
resources, this should receive a high priority in the
1981 budget request.

     At Headquarters, by December 31, 1890, we must have
completed our review and appropriate revision of all
existing ambient air quality standards.  The plan for
1980 should clearly recognize this requirement and, given
the need for a better quantification of benefits, provide
for the development of such a data base and analyses as
may be required.

     The budget for 1980 provides funding to complete the
development of new source performance standards for all
major stationary sources by 1982.  The program plans for
1980 and 1981 must demonstrate that we are on a schedule
which will meet that statutory deadline.

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                         -  13  -

     No large increment in resources is being provided in
1980 for activities related to hazardous air pollutants.
I expect that, before the next fiscal year begins, we will
have in place a policy on air carcinogens providing a
systematic approach to substantially reduce risks from air-
borne carcinogens.  Our plan in 1980 should provide for
the orderly implementation of that policy with a major
intensification of actions in 1981.  This program should
take into account and be coordinated with other programs
regulating risks from toxic or hazardous pollutants.

     In Mobile Sources we should have completed all vehicle
rulemaking specifically required by the Clean Air Act in
1980.  Our future standard-setting program should address
the need to regulate presently unregulated pollutants, and
resources to address the light-duty diesel should be
available in 1980 in the event that research establishes
the need for additional action.  Cur 1980 program should
focus on such assessment activities as may be necessary if
standards are to be proposed in FY 1981 or subsequent
fiscal years.

     Given commitments to inspection/maintenance programs
in the SIP's, we must be in a position of being able to
provide expert guidance to State and local I/M programs.
The 1980 plans should address, as a matter of priority,
such data gathering and assessment as may be necessary to
assure that we can assist I/M programs to achieve their
maximum potential.

     We should give major attention to other activities
which will help assure that vehicles in use perform as
intended, and the 1980/81 plans should specifically address
this concern.  In particular, we should continue to examine
test procedures to improve their relation to real-world
problems.
NOISE

     In FY 1980 I think that every effort should he made
to become current with our previous commitments to regulate
new products.  New commitments should be limited until we
are assured that the backlog of previous identifications
and/or proposals can be eliminated.  If we take on new
efforts, they should focus on transportation-related
concerns.

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                         -  14  -

To the extent the 1980 budget is not adequate to complete
the required pre-regulatory work for light duty vehicles
and tires, the Agency should not make formal commitments.
These sources would then be a major initiative in the
1981 budget.

     Although I am attracted by the idea of using noise
labeling as a method of enhancing consumer choice, I
believe we should complete promulgation of the general
labelling and hearing protector regulations first.  Any
proposal for additional work in the labeling area in
1980 must be carefully tailored to fit within available
resources and my desire for us to complete pending
actions.  An expanded program may be considered in 1981,
but it should have a lesser priority than work related to
transportation sources.

     I am anxious that we show material progress in
implementing the Quiet Communities Act.  To the extent
that our stated goals of 400 communities and 40 States
with effective noise programs provide a real basis for
program planning, our program plans for both 1980 and
1981 should clearly indicate projected progress against
these goals.

     We should likewise display our actions to undertake
investigations and studies on a more complete health
base for noise control against a specified'objective.  I
think it important that we develop an outline which
indicated the areas in which new information should be
produced on a priority basis and that our proposed
research-related plans in both 1980 and 1981 indicate how
they will meet our needs as outlined.
RADIATION

     In radiation the mission of EPA is now reasonably
well defined as a result of the IRG Report, Libassi
Committee deliberations, NRC Agreements, and our own
actions in developing criteria for waste disposal.  The
IRG Report indicating the multi-agency nature of the
Federal government's nuclear waste management program
should be used as a blueprint for defining the scope of
and timing required for EPA standard-setting in this
area.  The program focus in 1980 should be on actions
delineated in that report.

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                         -  15  -

     The priority we give to actions under the Clean Air
Act must be a product of the reduction in radiation risk
which such actions can accomplish compared to reduction
achieved in other radiation programs.  To the extent that
priority must be given to the issue of radioactive waste,
and/or to the completion of standards required under the
Uranium Mill Tailings Act, I am willing to accept a slower
rate of progress on Clean Air Act-related problems in 1980,
Nevertheless, the program plan for 1981 should present a
full range of actions to effectively implement our deter-
minations on the nature of radioactive air pollution
problems, we should assign them high priority.

     Given the acknowledged limitations of our resources,
I would expect only limited EPA resources devoted in 1980
to implement EPA's general authorities to provide Federal
radiation guidance.  I would much prefer that we take time
to establish an interagency committee to review the poten-
tial scope of the guidance function and assess priorities
as our major program action in the guidance area in 1980.
Implementation of the committee's recommendations would
follow in 1980 and 1981.  Additional resources for EPA in
1981 could be sought where necessary to supplement the
resources of other agencies.

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             OFFICE OF WATER AND WASTE MANAGEMENT

          Overview Statement of Priorities and Goals

          Thomas C. Jorling, Assistant Administrator


     The priority objectives of EPA's Water and Wastewater
Management programs are to implement statutory mandates
providing for:

     o  Achievement and maintenance of the physical,
        chemical, and biological integrity of the Nation's
        ground and surface waters,  with special emphasis
        on protection of public health and sensitive
        aquatic ecosystems;

     o  Treatment, containment, and control of toxic and
        hazardous materials in solid waste;

     o  Protection of an adequate supply of high quality
        drinking water for public consumption; and

     o  Federal, State, and local development of integrated
        environmental management systems which minimize
        transfers of pollutants between media and which
        identify optimal ultimate disposal strategies for
        pollutants.

     The objectives described above can be achieved most
efficiently in terms of both dollars and manpower through:

     o  Effective use of State planning and program funds
        to implement water quality management, water supply,
        and solid waste management goals through State/EPA
        Agreements;

     o  Management of the $4 billion/year construction grants
        program to meet the treatment needs of publicly owned
        treatment works (POTW's) effectively at least cost to
        all levels of government;

     o  Application of alternative, innovative, and cost-
        effective technologies and management practices
        to solve water and solid waste pollution problems;
        and

     o  Emphasis on resource recovery, reuse, and recycling
        to conserve energy, materials, and water.

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                          -  17  -
     The objectives and management tools to achieve them will
be delivered within a context of program integration and
consolidation.  An integrated focus for the Agency and for
OWWM in particular arises because the Resource Conservation
and Recovery Act (RCRA) closed the gaps in the waste disposal
cycle left by previous air and water legislation by providing
control for the disposal of pollutants in or on the land.
Since there is no "free dumping ground", an integrated
approach is necessary to determine the best mix of environ-
mental controls to minimize the adverse effects of pollution.
These integrative efforts will be manifest in the way we
deal with identifiable areas of control or regulation.  For
example; many programs within OWWM act on specific chemicals.
When one program is dealing with a chemical, it is imperative
that all programs regulating that chemical share knowledge,
experience, and implementation.

     Integration of water quality, water supply, and solid
waste programs will generally occur at the State level via
the State/EPA Agreement process.  EPA will encourage States
to conduct integrated problem assessments, develop long-term
strategies to solve their water and waste management problems,
and commit to one-year work programs to implement their
strategies.  In return, EPA will supply program and planning
grants from the Clean Water Act (CWA), Safe Drinking Water
Act (SDWA), and RCRA to assist the States that undertake
integrated approaches.

     An integrated State/EPA agreement process is a logical
outgrowth of the Water Quality Management (WQM) program,
which is a key focus of the Office of Water and Waste
Management.  The major goal of WQM is the development of a
State and local decision-making process to control point and
nonpoint sources of pollution.  Current WQM efforts are
concentrated on plan implementation to achieve water quality
improvements.   Continuing WQM grants will only be made to
State and areawide agencies who can show evidence of imple-
mentation.

     In managing the $4 billion/year construction grant
program, the Agency will consider publicly-owned treatment
work systems as a structural and functional component of
human community.  This should enable questions relating to
levels of performance and technology, operations and
maintenance, sludge management, pretreatment, toxics,
combined storm water overflow and urban drainage to be
viewed as parts of a single system.

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                          - 18 -
     EPA's strategy for 1980-81, then, is to orient funding
toward meeting environmental requirements through stringent
cost-effectiveness review and to stress innovative and
alternative approaches to waste treatment, including water
and energy conservation, reuse and recycling of pollutants,
and small systems.  Funds earmarked for State delegation
under Section 205(g) of the CWA will be directed toward
State assumption of program activities with high pro-
fessional quality consistent with Congressional policy and
requirements.  In addition, the construction grant program
will move rapidly toward reinforcing other Agency actions
such as the control of toxics and enforcement objectives
through implementation of the municipal enforcement strategy.

     Industry is a key focal point for the application of
technology and management practices to control environmental
pollution.   The multiple controls on industry must be
applied in a coherent way to a single facility or industry
category to control toxic and hazardous pollutants effectively.
The available control mechanisms include spill prevention
control plans; best management practices for toxics; BAT,
pretreatment, new source performance standards, and BCT;
RCRA hazardous waste controls; and underground injection
control (UIC).

     This arsenal of controls will be implemented coherently
through consolidated permitting of NPDES, RCRA Section 3005,
and UIC permits.  Permit consolidation will enable concen-
tration on programmatic, environmental, and procedural
permitting elements which allow technical and legal talents
to be applied effectively and efficiently to achieve environ-
mental objectives.

     All OWWM programs will emphasize conservation of our
precious natural resources:  energy, water, minerals and
other materials.  The resource recovery program will strive
to maximize the use of energy and materials which are
currently disposed of as solid wastes.  Municipal and
industrial point source control programs will stress
reuse of wastewater and recycling of pollutants through
standards, permits, and financial assistance.  In parti-
cular, the construction grants program will focus attention
on multi-purpose projects which recover energy and materials
and reuse wastewater.

     Four final OWWM priority areas are:  attention to
specific ecosystems; development of criteria and standards;
implementation of new OWWM public participation regulations;
and emergency response.

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                     - 19 -
o  An important focus is on specific ecosystems or
   subsets of ecosystems, such as:  ground water as it
   is influenced by the programs of OWWM; wetlands
   protection as it is specifically achieved by the
   regulatory program under section 404, and wetlands
   as influenced by such other factors as solid waste
   facility siting, treatment systems siting, and
   others.  The oceans represent another ecosystem
   which is high priority and can only be protected
   by the integrated application of OWWM programs.

o  Another integration of OWWM activity ranging across
   all programs is in development of criteria and
   standards.  Water quality criteria, 404 criteria,
   403 criteria, safe drinking water standards, and
   hazardous substance criteria all will be looked at
   as they are developed, issued and applied.

o  Overall public participation regulations for water
   quality, water supply and solid waste programs,
   which were promulgated in February 1979, will be
   implemented in 1980.  These regulations support
   program integration objectives by standardizing
   certain public participation requirements for OWWM
   programs.  They should foster more effective and
   constructive public involvement across these
   programs.

o  1980 must see the emergency response capabilities
   of OWWM integrated so that the various authorities
   under the Safe Drinking Water Act, Resource
   Conservation and Recovery Act, and the Clean Water
   Act are carried out in a coherent way by adequately
   trained people.  We must build on the emergency
   response capabilities already in place under
   section 311 and expand them to recognize that the
   response is attentive not just to surface waters
   but also to ground waters and to the landscape
   and atmosphere.

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            OFFICE OF TOXIC SUBSTANCES

    Overview Statement of Priorities and Goals

    Steven D. Jellinek, Assistant Administrator
     This Overview Statement lays out what I believe
to be the important priorities for achievement by the
pesticides and toxics programs for the years 1980
and 1981.  As such, it represents my "guidance" to
the managers and staff of the two programs and infor-
mation of interest to our colleagues throughout the
Agency.

     I have arranged the objectives for each into
"general" and "specific" categories.  The specific
objectives are subdivided further into "highest"
priority, "high" priority, and "other."  We have no
low priority objectives.

     The general objectives are provided to give a
sense of what I believe are the thrust and tone of
the programs.  The specific objectives are more in
the nature of outputs I expect to be delivered.

TOXICS—1979

General Objectives

     o    Continue the thrust toward institution-
          building.  From the organizational per-
          spective :

          -    Secure adequate space.

               Staff up to budgeted levels with
   ;            qualified professional and support
               personnel, with special efforts on
               increasing the number of women
               and minorities.

          -    Organize to the branch level.

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                       - 21 -
     From the regulatory perspective:

               Place more emphasis on premanufacture
               review, test standards, and test rules.

          -    Give less emphasis to existing chemical
               regulation.

     o    Complete the development of a priority
          setting system for choosing chemicals for
          testing and regulation under TSCA and
          other statutes; clarify and establish the
          role of the Toxic Substances Priorities
          Committee in this system.

     o    Develop a detailed program planning system
          for each DAA-ship.

     o    Clarify the regional role in TSCA implementation,

Specific Objectives

     Highest Priority

     o    Publish the Chemical Substances Inventory.

     o    Promulgate the final regulations on premanu-
          facture notification; establish and operate
          a system for screening and assessing notices;
          and take actions under TSCA sections 5(e)
          and 5(f) to prevent or control the manufacture
          of new chemicals, as required.

     o    Promulgate a final regulation establishing
          test standards for oncogenicity, chronic
          toxicity, combined oncogenicity and chronic
          toxicity, and good laboratory practices.

     o    Propose the first section 4 test rule
          requiring industry to test 20-30 chemical
          substances and categories of substances.

     o    Propose a rule under section 8(a)  to develop
          basic use/exposure information on approximately
          2-3,000 chemicals to aid in setting priorities
          for regulation.

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                        -  22  -
          Propose a regulation under section 6 banning
          or limiting the use of one existing chemical
          that poses an unreasonable risk to public
          health.

          Fully implement the program to help States
          and school districts identify and control
          asbestos in school buildings.
High Priority
          Propose testing guidelines for premanufacture
          notification.

          Propose remaining test standards for health
          effects and several fate and ecological
          effects test standards; resolve inconsis-
          tencies with pesticides testing guidelines.

          Conduct health and environmental effects
          assessments, monitoring, and economic impact
          analyses to support regulation of new and
          existing chemicals.

          Follow premanufacture notices with individual
          "significant new use rules" and/or individual
          section 8 (a) information rules for a few
          selected new chemicals, as required.

          Begin the development of generic follow-up
          systems for "significant new use rules" and
          section 8(a) information rules for new
          chemicals.

          Begin developing proposed regulations banning
          or limiting the use of an additional 2-4
          existing chemicals that pose an unreasonable
          risk to health or the environment.

          Complete an analysis of the issues concerning
          the impact of testing costs on small volume
          chemicals and, if appropriate, develop
          proposed legislative solutions.

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Other
                       - 23 -
          Continue the development of TSCA and inter-
          agency chemical information systems and data
          bases.

          Complete the development of responsive and
          effective document control data services,
          and FOI procedures.

          Develop model rules for information gathering
          under section 8(a).
     o    Develop a process to review and act expedi-
          tiously on carcinogens, mutagens,  and terato-
          gens under section 4(f).

     o    Initiate the development of generic approaches
          to banning or controlling the use  of chemicals
          under section 6.

     o    Promulgate the PCB ban rule.

     o    Provide industry assistance on TSCA require-
          ments .

     o    Distribute State grants.

     o    Continue development of public participation
          programs.

     o    Support OECD and other planned international
          harmonization programs.

     o    Propose model regulations under section 8(c)
          and 8(d) to require recordkeeping  and submission
          of health and safety studies concerning signifi-
          cant effects of chemicals.

TOXICS—1980

General Objectives

     o    Continue the thrust toward institution-
          building.   From the organizational perspective:

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                       - 24 -
               Staff up to budgeted levels with
               qualified professional and support
               personnel, with special efforts on
               increasing the number of women and
               minorities.

               Build effective staff teams through
               management actions and training.

     From the regulatory perspective:

               Fully operate premanufacture review
               and test rule development.

               Increase emphasis on existing chemical
               regulation,  both individual and generic
               approaches.

     o    Operate a priority-setting system for choosing
          chemicals for testing and regulation under TSCA
          and other statutes, in conjunction with the
          Toxic Substances Priorities Committee.

     o    Operate a detailed planning system for the
          toxic substances program; initiate formal
          evaluation;  modify program design, as needed,
          to increase quality and quantity of output;
          develop, jointly with the R&D community,
          specific program requirements for high
          priority research; examine the need for
          major legislative changes in 1981.

Specific Objectives

     Highest Priority

     o    Fully operate the premanufacture notification
          review process; take actions under sections
          5(e)  and 5(f)  to prevent or control the
          manufacture of new chemicals, as required.

     o    Promulgate the section 4 test rule proposed
          in 1979; propose and promulgate additional
          test rules.

     o    Conduct health and environmental effects
          assessments, monitoring, and economic
          impact analyses to support regulation of
          new and existing chemicals.

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                  - 25 -
o    Promulgate the section 6 regulations proposed
     in 1979 banning or limiting the use of one
     chemical; propose section 6 regulations for
     several additional existing chemicals.

o    Promulgate the section 8(a) information rule
     on 2-3,000 chemicals proposed in 1979.

High Priority

o    Promulgate final testing guidelines for premanu-
     facture notification.

o    Propose and promulgate model rules under
     section 8(a);  promulgate model rules for
     sections 8(c)  and 8(d).

o    Promulgate the full set of health effects test
     standards and the fate and ecological effects
     test standards proposed in 1979; propose
     additional fate and ecological effects test
     standards.

o    Futher develop and begin to use generic
     follow-up systems for "significant new use
     rules" and section 8(a) information rules for
     new chemicals.

o    Publish the revised chemical substances
     inventory; maintain the integrity of the
     inventory.

o    Develop proposed regulations implementing
     generic approaches to regulation under
     section 6.

o    Begin partial operation of TSCA and inter-
     agency chemical information systems and data
     bases; continue systems development.

o    Review and act expeditiously on carcinogens,
     mutagens, and teratogens under section 4(f).
Other
     Begin reviewing existing test standards as
     required by section 4.

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     o    Begin review of overall economic and
          innovation effects of TSCA.

     o    Provide industry assistance  on TSCA require-
          ments.

     o    Continue to develop public participation
          programs.

     o    Support OECD and other planned international
          harmonization programs.

TOXICS —1981

General Objectives

     o    Achieve institutional maturity.   From the
          organizational perspective:

               Have  a stable organization in place with
               technically and managerially qualified
               staff.

     From the regulatory perspective:

               Fully operate all major program com-
               ponents .

               Balance emphasis on regulation of new
               and existing chemicals.

     o    Operate an integrated priority-setting system
          for choosing chemicals for testing and regu-
          lation for TSCA and other statutes, in con-
          junction with the Toxic Substances Priorities
          Committee.

     o    Operate a  detailed planning  and evaluation
          system for the toxic substances program;
          explore alternatives to established regu-
          latory approaches.

     o    If appropriate, develop and  support pro-
          posals for major legislative changes.

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                       - 27 -
Specific Objectives

     Highest Priority
          Fully operate the premanufacture notification
          review process at an improved level;  take
          actions under sections 5(e)  and 5(f)  to pre-
          vent or control the manufacture of new chemicals,
          as required.

          Promulgate and propose regulations under section
          6 with greater emphasis on generic approaches,
          banning or limiting the use of a significantly
          greater number of existing chemicals  that pose
          unreasonable  risks to public health.

          Conduct health and environmental effects
          assessments,  monitoring, and economic impact
          analyses to support regulations of new and
          existing chemicals.

          Continue promulgating rules under sections 4
          and 8 to obtain data to support assessment
          and regulation.
     High Priority
     o    Revise testing guidelines for premanufacture
          notification to provide more specific guidance,

     o    Complete fate and ecological effects test
          standards;  review existing test standards
          as required by section 4.

     o    Use routine, generic follow-up systems for
          "significant new use rules" and section 8(a)
          information rules for new chemicals.

     o    Complete chemical information systems
          development; operate systems, services,  and
          data bases  at full scale.

     Other

     o    Continue actions under 4(f).

     o    Maintain industry assistance.

-------

     o    Continue to develop public participation
          programs .

     o    Support international harmonization programs.

     o    Continue TSCA overall economic and innovation
          impact studies.

     o    Evaluate and refine operating programs.

PESTICIDES — 1979

General Objectives

     o    Continue the thrust toward institution-building.
          From the organizational perspective:

          -    Secure adequate space.

               Staff up to budgeted levels with qualified
               professional and support personnel, with
               special efforts on increasing the number
               of women and minorities.

               Complete the reorganization; fill senior
               line positions.

     From the regulatory perspective:

               Place more emphasis on completing major
               RPAR actions, initiating conditional
               registration, establishing the registra-
               tion standards process, and making
               registration decisions on new chemicals
               with adequate hazard data.

               Give less emphasis to large-scale
               operation of the registration standards
               process .

     o    Develop management systems for expediting
          decisionmaking on high volume operations,
          such as registration and registration
          standards .

     o    Develop a detailed program planning system.

     o    Clarify the  regional role in FIFRA implementation

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                         29 -
Specific Objectives

     Highest Priority
          Review benefits and risks of 15-20 RPAR com-
          pounds identified as posing potentially
          unreasonable adverse effects,

          Reach 17-23 final risk/benefit determinations
          on RPAR compounds.

          Implement the conditional registration program.

          Process 25-30 new registrations,  5,000-5,600
          administrative/technical amendments and 2,000-
          2,500 routine/intrastate registrations in an
          efficient, effective manner.

          Give registration priority to  new chemicals
          for which complete  hazard data are submitted.

          Inititate the preparation of 42-47 generic
          standards, including the reassessment of
          associated tolerances.

          Evaluate the scientific basis  of  the system
          for establishing tolerances, including con-
          sideration of inert ingredients in order to
          revise tolerance regulations.
     High Priority
          Provide timely and responsive guidance to the
          States relative to their FIFRA section 5(f)
          experimental use permits and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

          Review 1,000-1,500 section 24(c)  special local
          needs registrations and conduct overview
          activities on their final actions.

          Review 170-220 section 18 emergency exemptions
          in a median turnaround time of 4  weeks,  including
          full scientific review of pertinent data.

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                        -  30  -
     o    Develop proposed guidelines for biological
          pesticides.

     o    Establish 80-120 pesticide residue tolerances
          and review 75-100 amendments for food and
          animal feed  crops after review of data and
          risk/benefit analyses in a median turnaround
          time of 105  days.

     o    Accelerate the program to classify pesticides
          for restricted use.  Aim for completion in
          1980.

     o    Develop and  initiate procedures to require
          early testing to fill data gaps on existing
          compounds instead of waiting until such gaps
          are identified in the development of generic
          standards,

     o    Integrate 1PM into the RPAR process and into
          regulatory actions (e.g., section 18 emergency
          exemptions)  when technically appropriate.
     Other
          Audit 50-70 testing laboratories.

          Develop more precise procedures for handling
          confidential business data.

          Conduct training program.

          Improve FOI response procedures, so that all
          requests are given an initial response
          within 10 days and a final response as
          quickly as possible.

          Monitor for hazard prediction and significance
          of potential problems.
PESTICIDES—1980
General Objectives
          Continue the thrust toward institution-
          building.  From the organizational perspective:

               Build effective staff teams through
               management actions and training.

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                       - 31  -
     From the regulatory perspective:

               Emphasize completion of the remaining
               RPAR reviews, increasing production of
               registration standards, and registration
               decisions on new pesticide chemicals.

               Initiate reregistration of existing
               pesticides.

     o    Operate priority-setting systems for selection
          of chemicals for the registration standard
          process and for priority registration decisions

     o    Operate a detailed planning system; initiate
          formal evaluation; modify program design, as
          needed, to increase quantity and quality of
          output; develop,  jointly with the R&D
          community, specific program requirements for
          high priority research.

Specific Objectives

     Highest Priority

     o    Review benefits and risks of 12-17 RPAR com-
          pounds identified as posing potentially un-
          reasonable adverse effects.

     o    Reach 15-20 final risk/benefit determinations
          on RPAR compounds.

     o    Implement the conditional registration
          program.

     o    Give registration priority to new chemicals
          for which complete hazard data are submitted.

     o    Reregister 1,000-1,400 products from available
          generic standards.

     o    Complete  the generic standards initiated last
          year,  and initiate the preparation of 40-50
          generic standards, including the reassessment
          of associated tolerances.

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                       - 32 -
    High Priority
         Provide  timely and responsive  gu '.dan^e  to  the
         States relative  to their  section  5MT) experi-
         mental use permits,  aiiu review 1?.)   40
         section  5 registrations in  a median  turn-
         around time of 120 days.

         Review 1,000-1,500 section  24(c)  special local
         needs registrations  and conduct overview
         activities on their  final actions.

         Review 170-220 section  18 emergency  exemptions
         in  & median turnaround  time of 4  weeks, in-
         cluding  full scientific review of pertinent
         dacr

         Prom- Igate guidelines  f _>r biological pesticides,

         Establish  80-120 pesticide  residue tolerances,
         a G rt.-r:ew  75-10C amendmeni-s  for food and
         animal  feed crops after review of data and
           isk/bencfit analyses,  in a median turnaround
         time of  105 days.
     Othe.:

     o    Audit 50-70 laboratories.

     o    Improve FOI response procedures, so that all
          requests are given an initial response within
          10 days and a final response as quickly as
          possible.

     o    Monitor for hazard prediction and significance
          of potential problems.

PESTICIDES--1981

General Objectives

     o    Achieve institutional maturity.  From  the
          organizational perspective:

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                       - 33 -
               Have a stable organization in place,
               with technically and managerially
               qualified staff.
     From the regulatory perspective:

               Fully operate all major program com-
               ponents .

               Substantially complete RPAR.

     o    Operate an integrated priority setting system.

     o    Operate a detailed planning and evaluation
          system.

     o    Intensify strategy for replacement of older
          pesticides with unknown or hazardous effects
          with new, safer pesticides and alternative
          pest control actions.

Specific Objectives

     Highest Priority

     o    Integrate the RPAR process into the generic
          standards production process,

     o    Give registration priority to innovative,
         \ environmentally protective compounds.

     o    Reregister 1,000-1,400 products from available
          generic standards.

     o    Complete the generic standards intiated last
          year,  and initiate the preparation of 40-50
          generic standards, including the reassessment
          of associated tolerances, with attention to
          detail and quality.

     High Priority

     o    Provide timely and responsive guidance to
          the States relative to their section 5(f)
          experimental use permits, and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

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                  - 34 -
o    Review 1,000-1,500 section 24(c)  special
     local needs registrations, and conduct
     overview activities on their final actions.

o    Review 170-220 section 18 emergency
     exemptions in a median turnaround time of
     4 weeks.

o    Establish 80-120 pesticide residue tolerances,
     and review 75-100 amendments for food and
     animal feed crops after review of data
     and risk/benefit analyses, in a median turn-
     around time of 105 days.
Other
     Audit 50-70 laboratories.

     Improve FOI response procedures, so that all
     requests are given an initial response within
     10 Jays and a final response as quickly as
     possible.

     Monitor for hazard prediction and significance
     of potential problems.

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                    OFFICE OF ENFORCEMENT

          Overview Statement of Priorities and Goals

          Marvin B. Durning, Assistant Administrator
     This guidance builds upon the top priority activities
set out for enforcement in the EPA Policy Guidance for
FY 1979/80.  The activities described are our top enforce-
ment priorities, not a complete list of all enforcement
activities.  These priorities are stated as programmatic
priorities and as management-institutional priorities, but
the two are obviously interrelated.

PROGRAMMATIC PRIORITIES

Enforcement in Emergencies

     All EPA, State, and local enforcement personnel should
give top priority to any true emergencies involving sub-
stantial threats to public health and safety.  Containment
and removal of the dangers is, of course, the top priority.
Follow-up on penalties for violations can be undertaken in
the course of other enforcement, rather than as an emergency,
This guidance applies, of course, to emergency enforcement
response to hazardous spills.

     At this time in FY 1979, EPA personnel have as their
top priority the investigation and prevention of substantial
and imminent hazards created by existing or abandoned
chemical waste sites.  Those efforts will continue as facts
may dictate.  We expect a large number of civil actions of
this nature in FY 1980 and 1981.

Major Source Enforcement Effort

     The major source enforcement effort against violators
of the Air Act and Water Act is our next highest priority
after emergency situations.  Enforcement against these major
sources is critically important to accomplishing our environ-
mental goals.  It is directed against that small minority of
major sources which failed to meet the requirements of the
Air and Water Acts by the statutory deadlines.  It includes
many of the most serious and most recalcitrant sources of
pollution in the country.  By bringing these sources into
compliance, with penalties where appropriate, we will keep

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                         - 36 -



faith with the great majority of firms and public bodies
which met their responsibilities and will build the
confidence necessary to continue voluntary compliance
with all the environmental laws.

     In FY 1980, Regions and States will bring the major
source enforcement actions to decision by settlement,
administrative process, or court trial, including
appropriate penalties, and make or defend appeals.  By
the end of FY 1980, the major source drive should be
nearly completed, with only a few actions and appeals
still pending in trial or appellate courts.  In FY 1981,
actions and appeals still pending should be completed as
rapidly as possible.

Enforcement against Automobile and Truck Pollution

     Because of the great public health and environmental
significance of air pollution from automobiles and trucks,
especially in urban areas, enforcement against mobile
sources of pollution will continue to be a top enforcement
priority in FY 80/81.

     EPA enforcement will continue to ensure that new
vehicles meet emission standards.  We will increase our              Jj
emphasis on maintaining the effectiveness of emission                ™
control systems throughout the period of their use.  To
achieve this, EPA's main emphasis will be on inspection
and maintenance systems in the major nonattainment areas
for auto-related pollutants, supplemented with Head-
quarters audits and I/M programs.

     o   To ensure that new vehicles meet standards, EPA
         enforcement will continue our assembly line
         audits, recall and warranty efforts.

     o   To ensure that cars in use meet standards and to
         support introduction of inspection and maintenance
         systems where needed, EPA will continue to focus
         investigations and enforcement actions (a) on
         national or regional fleets, chains, dealership or
         repair facilities, or "pattern" violations and (b)
         in major metropolitan areas where auto pollution
         is high and I&M will be introduced.  EPA will
         encourage State and local anti-fuel switching and
         anti-tampering efforts.

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                          - 37  -
     We will use private, State, or local contracts to
carry out inspections to ensure the availability and purity
of unleaded gasoline, and the installation and operation of
vapor recovery systems on fuel delivery trucks and at
gasoline outlets.

     EPA and the States, in cooperation with other agencies,
will implement any programs authorized to control the
leaded-unleaded gas price differential and other authorized
environmental/energy programs.

Consolidated and Simplified Permitting

     EPA is consolidating its permit programs, both to
simplify administrative steps and to get all important
environmental problems addressed in a single process.  By
October 1, 1979, companies will be able to submit just
one application for all water, solid and hazardous waste
permits, go through one review, and be issued one permit.
We expect application forms for air quality permits to be
consolidated in late FY 1980  (or early FY 1981).  NPDES
second round permits under the Clean Water Act will be
issued throughout FY 1980/81.  We will begin to issue
hazardous waste permits in late FY 1980, accelerating in
FY 1981.  We will also start  issuing Underground Injection
permits in FY 1981.

     In all permitting activities, we will give first
priority to large or major sources with serious adverse
health effects, including those with significant toxic
discharges.

Full Federal Compliance

     President Carter has directed all Federal facilities
to come quickly into compliance with Federal, State, and
local environmental requirements.

     By the end of 1980, we expect all, or almost all,
Federal facilities both major and minor sources will be
in compliance.  Regions should see to it that all Federal
facilities do indeed come into compliance as soon as
possible.  EPA will ensure that Federal agencies request
necessary funds for compliance by reviewing the agencies
plans included in the annual A-106 report.

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                          - 38 -
     EPA  is encouraging the States to assume  these respon-
sibilities for Federal facilities.  The States should
find the  managers of Federal facilities cooperative.  EPA
will assist the States in getting any disputes resolved.

Stationary Sources

     Completing the Major Source Enforcement  Effort contin-
ues to be of highest priority in FY 1980/81,  including the
monitoring of compliance orders to ensure that sources comply
with the  terms of the orders.  We also want to ensure that
major sources comply with new requirements placed on them
by SIP revisions and by the ambient standards for lead, and
to enforce new source performance standards and national
emission  standards for hazardous air pollutants.

     As the Major Source Enforcement Effort is completed in
FY 1979/80, EPA will design and implement an  improved program
of compliance monitoring and enforcement to ensure continuous
compliance.

     During FY 1979, regulations will be promulgated for
administrative assessment of noncompliance penalties under
Section 120 of the Clean Air Act.  This program should be
fully implemented during the second half of FY 1979 and
throughout FY 1980/81.  Prompt implementation of these
penalties should assist in obtaining and maintaining
compliance with the Air Act.

Water Enforcement

     Completion of the Major Source Enforcement Effort,
including actions against publicly owned treatment works
(POTW's), continues to be of highest priority in FY 1980/81.
As this effort is completed, EPA will design  and implement
an improved program of compliance monitoring  and enforcement
to ensure continuous compliance.

     Beginning in FY 1979 and growing in importance in
FY 1980/81 will be advice and assistance to delegated States
so that State pretreatment programs can be established and
the conditions of those programs enforced.  During FY 1981
the activities of assisting and advising States and POTW's,
modifying permits to incorporate pretreatment requirements,
approving POTW treatment programs, notifying  affected
indirect  dischargers, and determining treatment levels
should be at their peak level and of prime importance if we
are to achieve compliance by all affected POTW's and indirect
dischargers by FY 1983 or FY 1984.  NPDES permits will be
issued as part of the consolidated permits program.

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                          -  39  -
Strategies for New Programs (TSCA, RCRA, SDWA, FIFRA)

     In recent years. Congress has provided new programs
and has amended existing statutes to respond to the threats
of chemical poisons, hazardous wastes, and pesticides, and
to protect drinking water supplies.  We must carefully
devise or revise enforcement strategies under the additional
provisions of the Toxic Substances Control Act (TSCA), the
amended provisions of the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA), the hazardous waste provisions
of the Resource Conservation and Recovery Act (RCRA), and
the Safe Drinking Water Act (SDWA).

     Under RCRA, our priority enforcement activities in
FY 1980/81, in addition to responding to emergencies,
include monitoring and enforcing the notification program
(Section 3010); reviewing proposed State programs for
enforceability and adequacy; issuing permits, monitoring
permitted sites, and ensuring that Compliance Schedules
are met; and monitoring and enforcing the manifest
systems.

     Under TSCA, our compliance monitoring and enforcement
will initially focus on PCBs, chlorofluorocarbons, inventory
requirements and to premanufacturing notice requirements.
We will continue our special investigative efforts regarding
the accuracy and truthfulness of laboratory test data in
the toxics and pesticides programs.

     Under FIFRA, during FY 1980/81 EPA will attempt to
develop cooperative enforcement grant programs with the
remaining seven States (for a total of 50) and will
continue to enforce regulations on pesticide use until
States assume this responsibility.

     Under SDWA, EPA will respond to emergency situations
threatening public health and will concentrate on enforce-
ment of primary drinking water standards, particularly in
non-primary States.

Noise Control

     The noise enforcement program will continue to ensure
compliance with standards and requirements for products and
procedural labeling as its top priority.  Although urban
noise can often be controlled through State and local efforts,
it continues to be a Federal responsibility to ensure that
products meet the standards established under the Noise Act.
EPA Headquarters will carry out this function.

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                          -  40  -
MANAGEMENT AND INSTITUTIONAL PRIORITIES

     In addition to the preceding programmatic priorities,
we have a number of management and institutional improve-
ments as top priorities.  These improvements have to some
degree already been described in the programmatic priorities
and they obviously interrelate with them.

     o  Consolidated Permitting -- EPA will consolidate
        and simplify its permitting activities, mostly
        during FY 1979 and totally by the end of FY 1980.
        It will assist and encourage States to do so as
        well.

     o  Industry Enforcement Strategies — During FY 1979
        and FY 1980 EPA will develop and implement industry
        enforcement strategies for selected industries.

     o  Continuous Compliance — We will develop programs
        for ensuring continuous compliance by regulated
        sources, including compliance monitoring (and
        information systems for recording and tracking
        compliance), penalties to remove the economic
        benefit of non-compliance and remote sensing
        techniques.

     o  Improved Oversight of State Enforcement -- During
        FY 1979 and thereafter, Headquarters and Regional
        personnel will begin to apply standards of perfor-
        mance to State enforcement activities under all
        Federal grants or contracts for enforcement.

     o  Management and Management Information Systems —
        During FY 1979 and FY 1980 as needed, we will
        review our management, reporting, and information
        systems (including ADP systems).  Our emphasis will
        be on improved accuracy, usefulness, simplicity,
        and compatability.

     o  Improved Cooperation with Other Agencies —
        During FY 1979, 1980, and 1981, we will improve
        our cooperation with other agencies, such as the
        Department of Justice, the other members of the
        IRLG (OSHA, FDA, and CPSC), the Securities Exchange
        Commission (SEC), and the Departments of Energy and
        Interior.

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                 - 41 -
Innovative Methods — Throughout FY 1979, 1980,
and 1981 the Office of Enforcement will explore
innovations such as widened use of penalties to
remove economic benefits of delay, environmental
auditing, and contracts or grants with citizen
groups.

Investigating Criminal Violations — During
FY 1980/81 EPA enforcement will improve its
ability to investigate criminal violations of
environmental laws by recruiting and training
EPA investigative personnel.

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             OFFICE OF RESEARCH AND DEVELOPMENT

        Overview Statement of Priorities and Goals

         Stephen J. Gage, Assistant Administrator
     During the next two years, three major objectives will
be driving the Environmental Protection Agency's research
and development program: (1) continuing the integration of
the Office of Research and Development into the mainstream
of the Agency's activities, (2) enhancing the Office's
capability to provide the scientific and tecnnological data
the Agency will use fo" future regulatory and enforcement
actions, and (3) improving that data through scientific peer
review of research procedures and results, quality control
of risk assessments, and quality assurance of monitoring
data.

     Much of the groundwork for achieving these objectives
has been laid durinq the past year.  The Research Committees
have been quite successful in planning research in five
critical areas jointly with the Program Offices.  A signifi-
cant Public Health Research Initiative ($37 million, 46
positions) was developed and successfully defended with
OMB through the cross-agency zero-based budgeting for toxics.
A new Office of Health and Environmental Assessment, building
on the successful experiences in scientific assessments by
the Carcinogen Assessment Group and the Environmental
Criteria and Assessment Office, has been proposed.  Other
developments have also built a good foundation for future
action.

INTEGRATING ORD INTO THE_AGENCY'S MAINSTREAM

     Joint planning of the Agency's research and development
activities tnrough the five pilot Research Committees already
provides a very valuable linkage between the regulatory
program offices responsible for developing regulations and
the ORD scientists and engineers supporting the regulatory
efforts.  During early 1979, we will establish seven new
Research Committees to cover the joint planning of sub-
stantially all of the research in support of regulation and
enforcement.  Each of the 12 committees will be specifically
oriented to the users of the research information, typically
Program Office Deputy Assistant Administrators or, in some
instances, Division Directors (see Attachment A).

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                         - 43 -
     The new Research Committees will develop multi-year
research strategies oriented toward supporting regulatory
needs; identify research outputs required within the next
budget year (now beginning the FY 1981 cycle); seek the
required resources through the Agency's ZBB process; and
monitor and evaluate ongoing and completed research.  We
must make special efforts during this formative period
to bring more fully the Agency's enforcement and Regional
programs into the joint planning process.  In the interest
of cost-effectiveness, it will oe necessary for the Regional
Offices to coordinate their participation and share respon-
sibility for representing Regional interests in the Research
Committee; ORD will support the Regional Offices in this
effort.

     We will continue to experiment cautiously with matrix
management approaches as a means of improving the coordi-
nation and delivery of high-visibility, short-term research
outputs.  Matrix management of the diesel emissions program
will continue, and we will consider establishing a limited
number of similar programs, such as in Acid Precipitation.

     Closely related to the evolution of the joint research
plannng approach is the long-overdue simplification of
ORD'S planning and reporting systems.  We must take this
step to bring ORD's planning and management approaches into
synchronization with (1) the five-year plan developed in the
preparation of the Agency's Research Outlook, (2) the multi-
year plans developed by the Research Committees, and (3) the
Agency's ZBB review and decisions.  We must also eliminate
the redundant paperwork that absorbs too much ORD staff time,

     In order to improve accountability for the research
and development efforts, we must bring into operation a
reliable tracking system for the critical outputs required
by the Program Offices as identified by the Research
Committees.  As a corollary, we must also reduce to a
manageable number the outputs to be tracked.  While we must
have adequate information to monitor progress of the key
outputs, we must vigorously resist spending too much time
and effort reporting preliminary and fragmented data.  Good
research management means monitoring the right indicators,
not all of trie possible indicators, of orderly progress
toward objectives.  Too much reporting together with
overspecification of research investments will counterpro-
ductively tie the hands of the research managers and stifle
innovative research.  Management flexibility nust, of
course, be coupled with accountability.

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                          -  44  -
     With the increased pressure for higher quality manage-
ment of several key research areas, we will be realigning
the laboratory reporting relationships to consolidate
functional or discipline groupings.  These changes, which
should improve morale and productivity, will allow us to
improve the implementation of the Agency's research efforts.
Specifically, the realignment will establish an office for
health effects research management; an office to integrate
environmental transport, fate, and effects research; and an
office to integrate control technology and hazardous waste
research.

BUILDING A RESEARCH FOUNDATION FOR AN IMPROVED DATA BASE

     We made important progress in the past year in starting
the long-term process of building a foundation for a signifi-
cantly improved scientific and technological data base for
the future regulatory and enforcement actions of the Agency.
Planning and budgeting the Public Health Research Initiative
was a critical first step, but it was only a beginning.

     We must now commit ourselves to the detailed planning
and implementation of the Initiative.  Since the Initiative
represents the first significant expansion of the Agency's
basic environmental health sciences, we must wisely dedicate:
it to achieving a solid understanding of human health effects
caused by both direct and indirect environmental exposures.
Because we will be drawing heavily on scientific talent in
the private sector to assist us in this effort, we must
begin immediately to seek the best scientific advice
available to help us in this planning effort.

     The second critical step, a broad environmental
research initiative, must be taken immediately.  Because
of the heightened awareness in the Administration of
EPA's requirements for the best scientific and techno-
logical data that can be developed for the Agency's
comprehensive environmental regulations, we now have an
excellent opportunity to seek a government-wide review of
environmental research.  This review will focus on how
existing and future Federal resources can support broader
based, longer term environmental research to build an
improved data base.  We must assume the leadership in
developing the conceptual framework for such efforts,
bringing to bear on the program design the best scientific
advice available.  We must look to the Agency's Science
Advisory Board, the President's Office of Science and

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                           - 45 -
Technology Policy, and the National Academy of Sciences as
well as numerous individual scientists in this comprehensive
planning and review effort.  We are now in the process of
developing a select set of initiatives for 1981 and beyond,
focusing on protecting humans from environmentally mitigated
pollutants; identifying and protecting critical components
of ecosystems from injury; and addressing the more global
problems of protecting our life support systems.

     In parallel with these activities, we must carefully
review the longer-term research already underway in ORD to
assure ourselves that f..e are directing our attentions to
the most important future problems and are using the best
scientific talent we can attract to work on these problems.
We must determine if we are obtaining high quality, well-
documented results from our research grants -- the primary
mechanism we have for supporting innovative ideas.  We must
make the scientific community more widely aware of our
research grants, encourage much greater competition for
those grants, and ensure that they are awarded strictly on
the basis of merit through enhanced peer review.  We should
also see if alternative approaches for handling these longer
term grants can relieve the burdensome monitoring loads
placed on the individual laboratory researchers.

     An invigorated, competitive grant program for longer-
term research in each research area, coupled with an expanded
Anticipatory Research Program, will provide the Agency with
an important new base of exploratory research.  It is
essential that, with the significant infusion of new funding
associated with the Public Health Research Initiative, we do
not waste this opportunity to build a firmer foundation with
the help of the best scientific talent available in the
country.

IMPROVING THE QUALITY OF DATA USED IN DECISION MAKING

     Scientific and technological data come in many forms
and in varying quality.  The credibility and integrity of
all data used in Agency decisions is a prerequisite for
any analyses.  The evaluation and synthesis of the data is
an essential step in informing the many far-reaching
regulatory decisions.  We have made significant progress
during the last year in providing carcinogenic risk
assessments for the Program Offices and in improving the
capability of ORD to prepare Air and Water Quality criteria
documents by establishing the new Environmental Criteria and
Assessment Offices in Research Triangle Park and Cincinnati.

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                         - 46 -
     We have not yet, however, undertaken the special
responsibility assigned by the Administrator to provide
quality control of the Agency's risk assessments.  With
approval of ORD's new Office of Health and Environmental
Assessment (OHEA), we must now move ahead, first to quickly
develop guidelines for the several types of risk assessments
required for the Agency's regulation development, and then
to exercise oversight to ensure that the asssessments
prepared by the Program Offices conform reasonably to the
guidelines.  We must also proceed to staff OHEA with the
best qualified people we can attract from the scientific
community, significantly upgrading in this process ORD's
capability to provide consultation to the Program Offices
and, upon request, assessments of specific chemicals.

     Although we in ORD have discussed the role of peer
review extensively during the past year, we must now
act in the coming year to build into all of the Agency's
scientific and technological efforts appropriate review
mechanisms.  We must begin with enhanced peer review for
individual research projects.  The ORD senior laboratory
management must convey to the professional staff strong
support for and assistance in periodic external peer
review of individual projects.  Whenever feasible, the
results of individual projects should be subjected to
rigorous scientific or technological scruntiny through
publication in referred journals.  We should also see
that the results of our grants and contracts are published
in peer-reviewed journals, slowing the growth of that body
of EPA-published "gray literature" which now constitutes
the only publication channel for too much of our work.
Publication of research results in the peer-reviewed
literature must become an important criterion for advance-
ment in all of our laboratories.

     In addition to peer review of individual research
efforts, we must systematically review our research programs,
While such reviews may begin at the laboratory level, it is
usually more appropriate to conduct them at the level of the
Deputy Assistant Administrators or even of the Assistant
Administrator.  Since the Research Committees will be
providing the primary focus for the bulk of our research
activities, it is logical that we direct our attention
increasingly to programmatic reviews along the lines of the
committees.  We should also be mindful of other mutually
supporting programmatic areas which may provide results for
several committees, such as biological screening tests,
analytical methodologies, etc.

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                         - 47 -
     Finally, we have been expanding in the past year our
efforts to provide support to Agency laboratories for
quality assurance of environmental monitoring data.  We must
now assume the lead for improving the quality assurance of
all of the environmental monitoring data used in the Agency's
decisions.  We must first make sure our house is in order
by requiring adequate quality assurance practices for all
environmental quality monitoring, sampling, and analytical
activities conducted in the ORD laboratories or by our
contractors or grantees.  This policy should become effective
immediately.  We must also require, through the Blue Ribbon
Monitoring Task Force, similar quality assurance practices
for all of the Agency's laboratories, contractors, and
grantees.  Lastly, we must work closely with the Regional
Offices to bring quality assurance practices into uniform
use in all of the State and local laboratories, which
provide the bulk of the environmental quality data available
to the Agency.

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            OFFICE OF PLANNING AND MANAGEMENT

       Overview Statement of Priorities and Goals

     William Drayton, Jr., Assistant Administrator


     The Agency's central management objective remains that
of creating a national environmental program that derives
strength and initiative from decentralization and purposive-
ness and environmental coherence from effective integration.
Toward these and other ends we must strengthen our analytic
and common services in a number of areas.  This guidance
deals first with that central objective, then with other
objectives connected with our analytic and common services.

AN INTEGRATED,
DECENTRALIZED PROGRAM

     From its inception EPA rejected the top-down, over-
centralized, untrusting Louis XIV/Herbert Hoover form of
management common to most government organizations, a form
that has failed.  Instead we are building on the philosophy
of the Federalist Papers:  decentralize and democratize
within a realistic set of incentives designed to ensure
organizationally responsible results.

     Not only are we doing what makes sense for EPA, but             ™
we're setting the pace for others.  That's why others in
the government have quickly recognized so many of our
reforms as models.

     No matter how satisfying being out front is, however,
it doesn't make ground breaking any easier.  Although
we've come a long way, we still have several years of
intense work ahead of us:

     (1)  We should continue to strengthen our regulation
          development and zero-base budgeting.  They
          provide the structure that makes possible broad
          involvement in the Agency's two principal cross-
          cutting areas for decision making:  respectively,            ,,
          (a) regulation and policy development and (b)
          priority setting, management, and resource allo-
          cation.  Regulation development is mature, and
          ZBB is over the worst of its start-up pains.
          Both need continuing adjustment and strong support.          *

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                    - 49 -
     The Regions should contribute more heavily to
     regulation development and review, especially
     regarding operational and resource issues.

     Last year ZBB focused heavily on process;
     henceforth it should focus more on substantive
     analysis: getting workload analysis fully
     implemented,  finding efficiencies, developing
     new program initiatives,  and re-examining  older
     programs carefully.  We must also continue to
     help Office of Management and Budget develop
     cross-agency ZDri.

(2)   We need both stronger State programs and
     stronger State/EPA collaboration.  State and
     local officials now staff 85 percent of the
     national environmental regulatory effort,  and
     we are seeking to delegate even more.  We  must
     strengthen our joint environmental management
     effort, especially in the following areas:

        We have more than doubled the Federal grant
        support to State and local units since  1977
        (including the addition of the Clean Water
        Act, Section 205(g) funds).

        Our new State/EPA agreements should become
        more than contracts:  they should induce
        joint planning and they should press
        decision making up to the senior policy
        officials on both sides.  This should make
        it easier to refocus programs as our needs
        change and to innovate and integrate.  By
        1981 the agreements should cover all our
        programs.

        We must win passage for and then implement
        our Integrated Environmental Assistance
        legislation to give the States the flexibility
        and added resources for such refocusing,
        innovation, and integration.

        We should encourage personnel interchange
        and training, e.g., through group IPA's.

(3)   Our Regional Administrators must strengthen
     their management/analytic capacity so that
     they can better manage their Regions, lead
     and evaluate the State and local agencies  in

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                         - 50 -
          their areas more effectively, and participate
          equally in Agency-wide policy and management
          decision making.  Unless the Regions' ability
          to think and manage is strong, both Regional
          decentralization and EPA's linkage with State
          and local government are at risk.  Headquarters
          analytic units must help the Regions develop
          this capacity, and both sides should build
          strong, continuing ties.

     (4)   Our managers should adopt Agency-wide career
          paths.   True independence, based ultimately
          on the real ability to move if frustrated,
          will flow from the professional breadth,
          self-confidence, and reputation such mobility
          will foster.  It will also give the Agency a
          management team with Agency-wide environmental
          perspective and loyalty, a critical step in our
          successful integration.

     (5)   The Agency's grantees, programs, and managers
          should be held accountable for their perfor-
          mance.   We do not do this core management task
          at all well now.  Our new personnel performance
          evaluation and reward program -- probably our
          most demanding management reform for the next
          12 to 18 months — will make major difference.
          Our review of monitoring and the new Regional
          Profiles may help.  OUr fundamental scrutiny
          and rationalization of our many computer-based
          information systems will help.  A systematic
          regiment of evaluations beginning at the local
          and State levels and working up is critical.
          Such evaluations should be backed by a reformed
          reporting system and tied to the promises made
          in ZBB.  Designing and implementing a practical,
          integrated, limited-cost way of holding the
          States' and our own decentralized managers
          accountable is a difficult, missing part of our
          management construction.

RESPONSIVE,
EFFICIENT SERVICES

     We will continue implementing a number of fundamental
improvements in the Agency's services in 1980-81:

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                         - 51 -
     (1)  We must begin to manage EPA's personnel.  The
          new Civil Service Reform Act only makes this
          possible:  we will have to make it happen by
          changing the way each of our managers does his
          or her most important job.

     (2)  We will begin pilot tests of contracting reform
          in 1979 to improve responsiveness and cut
          processing time.

     (3)  The Agency will commit to new computers after
          a thorough management review of our data needs
          and of our existing and planned programs.

A SMART AGENCY

     Our analytic services — directly supporting our top
managers, helping prepare regulations, checking budget
pricing, providing legal or economic analyses, negotiating
with other agencies, and the like — must keep up with a
growing workload and maintain a superior level of pro-
fessional quality.  Compromise here is foolish.

     We must continue our leadership in regulatory reform.
Finding more effective, equitable, and economical ways of
doing our work is one of the most useful, highly leveraged
opportunities open to us.  (Further, as America's largest
regulatory agency, we have a responsibility to lead.  Our
two most important reforms are controlled trading and tools
for regulatory decision making, including benefits analysis.

     Once we set a standard for controlled trading of
clean-up requirements, we can allow those we regulate to
find more efficient ways of achieving the same (or better)
environmental result.  These alternatives must also be as
administrable and enforceable as our initial approach.
Offsets (in both non-attainment and PSD areas), the bubble,
banking, brokerage, and perhaps marketable rights should
gradually all fit together into an increasingly important
complement to traditional "command and control" regulation.
If we can make this approach work on a wide scale, we will
provide our first positive incentive for control technology
innovation and significantly reduce clean-up costs (and
therefore resistance to clean-up).

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                         - 52 -
     To strengthen both performance and accountability
we should strengthen our program evaluation capacity at
all levels.  We should also play a stronger leadership
role in Administration debates on both economic and energy
policies; the best defense is a more sensible alternative.

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1980/1981 AIR MEDIA GUIDANCE

-------
                        AIR
MEDIA OVERVIEW
Planning Assumptions

     New Source Review (
     will have EPA appro
     for Prevention of S
     During FY 80, Regio
     review of PSD permi
     pal Regional Office
     maintaining an over
     grams with little o
     EPA will make maxinuKra
     support in conduct!
     vities in 1980 unti
     will utilize Sectio
     assistance.

     Headquarters and Re
     specific expertise
     policy and guidance
     implementing the PS
     Regional overview f
     ticular attention t
     adjoining States,,
     assistance from Hea
     in mediating/arbitr
     state impact on gro
     particularly in hig

     The promulgation of
     requirements to inc
     dioxide, and volati
     will be completed b
     Radiation  (OANR) by
     support the States
     policy in the revie
     control technology
     a clearinghouse for

     During FY 80/81, th
 SR)_ — In FY 80,  most States
 ed State Implementation Plans
 gnifleant Deterioration (PSD).
 al Offices will curtail their
  applications with the princi-
 role in FY 81 being one of
 lew of State and Local pro-
  no direct EPA permit issuance.
   utilization of contractor
 g required permit review act.i-
, State plans are approved and
  105 grant funds to secure such
 ional Offices will provide
and interpretation of Agency
 (ex. modelling)  to States in
  program.   In addition, the
.motion in FY 81 will give par-
  assuring consistency between
 he Regional Offices with
Iquarters will be involved
ating issues relative to inter-
 th plans and use of the increment
  growth areas.

 regulations expanding PSD
 ude carbon monoxide, nitrogen
 e organic compound emissions
7 Office of Air,  Noise,  and
 the end of FY 80.  OANR will
 fforts to insure consistent
  of new source permits and
leterminations by maintaining
 these decisions.

e number of New Source Performance
     Standard promulgations by OANR will be greatly
     increased.  These new emission limits will provide a
     general basis for determining required case-b', --^atvj
     Best Available Control Technology  (BACT) by either
     the State or Regional Office for sources subject
     to PSD.

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                     56 -
In those States not delegated New Source Performance
Standards (NSPS),  National Emission Standard for
Hazardous Air Pollutants (NESHAPS)  or having an
approved SIP for PSD, Regional Offices will con-
tinue to verify the compliance and initiate enforce-
ment action against new sources including Federal
facilities subject to NSR requirements which are in
violation of procedural, permit, or emission require-
ments .

The Office of Air, Noise and Radiation and the
Office of Enforcement in FY 80 will develop procedures
for the overview and audit of State new source review
activities including engineering determinations,
modelling, public notification, surveillance, and
enforcement to assure new source compliance with both
procedural and emission requirements.  This review
will also include adequacy of procedures for tracking
increment utilization, growth and impact on air
quality including Reasonable Further Progress in
attaining standards.

The consolidation of EPA new source permitting
programs will continue in 1980.  Inclusion of the
air permits into the consolidated program where
direct Regional Office permitting activities are
still necessary will occur in FY 81.

Carbon Monoxide and Ozone (CO/03) — During FY 80,
the review and possible revision of the National
Ambient Air Quality Standards  (NAAQS) for CO will
be completed.  It is expected that if there is a
revision to the CO standard, it will not signicantly
change the number of major urban nonattainment areas
where the development and implementation of trans-
portation measures  (including automobile inspection/
maintenance  (I/M))  by the States would be necessary to
attain the standard by 1987.

In FY 80 followup actions to remedy deficiencies in
the 1979 SIP submissions will be completed by most
States and reviewed by Regional Offices.  Also, the
schedules contained in the 1979 SIP for develop.! ng
mandatory I/M programs, conducting a transportauinn
control planning process, and enacting additional
volatile organic compound (VOC) regulations consis-
tent with the Control Technology Guideline  (CTG)
documents will be met by most States in both FY 80/81.
Regional Offices will track the progress of States
in meeting these schedules with major guidance being

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                   - 57 -


provided in the development of the transportation
planning process in urban areas greater than 1,000,000
population, and the development of mandatory I/M
programs.  The appropriation by Congress of any
additional Section 175 monies for support of the
transportation planning process is not expected in
FY 80 or 81.

Development of a regional ozone model will be completed
by the Office of Research and Development (ORD) in
FY 81 with support from OANR.  The model will serve
as a major tool in developing the appropriate strat-
egies by States for inclusion in the 1982 SIP sub-
mission for those major urban nonattainment areas
having an extension that are experiencing extensive
air quality violations and which will require imple-
menlation of complex and costly control measures to
attain by 1987,,  Use of the model will require in
FY 1980 the development by the States of extensive
data bases within these areas  (i.e., emissions, air
quality, meteorology!.  The establishment of National
Air Monitoring Stations (NAMS) for ozone and the
quality assurance of the data from these stations
should be completed by the States to provide the
ambient data necessary for model application.

Verification of compliance and initiation of necessary
enforcement action by the States against existing
stationary sources subject to the new VOC emission
limits included in the 1979 SIP and the additional
regulations required to be enacted by January 1980
will commence.  Regional Offices will work with
States to develop a strategy for these sources and
oversee State efforts to verify and secure compliance.
The Regions will initiate necessary enforcement action
where States fail or cannot act or request EPA
assistance.  The 1979 SIP is expected to increase
the number of major VOC sources subject to the SIP
by 3,000 with an estimated 6,000-8,000 additional
sources anticipated by the end of FY 81.

In FY 80, enforcement by EPA of anti-tampering and
fuel switching requirements in areas requiring man-
datory I/M programs will be initiated by Mobile
Source Enforcement Division  (MSED).  These actions
will assist in reducing the costs to the public of
passing a mandatory vehicle inspection.  States will
be encouraged to enforce existing State anti-tampering
or fuel switching regulations or to develop regu-
lations if none exist.

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                    -  58  -
In FY 80, both EPA Regional Offices and the States
will establish more effective measures for informing
the public and securing public participation in the
strategy development and implementation process
particularly as it relates to the transportation
planning process and mandatory I/M programs.

Procedures will be established and implemented by
OANR to insure consistent application of sanctions
nationwide as required by Sections 176 and 316 of
the Clean Air Act where States fail to enact or
carry out necessary controls for the attainment of
NAAQS.

The development and promulgation of additional mobile
source emission standards required by the Clean Air
Act will be completed by OANR in FY 80.

Total Suspended Particulates and Sulfur Oxides
(TSP and SOX) — In FY 80, the required review of
NAAQS for TSP and S02 will be completed by OANR with
necessary revisions to be promulgated by EPA in FY 81.
The review of the TSP standard may result in the
promulgation of new primary ambient standard for
inhalable particulates (IP) and subsequent secondary
ambient standards for sulfates and fine particulates
during FY 81.  The modification and promulgation of
additional TSP/S02 standards will require major State
efforts to revise the SIP in FY 81 with completion
required in FY 82.  In FY 80, efforts to refine the
definition of the nature and extent of the TSP prob-
lem  in urban nonattainment areas where re-entrained
fugitive dust is a major element will be conducted
by both ORD and the States in anticipation of the
new standards.

By the beginning of FY 80, all State or EPA-initiated
civil/criminal actions associated with the Major Source
Enforcement Effort (predominantly TPS and SO2 sources)
will have been undertaken with decisions either by
settlement, administrative process, or trial completed
by the end of FY 80 and disposition of appeals com-
pleted as early as possible in FY 81.  The compliance
of Federal facilities with existing SIP requirements
will also be completed by EPA or the States by the
end of FY 80.  States in FY 80 will assume a larger
role in securing and maintaining the compliance of
Federal facilities.

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                        - 59 -
     Delegation to the States of the non-compliance
     penalty program (Section 120)  initiated by EPA in
     FY 79 will be undertaken in FY 80 and accelerated
     in FY 81.  It is estimated that the program will be
     delegated to 15 percent of the States in FY 80 and
     to 30 percent in FY 81.

     In those cases where the States have not accepted
     delegation for the non-compliance penalty program by
     FY 81, Section 105 grant funds will be utilized by
     EPA for implementing the program.  These funds will
     provide contractor assistance for implementing the
     program to minimize impact on available EPA resources
     in assessing penalties.

     In FY 80/81 new programs devoted to ensuring that
     major TSP/SO2 sources that have obtained or are
     presently in compliance remain in compliance will be
     initiated both by EPA and the States.  OE will
     complete development of an improved program in FY 80
     in consultation with the States and then secure
     State plans for implementing the improved program
     with the States focusing first on a limited number of
     selected troublesome sources.

     Toxics — During FY 1980/81 emphasis on control of
     hazardous pollutants will  increase  as result  of the
     Air  Carcinogen Policy.   Promulgation of NESHAP
     standards will be  accelerated.   NESEAPS for benzene
     and  arsenic  are currently  olanned for Py 1980/Rl.
Goals/Priorities/Obj ectives

     The goal of the program is to protect public health
     and welfare through a combination of national efforts
     which provide for consistent and timely progress in
     rectifying existing air pollution problems and avoiding
     new ones.

     With respect to priorities, States were required '.o
     submit revised Implementation Plans in January 19/0
     outlining their strategies for attaining ambient air
     quality standards in designated nonattainment areas.
     High priority will be given to correcting deficiencies
     in these SIPS and to providing adequate guidance to
     States in developing and implementing additional pro-
     grams required for the attainment of standards.  High
     priority will also be given to review of ambient air
     quality standards and development of supporting
     analyses for revisions to the standards.

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                   - 60 -
Emphasis will be given to a program obtaining State
acceptance of full responsibility of all New Source
Review activities, providing adequate guidance for
development of PSD SlPs and maintaining an effective
national clearinghouse for NSR decisions.  The
clearinghouse will, be used by both Regions/States to
assure consistent policy in conducting NSR.

The NSPS program will receive increased funding in
FY 80, thereby allowing work to begin on all NSPS
on schedules consistent with the statutory deadline.
When an Air Carcinogen Policy has been established,
development of NESHAP53 consistent with that policy
will become a priority item,

In FY 80 priority wjs •  be given to establishment of
technically sound NAMS/SLAMS and implementation of
quality assurance measures to establish increased
credibility to air dala,

Development of regulations for PSD Set II and
visibility will receive priority in FY 80.

The highest priority in the mobile source program is
the support of I/M implementation by States and the
development of requisite technical information on
evolving aspects of 1/M programs, such as its appli-          •
cability to newer technology control systems.  Also
of importance will be the completion of the standard-
setting activities mandated by the Clean Air Act, and
the implementation of controls necessary to assure
public health protection.

During FY 1980, many standard-setting activities will
result in final rulemaking.  It is expected that
during FY 1981 the standard-setting program will shift
its priority focus to the control of hazardous pollu-
tants, bioactive materials, and emissions under non-
FTP conditions.

Enforcement priorities include:
                                                               *
     o    Enforcement actions in emergency situations
          involving substantial threats to public
          health and safety,

     o    Major Source Enforcement Effort against
          violators of the Clean Air Act.

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                    - 61 -
     o    Enforcement against automibile/truck pollution.

             anti-tampering
             fuel switching
             inspection and maintenance program

     o    Fuel compliance by Federal Facilities.

     o    Review for enforceability in FY 1980/81 with
          respect to any continuing SIP revision work

     o    Section 120 noncompliance penalities

     o    Major source compliance with SIP revisions, and
          enforcement of NSPS and NESHAPS

     o    Improved program of compliance monitoring and
          enforcement to assure continuous compliance

Regional priorities are set forth in the Regional Guidance
section.

The objectives of the Air Program Regional Activities in
1980 and 1981 are to:

     o    Assure attainment of standards in accord with
          the approved SIP schedules

     o    Assure consistent application of the law in all
          States

     o    Increase the State responsibilities in new source
          review

     o    Initiate enforcement actions in all appropriate
          emergency situations

     o    Complete all civil/criminal action associated
          with the Major Source Enforcement Effort

     o    Implement effective inspection and maintenance,
          anti-tampering, and fuel switching program

     o    Initiate civil/criminal actions and impose
          noncompliance penalties against all appropriate
          major sources in violation of SIP standards,
          NSPS, and NESHAPS

     o    Perform annual evaluations/audits of State
          enforcement programs

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                         - 62 -


          o    Improve and have at least quarterly updates of
               CDS

          o    Assure full compliance by Federal Facilities

          o    Followup on all enforcement actions and
               compliance schedules

HEADQUARTERS PLAN

Office of Air Quality Planning and Standards (OAQPS)

     There are no major redirections from the President's
     budget in FY 80.  Major program changes took place in
     FY 79 with the establishment of an accelerated program
     to develop New Source Performance Standards (NSPS)
     relying on contract support.  This accelerated program
     will continue in FY's 80 and 81 to meet the requirements
     of the CAA Amendments of 1977.  In 1980 we will propose
     ambient standards for N02/ particulate matter, and
     sulfur oxides and promulgate NAAQS for carbon monoxide.
     All standard reviews and revisions, where required, are
     to be completed by the end of calendar year 1980.  As a
     follow-up to the review of the TSP and S02 standards,
     OAQPS expects to initiate a program for the development
     of secondary ambient air quality standards for fine
     particulates and sulfates.  Substantial increases in
     the level of analytic support for NSPS, NESHAPS, and
     ambient standard actions have significantly increased
     costs and time requirements.  This will require some
     reprogramming in FY 1980 with continued funding in
     FY 1981.  As part of the analytic effort OAQPS will
     increase its emphasis on identifying benefits to
     complement the standard-setting process.  The esta-
     blishment of an Air Carcinogen Policy early in FY 80
     will provide a basis for OAQPS to increase emphasis
     on development of new NESHAPS.

     OAQPS has assigned a very high priority in FY 80 to
     approval of State programs for PSD.  To support this
     effort a clearinghouse for New Source review decisions
     is being developed in OAQPS and will be available in
     FY 80 for use by Regions/States to ensure consistent
     and timely issuance of permits.  In FY 80 EPA will
     develop a program to consolidate its own air and water
     permit programs in the few remaining States where EPA
     has not yet achieved its objective of securing State
     permit programs.  This program will be initiated in FY 81.

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                       - 63 -
     In FY 1980 OAQPS will expand the PSD program to
     include the development, proposal, and promulgation
     of regulations and supporting guidance to address
     visibility and automotive pollutants.  Studies will
     be conducted on methods of assuring visibility levels
     and models for measuring visibility degradation.

     OAQPS efforts will continue to develop the improved
     63 modelling techniques that will provide a basis
     for 1982 SIP submissions.  Also, OAQPS will carry
     out studies to support the anticipated shift to an
     inhalable particulate standard.

     In FY 80 and 81 OAQPS will increase its emphasis on
     public participation and public awareness.  OAQPS
     will hold public meetings and hearings to allow more
     public participation in the standard-setting process.
     Public awareness will be enhanced by the dissemination
     of additional fact sheets that explain in everyday
     language our intent in regulating air pollution from
     stationary sources.

     In FY 80 we will work with the regions to assure
     that NAMS sites are established in accordance with
     criteria, that instrumentation not meeting specifi-
     cations is replaced, and that quality assurance programs
     are incorporated in the operation of the sites.

Office of Mobile Source Air Pollution Control  (QMSAPC)

     There are no major redirections in FY 80 from the
     President's budget.  Major program changes were
     initiated in FY 1978 and implemented during FY 1979,
     including major program shifts (i.e., increased
     emphasis on I/M) regulatory reform measures  (i.e.,
     revised certification process), and contracting out
     of functions.  During FY 1980 and FY 1981, these
     program changes will continue.

     OMSAPC Program efforts will concentrate,  in FY 31, on
     I/M program support, completion of key regulatory
     measures mandated by the Clean Air Act, and control
     of hazardous pollutants.  "No new program, organization /
     or legislation initiatives are foreseen for FY 1981.
     However, we foresee new regulations in the area of
     hazardous pollutants control and non-FTP condition
     emissions.  We also foresee a potential need to con-
     trol bioactive materials if breakthroughs are made in
     methodologies used to assess the health effects of
     these substances.

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                         - 64 -
     No significant alternatives for carrying out the
     program are foreseen for FY 1981.   Changes currently
     being implemented will be consolidated by FY 1981.
     Additional changes may be identified in the distant
     future, but it is more likely that FY 1981 will
     represent a period of consolidation rather than
     large-scale changes.

Office of Transportation and Land Use Planning (OTLUP)

     The activities that OTLUP plans to carry out during
     FY 1981 fall into the categories listed below.
     Priority will be given to assuring reasonable progress
     towards the 1982 plan submittals for 60 large urban
     nonattainment areas.

          o    Implement policy guidance for the appli-
               cation of sanctions under Sections 176 and
               316

          o    Develop new technical guidance and revise
               existing guidance for developing the
               transportation element of State Implementa-
               tion Plans and for analyzing the air  quality
               and other (e.g., economic, energy, etc.)
               consequences of transportation and land use
               measures

          o    Implement a monitoring program to track
               State progress in: 1) preparing selected
               portions of the 1982 plan submittals and
               2)  completing the reasonably available
               transportation measures contained in the
               1979 plan submittal

          o    Develop guidance for strengthening portions
               of SIPs dealing with growth forecasting and
               management, tracking of reasonable further
               progress, and alternative analyses for
               new sources

          o    Implement demonstration projects to establish
               institutional structures for reconciling
               differences between urban air quality and
               economic development goals

          o    Implement a monitoring program to evaluate
               the effectiveness of the use of Section 175
               funds

          o    Develop policies for coordinating federally
               sponsored planning programs

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                         - 65 -


Stationary Source Enforcement Division (DSSE)

     As in the past, DSSE provides national program management
     to the Stationary Source Enforcement Program, and also,
     serves as a coordinating center for Regional and State
     stationary source enforcement functions.  Further, DSSE
     establishes program direction and strategy, and helps
     assure nationally consistent enforcement of the Regional
     and State programs, provides support and guidance to
     Regions and States, and assesses the effectiveness of
     the nationwide program and recommends corrective measures.
     Also, DSSE coordinates with other agencies on matters
     impacting this program.  The following are DSSE's planned
     tasks and responsibilities for FY 80/81.

Respond in Emergency Situations

     o    Provide legal/technical assistance in Section 303
          emergencies.

Ensure Compliance by Major SIP Sources

     o    Support Major Source Enforcement Effort

             Expedite initiation of litigation by Regional
             offices and review and make recommendations on
             referral to Department of Justice  (DOJ).

             Track and expedite processing of litigation actions
             through DOJ/U.S. Attorneys to ultimate disposition.

             Provide legal/technical assistance in conduct
             of litigation.

             Participate in litigation coordination teams.

             Participate in development of enforcement
             strategies for selected source categories.

     o    Review, Interpretation, and Develop Regulations

             Make applicability determinations for Delayed
             Compliance Orders (DCOs).

             Review new and revised SIPs and DCOs with national
             significant issues.

             Implement Section 120 (Noncompliance Penalty)
             regulations.

             Implement of  Section 119 (Primary Nonferrous
             Smelter Order) regulations.

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                         - 66 -

          -  Provide advice and guidance to Regions and partici-
             pate in implementation of Section 125 (Measures to
             Prevent Economic Disruption or Unemployment) and       I
             Section 126 (Interstate Pollution Abatement).

             Develop policy on flue gas conditioning as a means
             of interim compliance.

     o    Manage Compliance Monitoring Program

             Provide contractor assistance

             Manacre and update compliance data system

Manage NSPS and NESHAPS Enforcement Program

     o    Review and refer NSPS and NESHAP cases prior to
          referral to DOJ.

     o    Develop enforcement inspection manuals.

     o    Review and interpret regulations.

             Make applicability determinations for NSPS and
             NESHAPS.

             Review proposed regulations for enforceability.

Ensure Compliance by Federal Facilities                             *

     o    Assure compliance by all Federal sources with all
          applicable requirements under the Clean Air Act.
   f-

Enforce Applicable Sections of the Power Plant and Industrial
Fuel Use Act of 1978

     o    Coordinate with Department of Energy

     o    Applicability determinations

     o    Revise Part 55, Energy Related Regulations

     o    Provide guidance to Regions on coal conversion program.    ,

     o    Review Section 113(d)(5) coal conversion DCOs.

Develop a Continuous Compliance Strategy
                                                                     T
     o    Work with Regions, OANR, 0PM, States, and localities
          to develop the needed strategy.

     o    Provide guidance to Regions and States.

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                         -  67  -

Mobile Source Enforcement Division (MSED)

     The Mobile Source Enforcement Program is directed primarily
     towards achieving compliance with motor vehicle emission
     standards and fuels regulations.

     In FY 80, the new mobile source enforcement strategy will
     be fully implemented.   The program supports inspection/
     maintenance (I/M.) by retarding further emission deterior-
     ation of the vehicle fleet before I/M programs are
     implemented through the enforcement of the anti-tampering
     and anti-fuel switching prohibitions.  Public resistance
     to I/M is likely to increase proportionately with the
     percentage of the fleet that would ultimately fail an I/M
     due to the cost of repairing emission control systems to
     pass I/M.  If resistance to I/M implementation is to be
     minimized, tampering and fuel switching must be controlled.

     This new initiative will focus on a nationally coordinated
     effort of tampering and fuel switching inspections of
     major new car dealerships,  fleet operators, gasoline
     retailers, and commercial repair facilities and support
     the President's Denver Air Initiative.  In FY 81, the new
     strategy will be continued, and I/M audits of ongoing
     programs will be conducted to assure that States are
     achieving the emission reductions indicated in their SIP
     revisions.

     In FY 81, the plans and emphases of the Mobile Source
     Enforcement Division are to:

     Assure that emission control systems are not removed
     or rendered inoperative.

          o    Continue the new mobile source enforcement
               strategy by conducting anti-tampering and fuel
               switching investigations in support of I/M.

          o    Conduct audits of ongoing I/M programs.

          o    Enforce unleaded gasoline regulations.

          o    Continue monitoring the rates of tampering and
               fuel switching.

     Assure that new vehicles meet emission standards.

          o    Continue the Selective Enforcement Auditing
               program.

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                    -  68  -

     o    Conduct inspections of new motor vehicles and
          engines at assembly plants to verify installa-
          tion of proper emission control components.

     o    Monitor the importation of motor vehicles to
          assure their compliance with Federal import
          regulations.

Assure that vehicles meet emission standards in-use.

     o    Conduct recall investigations to determine
          compliance of in-use vehicles with emission
          standards and recall noncomplying classes.

     o    Implement the warranty regulations.

     o    Implement the maintenance instruction regulations.

     o    Implement the aftermarket parts certification
          program.

     o    Continue to perform testing by METFac.

Assure that harmful gasoline additives are not distributed
in commerce.

     o    Prepare administrative decisions for waivers from
          prohibitions against distribution of fuels and
          fuel additives that may adversely affect vehicle
          emissions.

     o    Enforce prohibitions.

Assure control of hydrocarbon emissions during gasoline
transfer operations.

     o    Conduct inspections of gasoline dispensing
          facilities for installation of Stage I Vapor
          Recovery equipment.

     o    Enforce Stage I Vapor Recovery regulations.

     o    Develop enforcement programs to ensure gasoline
          transfer from gasoline pump to vehicle
          minimizes release of hydrocarbons.

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                         - 69 -
     Assure compliance with transportation control  measures.

          o    Develop and implement policy in application of
               CAA sanctions for noncompliance of SIP revisions
               statutory requirements.

     Administer California waivers.

          o    Review waiver requests.

     Administer the statutory emission  waivers.

          o    Review applications,  studies conducted by NAS,
               and other information to assess appropriateness
               of granting waivers.   Prepare administrative
               decisions.

Office of Research and Development (ORD)

     In FY 81 and FY 81 the research and development
     program will continue to carry out its extensive
     activities in support of the full  range of short- and
     longer-term needs of the Office of Air, Noise  and
     Radiation Programs.  The program will include, however,
     some major shifts in emphases in response to the
     changing nature of the air pollution problems.  The
     FY 80 program has already passed through ZBB process;
     its general contours have been established.  Therefore,
     we do not anticipate any major shifts to occur as a
     result of detailed plan implementation in coordination
     with the relevant research planning committees.  Shifts
     that do occur are expected to be at a level of resolu-
     tion that will not affect the FY 80 program.

     In FY 81, we do anticipate some major shifts in pro-
     gram emphases that will lead to redirection of resources.
     These emphases reflect certain assumptions about
     national and program office concerns with respect to
     the most pressing research needs.   In some cases,
     the emphases flow directly from a  research plan,
     e.g., work on inhalable particulates, in others,
     they reflect ORD's attempt to get  the jump on what
     we anticipate to be program office needs within the
     next five years.

     This guidance is not exhaustive.  It merely identifies
     the peaks on what is the much more elaborate and
     extensive topography of the complete research program.

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                         - 70 -

     The exact composition of the entire research program
     will be hammered out in detail  in the deliberations
     of the appropriate research committees.   The guidance
     provides only the benchmarks for that detailed planning
     activity.  Effective with the FY 80/81 planning cycle,
     the major part of the Office of Research and Develop-
     ment (ORD)  planning and management system is organized
     around 12 research committees.   These research
     committees provide the means for ORD to work jointly
     with representatives of the program offices in preparing
     research plans.

     All of the research in support  of air program regulations
     in FY 80/81 is covered by the planning activities of
     four committees:

          1.   Oxidants (includes ozone, NOX and hydro-
               carbon research)

          2.   Gaseous and Inhalable Particles (includes
               SOX, nitrates, suspended particles, and
               lead)

          3.   Mobile Source Air Pollution

          4.   Hazardous Air Pollutants (includes organic
               emissions as toxics,  metals, such as Hg,
               As, Cd, and asbestos)

     For purposes of clarity and consistency, this research
     guidance has been organized along the lines of the
     research committee structure.  Such a division can
     never be totally clean.  For example, field studies on
     NOX and nitrates provide outputs that are valuable in
     addressing both the oxidant and the inhalable particles
     problem.  Similarly, research on the characterization
     and control of fugitive emissions can address questions
     concerning both the suspended particle and the
     hazardous air pollutant problem.  The guidance does
     not attempt to deal with this ambiguity.  Rather each
     major effort is assigned to a particular research
     committee domain based upon that aspect of the study
     which appears most critical from a programmatic
     perspective.

Oxidants  (Ozone, N0y, and Hydrocarbons)
                            	

     In FY 81, the health effects program will continue
     to focus on ozone.  Studies will be undertaken to
     determine conclusively the effects of low level

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                    - 71 -
exposures on the cardiorespiratory efficiency of
health exercising individuals.  Also, an attempt
will be made to isolate the effects of low level
exposures to ozone on individuals suffering from
chronic lung disease, viz., asthma and bronchitis.
The effects of low level exposures on defense
mechanisms to bacterial and viral infection will also
be studied.

The program will also focus upon the potential health
effects from exposures to secondary photochemical
products such as formaldehydes, formic acid and
acrolein.  The ecological effects program will carry
out studies to determine the acute and chronic effects
of exposures to ozone on important and signal plant
species.  Assessment of impacts will include the
effects on productivity, quality, and basic processes
for forest and crop species and on integrated eco-
systems.  Some work will continue to assess the bio-
genie emissions from vegetation and their contribution
to ambient ozone and oxidant levels.

In the transport area, the FY 81 program includes a
commitment to continue ORD's program of targeted field
studies.  In addition the program includes continuation
for a major effort begun in FY 80 to assess the impact
of regional scale oxidants in the Northeast.  Laboratory
studies will complement the field studies in order to
provide a more comprehensive understanding of the
atmospheric reactions that occur among ozone precursors
(volatile organic compounds and oxides of nitrogen).

The characterization program in FY 81 will continue
field and laboratory measurements to determine the
formation and distribution of secondary photochemical
products associated with mobile and stationary sources.

In the control technology area, the effort wil continue
to demonstrate NO  control technology to include
industrial processes employing fuel combustion,
advanced control technology for stationary internal
combustion engines and gas turbines, and new techno-
logies for power plants.

Finally, the modelling area work will continue to
provide improvements with particular emphasis on
developing validated, multiday air quality simulation
techniques for ozone and oxidants.

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                         - 72  -
Gaseous and Inhalable Particles (includes S0y,  Nitrates
suspended particles and lead

     Inhalable particulates will continue to demand major
     attention in the FY 81 health effects research program.
     Animal toxicology studies will examine potential
     chronic effects of exposure to coarse and  fine particles.
     Clinical studies will examine the acute effects of
     exposure to combinations of particulate pollutants.
     In addition, studies will continue on the  acute effects
     of exposures to N02, on healthy and sensitive popula-
     tions, and the short- and long-term effects of exposures
     to nitric acid vapor and nitrates, including the
     possibility of in vivo nitrosamine formation.  Finally,
     the health effects program will contain a  significant
     effort in the area of particle epidemiology studies.

     As part of the mandatory 5-year review and updating of
     criteria documents, in the area of secondary air
     quality standards, research will continue  to improve
     our ability to assess the impact of gaseous and particle
     pollutants in the terrestrial environment.  Long-term,
     low-level chronic exposures of gaseous pollutants
     acting singly and in combination need to be further
     studied.

     In anticipation of a possible change in the TSP
     standard that may include separate consideration of
     inhalable and fine particulates, the FY 81 program
     will include considerable effort in the areas of
     characterization and methods development,  modelling,
     and control technology for inhalable particles.  The
     program includes an extensive emissions characteri-
     zation/emission factor program to provide  a national
     assessment of sources, concentrations, distributions,
     and components of particulate matter.  Control tech-
     nologies will be evaluated with an emphasis upon
     their removal efficiencies for inhalable size fractions
     and selected chemical components.

     Paralleling the characterization effort will be a
     continuing program to develop particulate  emission
     measurement equipment and materials.  This research
     will address problems of continuous measurement, size
     distribution, and Identification of individual com-
     pounds in particle emissions.  Studies will also try
     to establish signatures for emissions from different
     sources in order to attribute ambient air  particulate
     concentrations to specific sources.

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                    - 73  -

Transportation studies will include a continuing
major effort to provide validated multiday air quality
simulation models for sulfates, nitrates and other
inhalable particles.  The modelling research will
attempt to provide a means for assessing the long-
range impact of particle emissions on primary
standards and visibility under the assumption that
a secondary standard for visibility may be necessary.
During FY 81, data analysis and modelling activities
in State will be emphasized using the FY 80 experi-
mental results from the PEPE field intensive study.
These results will cabstantially support the develop-
ment of a visibility standard and of air quality
transport models.

Field studies of visibility will continue to better
identify the particle species and their source that
contribute most significantly to visibility reduction.
Methods development will continue to improve the
existing instruments and techniques for quantifying
visibility and related parameters.  The FY 81 modelling
program will also include a significant continuing
effort to evaluate, validate and apply an acceptable
complex terrain emissions assessment system.

The FY 81 program contains a significant effort to
deal with the problem of acid rain.  The emphasis of
the program will be on the solution of those aspects
of the problem are most critical and most amenable
to solution.  Most of the acid rain research will be
funded under the Anticipatory Research Program
(planned by the interdisciplinary Media), but some
ancillary  applied research will be funded by base
research under the Air Media.  Quality assurance in
FY 80 will continue to conduct and coordinate on-site
inspections and performance audits for the National Air
Monitoring Stations with some increased support to
EPA Regional reviews of State and Local Air Monitoring
Stations.

Exposures assessment methods will also continue to
demand a significant share of the monitoring and
measurement techniques resources for inhalable parti-
culates as well as all other air pollutants.  Particular
emphasis will be given to tying together epidemiological
methods, stationary site monitoring systems, and per-
sonal monitors into compatible systems in terms of
time, space and concentrations.  As part of this effort,
the FY 80 program will include the final stage of
deployment of the inhalable particle sampler network.

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                        - 74 -


     Control technology research will continue to evaluate
     the relative efficiencies and costs of alternative
     means to control different size fractions of primary
     emissions.  Control of fugitive emissions will also
     be investigated for priority industrial processes
     as well as for problems of resuspended particles from
     streets and other nonpoint sources.  Associated with
     the technology studies will be the development of
     methods for and the actual acquisition of emissions data
     from non-traditional particulate matter sources needed
     for evaluating the long-term and short-term impacts of
     fugitive emissions of particles.

Mobile Source Air Pollution

     The FY 81 program will continue to focus heavily upon
     the effort to define better the risks from diesel
     emissions by means of bench and field studies.  In
     the characterization area, there will continue to be
     a substantial demand for the collection of exhaust
     products with different operating conditions, different
     engine designs, and fuel types.  In addition, there is
     likely to be some characterization and measurement of
     exhaust products from candidate control systems.

Hazardous Air Pollutants (includes organic emissions as
toxics, metals such as Hg, As, Cd, and asbestos)

     The FY 81 health program will also include a signi-
     cantly expanded emphasis on air pollutant induced
     carcinogenesis.  The primary emphasis will be on
     testing methods and epidemiological investigations.
     The test method development will address the design
     of an optimal tiered battery of tests for assessing
     potential for carcinogenesis.  The epidemiological
     program will try to relate the incidence of cancer
     observed on cancer registeries to exposure to air
     pollutants.  In the area of prospective epidemiology
     research will focus on the development of methods to
     track health status of populations subject to extra-
     ordinary exposure incidents.

     In addition, we expect the research on air pollutant
     health effects begun under the Public Health Initiative
     to continue in F!£ 81.  Some of the major problems that
     will continue to be addressed include:  the improvement
     of methods to relate animal toxicity to human clinical

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                    -  75  -
results; the development of faster, sensitive methods
to detect biochemical, genetic and immune changes;  and
and epidemiological studies of selected pollutant
problems, e.g., indoor pollution, improvement of our
quantification ability with respect to exposure
characterization, and temporal exposure patterns.

The FY 81 research program will also emphasize the
characterization of hazardous organic emissions from
stationary sources—both constrained emissions from vents
and stacks and fugitive emissions.  In both instances,
the characterization may require the development of
either sampling and collection methods or improved
analytical techniques, e.g., for total organic emissions
or for selected toxic substances.

Characterization activities in FY 81 will be expanded
to begin a systemmatic effort to determine the inventory
and significance of regulated air pollutants from
stationary sources.  In addition, the program will
focus upon the characterization of indoor air and attempt
to relate indoor air quality to 24-hour and annual
exposures to various air pollutants.

Studies will be carried out to assess population
exposures to toxic organic vapors and particulates,
especially potential carcinogens and mutagens developing
and employing where appropriate personal monitors.

The FY 81 program will include an attempt to identify
and quantify hazardous materials associated with fugitive
dust from mining activities, transportation of materials
and industrial operations.  Research will also be
carried out to characterize VOC emissions and develop
appropriate control technology.  The development of
solvent collection and disposal/recovery systems will
also be pursued as well as the development of alter-
native solvents or solvent-free processes.

The control technology program will also include an
expansion of the demonstration control options for the
second round NSPS stationary sources and the effort to
generate AP 42 emission factors and cost curves for
selected control technologies and pollutants.

A final area of emphasis will be development and
deployment of monitoring systems to allow broad scan
screening of emissions and ambient air for a variety

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                    -  76  -

of toxic organics.  In addition, the program allows
for some contingency to cover short-term delivery of
targeted measurement devices to deal with particular
problems, e.g., those efforts in the past to measure
vinyl chloride around PVC plants.

Technical Support

The FY 81 program anticipates a significant amount of
resources will be devoted to technical support to the
program offices.  In the past, this support has been
provided, and we assume will continue to be provided,
by the ORD base program.   There is no rational way to
assign specific levels of effort to each of the four
major research areas a priori.  The level and distri-
bution of this technical support activity will be set
as a result of the deliberations of the respective
research committees.

Quality Assurance

Following on the major effort of FY 80, Quality Assurance
will continue to be a major concern in the FY 81 research
program.  In addition to maintaining oversight over the
Agency's quality assurance system, the research program
will continue to investigate ways to improve the Agency's
Quality Assurance activities.

Exploratory Research

The new structure for planning research in the Agency
provides assurance that studies will be carried out
in the support of the regulatory programs.  However,
the long-term viability of the Agency's assessment
and control of environmental problems as well as the
quality of ORD's programs depend upon a stable base
level of exploratory research.  The exact nature and
amount of such research that is necessary will vary
from program to program within any medium and even
accross media.  The FY 81 program for air research
assumes that 15% of the total budget will be devoted
to exploratory research,  i.e., research which is not
in direct support of some existing or anticipated
regulatory need.  This 15% figure appears low but
given the pressing need for research in support of
regulation, such minimum level may be necessary.  In
any event, this guidance establishes this minimum
level of 15% as a base on which the research committees
can base their deliberations.

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                   _ 7 7 —

Energy

The Energy Research Program is ranked by the Energy
media team.  Nevertheless, a great deal of the energy
research addresses air pollution problems.  Every
attempt will be made to factor the Energy activities
into the deliberations of the Air media group.  To
aid in those deliberations, the following major
emphasis of the FY 81 Energy program are provide for
reference:

          Field experiments on the formation and
          transport of nitrates and secondary
          organic particles will continue in FY 81.
          An effort will be initiated in FY 81 to
          expand the geographical areas of concern
          for baseline measurements of nitrates and
          organic particles beyond the Ohio Valley
          Region.

          Continuation of the demonstration of low
          NO  burner technology for new and existing
          industrial and utilty oil and coal-fired
          boilers.

          Continuation of the characterization of
          particulates (including the condensible
          fraction) for energy facility emissions.

          Development and demonstration of dry low
          cost SOX control technology for new and
          exixting industrial and utility boilers.

     -    Continuation of the air quality monitoring
          network in the East in order to establish a
          baseline from which to assess the impact of
          energy activities.

          Finally, consultations and discussions
          during FY 80 between EPA and National
          Laboratory Scientists in DOE should lead
          to integration of the MAP3S program into
          the overall EPA-ORD research program.

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                         -  78  -


REGIONAL GUIDANCE

Air Abatement and Control—Air Quality Management

     Major Priorities for FY 80

     o    The first level of priorities reflects activities
          which all Regional Offices are expected to perform
          in  FY 80.  Resources for FY 80 will be allocated
          to Regional Offices for implementing each of these
          priorities as well as to maintain an air grants
          management function for Section 105 and 175 grants
          and a core Regional Office base program for air
          management.

     o    The second level of priorities reflects activities
          which are required by the Clean Air Act or represent
          activities for which Regional Office involvement is
          considered important to the development of effective
          SIPs.  The Regional Offices, however, will have
          flexibility to choose which of these priorities to
          undertake.  Resources allocated to the Regional
          Office for FY 80 will not be adequate to fully carry
          out every priority in this level.

     o    The third level of priorities reflects activities
          which may be required by law but in general have
          limited public health and socio-economic impacts.
          In specific local circumstances, they may be signi-
          ficantly important.  The Regional Offices will have
          flexibility to choose which of the priorities to
          undertake.  Resources allocated to the Regional
          Office for FY 80 for allocated to the Regional
          Office for FY 80 for these priorities will be very
          limited.

          Priority Level i

               Review, Track, and Approve Fanctionable SIPs

               Guide/ Review, and Approve State Plans for PSD

               Coiv-ti.'.. •• n ier II Reviews for PSD where States
               do rot v-uvi: an Approved PSD Plan

               Guide &\ <_':e,s to Develop Transportation Planning
               Fr-jcr-v a .*.r,i Transportation Control Measures in
               LdtJ  i'rr-.o" Nonat tuir.KVir.t Av-:as

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               -  79  -
     Audit Selected State Performed PSD Reviews
     where State PSD Plan has been Approved

     Act on Major Energy Related Actions (e.g.,
     Fuel Conversions) which have Potential Impact
     on Air Quality

Priority Level II

     Guide States in Developing Mandatory I/M
     Proarams

     Review, Track and Approve Non-sanctionable SIPs
     including Lead (Pb) and other Reauired Mis-
     cellaneous SIP Revisions

     Guide States in Developing Additional VOC
     Regulations

     Guide States in Analvzing Measures and Conduct
     of Pilot Demonstrations for Control of Urban
     Fugitive Dust in Manor Urban Nonattainment Areas

     Guide States in Developing Lead (Pb) SIP for
     Primary Lead Smelters

     Review/Approve other State Initiated SIP
     Revisions

Priority Level III

     Promulgate Required SIP Provisions where
     States Fail to Act or Correct Deficient SIPs

     Guide States in Developing Transportation
     Planning Process in Smaller Urban Nonattainment
     Areas

     Guide States in Developing other Required
     SIPs for Lead (Pb)

     Guide States in Developing Required SIP Revisions
     Rural Nonattainment Areas

     Guide States in Developing Required Miscellaneous
     Revisions to the SIP

     Guide, Review,  Approve 111(d) Plans

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                     - 80 -
Principal Regional Activities
          Review, Track and Approve Sanctionable SIPs
          SIP review,  tracking,  and  approval  is  a
          non-discretionary function for the Regions
          and the public health and economic impacts
          make it especially critical for the
          sanctionable SIPs.  The intent here is to
          prevent Regional approval/disapproval
          action from delaying the SIP process and to
          place increased emphasis on the Regional
          management function in the SIP process.
          This is a reflection of the Agency's
          priority on improved management of
          environmental programs.  In FY 1980 the
          initial nonattainment SIPs will have already
          been submitted and approval/disapproval action
          taken.  Therefore, the most important tasks
          for FY 80 will be tracking State milestones
          for:  I/M development; transportation
          planning; VOC regulation development; urban
          fugitive dust analysis; satisfying
          reasonable further progress requirements as
          well as reviewing and approving revisions
          to the SIP resulting from the schedules.
          Also included is the review and approval of
          those SIPs which were given "conditional"
          approvals and require follow-up actions by
          the State.  "Conditional•' approval here
          refers to SIP regulations which were
          approved subject to the condition that they
          be revised in some minor aspect (e.g., cut
          size, etc.) and not the SIP scheduling
          provded for in Mr. Costle's February 24,
          1978 memorandum.  The Regions should
          complete the review and approval of most of
          the "conditional" approvals before the end
          of FY 1980.  In addition to following up on
          the 1979 non-attainment SIPs, there is the
          potential need for review and
          approval/disapproval of SIP actions in
          newly designated nonattainment areas.

          Prevent. Significant Deterioration  Efforts
          to secure State assumption of the PSD
          program and completion of individual PSD
          reviews by the Regional Office where the
          State has not assumed the program are
          essential activities in FY 80.  The
          Congress clearly expected States to assume
          the PSD program and the workload associated
          with continued EPA responsibility for the

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           - 81 -
program exceeds resources available for it.
It is EPA policy that Regional Office
efforts in FY 81 will be limited
principally to one of overview.  Therefore,
the Regional Offices should provide
extensive guidance to States in preparing
PSD plans and, review/approve State
submitted plans.  Upon approval of a State
plan, the Regional Offices should audit and
evaluate the technical adequacy of the
State program through selective
(approximately 10%) review of individual
State Tier II permits.  In FY 80, EPA
Headquarters will develop more
comprehensive guidelines regarding Regional
Office roles in overviewing and auditing
State and local new source review programs
(including PSD).  It is anticipated that
EPA's major interest after FY 80 would only
be with auditing those new sources which
are precedent setting or have major
inter-state impacts.

In those cases where the State cannot or
will not develop an approvable plan, the
Regional Office will continue to carry out
the BACT and modeling analysis for the Tier
II reviews.  However, the conduct of Tier I
reviews should not be handled by the
Regional Offices.  The purpose of the
two-tier system in PSD is to prevent
significant resources from being employed
for review of relatively minor sources.  If
a new source applicant has a valid State
permit, which brings allowable emissions under
50 tons per year, Regional Offices should
not expend resources re-reviewing the
permit.  Where Regional Office conduct of
Tier II reviews is required, Section 105
grant funds should be employed to obtain
contractual support to aid in the conduct
of the necessary reviews.  In the conduct
of PSL/ reviews, priority consideration
should ne given to Air Quality Control
Regions (AQCR) where energy facilities are
requesting approval to construct.  Within
the AQCR, reviews against the allowable PSD
increment, should continue to be conducted
on a fjrat-come-first-served basis, by the
Regional office.  In interstate areas the
Regional Off:ce would need to consider the
impact of the review on a state's growth

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policy if one or more of the States had an
approved SIP containing a growth policy,

Guide Transportation Planning in Large Urban Areas
The special significance of transportation
control measures and their role in the
Agency's overall urban strategy require
that major Regional Office guidance be
given to the development and implementation
of the transportation planning process in
nonattainment areas for ozone/carbon
monoxide having a population in excess of
1,000,000.  Regional involvement with the
Section 175 grantee agencies must continue
to ensure that these one-time grant funds
result in an EPA approvable SIP and an
effective transportation planning process.

Maintain Grants Management/Regional Office Base
As in FY 79 the Regional Office will
continue to perform essential activities
for grants management and maintain a core
Regional Office base program for managing
the Air and Hazardous Materials Division,
preparing responses to the public,
conducting public information arid
participation activities, and reviewing
draft policies and regulations.  Proposals
are currently being considered in Congress
to amend solid waste legislation to require
that abandoned or closed disposal sites be
surveyed for presence of improperly
disposed hazardous wastes.  With the
expectation that the surveys will uncover a
number of such cases and that the
incineration of these wastes will be a
prime measure for final disposal of the
materials uncovered, the Regional Office
air staff in FY 80 can anticipate
increasing workloads in determining if such
wastes can be safely incinerated.

During FY 80, EPA Headquarters will
evaluate a!ternatives for enhancing
Regional Office involvement in the
preparation and review of the more major
regulation development actions which will
have significant impact on EPA Regional
Office responsibilities and workloads as
well as those of State and local control
agencies.  Within the air media, likely
candidates for FY 80 are the PSD

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           - 83 -
regulations for automobile related
pollutants, regulations for visibility
protection and changes in the National
Ambient Air Quality Standards for Total
Suspended Particulates.

Guide for I/M Development  Providing
guidance to States in the development of
mandatory I/M programs in urban
nonattaihment areas is an important
activity in FY 80.  Guidance to States
should focus on implementation of the
introductory phases of the program where
full legislative authority exists.  Because
of the large start-up expenditures
associated with this program, an effort
should be made to fund certain introductory
steps of I/M projects using Section 105
grants.  In addition, support for training,
public information, and acquisition of data
on program effectiveness may be necessary.

Review, Track, and Approve
Nonsanctionable SIPs. Although review and
approval actions for the SIPs (e.g., other
revisions required by the Act, as well as
State initiated revisions) are
non-discretionary, their economic and
public health impacts are generally minor.
Regional Offices may choose to process them
administratively after a minimal technical
review or delay action on them until other
priorities are completed.

Other SIP Guidance^in Urban
Nonattainmelit Areas  In general, the
greatest attention should be given by the
Regional Offices to guiding State
development of ozone and TSP SIPs in
nonattainrnent areas having large urbanized
populations  and significant air quality
problems.  The emphasis on the larger urban
areas and the most significant air quality
problems should provide the most public
health benefit.  Also, it is consistent
with the Agency's urban initiatives for
providing technical assistance,
demonstration programs, and planning grants
to cities in urban nonattainment areas.
Areas of possible guidance include
development of additional VOC regulations
required to be submitted by the States in

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            -  84  -
 January  1980  and  1981; development and
 implementation of the transportation
 planning process  in urban areas having
 population between 200,000 and 1,000,000;
 the development of additional TSP controls
 for industrial stack and fugitive process
 emissions if  not  included or approved in
 the 1979 SIP; the analysis of possible
 measures for  control of urban fugitive
 dust;  and collection of necessary baseline
 data  for conduct  of ozone modelling in
 severe urban  nonattainment areas (areas
 with  design value in excess of 0.20 ppm and
 population of 1,500,000 or more).  Guidance
 on fugitive dust  during FY 1980 should
 focus  on the  need to build an adequate data
 base prior to implementing any control
 measures.  Given  the possiblity that an
 inhalable particulate standard may result
 from current  EPA  review of TSP standard,
 field  studies being conducted by the State
 to improve the definition of the nature and
 extent of the fugitive dust problem should
 include  the acquisition of limited data on
 particle size distribution.

Guide  Development of Lead SIP

Guidance to States for the development of most of
the required  SIPs for Lead (Pb)  should generally
be limited.   However, guidance for the development
of the SIP for primary Lead smelters should receive
the most emphasis in FY 80 where such SIPs are
required.  It will be particularly difficulty for
States to develop effective control measures for
 smelters as part  of the SIP which are reasonable
 in cost.  EPA has committed itself to assist the
 States and the primary lead industry in developing
approvable strategies and controls and guidance
 from the Regional Offices in FY 80 will be
necessary.

Promulgation of Inadequate SIPs

Promulgation of SIP strategies is generally low
priority for FY 80.   However,  exceptions should
be considered for those promulgations which,  for
relatively few resources,  would  result in removing

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                            - 85 -
                  sanctions or would provide a significant
                  benefit to public health.  In most cases, the
                  resources involved are substantial and would
                  duplicate money already allocated to States
                  in FY 79 under Section 105.  To the extent
                  major promulgations appear to be necessary
                  later in FY 1980, they should be handled
                  through reprogramming after their policy and
                  resource implications have been thoroughly
                  analyzed by the Regional Office and the Office
                  of Air, Noise, and Radiation.

Abatement and Control-Ambient Monitoring

Major Priorities forFY-80  — Resources  to  be allocated  for  the
accomplishment of the priorities listed below in the three
priority levels for Ambient Monitoring are similar to the
approach for Air Quality Management.  Priority I tasks will
be mandatory and Regional offices will be allocated resources
to accomplish each priority.  Regional offices will have
flexibility in selecting from Priority II and III as the
resource allocation will not be adequate to carry out every
priority listed.

     o  Priority Level I

             Prepare SIP Revision for State Network and
             conduct Networks Reviev/s

          -  Evaluate NAMS Sites

          -  Submit Air Quality Data to NADB and Validate
             NAMS Data

             Participate in 105 Grant Negotiations

             Conduct State, Agency System Audits and Prepare
             Quality Assurance Program Descriptions

             Conduct Data Acquisition for Special O_ Disper-
             sion Modelling Efforts to Support 1982 SIP
             Revisions

             Conduct Data Quality Assessments

             Respond to Emergency Situations

          -  Participate in Regional Office Lab Performance
             Audits

          -  Prepare Regional Environmental Profiles

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                       -  86  -



o  Priority Level II

        Process Emissions Data

        Implement Daily  Index Reporting in Areas with
        Population Greater than 500,000

        Conduct Ambient  Network Review and Analyze
        Ambient Data for Critical New Sources
        Conduct NAMS Performance Audits (Higher Priority
        in FY 81)

        Conduct SLAMS Site Evaluations in Areas with
        Population Greater than 200,000

     -  Validate of SLAMS Air Quality Data

        Coordinate Special Purpose Monitoring (Health or
        SIP Related)

o  Priority Level III

        Review Lead SIP Network

        Develop Population Exposure Analyses

        Audit Small Local Agency Systems

        Conduct SLAMS Site Evaluations in Areas with
        Population Less than 200,000

        Implement Daily  Index Reporting in Areas Less
        than 500,000

        Conduct SLAMS Performance Audits

        Coordinate Special Purpose Monitoring (Not
        Health or SIP Related)

The highest priorities for FY 80 are the activities  asso-
ciated with the implementation of the new air monitoring
regulations developed by the Standing Air Monitoring
Work Group (SAMWG).  The most critical of these activi-
ties will be the ones involving the National Air Moni-
toring Stations (NAMS).  Due to the size of the State
monitoring proarams, it  is recognized that intensive
Regional Office oversight of State activities must be
limited to a subset of the total network in any one
year.  Accordingly, in FY 80, Regional Offices should
emphasize the NAMS network as these sites represent
areas of highest concentrations and population exposure.

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                       -  87  -
The first step in implementing the provisions of the
revised monitoring requirements involves the State sub-
mission by January 1, 1980 and Regional review of the
SIP revision detailing the state air monitoring program.
At the time the  SIP  revision  is submitted  to the Regional
Office the States should  have reviewed  and redesigned
their monitoring network.

The second step in implementing the regulations involves
the review of the entire network of State and Local Air
Monitoring Stations  (SLAMS network) by the Regional
Offices to identify potential NAMS sites and to document
where new or relocated sites are needed if not already
completed in FY 79.  The review of the entire SLAMS
network is required to be performed on an annual basis,
to insure that the State networks remain responsive to
EPA needs.

The third step is the evaluation and documentation by
the Regional Office of identified NAMS sites including
on-site visits to determine conformance to 40 CFR 58,
Appendices C (Monitoring Methdology), D  (Design
Criteria), and E  (Probe Siting) followed by detailed
documentation of site descriptions.  SLAMS site evalua-
tions could be conducted if the SLAMS monitor is
co-located with NAMS.  Other SLAMS (not co-located with
NAMS) should be evaluated by the Regional Offices only
after all NAMS have been completed.

Regional Offices in FY 80 should conduct a quality assur-
ance system audit for all State monitoring programs.  The
Regions should, to the extent possible, negotiate with
the States to audit all Local monitoring programs.  In
cases where a Local monitoring program is  larger than the
State program or includes all or the majority of NAMS in
the State, the Local system audit should receive a higher
priority than the State audit.  During this audit, the
Regions should verify that all requirements of 40 CFR 58,
Appendix A (Quality Assurance) are being met.  All EPA
Regional laboratories must participate in  the Environmental
Monitoring Support Laboratory  (EMSL) performance audi-
in program for Nitrogen dioxide (N02), Sulfur dioxide
(802), hi-volume flow, Carbon monoxide  (CO) and Lead, if
they perform monitoring for these pollutants.

The Quality Assurance program description  required by
40 CFP 58, Appendix A, must be developed by States and
approved by the EPA Regional Office no later than the
end of FY 80.  This program description should address
the technical details of the State's quality assurance
policies and procedures.

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                       -  88  -
Air quality data from all SLAMS must be reported by
States to the National Air Data Bank (NADB) in FY 1980
with priority given to the validation of NAMS data.
Beginning in January, 1981, only data from NAMS will be
required to be reported by the State to NADB, but al]
air quality data will continue to be accepted.  The
assessment of the quality of environmental data is con-
tinually receiving increased emphasis within the EPA;
and as a result, the Regional Offices should become
extensively involved with State programs to assess the
quality of ambient data during FY 80.  Beginning in FY
81, the new monitoring regulations will require that pre-
cision and accuracy statements accompany all NAMS data
submitted to the data bank by the States.

In FY 80, Regional Offices should provide coordination
and guidance to States which will be collecting short-
term ambient and emissions data in areas where ozone
dispersion modelling will be conducted in preparation
for the 1982 SIP (i.e., urban areas with design value in
excess of 0.20 ppm and population of 1,500,000 or more).
This includes the Northwast Corridor Modelling Study and
other severe urban nonattainment areas where ozone dis-
persion models will be employed in developing the 1982
SIP revisions.

In FY 80, the review and negotiation of the Section  105
grants must be given greater attention by the Regional
Offices than in previous years.  The Regional Offices
Air Monitoring staff should be actively involved in
negotiation of specific State accomplishments, includ-
ing the upgrading of networks, improving data quality,
and State participation in special monitoring studies.

For FY 80 new source review related monitoring activi-
ties are included in Priority Level II for the Regional
Office because it is expected that Regional Offices  new
source review activities will decrease rapidly as States
develop PSD plans and implement the PSD program.  How-
ever, some Regional involvement in the more complex  or
critical PSD reviews is foreseen for FY 80 and possibly
beyond.

The activities placed in Priority Level II are of lower
priority because:  (a)  they generally involve the first year
of a multi-year program, (b)  involve activities which are
guidance-related rather than review or management-related,
or (c)  do not relate to data needed for SIPs.  Activities
in Priority Level  III are considered to be of lowest priority
because of either  (a), (b)  or (c)  above,  or because  (d),
they involve areas of low population,  or (e), they pertain
to areas that are  not health-related.

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                         -  89  -

Enforcement

     Of highest priority, the regional enforcement personnel
     must initiate enforcement actions when needed to contain
     and remove the danger in emergency situations involving
     substantial threats to public health and safety.

     Next to emergencies, the most important activity in
     the Regions is the completion of the Major Source Enforce-
     ment Effort.  In FY 1980, Regions will bring the
     enforcement action to decision by settlement, admini-
     strative process, or court trial, including appropriate
     penalties, and take or defend appeals.  By the end of
     FY 1980, the major source effort should be virtually
     completed with only a few actions and appeals still
     pending in trial or appellate courts.  In FY 1981, those
     enforcement actions still pending in courts should be
     completed as rapidly as possible.

     In FY 1980, the emphasis of the mobile source enforcement
     program changes.  The program intends to complement
     and facilitate the I/M program by retarding further
     deterioration of the vehicle fleet before I/M programs
     are implemented.  Public resistance to I/M is likely
     to increase proportionately with the percentage of the
     fleet that would ultimately fail an I/M inspection due
     to the cost-related aspects of repairing emission
     control components to pass I/M.  If resistance to I/M
     implementation is to be avoided, tampering and fuel
     switching must be controlled.  The new FY 1980 initiative
     will focus a Headquarters (MSED) effort in support of
     I/M by conducting tampering and fuel switching inspections
     of major chains of automobile repair facilities, fleet
     operators, new car dealerships, and gasoline retailers,
     and support of the President's Denver Air Initiative.
     In FY 1981, the new strategy will be continued and I/M
     audits of ongoing programs by Headquarters v/ill be
     conducted to assure that States are achieving the emission
     reductions indicated in their SIP revisions.  It is
     important that the Regions recognize the priority of
     mobile source enforcement program in FY 1980, especially
     in the context of EPA 105 air grant negotiations.  As
     States are funded, the Regions will forward State reporting
     requirements to Headquarters.

     By the end of FY 1979, regulations will be promulgated
     for Section 120 noncompliance penalties; this program
     is projected to be very resource intensive.  Notices
     of noncompliance will be issued to most appropriate
     major sources in FY 1979 but the large burden of the
     resultant adjudicatory hearings and litigation will be
     felt in FY 1980.  Also, the Regions must advise and
     assist the States to facilitate delegation of Section
     120 to as many States as possible.

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                       - 90 -


By the end of 1980, it is expected that all, or almost
all, major federal facilities will be in compliance and
most minor source federal facilities as well.  Regions
should see to it that all federal facilities do indeed
come into compliance as soon as possible, and no later
than the end of FY 1980.

To ensure that the gains obtained in enforcement efforts
in FY 1979 are preserved, substantial effort will be
required in FY 1980 to monitor compliance with consent
decrees entered into in FY 1979.  Similarly, emphasis
will be placed on an improved program of monitoring and
enforcement to assure continuous compliance of major
sources which have obtained initial compliance.  There
will be an increased emphasis on continuous monitoring
as one aspect of this effort and other approaches will
be explored as well.

Each Regional Office should assure that the States in
its Region have adequate compliance monitoring programs.
This obviously requires a close working relationship between
the Regions and States.  While Regional overview
inspections provide one measure of the State's performance,
a complete picture of the adequacy of State compliance
monitoring, and the State enforcement in general, requires;
an annual on-site State evaluation/audit by EPA.  The
compliance monitoring part of the evaluation will allow
EPA to validate the State compliance statistics and,
where necessary, provide recommendations and support for
corrective action.

The maintaining and updating of CDS is a major component
of the proper management of the stationary source
enforcement program.  Each Region must update CDS in a
timely manner (at least quarterly) and ensure that
the data is complete and accurate as defined in
Headquarters guidance.

Emphasis in FY 1980/1981 is also placed on providing
support for continuing SIP revision work.  Also, these
revisions will increase significantly the number of major
VOC sources that must meet SIP standards, and thus,
ensuring expeditious compliance by these sources is
imperative.  Efforts in FY 1980 should also be devoted to
ensuring that new sources are constructed in accordance
with applicable NSPS, PSD and emissions offset provisions.
Regions should also assure compliance with standards for
hazardous pollutants under NESHAPS, and enforce all appli-
cable provisions of the Power Plant and Industrial Fuel
Use Act of 1978.

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                            - 91  -,

     During FY 1980, the Regional Offices should complete
     an evaluation/audit of all of their States' air
     enforcement programs.  The Regions should review the
     SIP enforcement, enforcement aspects of NSR/PSD permitting,
     and NSPS and NESHAPS programs.  Further, there must_be
     a thorough review of the States' compliance monitoring
     and surveillance program.  When appropriate, the Regions
     should provide recommendations and assistance to States
     whose programs need improvement.

REGIONAL OFFICE PROJECTED PROGRAM ACCOMPLISHMENTS

Air Quality Management

Priority I

 1    Percent  of States  having EPA approved  SIP for the
 Prevention of Significant Deterioration. — This PPA measures
 the  status of the  development by the States and approval  by
 EPA  of State plans for the  revention of significant Deter-
 ioration as  required by Part C of Title i  of the Clean Air Act.

 2.   Percent  of States  having full legislative authority
 approved by  EPA for  implementing  automotive inspection/
 maintenance  program. — This PPA measures  the status of the
 enactment by States and approval by EPA of the legislative
 authority necessary to implement mandatory inspection/main-
 tenance programs in required urban nonattainment areas for
 ozone and/or carbon monoxide.

 3.   Percent  of required inspection/maintenance programs
 proceeding to develop on schedule. — This PPA measures the
 status of"state progress in carrying out the schedule  con-
 tained in the 1979 attainment SIP for the development of
 mandatory automotive inspection/maintenance programs.

 4.   Percent of conditionally approved SIPs corrected by the
 State on schedule  (by pollutant). — This  PPA measures the
 status of State efforts to  correct, modify, or  add provi-
 sions to their 1979 attainment SIP as a result of condi-
 tional approval of the original  submission.  Actions by the
 State are to be in accordance with  the schedule  set forth by
 EPA in the  conditional approval.  Only one SIP  per  pollutant
 per State should  be counted  in  the  PPA.   If  any  part of an
 attainment  SIP for one of the criteria pollutants has been
 conditionally  approved by EPA,  the  entire state  SIP for that
 pollutant is considered  to  be conditionally  approved  for  the
 purpose of  this PPA.  (i.e./  SIP  for  0- where one VOC  regu-
 lation has  been conditionally approved).

 5.  Number  of  0 /CO SIP  Strategies  Tracked and Reviewed  as  a
 ratio of  the  to?al  number 0 /CO strategies.  — This PPA
 covers  the  Regional tracking, review (including RFP)  and
 approval/disapproval  of  C) /CO SIPs.   Regions should count as
 a strategy  each separate T/M program,  TCM program,  and  set
 of  VOC  regulations tracked  and  reviewed as a ratio  of the
 total number of such  strategies.

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                           - 92 -
 6.  Number of TSP nontraditional SIP strategies tracked and
reviewed as a ratio of the total number of TSP nontraditional
strategies. -- The regions should count as a strategy each
separate TSP nonattainment area which will have an approved
SIP calling for nontraditional controls (i.e., fugitive dust
control studies and/or measures) as a ratio of the total num-
ber of such strategies.

 7.  Number of TCM programs in areas >1 million. -- This PPA
covers the guidance and assistance to TCM programs in urban
areas >1 million.  The Regions should count the number of
such areas assisted as a ratio of the total number of such
areas.

 8.  Number of State PSD programs as a ratio of the number of
States. -- The Regions should count the number of approved
State PSD plans and the number of full delegations of the PSD
program.

 9.  Number of Tier II reviews completed by a Region as a
ratio of the total number of Tier II sources.  — The Regions
should count the number of Tier II reviews (i.e. BACT deter-
mination and air quality impact analysis)  which they or their
contractor will conduct as a ratio of the total number of all
Tier II reviews  (i.e., including State completed Tier II
reviews).

Priority II
10.  Number of I/M programs guided and assisted as a ratio of
the number of I/M programs. — This PPA covers the guidance
and assistance to I/M programs or areas starting a SIP
required I/M program as a ratio of the total number of such
programs.

11.  Number of VOC regulatory programs guided and assisted as
a ratio of the number of VOC regulatory programs. — The
Regions should count the number of programs assisted a,s a
ratio of the total number of State and local regulatory pro-
grams (agencies) which are developing VOC regulations,

12.  Number of TSP nontraditional SIP strategies in areas
>200K population guided and assisted as a ratio of the total
number of such strategies.  — The Regions should count the
number of areas >200K population requiring nontraditional
TSP controls where guidance is provided as a ratio of the total
number of such areas.

13.  Number of Pb SIP strategies tracked and reviewed as a
ratio of the total number of such strategies. — The Regions
should count the number of Pb SIP strategies which are

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                           - 93 -
reviewed and approved/disapproved as a ratio of the total
number of such strategies required.  A Pb SIP strategy is
considered to be each area or source(s) which require a sep-
arate control strategy demonstration.

14.  Number of point source Pb SIP strategies guided and
assisted as a ratio of the total number of such strategies. —
The Regions should count the number of point source Pb con-
trol strategy demonstrations where assistance and guidance
are given as a ratio of the totaL number of such control stra-
tegies.  The definition of a Pb point source is contained in
40 CFR 51.

15.  Number of "other" Clean Air Act required SIP revisions
tracked and reviewed as a ratio of the total number of such
revisions. -- The Regions should count the number of Clean
Air Act required SIP revisions reviewed and approved/dis-
approved as a ratio of the total required.  "Other" Clean Air
Act required SIP revisions are defined as those revisions,
required by the Act, but not covered by the general headings
of nonattainment SIPs or PSD (e.g., Stack Height, Board
composition, permit fees, etc.)

16.  Number of State initiated SIP revisions tracked and
reviewed as a ratio of the total number of such revisions. —
The Regions should count the number of revisions initiated by
the States but not required by the Act which are reviewed and
approved/disapproved as a ratio of the total number submitted
to the Regions.

Priority III

17.  Number of TCM programs in area >1 million population guided
and assisted as a ratio of the total number of such programs. —
Same as #7, but applied to areas >1 million.

18.  Number of TSP nontraditional SIP strategies in areas
>200K guided and assisted as a ratio of the total number of
such strategies. — Same as #12, but applied to areas >200K.

19.  Number of Tier I reviews completed by a Region as a
ratio of the total number of Tier I sources. — Same as # ,
but applied to Tier I reviews  (i.e., engineering review on
sources >50 TPY SI? allowable).

20.  Number of nonattainment SIP promulgations as a ratio of
the total number needed. — The Regions should count the num-
ber of promulgations made to help complete a disapproved
nonattainment SIP as a ratio of the total number needed to
lift sanctions.

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                            - 94 -
21.  Number of urban (>500K population) Pb SIPs guided and
assisted as a ratio of the total number of such SIPs.  — The
Regions should count the number of Pb SIPs in areas >500K
which are given assistance as a ratio of the total number of
such SIPs required.  Any SIPs in urban areas >500K which
involve only the control of a few point sources should be
accounted for under #14 above and not here.

22.  Number of Class I area visibility plans guided and
assist as a ratio of the total number of such plans  (i.e.,
the total number of designated Class I areas or State por-
tions thereof). — The Regions should count the number of
visibility plans for designated Class I areas which they
guide and assist as a ratio of the total number of such
plans (i.e., the total number of designated Class I areas
or State portions thereof).

23.  Number of PSD Set II SIPs guided and eissisted as a ratio
of the number of States. — The Regions should count the num-
ber of PSD SIPs for CO, 03/  and NO  which they guide and
assist as a ratio of the number ofxStates.

24.  Number of 111 (d) plans tracked and reviewed as a ratio
of the number of such plans needed. — The Regions should
count the number of pollutant/source specific lll(d) plans
which they review and approve/disapprove as a ratio of the
total number of pollutant/source plans needed.

Air Quality Monitoring



 PRIORITY I

  1.   Percent of National  Air Monitoring Stations (NAMS)
 meeting all requirements  of the EPA ambient monitoring regu-
 lations, (location, probe siting, quality assurance).  --
 This PPA measures the status of State efforts to establish
 national air monitoring sites as part of their state ambient.
 monitoring network.  The  national air monitoring stations
 are to be fully in place  and operation by January 1, 1981.

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                            -  95  -


 2.  Number of NAMS monitors evaluated and fully documented
for conformance to 40 CFR 58 expressed as a ratio to the total
number of NAMS monitors. — Every NAMS pollutant monitor site
(NAMS being a subset of the SLAMS) must be evaluated for con-
formance to Appendices C, D, and E requirements of 40 CFR 58.
This involves visiting each site in the NAMS network over the
next year to verify whether requirements have been met.  The
documentation consists of a detailed site description form
being' completed and schedules established for complying with
any 40 CFR 58 criteria not being met at the time of the pollu-
tant monitor evaluation.  The site documentation also includes
the collection and submission of management information to
OAQPS.  This management information consists primarily of
site descriptive data as well as information on schedules for
implementing the provisions of the 40 CFR 58 requirements.
All NAMS monitors should be evaluated by the end of FY-80.

 3.  Number of State and local agency 105 grants reviewed,
expressed as a ratio to the total number of agencies receiv-
ing grants. -- The Regions should include the number of 105
Agency Grants that have been reviewed for monitoring as a
ratio to total number of agencies receiving 105 grant monies.

 4.  Number of State or local agency system audits completed,
expressed as a ratio to the total number of State and local
agencies with air monitoring systems receiving 105 grant
monies. — This is a Regional responsibility involving an
annual on-site qualitative review of State or local agencies'
monitoring capabilities and facilities as required by 40 CFR
58, Appendix A, Section 2.4.  The Region should account
only for those system audits involving 105 funded agencies.


 5.  Number of State monitoring  (SLAMS) network descriptions
submitted  to the Regional Office by January 1, 1980. — The
States are required to  have a complete description of their
SLAMS  (including NAMS)  network available at the time the  SIP
is  revised to reflect the new 40 CFP  58 requirements.  The
network description requirements are  listed in 40 CFR 58.20.

 6.  Number of State quality assurance programs that are
reviewed and approved by the Region. — The Region should
include the number of State quality assurance programs (re-
quired and described in Appendix A of 40 CFR 58) which are
reviewed and approved by the Region.  As a minimum, the State
quality assurance program description should cover the NAMS
network.  It is recommended that the entire SLAMS network be
included in the quality assurance program in FY-80.  The
quality assurance program should be submitted by the State
by  6/30/80 and approved by  the Regional Office no later than
the end of FY-SO.

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                           - 96 -
 7.  Number of EMSL performance audits in which the regional
laboratory participates, expressed as a ratio of the total
number of audits EMSL schedules. — These audits are required
by 40 CFR 58 for all agencies operating SLAMS.  For FY-1980,
those Regional Offices actually involved in ambient sampling
and analysis will be strongly encouraged to participate.
EMSL schedules a total of 13 performance audits annually
(S02, NCU, CO, nitrate, sulfate, and lead are semi-annual and
Hi-vol flow annual).

 8.  Number of SIP revisions for ambient monitoring reviewed,
expressed as a ratio to the total number of SIP's to be
revised. -- The States are required to submit a SIP revision
to 40 CFR 51.17 to reflect the 40 CFR 58 requirements by
January 1, 1980.  The Regions should count the number of SIP
revisions to be made as a ratio to the number of SIP's needed
to be revised.

 9.  Number of special ozone studies in which the Region will
participate for areas which will need an extension for attain-
ment to 1987 and for which complex photochemical dispersion
models will be exercised. — The Region should include only
those studies which will involve the application of urban or
regional diffusion models.  Generally, areas whose O3 design
value is less than 0.2 ppm and whose urbanized area - popula-
tion is less than 1.5 million will not be encouraged to
exercise complex photochemical models.

10.  Number of States for which Region will process and vali-
date SLAMS data. -- The Regions should count those States for
which they will process and validate SLAMS data.  The 40 CFR
58 regulations will change the requirement from all data being
reported quarterly to EPA to NAMS data being reported quarter-
ly to EPA.  These new requirements will take effect with data
collected beginning in FY 1981.  Therefore, in FY-80, all
SLAMS data should be reported and validated quarterly as is
current practice.

11.  Number of data quality assessments completed for State
and local agency air quality data bases, expressed as a ratio
to the total number of data bases which need to be assessed.
-- The Region should display the number of State and local
agency data bases which will be assessed as a ratio to the
total number of State and local agencies operating a SLAMS
network.  This activity involves the implementation of the
recommendations of the Quality Assurance Committee in terms
of assessing the quality of data in EPA data banks.  This is
primarily the summarization of a series of qualitative judg-
ments on data quality.  These assessment activities should be
considered interim measures until the precision and accuracy
reporting requirements in 40 CFR 58 Appendix A take effect.

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                            - 97 -
12.  Number of Regional Environmental Profiles completed
which  involve air quality displays or analyses. — The  Regions
should count the number of urbanized areas  greater than
200,000 population which will be part of  the  Regional
Environmental Profile.

13.  Number of emergency spills or emergency  episodes to
which  the  Region responds. — The Region  should count only
those  spills or episodes during which the Region  takes  envi-
ronmental  samples or  for which Regional personnel are involved
on-site.

PRIORITY II

14.  Number of New Source Review Data Analyses performed  by
the  Region. — The Region should count  the  number of new
source permits for which they review the  air  quality data.

15a. Number of source operated monitoring networks reviewed
in States  where the Region is implementing  the PSD program
expressed  as a ratio  to the  total number  which need to  be
reviewed.  — The Region should include  the  number of source
networks that the Region reviews in States  that do not  have
a PSD  program.  Review means discussions  with the proposed
source on  the monitoring plan described in  "Ambient Monitor-
ing  Guidelines for PSD" - OAQPS 1.2-096.  In  the  case of
large/controversial sources, and-on-site  visits to monitoring
sites, performance audits would be included in the review.
15b. Number of source operated monitoring networks reviewed
in States with PSD programs. — The  Regions  should  include  the
number of source networks that they review in States with a
PSD program.  (i.e., in States with permit granting authority
either by means of a SIP or EPA delegation)^

16.  Number of States for which the Region will process
emission data. — This covers those States for which the
Region will process and submit emission data to NADB for
inclusion in NEDS.

17.  Number of pollutant monitor performance audits completed.
— The Region should count the number of quantitative on-site
performance audits of individual pollutant monitors that the
Region conducts.   (Reported by pollutant).

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                            -  98  -
18.  Number of urbanized areas for which the Region will coor-
dinate the reporting of a daily air quality index expressed
as a ratio to the total number of urbanized areas needing
coordination. — The Region should include the number of urban-
ized areas greater than 500,000 population which will require
Pegional coordination and overview to implement an air quality
index report expressed as a ratio to the total number of
urbanized areas greater than 500,000.  For areas already
reporting an index, coordination would involve review of the
existing index report for consistency with 40 CFR 58, Appendix
G.

19.  Number of SLAMS monitor sites (excluding NAMS) evaluated
and documented for conformance to 40 CFR 58 expressed as a
ratio to the total number of SLAMS monitor sites. — The total
number of SLAMS pollutant monitor sites that the Regional
Office will evaluate and provide detailed site documentation
should be displayed as a ratio to the total number of pollu-
tant monitors in the SLAMS network.

PRIORITY III

20.  Number of urban lead monitoring networks reviewed,
expressed as a ratio to the total number of networks which
need review. — The number of urban lead networks that the
Region reviews for areas greater than 500,000 population
should be displayed as a ratio to the total number of urban
areas greater than 500,000 population.  In addition, the
Regions should include any other areas for which the State
will be required to operate a lead network.

21.  Number of population exposure analyses the Region con-
ducts expressed as a ratio to the total number of analyses
needing to be performed. — The Region should count urban-
ized areas greater than 200,000 population for which they
will perform population exposure analyses expressed as a
ratio to the total number of urbanized areas greater than
200,000 population.

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                          - 99 -
AIR ENFORCEMENT

I.   Ensure Compliance by Major SIP Sources

        Number of major SIP sources determined to be
        in compliance with emission limitations

        Number of major SIP sources determined to be
        in violation of emission limitations, but
        meeting compliance schedules.

        Number of major SIP sources determined to be
        in violation of emission limitations and not
        meeting or not on compliance schedules.

        Number of major SIP sources of unknown status
        with either emission limitations or schedules.

     -  Number of overview inspections for existing
        major SIP sources. -

        Number of existing major SIP source^case
        development inspections completed. —'

        Number of civil/criminal actions against      . /
        major existing sources in violation of SIPs. —

        Number of Section 113 administrative orders
        against major existing sources in violation of
        SIPs.

        Number of notices of noncompliance iss :ed
        (for all major sources).

        Number of noncompliance penalty assessments
        (for all major sources).

        Total dollar amount of noncompliance penalties
        assessed (for all major sources),

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                         - 100  -
II.   Ensure Adequate New Source Program

      -  Number of identified sources subject to
         NSPS and determined to be in compliance.

      -  Number of subject sources determined to be
         in violation with respect to any procedural
         and/or emission requirements for NSPS.

         Number of subject sources of unknown
         compliance status with respect to any
         procedural and/or emission requirements
         for NSPS.

         Number of PSD sources in compliance with
         procedural permit requirements.

      -  Number of PSD sources determined to be  in
         violation with respect to procedural or
         permit requirements.

         Number of PSD sources of unknown compliance
         status with respect to procedural or
         permit requirements.

         Number of new source (subject to NSR, NSPS,
         and PSD)  case development inspections.—/

         Number of State NSR permits reviewed for
         enforceability.

         Number of State NSR permits found to be
         deficient.

         Number of audits of State NSR programs  (can
         be part of the general State audit or a
         separate audit).

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                         - 101 -
         Number of Regional Offices issued permits
         for:

         (a)   NSR
         (b)   PSD
         (c)   NESHAPS

         Number of NSPS performance tests observed.

         Number of civil/criminal actions against
         new sources in violation of NSR, NSPS,
         and PSD requirements.!/

III.   NESHAPS  Program-/

      o  Number of non-transitory sources subject
         to NESHAPS regulations that are in
         compliance.

      o  Number of non-transitory NESHAP sources
         determined to be in violation of standards
         or waivers.

      o  Number of non-transitory sources subject
         to NESHAP regulations  of unknown com-
         pliance status with respect to standards
         or waivers.

      o  Number of non-transitory sources that are
         on waivers and are in  compliance with
         their waivers.

                                                2/
      o  Number of NESHAPS overview inspections.—

      o  Number of NESHAPS case development
         inspections.I/

      o  Number of civil/criminal actions against
         NESHAP sources.!/

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                         - 102 -

                                                              <
IV.  Create and Maintain Priority Source
     File in the Compliance Data System

      -  Number of States for which an adequate
         priority source file is maintained in
         CDS.

V.   Energy Related Activities--^

      -  Number of 113(d)(5) orders issued.

VI.  llKd)-/
        1    •

         Number of sources subject to lll(d)
         requirements.

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                         - 103 -
Footnotes

3,/Quarterly updates of compliance status reported
~ through CDS.

2/Facility Overview Inspection - means verification
  of State reported compliance status for all
  emission points within a facility for all
  regulated pollutants and determination of com-
  pliance by the facility with all enforceable
  procedural requirements.  Individual field
  surveillance actions comprising a facility
  inspection must be completed for each major source
  within the fiscal year.

3/Case Development Inspections - distinguished
  from facility overview inspections and counted
  separately.  Inspections of a given facility
  subsequent to an overview inspection may be
  counted.  Case development inspections support
  specific enforcement actions originated by
  regional overview, citizen complaints, etc.

4/A civil/criminal action can be counted once a
  complete litigation report has been submitted
  to Headquarters.

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1980/1981 WATER QUALITY MEDIA GUIDANCE

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                   WATER QUALITY

MEDIA OVERVIEW

Major Objectives

During 1980/81 the Water Quality Program will aggressively
pursue the following three central objectives which are
encompassed in this Guidance:

     o  To aggressively control pollution discharges in
        order to protect public health and sensitive
        ecological systems such as wetlands;

     o  To share responsibilities with States and localities
        while encouraging public participation in water
        quality management; and

     o  To manage the program in an efficient manner.

Clearly, the driving force in the Water Quality Program is
to control pollution, to protect public heatlh and the
environment.  As our knowledge has increased regarding the
effects of toxic pollutants on human life, so too have we
intensified our efforts on controlling toxic pollutants
from entering the environment.  Similarly, the significant
improvements in our understanding of aquatic resources,
especially wetlands and shallow water areas, is paralleled
by increased legislative attention to protect these
resources through Section 404 of the Clean Water Act.
It is essential that responsibilities are shared between
Federal and non-federal authorities to maximize our efforts
on improving water quality, to limit redundancies in
Federal and non-federal programs, and to utilize the best
mix of resources to identify and solve our environmental
problems.  Because of the critical nature of the Water
Quality Program and the large number of dollars the program
utilizes, it is essential that the program be managed
efficiently to maximize environmental benefits.  This can
be achieved through an integrated planning and implementation
process within the Agency as well as integration with other
Federal agencies and States and localities.

Major Planning Assumptions

Inherent in the priority activities for FY 80/81 for
achieving media objectives are the following major planning
assumptions:

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               - 108 -

Construction Grants

o  The Construction Grants appropriation will be               f
   $3.8 billion in FY 1980 (available by October 1,
   1979), and $4 billion is requested in FY 1981,
   with the allotment formula for both years the
   same as in FY 1979.

o  The Congress will enact a one-year extension of the
   allotment period for FY 1979-1982 Construction
   Grants funds, increasing the period of availability
   to three years for all appropriations authorized
   in the Clean Water Act.

Spill Prevention

The Spill Prevention and Response Program, while
continuing in the general program direction established
during the last two years, is experiencing some major
changes in emphasis to allow response to hazardous
spills.  The principal assumptions for program
planning in FY 1980 are:

o  Publication of final Hazardous Substances Reg-
   ulations, revised to incorporate the October 1978
   amendments to Section 311 of the Clean Water Act,
   is expected in the Spring of 1979.

o  The list of 299 hazardous substances which must be
   reported in the event of a spill and which will
   require EPA spill emergency response will be
   expanded by 1981.

o  Based on voluntary reports, the program estimates
   about 700-1,200 hazardous spills, involving one or
   more of the 299 substances, will occur annually.

Ocean Disposal

o  All interim Ocean Disposal Permits are to be
   phased out by the end of 1981, by regulation.
   All dumping of harmful sewage sludge is to stop
   by the end of 1981,  by statute.                              *

Dredge and Fill

o  Transfer of Section 404 Dredge and Fill Program              a
   responsibility to qualified States will begin in
   FY 80 and increase in FY 81.  Approvals will remain
   low until later years  (reflecting both a waiting

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                    - 109 -
        period while EPA finalizes regulations and the
        lead time for States to develop their programs),
        but EPA will be heavily involved in assisting
        interested States in program development.

     o  The total Dredge and Fill permit load will
        increase gradually from the current level as
        EPA enforcement activities increase.  This change
        results from better surveillance methods and more
        citizen participation and increasing attention to
        the total acreage and stream mileage being actually
        regulated.

     Water Quality Management

     o  Funding of continuing planning will be limited to
        those areas in which substantial implementation of
        the initial approved plan is taking place.

     o  Funds will be available for continuing planning
        under Section 208 in FY 81 with emphasis on com-
        pletion of planning in high priority problem areas.

     Permits Issuance

     The FY 80/31 Guidance is premised on three major
     assumptions:

     o  FY 80/81 priorities will be essentially the same
        as in FY 79, that is emphasis is placed on issuing
        and reissuing permits to control major sources
        of industrial and municipal pollution, including
        Federal facilities.

     o  Additional priorities which must be addressed
        within the context of decreasing resources are
        implementation of the permits consolidation
        effort and implementation of the National Pre-
        treatment Program.

     o  Clean Water Act amendments require consideration
        of new variances such as the Section 301 (i)
        municipal time extension, the Section 301(g)
        water quality variance, and the Section 301(h)
        marine waiver.

Media Priorities

Program plans in FY 80/81 will emphasize activities that
are designed to better assess environmental problems, and
to develop and implement programs to solve and prevent
environmental hazards.

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                     - 110 -
Essential to an efficient pollution control program is
the ability:

     o  To identify potentially harmful pollutants;

     o  To assess the effects of levels of pollutants on
        aquatic organisms, other food chain organisms,
        and man,

     o  To assess the transport and fate of pollutants
        in the environment,

     o  To monitor for potential pollution problems, and

     o  To evaluate improvements in water quality.

Much is known about conventional pollutant indicators such
as biological oxygen demand and bacterial counts.   However,
our ability to assess toxic pollution problems is hampered
by the large number of toxic pollutants in the environment
and the necessity of using highly sophisticated and
expensive technology to monitor pollutant levels.   Currently
there is much ongoing work to resolve these problems.

Program plans demonstrate an integrated effort by the Office
of Research and Development and the Office of Water and
Waste Management to improve problem assessment capabilities.

Concurrent with our activities designed to identify and
assess environmental problems, the Water Quality Program
is aggressively pursuing activities to solve our water
quality problems while limiting environmental impacts to
other media.  Major Water Quality Program thrusts for
1980/81 are in response to the mandate of the Clean Water
Act of 1977.

Program plans represent a coordinated effort by the Office
of Water Program Operations, Office of Water Planning and
Standards and Office of Enforcement, working in. concert
with States and localities to:

     o  Control industrial and municipal dischargers of
        pollutants through technology-based controls.

     o  Control nonpoint source pollution and prevent
        and clean up oil and hazardous spills.

     o  Protect sensitive ecological systems such as
        lakes and wetlands.

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                     - Ill -


     o  Utilize Water Quality Standards and environmental
        quality based effluent controls, where necessary,
        to assure protection of public health and
        environment.

     o  Enforce environmental control requirements.

The implementation of these priorities will be characterized
by their integration within the Water Quality Program and
integration with other Agency activities directed at
improving environmental quality.  Information gleaned
from problem assessment activities will be critical to
the continuing evolution of solutions and strategies.

     Industrial and Municipal Dischargers

     In 1980 and 1981 the control of industrial and
     municipal dischargers of pollutants will remain the
     keystone to water programs control activities.   The
     1980 program will also include additional pollutant
     studies (e.g., "hot spots" analyses) that will con-
     centrate on selected areas of industry where monitoring
     data indicate high cancer incidence or potential water
     pollution problems would persist after the imple-
     mentation of effluent limitations.  The studies will
     lead to the development and implementation of additional
     controls.   Efforts also will continue in 1980 to
     identify other toxic pollutants and industries that
     should be addressed in effluent guidelines.

     By 1984, industrial sources of toxic pollutants will
     be required to meet technology-based toxic effluent
     discharge limitations for both direct and indirect
     wastewater  discharges.   This effort entails detailing
     the presence or absence of 65 toxic pollutants or
     classes of toxic pollutants.  An in-depth economic
     analysis of each industry also must be conducted
     to ensure that regulations are economically achievable
     and equitable.  This program will peak in 1979 and
     1980 arid continue through 1981 with final promulgations
     and court defenses.

     Municipal point source control activities are addressed
     principally through the Waste Treatment Facility
     Construction Program.  This program is of major
     importance to reduce water pollution problems resulting
     from conventional pollutants, such as suspended
     solids, bacteria, and oxygen demanding loads that
     degrade our waters and continue to pose problems to
     public health and the environment.  The long range
     goal of the Construction Grants Program is to eliminate

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                - 112 -
the municipal discharge of untreated or inadequately
treated pollutants and thereby help restore or
maintain the quality of the Nation's waters.  A
large number of amendments to Title II of the
Clean Water Act created incentives for use of
environmentally justifiable, innovative and
alternative technologies in municipal treatment
systems; established funding for States to assist
them in adopting and managing Construction Grants
Programs; made special considerations for the needs
of small communities; and increased emphasis on water
reuse and recycling, recovery of energy, and confined
disposal of pollutant wastes to prevent their migration
to the water.

Through the passage of the Clean Water Act the Congress
reaffirmed its intention that States have a major and
continuing role in environmental programs.  The year
1980 will mark the start of a new era in planning,
implementing and managing environmental programs at
the Regional and State levels.  State/EPA Agreements
will present consolidated approaches to solving
water supply, solid waste, and water pollution control
problems.  The integration of these program areas
will be a major step toward the objective of compre-
hensive environmental planning and management.

Activities aimed at integrated management are being
initiated in 1979.  EPA is requiring all States to
develop comprehensive State/EPA Agreements to cover
Clean Water Act programs including consolidation of
Sections 106, 208, 303, and the Clean Lakes provisions
of Section 314.

State/EPA Agreements will be the result of a negotiation
process between each State and its respective EPA
Region.  The Agreements will describe activities that
States and EPA will undertake during the coming year.
An agreement will be the result of an assessment of
the environmental problems faced by an individual
State, development of a long-term strategy to solve
those problems, and a determination of critical steps
to take during the next year.

Each State/EPA Agreement will reflect important decisions
on environmental and programmatic problems, State and
EPA priorities, timing, and responsibilities.  It
also will be a management tool which focuses attention
on the evaluation and accomplishment of major
environmental efforts.

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                - 113 -
Initial Water Quality Management Planning will be
completed by all States and areawide agencies by
the end of 1979.  The continuing planning effort by
local and State agencies in 1980 will focus on the
highest priority problem areas with special emphasis
on toxics.  The Agency will stress implementation
of the initial plans and require that substantial
implementation occur as a condition for future
funding.

The key change in program management to ensure Section
208 plans are being carried out is the development
of the State/EPA Agreement process.  State imple-
mentation will utilize funds provided under Section 106
Program Grants to accelerate establishment of regulatory
programs and to provide for monitoring to assess the
adequacy of clean-up efforts.

Implementation of the Construction Grants Program
requires integrated Agency and State efforts with a
large delegation of responsibilities to the States.

The program strategy for 1930  recognizes that there are
limited funds available to meet these pollution control
needs and that the funds available must go toward
assisting municipalities in meeting the most critical
needs in the shortest possible time.  Accordingly,
the EPA strategy for 1930-1931 is:  (a) to orient
funding toward meeting the environmental requirements
of the Act through stringent cost-effect review on
a project-by-project basis, and (b) to stress
innovative and alternative approaches to waste
treatment, including emphasis  on water and energy
conservation, waste water reuse and recycling of
pollutants, and small systems.  Funds specifically
earmarked for State delegation under Section 205(g)
of the Act will be directed toward maximizing
State assumption of program activities in the shortest
possible time.  In all cases,  State delegation will
be part of an overall agreement that will ensure that
EPA policies and environmental objectives continue to
be met.

EPA will continue to pursue program strategies that
provide sufficient certainty and stability to States
and municipalities to facilitate effective planning
and management at all levels.   The 1980 appropriation
request of $3.8 billion is a critical component of
this management need.

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                - 114 -
The State Management Assistance Grant Program                 *
authorizes the use of two percent or $400,000,
whichever is greater, of each allotment to cover
the cost of delegation to the States of the
Construction Grants Program and (to the extent that
funds suffice) the National Pollution Discharge
Elimination System  Permit, Dredge arid Fill, and
Section 208 Management Programs.  EPA's long-term
goal is to allow the States, rather than EPA, to
assume responsibility for day-to-day management of
Construction Grants activities.  The timing and
extent of delegation to each State depends on the
State's ability to operate a program that meets the
necessary competency requirements and policy direction
mandated by the law and EPA objectives.  A grant is
given to a State when it can show that it is able to
assume delegated responsibility for a substantial
portion of Construction Grants program activities.

Approximately 26 States are expected to receive
State Management Assistance Grants during 1979,
which will allow gradual phase-in of most program
activities as the States staff up and are trained
to accept each task.  Most of the remaining interested
States will have entered into preliminary negotiations
during 1979 leading to a grant in 1980 and 1981.
Resource benefits from this State delegation strategy
should begin to be evident in 1981.

Control of Nonpoint Sources

Nonpoint source pollutants are a continuing cause of
water quality degradation.  A substantial number of
the nation's waterways will continue to fail to meet
their intended uses unless nonpoint source programs
are developed and controls enacted.  Nonpoint
source problems require further identification;
control techniques must be developed and tested;
and cost effective, best management practice
systems designed and demonstrated.  Substantial
efforts will be directed to the identification and
evaluation of these practices both with Agency resources
and in conjunction with other Federal agencies.

It is a priority to continue to develop and assess
methods of controlling urban nonpoint source
pollution and additional methods for controlling
rural nonpoint source pollution.

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                 -  115  -
Hazardous Spills

In 1980, the Agency will implement and expand its
Spill Prevention and Response Program to cover not
only oil spills but also the discharge of those
substances determined to be hazardous by EPA.  The
Agency is currently developing and will promulgate
regulations for hazardous substances designations,
removability, harmful quantities, and rates of
penalty.  An Environmental Emergency Response Team
has been established to provide immediate on-the-
scene expertise in handling, clean up, and disposal
of most critical oil and hazardous substance spills.

Protection of Ecological Systems

Wetlands

In FY 80 and especially FY 81 the Wetlands Protection
Program will have a high priority within the Office
of Water and Waste Management.  Section 404 of the
Clean Water Act provides the principal protective tool
and may underpin other non-Federal activities for
protection of wetlands.  EPA shares the responsibility
for implementing Section 404 with the U.S. Army
Corps of Engineers, the U.S. Fish and Wildlife
Service, and in the future, with the States.

A significant increase in Section 404 responsibility
for EPA will occur in 1980 as the Agency provides
a significant degree of the substantive review on
at least the most significant environmental permits,
whether issued by the Corps or the States, and
responds to the variety of new program developments.

Under the 1977 Act, the Corps will continue to allow
dredge and fill material discharge in the traditionally
navigable waters.  States may assume permit respons-
ibility in other waters, if they are qualified.  EPA's
role in this process is large and includes respons-
ibility for issuing regulations, establishing State
program approval criteria, reviewing and acting upon
applications from States, and providing continuing
oversight for both States and the Corps permit programs.

EPA is currently drafting two sets of regulations
for State assumption of permitting responsibilities.
The regulations are for program approval and State
program operations.

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                     - 116 -
     Lake Protection

     The Clean Lakes Program is authorized by Section 314
     of the Clean Water Act.   The program provides grants
     to States for:   identification and classification
     according to euthrophic condition of all property
     around freshwater lakes;  procedures, processes,  and
     methods to control sources of pollution; and pro-
     cedures for restoration.

     Program plans demonstrate continual efforts directed
     at efficient control of lake pollution problems  and
     activities designed for lake quality enhancement.

     Water Quality Standards and Environmental Quality
     Based Effluent Controls

     Water quality standards are a means for States to
     protect the ambient quality of their waters.   Section
     303 of the Clean Water Act requires States to review
     Water Quality Standards every three years and to
     submit new and revised standards to the Administrator
     for approval.  If standards are unacceptable to  the
     Administrator,  the EPA can promulgate State standards
     where States fail to comply with Federal regulation.

     At present, many State standards do not contain
     criteria for toxic substances.  Even where States do
     have certain criteria for toxics, NPDES permits
     frequently are not written to meet such criteria.
     In FY 80/81 EPA is considering revising the Federal
     standards regulations so that States may be required
     to adopt numerical criteria for a minimum list of
     toxic substances.  The Office of Water Planning  and
     Standards is further attempting to remedy this
     through technical assistance on wasteload allocation
     procedures and methods of implementing bioassay
     criteria in Water Quality Standards.   An additional
     priority here is to develop a strategy for the use
     of Section 307 (a) toxic effluent limits where BAT
     requirements are sufficient to protect public health
     and environment.

Enforcement

Enforcement activities play a central role in implementing
an effective pollution control program.  Toxic pollutant
and hazardous materials enforcement wll be pursued through
enforcing reissued permits, bioassay inspections, pre-
treatment requirements, Section 404 requirements, Section 311

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                     - 117 -
hazardous substances requirements, and use of Section 504
emergency powers.  In 1980, the Permit Program will initiate
its issuance of permits based on promulgated effluent
guidelines for toxic pollutants.

Implementation of the pretreatment requirements demon-
strates the importance of working liaison between the EPA
and localities.  The Clean Water Act of 1979 requires that
POTW's must develop programs to enforce the EPA's National
Pretreatment Requirements.  Following the 1978 promulgation
of Federal pretreatment guidelines, the program will begin
to shift in 1979 and 1980 to the local level.  Toxic
pollutant controls will proceed through incorporating
pretreatment requirements in municipal permits for control
of indirect discharges.  Enforcement resources will be
devoted to the pretreatment programs, consider requests
for modification of pretreatment standards, and modify
municipal permits to incorporate pretreatment requirements.

The Water Quality Program will make a major initiative
to limit the redundancies of the regulatory process and
to provide for more efficient program management.  In
1980 the Permit Program will work to consolidate National
Pollutant Discharge Elimination System (NPDES) permits
under the Clean Water Act with Hazardous Waste permits
under the Resource Conservation and Recovery Act, and
Underground Injection Control permits under the Safe
Drinking Water Act.  Consolidation of these permit programs
will eliminate duplicative permit issuance reporting
requirements for affected facilities.

Emphasis will continue in 1979 and 1980 on the Municipal
Enforcement Strategy first formulated in 1978.  As with
other water quality programs, this strategy is an attempt
to integrate program activities of the Grants, Enforcement,
and NPDES Permit Compliance Programs, to better coordinate
and reinforce planning and scheduling of municipalities to
meet the goals of the Act.  The principal effort in 1979
and 1980 will be to implement a program of action through-
out EPA and the States, leading to:

     o  Integrated municipal permit and grants schedules;

     o  Compatible information systems;

     o  Internally consistent operating procedures; and

     o  Coordinated grant and enforcement sanctions for
        noncomplying municipalities.

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                      - 118  -


The overall result is expected to be more effective and
expeditious actions toward the compliance of municipalities
with requirements established in the Act.

Permits Issuance

The major objectives of the FY 1980/81 Permits Program
will be to maximize the control of toxic pollutants
through the initiation of the second round permitting
effort and the implementation of the National Pretreatment
Program; to accomplish a major regulatory and management
reform initiative by streamlining the permit process to
allow for consolidated procedures, organization and permit
format; and contribution to the major source enforcement
effort through implementation of the National Enforcement
Strategy.

Under separate cover, OWE will provide more detailed
guidance on integrating permit program priorities
with particular reference to pretreatment activities.

     o  Toxic control through second-round permits— NPDES
        second-round permits under the Clean Water Act
        will begin to be issued in FY 80 and will be issued
        throughout FY 80/81.  The reissuance of expiring
        permits to these industries, including Federal
        facilities, covered by the NRDC consent decree
         ("primary" industries) will be of particular
        importance as it will impose BAT/toxic limitations
        on the significant sources of toxic pollutants.
        Emphasis on permits issuance will be prioritized
        in FY 1980/81 as follows:  major primary industries
        which could be sources of highly toxic substances,
        major secondary industries, remaining (80%)  minor
        primary industries, and minor secondary industries.

     0  Regulatory and management reform through consolidated
        permitting — EPA is consolidating its permit pro-
        grams, both to simplify administrative steps and
        to facilitate addressing all environmental concerns
        through a single process.  By October 1, 1979,
        EPA will consolidate permit issuing, i.e., permit
        drafting, paper flow and initial point of contact,
        for NPDES permits; Hazardous Wastes permits;
        Underground Injection Control permits; Ocean
        Dumping permits;  Air New Source permits; and other
        permit-like programs in one place in each of its
        Regional Offices.  Regulated facilities will be
        able to submit one application for all water, solid
        and hazardous wastes related permits; go through
        one review; and be issued one permit.

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                     - 119 -

     o  Toxic control through pretreatment — The pre-
        treatment program is expected to take on increasing
        importance in 1980.   Pretreatment activities in
        FY 1980 should be addressed generally according
        to the following priorities:  1) provide assistance
        to States in developing State pretreatment programs
        and approve such programs: 2) review and make
        determinations on requests for local pretreatment
        program approval; 3)  develop compliance schedules
        for insertion in NPDES municipal permits requiring
        the development of a local pretreatment program;
        and 4) work with States and municipalities in
        identifying industrial users subject to categorical
        pretreatment standards as such standards are
        promulgated.

     o  Major source enforcement through implementation of
        the Municipal Strategy — The National Municipal
        Policy and Strategy published in FY 1979 sets forth
        priorities for reissuing expiring major municipal
        permits.  This policy directs that municipalities
        requesting time extensions for compliance with
        secondary treatment requirements (Section 301 (i)
        extensions) be given priority in permit reissuance.

        The 301 (i) compliance extension is a major
        mechanism for bringing non-complying municipalities
        into compliance with the lav; thus contributing
        significantly to the Agency's major source enforce-
        ment effort.

Research and Development

Much is known about conventional pollutant indicators such
as biological oxygen demand,  and bacterial counts.
However, our ability to assess toxic pollution problems
is hampered by the large number of toxic pollutants in
the environment, and the necessity of using highly
sophisticated  and expensive technology to monitor pollutant
levels.  Currently there is much work ongoing to resolve
these problems.  Priority activities  (not necessarily in
priority order) in 1980/81 include an integrated effort
by the Office of Research and Development and the Office
of Water and Waste Management to:

     o  complete the publication of water quality criteria
        for 65 classes of toxic pollutants, to assess
        impacts of those pollutants on aquatic species
        and human health, and to determine acceptable
        levels,

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                 -  120  -
o  select additional priority pollutants and develop
   criteria,

o  develop wet weather criteria for pollutants to
   account for nonpoint source contributions during
   high flows,

o  add carcinogens and chronically toxic pollutants
   to the hazardous substance list,

o  develop recreational water quality criteria,

o  expand selected water quality predictive models to
   include toxics and sediments in assessing transport
   and fate of pollutants,

o  develop rapid screening tests for characterization.
   of toxic pollutants in complex effluent,

o  assess effects of specific pollutants, pollutant
   transformation products  and combinations of
   pollutants on marine biota,

o  develop simulation techniques, including microcosms,
   to predict pollutant stress on marine biota and
   ecosystems,

o  develop a simple implementable technique for
   assessing wetlands transition zones, and
   characterization of productivity of wetlands, as
   a tool for assessing the quality of wetlands,

o  improve solid phase bioassay techniques to test
   toxicity of dredged and fill material,

o  develop broader spectrum and more cost-effective
   methods for screening and quantifying organics in
   water and wastewater with increased emphasis in
   FY 81 on nonvolatile organics,

o  develop more cost effective multi-element and
   chemical specification methods, with emphasis
   in FY 81 on solids,

o  perform multi-media toxic and hazardous material
   problem assessments in local areas in response to
   public health concerns,  in absence of State or
   local capabilities,

o  continue study of toxic materials in publicly
   owned treatment works in order to develop compre-
   hensive urban toxic pollutant control strategies,

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                - 121 -

o  continue development of methodologies to assess
   impact of nonpoint source pollution, and perform
   nonpoint source assessments,

o  integrate Agency monitoring efforts for priority
   pollutants, including establishing a single
   data base system and approved quality assurance,

o  develop, evaluate, and report on a practical lake
   (quality) evaluation index  (LEI) procedure to
   assist lake managers in interpreting lake problems
   and selecting corrective actions,

o  assist Regions and States to develop toxic pollutant
   monitoring capabilities to support State/EPA
   Agreements, toxic wasteload allocations, water
   quality standards, permit setting, and permit
   compliance monitoring,

o  continue exploratory research to identify potential
   pollutant problems in the future and to develop
   potential controls for pollution problems; to
   develop technologies that minimize pollution
   production.

o  sludge:  evaluate innovative and alternative
   technology projects; improve data on exposures of
   organics, metals, and pathogens from land appli-
   cation; develop beneficial uses, including energy
   recovery technologies, evaluate detoxification
   methods,

o  small flows/land treatment: demonstrate central
   management of onsite systems; extend overland
   flow systems to colder climates; evaluate toxics
   management in land application systems; investigate
   higher rate nutrient update systems,

o  investigate process development for treatment
   systems for small communities and combined sewer
   overflow management and technology; evaluate
   conservation/reuse demonstrations and high rate
   biological removal of specific pollutants; and
   develop surrogate control parameters,

o  initiate a major program for development and
   demonstration of reuse/recycle technologies and
   to reduce intermedia impacts of wastewater
   treatment.

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                     - 122 -
HEADQUARTERS PLANS

Construction Grants;  Municipal Operations

     Plans and Priorities, FY 80 and 81

     The Construction Grants Program in FY 1980 and FY 1981
     will put principal emphasis on program implementation
     and management;  few  (if any) new legislative changes
     are anticipated.  Although the overall goal of the
     program remains  intact, the new thrusts arising from
     the Clean Water  Act of 1977 will significantly alter
     EPA's management strategy.  The highest management
     priority effort  in the near term is to shift the
     program toward decentralized management, with State
     delegation and use of Corps of Engineers resources
     receiving maximum emphasis.  Effective management in
     this decentralized environment will require increased
     use of the Regional Construction Grants Management
     Information System (RCGMIS) at the EPA level and
     development of improved, program management systems,
     all with delegation.

     The principal Headquarters emphasis in FY 1930 and
     FY 1981 will be  to implement on a national basis the
     overall program  management strategy.  The emergence
     of major Corps and State delegation of activities has
     accentuated the  need for support structures that will
     both enhance the benefits of decentralized management
     and facilitate control and coordination across the
     various management levels.  The highest Headquarters
     priority will be to make the overall program management
     strategy work; the principal methods will be through
     policy and guidance,  technical assistance to States
     and use by the Regions and States.  For the first
     time, the Construction Grants Program Guidance includes
     municipal operations and maintenance activities.  The
     major activities related directly to Construction
     Grants policy are:

        o  Establish policy and implement guidance in
           support of the program shift into decentralized
           management, including delegation to States
           and the Corps,  and definition of the EPA role
           and responsibilities in a decentralized situation.

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                  - 123 -
o  Provide guidance on and evaluate (on a national
   basis) the five-year State priority list,
   including guidance on priority systems, long-
   term planning and uses, and management of the
   priority list.

o  Coordinate with the Enforcement Division in
   the management of the National effort under
   Section 301 (h), to review and take action on
   applications from municipalities regarding permit
   modification requests for ocean dischargers.

o  Provide guidance on and evaluate (on a nation-
   wide basis) the Step 1 facility planning stage,
   including implementation of new amendments
   regarding innovative and alternative (I&A)
   technology, small systems, cost-effectiveness,
   changed eligibilities, multi-purpose projects, etc.

o  Provide innovative and alternative technology
   assistance and support thru Cincinnati and Ada
   offices.

o  Review and coordinate the Advanced Waste Treat-
   ment  (AWT) and Advanced Secondary Treatment  (AST)
   decisions in accordance with PRM #79-7, for
   direct review by the Administrator.  The develop-
   ment of Guidance for and review of AWT and AST
   Regional level decisions.

o  Coordinate (on a nationwide basis)  the manage-
   ment of construction outlays and the meeting
   of national estimates.

o  Coordinate and evaluate Regional Office and
   State implementation of program guidance
   (being developed by MOB) on operational
   requirements.

o  Coordinate national public participation
   policy in the Grants programs.

o  Coordinate national Minority Business Enterprise
   (MBE) policy in conjunction with the Office of
   Civil Rights for the Grants program.

o  Continue support to implementation of the
   President's Urban Initiative to discourage
   sprawl.

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                - 124 -

   o  Develop guidance on multiple purpose pro-
      jects and funding strategies.

   o  Direct, in conjunction with the Enforcement
      Division, the National Municipal Strategy.

   o  Provide close support and technical assistance
      to the Regions in problems related to design
      and construction of treatment facilities.

   o  Coordinate a comprehensive program management
      strategy which encompasses the management of
      priority lists,  applications,  awards, precon-
      struction lags,  completions, outlays, etc.

   o  Promote (encourage) rural development
      iniatives, including use of alternative systems.

   o  Prepare a long-term funding strategy and
      legislative program.

   o  Initiate 1980 State Facilities Needs Survey.

The major Headquarters activities related to Environ-
mental Impact Statement  (EIS) Policy for Construction
Grants* are:

   o  Revise 40 CFR Part 6 in accordance with new
      Council on Environmental Quality regulations
      and new Construction Grants regulations.

   o  Revise the Manual for Preparation of EIS's for
      201 Construction Grants Projects in accordance
      with new CEQ regulations and new construction
      grants regulations.

The major Headquarters activities related to municipal
operations and maintenance are:

   o  Follow up with Regions on implementation of
      newly-issued PRMs on:  (1) operational reviews
      of facility plans and plans and specifications;
       (2) plan of operation implementation; and
       (3) required use of operations checklists.
      Also,  follow up with Regions previously  issued
      PRMs on start-up services subagreements  (#77-2)
      and plans of operation  (#77-3).
   See Guidance on Non-Regulatory' NEPA Compliance in
   the Interdisciplinary Media for detailed EIS
   Guidance

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                     - 125 -


        o  Modify the EPA/Corps of Engineers agreement
           to provide for use of Corps personnel for:
           (1) operational review of plans and
           specifications; and (2) flagging plan of
           operation compliance schedule violations.

        o  Provide informal guidance on: (1) correction of
           design errors during Step 3 and  (2) coordination
           of outside start-up service related activities.

        o  Refine the operations checklist package.

        o  Evaluate O&M inspection feedback on new,
           Federally funded POTWs.

        o  Monitor existing POTW performance levels and
           problems nationally.

        o  Coordinate with Enforcement, et. al. on POTW
           operations related issues.

        o  Cooperate with the National Training and
           Operational Technology Center (NTOTC) on
           establishment of an EPA "hotline" for referring
           municipalities with O&M problems to sources
           with applicable and documented solutions.

In addition to these specific activities, Headquarters
will become more actively involved in review and evaluation
of program performance, through  (a) review and analysis
of performance indicators, (b) specific project reviews
(e.g., facility planning quality reviews),  (c) construction
management evaluation inspections, and  (d) close oversight
and assistance in areas of greatest need.  In FY 1980,
particularly, this Headquarters "audit" function will
stress overview of the State delegation and the Corps
agreement.

Spill Prevention and Response

In the Spill Prevention and Response Program, management
efforts in FY 1980 and FY 1981 will be directed to:

         o  Provide program and policy guidance to
            implement and support the National Spill
            Prevention and Control Program at the
            Regional and State levels, including imple-
            mention of the recommendations of the EPA
            Task Force on Environmental Emergencies.

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                      -  126  -

        p  Develop regulations and implementation
           guidelines for Regional operation of a                A
           Hazardous Substances Spill Prevention                 "
           and Response  Program.

        o  Continue development of an Environmental
           Response Team (ERT) capable of independent
           on-scene response,  individually or as a
           team, to augment the Regional response
           capabilities.  (The ERT will be fully
           operational by late 1979).

        o  Provide a contract-supported Technical
           Assistance Team (TAT)  for each Region
           and for the ERT, to be managed, tasked,
           and utilized  at the field level to augment
           resources in  the Spill Prevention and Control
           Program.

        o  Prepare guidelines  for Regional contingency
           plan revision.

        o  Revise dispersant acceptance program and
           develop new dispersant test standards.

        o  Provide the mechanism for aerial photomapping
           of significant oil  and hazardous substance
           spills and for aerial surveillance in support
           of oil pollution prevention compliance monitor-
           ing .

        o  Provide guidance and establish program priorities
           for technical assistance and support during
           disasters declared  by the Federal Emergency
           Management Administration  (FEMA).

        o  Provide a coordinating mechanism for training
           the ERT, Regional,  State and local personnel
           in hazardous  substances response.

        o  Plan and provide for multi-Regional meetings to
           review program accomplishments, program and
           policy guidance, and future program directions.

Ocean Disposal and Permits

In the Ocean Disposal and Permits Program, management
in FY 1980 and FY 1981 will:

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                - 127 -
   o  Prepare annual reports for Congress and the
      Intergovernmental Maritime Consultative
      Organization (IMCO)  Ocean Dumping Convention.

   o  Prepare position papers and technical docu-
      ments to support the Ocean Dumping Convention
      (ODC) .

   o  Continue an environmental impact statement
      (EIS) contract to re-analyze available data
      on dumpsites and perform additional
      baseline surveys to result in the designation
      06 two municipal/industrial dumpsites.

   o  Revise Ocean Dumping Regulations based on new
      statutory requirements, changing program needs,
      and operational experience.

   o  Revise the Implementation and Procedures
      Manual on dredge/nondredged materials; review
      the bioassay manuals based on operational and
      research experience in ocean dumping.

   o  Develop environmental guidelines for one major
      offshore activity.

   o  Organize interagency monitoring of the Flower
      Garden Banks in the Gulf of Mexico.

   o  Review 10 EIS's, 10 development plans, and 25
      regulations for outer continental shelf lease
      sales;  review 3 EIS's for other offshore
      activities.

Water Quality Training

Because of the resource  constraints, EPA cannot
actively help States and municipalities document and
resolve workforce development and training program
development problems related to POTW noncompliance
issues,  not can it substantially address the limited
capabilities of States to assume delegated Section 205
or other Water Quality Program responsibilities.
Technical and training support resources for States
and municipalities to solve workforce development and
training problems must be developed by the private
sector,  State agencies, municipalities, and educational
and training institutions.

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                - 128 -
However, the National Training and Operational
Technology Center (NTOTC)  in Cincinnati, Ohio, will
provide limited resources  and expertise to support
development of State and local training programs.
Instructor training, courses, instructional materials,
and complete course packages on various water quality
subjects will be provided, with special emphasis
given to Section 205 program delegations and operator
training.  An expanded Instructional Resources Center
program will provide services to State and local
training programs and educational and training
institutions.

In the short term, NTOTC will also provide a limited
schedule of specialized training courses for EPA,
State, and local agency personnel.  Ultimately, the
delivery system for these  courses must be provided
through existing State, local and private sector
capabilities; also, through the establishment of a
number of Area Training Centers.  The establishment
of Area Traning Centers will serve as an effective
extension of EPA's capabilities for training EPA and
State personnel.

NTOTC activities will include:

   o  Informal guidance (via a national meeting)
      by July 1979 for the delivery of training
      courses to Section 205 State Agency staff
      and POTW personnel.

   o  Development, demonstration and initial
      delivery of Section 205 training courses and
      packages  (including the training of instructors
      for conducting these courses).

   o  Increased emphasis on training of State,
      local, educational system and private sector
      instructors.

   o  Guidance and grant funds for Section 104(g)l
      and Section 109 (b) State training program
      efforts.

   o  Development of instructional materials,
      including AV units,  individual modules, and
      complete course packages, for use in State
      and local training programs.

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          - 129 -
Specialized direct technical training for
EPA, State, and local agency personnel.   A
course schedule for FY 80 will be prepared by
June 30, 1979.  It is intended that increased
State, local and private sector training
capabilities, plus the establishment of Area
Training Centers, will minimize the need for
NTOTC direct training activities.

Consultative assistance for selected municipalities
in identification, correction, prevention
and documentation of those POTW performance
problems which are significant causes of the
national noncorapliance problem.

Support of programs which will lead to the
development and documentation of new, improved,
or expanded operational technology, and related
courses, materials, and guidance.

Maintenance on the Instructional Resources
Center, including the Instructional Materials
Lending Library, the Instructional Resources
Information System (IRIS) and distribution of
the IRC Bulletin.

Development of methodology for evaluating the
effectiveness of State and local training
programs and NTOTC support needs.

Development, demonstration and provision of
courses and packages on request of OWWM
programs.

Design of technical assistance packages to
support the Public Service Employment (CETA)
program objectives of the President's Urban
Policy  (new-entry O&M training and occupational
standards).  Support of the President's Urban
and Rural Initiatives by continuing or develop-
ing interagency agreements with DOL, HEW, DOI
and other agencies to provide Drinking Water
and Water Quality job opportunities and training.

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                     - 130 -


Water Quality Management

     Plans and Priorities,  FY 80

     The Water Quality Management and Standards Program
     activity will emphasize an integrated Federal,  State
     and local partnership to address water problems
     primarily through management controls, planning and
     local regulation.

     The fundamental goal and purpose of the Water Quality
     Management Program is the development of a State and
     local government decision-making process to control
     point and nonpoint sources of pollution to meet
     fishable and swimmable water quality goals.  To meet
     this goal in FY 1980,  the following will be done:

        o  Implement the State/EPA Agreement process by
           preparing guidance and other information
           documents, working with other program offices
           involved, establishing an information exchange/
           assistance mechanism for the States and Regions,
           tracking progress of Agreement development and
           maintaining periodic status reports, and reviewing
           other EPA and non-EPA program documents to assess
           their applicability.

        o  Develop policy guidance and strategies for the
           national WQM program, coordinate development oE
           short-term policy positions, and systematize
           the policy-development process for long-term
           WQM policy.

        o  Update the National Water Quality Management
           Needs Assessment which covers control of point
           and nonpoint sources of pollution.

        o  Conduct biannual evaluations of Regional Office
           management of the WQM program,  placing emphasis
           on leadership and long-term strategies as
           opposed to reactive management; develop management
           strategies with examples of management techniques.

        o  Manage/provide a program of effective, timely
           training and technical assistance to appropriate
           Federal, State,  and local personnel concerning
           financial planning and techniques to overcome
           funding barriers to implementation of approved
           plans.

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               -  131  -

o  Provide technical assistance in the areas
   of ground water management, urban storm runoff
   control, and advanced waste treatment (AWT)
   decisions; in the area of AWT decisions, pro-
   vide assistance in WQM agencies, especially
   on water quality standards and wasteload
   allocation issues required to make specific
   AWT decisions.

o  Work with Regional Offices to complete the
   current triennial review of Water Quality
   Standards (WQS).

o  Monitor and evaluate implementation of the
   cost effectiveness guidelines.

o  State Water Quality Standards do not generally
   contain criteria for toxic substances.  EPA is
   considering revising the Federal standards and
   regulations so that States may be required to
   adopt numerical criteria for a minimum list of
   toxic substances.   Even where State standards
   do contain criteria for toxics, NPDES permits
   frequently are not written to meet such critiera.
   OWPS is attempting to remedy this through
   technical assistance on:   (1) wasteload
   allocation procedures; and (2) methods of
   implementing bioassay criteria in water quality
   standards.

o  Review criteria in Quality Criteria for Water
   to determine which toxic constituents are
   technically defensible for promulgation as
   standards, ar>^ necessary to protect 1983
   goal uses.  However, EPA is still considering
   the question of the necessity of promulgating
   such standards.

o  Review criteria for the 65 toxics to determine
   which, if any, should be required for inclusion
   into standards.

o  Prepare or clarify guidance on a number of WQS
   issues such as:  justification for stream down-
   gradings, application of WQS to intermittent
   streams, inclusion of toxic criteria in WQS,
   designation of outstanding natural resource
   waters and other issues currently included in
   Chapter 5 of Guidelines for State and Areawide
   Water Quality Management Program Development.

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   o  Initiate projects to resolve interstate and
      interregional inconsistencies in WQS applicable
      to interstate boundary waters.

   o  Develop guidance for use of WQS in controlling
      nonpoint sources of pollution.

   o  Increase WQS integration with other EPA programs
      such as Water Quality Management,  NPDES Permits,
      Construction Grants, and TMDL assessments..

   o  Develop Headquarters policy guidance to Regions
      and States on the third round of WQS revisions.

   o  Encourage and assist public participation on
      the WQM program by promoting Regional Office
      capability;  training WQM grantees, advisory
      committees,  and citizens in public involvement;
      supporting State and local involvement; and
      coordinating public participation activities
      with other programs,

   o  With the Regions, improve the basic policy  and
      guidance for AWT planning by WQM agencies and
      establish better State processes for incorporating
      Water Quality Standards, wasteload allocations,
      effluent discharge requirements, and service
      area and capabity requirements into decisions
      on AWT facilities.   Apply improved policy to
      specific prototype situations requiring AWT
      decisions.

106 Grants

Headquarters will work with the Regions, States,
interstate agencies, and other EPA offices to agree
on modifications to the present 106 allocation formula.
Based on the WQM National Needs Assessment, a work
group will work out details of a policy for determing
levels and uses of 106 funding, including considerations
of equity and defensibility.  The objective of the
work group is to work out policy details for FY 81
allocations.

208 Grants

The key elements for the management of 208 grants to
State and areawide agencies are:   (1) implementation
of problem solutions identified in certified and
approved WQM plans and. (2)  further identification of
pollution sources, water quality relationships, and
cost-effective controls.  During FY 30, the following
will be done:

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            - 133 -
Develop guidance on Regional agricultural
strategies, provide guidance and assistance
to individual agricultural MIPs (Model Imple-
mentation Projects), coordinate with other
agencies working in agriculture, develop
guidance on the operation of the Rural Clean
Water Program 208 (j), participate on the
National Rural Clean Water Coordinating
Committee, and manage joint research studies
on agriculture pollution controls with ORD,
USDA, and USDI.

Manage and coordinate EPA's efforts to assess
urban storm runoff problems and potential
controls; with the regions, complete selection
of 15-20 prototype projects and develop
workplans; provide technical and management
assistance to the selected agencies; make a
preliminary assessment of the data, and report
to Congress on progress.

Develop joint OWPO/OWPS policies for obligation
of the $21 million in Section 201 funds earmarked
for AWT review and planning in FY 80.

Work with the Regions, States, and areawide
agencies to develop and implement controls on
construction runoff and pollution from septic
systems, with particular emphasis on fiscal
and financial aspects of controls.

With other EPA Headquarters offices, and with
the help of a contractor, manage 4-5 major
studies in selected demonstration areas on ground-
water aquifer designation and protection; work
with a consulting team to manage a hands-on
implementation assistance effort.

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                  -  134  -
   o  Provide guidance to Regions,  States,  areawide
      agencies and others on methods for incorporating
      water conservation into problem solutions for
      agricultural runoff, municipal facilities,
      urban runoff, construction runoff, and other
      areas.

Clean Lakes Grants

Implement completely the new structure of Clean Lakes
Program as provided under 40 CFR 35.1600.

   o  Work closely with the Regional Offices to help
      them understand the specific  requirements of
      the new regulatory procedures for the Clean
      Lakes Program and to improve  the operating
      effectiveness of the program to acheive its
      mandated objectives.  This will be accomplished
      through:

             Development and distribution of additional
             policy and program guidance under
             established program information transfer
             procedures (Clean Lakes Assistance
             Memoranda) .

             Schedule and conduct workplans for State
             and Regional personnel to discuss and
             exchange opinions on the new regulatory
             requirements and policy and guidance
             and to seek ways to further improve
             these procedures.

          -  Meet with the Regional program personnel,
             as requested, to help resolve project
             specific problems.

             Develop and make available a grants
             assistance manual and other instructional
             materials to be used by grant applicants,
             grantee project managers and Regional
             program coordinators.

   o  Continue to develop optimum program integration
      between the Clean Lakes program and other EPA
      and other agency programs.  Such activities
      would define ways to include these other pro-
      grams in Clean Lakes projects during the

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            -  135 -
project proposal stage when such integration
is most easily accomplished.  Such program
cooperation can lead to reduced program costs
of all programs involved, while improving
the benefits and outputs derived from each program
and support of Agency Urban initiatives.
Emphasis will be placed on EPA's National
Urban Runoff program, the Model Implementation
Program, the development and implementation of
alternative methods to treat domestic wastes
and the Office of Research and Development
demonstration program for nonpoint source
pollution control, including storm water
treatment.  Other agency programs include
those of the Departments of Agriculture, Housing
and Urban Development, and Interior.

Review all Clean Lake grant applications and
provide the Pvegions with timely grant funding
recommendations.

Continue to review the efficacy of the Clean
Lakes Program to control water pollution,
particularly nonpoint sources, to enhance
lake quality in a cost-beneficial manner.

Compile a yearly summary of the overall program
status on a project basis.

Work with the Office of Research and Development
to encourage the continued development of new
procedures, to improve existing procedures,
for lake quality enhancement.

Continue to review the adverse environmental
impacts associated with lake restoration and
define the mitigative measures available to
reduce these impacts.

Prepare and publish every two years the required
Section 307 (j)  report presenting the state-of-
the-art knowledge on methods and procedures
avaialble for lake restoration.

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                  -  136  -


Changes—FY 1980

   o  Increased importance of State/EPA Agreements.

   o  Increased emphasis on national WQM priorities
      — urban storm runoff, AWT planning and review
      (especially regarding water quality standards,
      wasteload allocations, stream classification,
      and effluent requirements), agricultural
      runoff,  construction runoff,  ground water
      management, and septic system management.

   106 Grants

   o  106 grants will be allocated to the Regions
      using the existing formula (including general
      State allotments as target amounts).  The
      exact amounts of grants from the allotments to
      the States, however, will be based on demon-
      strated  needs determined in the negotiations
      in the State/EPA Agreement process.

   o  With the advent of increasing numbers of 205(g)
      delegations to States, some 106 funds will be
      freed up for nonconstruction purposes such as
      implementation of nonpoint source controls,
      504 emergency response requirements, and
      hazardous and toxics monitoring.

   208 Grants

   o  An increased percentage of 203 funds will go
      into the conduct of workshops and conferences
      and wider participation in activities providing
      opportunity for making presentations.

   o  EPA will support States in 404 program develop-
      ment and approval, including providing them
      with model statutes and regulations; assisting
      them in  developing procedures and staff; con-
      ducting  training workshops; and coordinating the
      review and approval process (working with
      Regions) and nonpoint source control planning
      and demonstrations.

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                      - 137 -

        o  WQM agencies  will continue to do "up-front"
           work related  to facility planning in areas
           where AWT decisions  are being made.   They will
           concentrate on  water quality standards issues,
           wasteload allocations,  and size and location
           of treatment  works.

        o  EPA will develop a water quality-based strategy,
           illustrating  the role of WQS.

        o  EPA will issue  revised WQS regulations (40 CFR
           130.17).

        o  EPA will call for increased consideration and
           inclusion of  toxic criteria in WQS.

        o  Headquarters  will reassume some minimum degree
           of participation in  the approval/disapproval
           of State Water  Quality Standards.

        o  Headquarters  will assume a direct role in
           projects designed to eliminate inconsistencies
           in standards  applicable to interstate waters.
           In the Water  Quality Monitoring Program,  most
           main changes  are in  emphasis rather than in
           major program redirection.  However, EPA's
           Blue Ribbon Monitoring Panel is addressing several
           issues which  may impact this guidance.  Any
           guidance or policy determinations generated
           by this group will be factored into this Guidance
           as it becomes available.

     Alternatives

        o  A number of alternatives affecting the role
           of the WQS program will be described and
           debated during the effort to revise existing
           40 CFR 130.17 regulations and in the development
           of a water quality-based strategy.

Water Quality Management

     Plans and Priorities — FY 81

        o  Establish a more aggressive, rather than
           reactive, management stance for the WQM pro-
           gram with more emphasis on national priority
           problems identified in the nationwide needs
           assessment.

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                  - 138 -
   o  Pay more attention to Regional Office manage-
      ment of the WQM program, particularly with
      respect to Regional organization and coordination/
      integration mechanisms; make recommendations
      as appropriate.

   106 Grants

   o  With the States and Regions, evaluate the
      State strategy/needs assessment method of
      allocating 106 funds.  Since this attempt
      to improve the management of 106 funds involves
      many complex issues, anticipate adjustments
      in 106 funding policies for FY 82.

   o  Concentrate on establishing improved monitoring
      practices, including improved intensive surveys
      and refined, fixed-station networks; establish
      improved problem assessment methodologies for
      better utilization of resources.

   208 Grants

   o  Prepare a preliminary report for Congress on
      urban storm runoff problems, effects, and
      controls.

   o  Manage hands-on technical assistance projects
      in selected areas studying groundwater aquifer
      designation and. protection, with the Offices
      of Solid Waste and Drinking Water.

   o  Prepare a national summary report on results of
      Model Implementation Projects for agricultural
      pollution control.

   o  Assist the Regions and States in developing
      Statewide Dredge and Fill regulatory programs
      under Section 208(b) (4) (B).

Changes — FY 81

As mentioned above, Headquarters will assume a more
positive role in program management,  with an emphasis
on leadership and development of long-term management
strategies as opposed to reactive management.   Head-
quarters will hold each Regional Administrator account-
able for accomplishment of the outputs agreed to in
the State/EPA Agreements,  and will conduct biannual
evaluations of Regional performance on management of
106 and 208 grants.

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                      - 139 -
        106 Grants

        o  For FY 81, 106 grants will be awarded to State
           and interstate agencies based on their needs,
           taking into account the nationwide WQM Needs
           Assessment which the Water Planning Division
           will manage during FY 79 and 80.  Headquarters,
           the Regions, the States, and the interstate
           agencies will continue to meet to work out
           details of 106 funding policies.

        208 Grants

        o  No major changes expected from FY 80.

Effluent Standards and Guidelines

     Plans and Priorities, FY 80

     The Effluent Guidelines Division (EGD) is a Head-
     quarters function without direct counterpart Regional
     organizations.  However, the Division's programs
     directly affect many areas of program implementation
     in the Regions and States as well as Headquarters.

     By virtue of the expanded mandate of the 1977 Clean
     Water Act (in toxic pollutant control, conventional
     pollutant control technology, sludge and "spills")
     and specific requirements of the NRDC "Settlement
     Agreement," the EGD role with the Office of Water
     Enforcement and the Office of Solid Waste has
     expanded considerably.

     Within the broadly stated mission of developing
     industrial point source effluent and pretreatraent
     standards, there are six principal activity groups
     for which this Guidance is appropriate.  For each of
     these activity groups, the Division is committed to
     integration and coordination with all major affected
     programs as summarized below for FY 80.

        Toxic Pollutants Effluent Limitations.  This
        activity includes the plans and priorities for
        establishing BAT effluent limitations, New Source
        Performance Standards, and pretreatment standards
        for new and existing sources.

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             - 140 -                                        .
o  Complete sets of regulations will be promulgated
   for 24 industry categories.   The regulations
   will set forth specific numerical standards
   for toxic pollutants where possible.  Certain
   regulations which have already been designated
   will also have an Urban and Community Impact
   Analysis (EO 12074)  prepared.

o  In addition to the issuance of these final
   rules, complete sets of regulations will be
   proposed for 22 industry categoreis.

o  In cooperation with ORD, OWE and other offices,
   toxic pollutant treatability studies will be
   performed in laboratory scale in support of both
   the EGD standards setting program and the
   OWE NPDES permit function.

o  Work will continue with ORD, Regional laboratories
   and contractor services in analytical methods
   refinements, including Quality Assurance and
   Quality Control for detailed quantification of
   pollutant levels.

o  With the support of other programs in OWPS,
   work will continue in defining industry
   categories or subcategories to be excluded
   from national standards or deferred for develop-
   ment of regulations in FY 1981 due to resource
   limitations.

Conventional Pollutants and BCT Limitations.  This
activity includes plans and priorities for all work
in the area of conventional pollutants for both
primary  (e.g., covered by Settlement Agreement and
CWA)  and other industries.

o  BCT regulations will be promulgated for 24
   primary industries for conventional pollutants
   in conjunction with BAT regulations for toxic
   pollutants.

o  In the area of "secondary" industries, BCT
   regulations will be promulgated.

o  Work will continue on toxic  "indicator" relation-
   ships using conventional pollutants.

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               -  141  -
Study of Publicly Owned Treatment Works (POTW).
This activity encompasses all technical evaluations
and data acquisition actions to be conducted in
support of the Agency POTW regulatory strategy,
including pretreatment, sludge guidelines, treat-
ability and toxics "problem" assessment.  A short
term field sampling survey of 40 POTW1s will be
completed.  Extensive treatment performance and
toxic discharge data will be collected.  Similar
survey and studies by ORD will be incorporated into
this investigation, as will data and information
from 301 (h), Marine Waiver submissions.

o  Action will be taken to initiate the integration
   of these data with activities under OWE (Pre-
   treatment Program) and OSW (sludge disposal
   guidelines).

o  Regional Surveillance and Analysis compliance
   monitoring data will be requested to supplement
   other sources.

o  Regional,  ORD, and Contractor laboratories will
   be conducting analyses of samples.

o  Preliminary treatability information will be
   assembled to help define longer-term needs
   for field evaluations of secondary treatment,
   and advanced secondary treatment.

o  Assessments of "compatibility", i.e., inter-
   ference of pass-through of pollutants,  will be
   initiated for inclusion in industrial pretreat-
   ment standards where possible.

o  Intensive  (4 to 6 weeks) studies of several
   selected cities will be initiated to define
   treatability sampling requirements and long-
   term performance.

Sludge, Wastes and Spills.  This activity includes
engineering analysis and data acquisition on
industrial and POTW sludge characteristics, wastes,
and sludges associated with meeting effluent
limitations, and 304 (e) best management services
for leaks, spills, runoff, etc., associated with
industrial processes.

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                                                            4

o  Work will continue in developing mechanisms for
   integration of RCRA and BAT regulatory impacts.

          Support for this work will include
          collection of initial data on sludge
          generated by 33 industrial point
          sources arid by POTWs.

          A program initiated in FY 1979 with ORD
          and contractors to develop sludge analysis
          protocols is expected to be completed for
          initial "field testing" of improved
          analytical methods.

o  Data collection efforts to support the develop-
   ment of supplemental BMP regulations for the
   control of leaks and spills, raw material
   storage runoff, and sludge disposal will
   continue in coordination with the Offices of
   Water Enforcement and Solid Waste.

Litigation.  This activity includes preparing
briefs and court records to respond to anticipated
lawsuits filed against the BAT regulations.  The
Division is fairly certain of litigation in most
industry categories.

o  Respond to anticipated lawsuits for promulgated
   BAT regulations.

o  The timing of these court challenges is unpre-
   dictable,  but they usually take longer than
   anticipated due to the highly complex legal
   and technical questions which arise.  Thus,
   decisions on these regulations will probably
   not be forthcoming until FY 1981.

Technical Support and Assistance.  This activity
includes providing consultation and technical
support to permitting authorities for non-con-
ventional waivers, and implementation of the
standards in the National Pollutant Discharge
Elimination System (NPDES)  integrated permits.

o  EGD intends to provide the principal technical
   support to Regional and State permitting
   authorities as to how to interpret and apply
   regulations in situations where pollutants
   have been excluded from regulations.

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                 - 143 -
             This technical assistance will also
             involve application of the "indicator"
             concept as well as advice on subcategories
             or facilities excluded from national
             standards or implication involving BAT
             regulation of nonconventional pollutants.

Plans and Priorities - FY 81

   Toxic Pollutant Effluent Limitations

   o  Nine sets of industry category regulations will
      be promulgated.

   o  Treatability studies will be focused on a larger
      scale (e.g., pilot studies) for actual industrial
      waste streams.  Emphasis will be placed on
      pollutants not readily removed or treated by
      traditional methods.

   o  An expected 6 categories covering about 380
      subcategories deferred from FY 1980 will be
      investigated for developing necessary effluent
      standards.

   o  It is anticipated that additional specific toxic
      compounds will be identified for which further
      sampling, analysis and technology performance
      review will have to be conducted.  Related
      closely to this work will be increased emphasis
      on investigations of "innovative" technologies
      to minimize the overall discharge of all toxics
      (whether identified or not) into the environ-
      ment, especially concepts which reduce costs of
      pollution control or result in improved pro-
      duction system efficiency by recycle and reuse
      of by-products and wastes.

   o  It is estimated that 10 categories representing
      over 300 subcategories will be emphasized in
      "innovative" technology review due to potential
      economic impacts of BAT requirements.

   Conventional Pollutants and BCT Limitations

   o  Promulgate BCT regulations for 9 primary industry
      categories with supporting documents as described
      above, as well as propose amendments or issue
      "guidance" revising or confirming BCT limitations
      for several food commodity industries  (e.g.,
      dairy products, fruits and vegetables, etc.)
      in accordance with review of Sections 301 and
      306 of the CWA.

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               -  144  -
o  Statistical and technical means to define
   quantifiable "surrogate" relationships will be
   defined for pollutant parameters common to
   several (or all) industry categories.  These
   surrogates will represent specific levels of
   conventional pollutants with associated
   specific levels of one or more toxic pollutants.

Study of Publicly Owned Treatment Works (POTWs)

o  Anticipate formulation of recommendations for
   a specific POTW regulatory strategy, including
   support for mechanisms for pretreatment credits
   at the local level, inputs to OWPO and OWE
   program efforts, and possible "guidance" to
   Regions and States on POTW toxics problems.

Sludge,  Wastes and Spills

Supplemental BMP regulations will be proposed for
several  industries where these controls are appropriate,

o  Sampling and analysis of "spills" and waste
   streams will be incorporated  into these to help
   define the potential for toxic discharges into
   surface waters  as well as potential  mechanisms
   for  treatment or control by traditional or
   innovative management schemes.

Litigation

o  Respond to anticipated  lawsuits  for  promulgated
   BAT  regulations.

o  Demands for  substantial  additional  data
   collection on  toxic  levels  in effluents,
   technology performance,  and environmental
   impact are expected  for  all industries
   challenged in  FY  1980,

o  If there  are substantial successful challenges
   to the earlier regulations, many others  scheduled
   for  promulgation  in  FY  1981 may  be  delayed
   pending  additional work to  strengthen these
   later rulemaking  efforts.
                                                              4

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                       -  145  -
       Technical Support and Assistance

       Because of the uncertainty in timing, but antici-
       pated intense court activity on these regulations,
       technical assistance will be made available as
       necessary to advise on "best engineering judgment".
       Section 402(a) permits, many of which may have to
       be issued while litigation/remands are in progress.
       In addition to the "indicator" concept, problem
       areas are expected to be in technology transfer,
       technology performance, and innovative technology.

Dredge and Fill

     Plans and Priorities, FY 80

     The Dredge and Fill Program focuses on a specific
     water pollution problem and is especially concerned
     with the impact and control of this source of
     pollution as it affects the nation's wetlands.   This
     program is of high priority within the Office of
     Water and Waste Management and plans for FY 80  and
     particularly FY 81 represent intensified activities
     within this area.  The following plans and priorities
     will be addressed in FY 1980:

        o  Complete and issue basic 404 regulations
           (State permit programs) and issue necessary
           policy guidance supplements where special
           interpretations or implementing instructions
           are needed.

        o  Provide guidance to the Regions and States on
           development and operation of Statewide Dredge
           and Fill regulation programs under Section
           208(b) (4) (B).

        o  Improve support of Regional operations through
           improving technical and administrative training,
           operating procedures, information and data
           systems (e.g., establish a computer-based
           permit system), providing assistance on major/
           controversial cases,  etc.

        o  Assess 404 program research needs and initiate
           programs to accomplish that research through
           ORD and other organizations.

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                      - 146 -
        o  Initiate efforts in public information,  education,
           and participation through development and dis-
           semination of information, general education,
           and training materials.

     Plans and Priorities - FY 31

     In the Dredge and Fill Program, the following  plans
     and priorities will apply for  FY 1981:

        o  Accelerate emphasis in solving remaining
           problems with regard to  program management
           and operations and threats to aquatic eco-
           systems through research, information and
           education, monitoring and evaluation,
           assistance to Regions, etc.

        o  Participate actively in  providing assistance
           to States (as above) and in coordinating and
           assisting with State program review/approval.

     Changes - FY 81

     The only major change for the  Dredge and Fill  Program
     will be moving from a rulemaking to a program
     management emphasis in FY 81.

Monitoring and Data Support

     Plans and Priorities - FY 80

     In the Water Quality Monitoring Program, emphasis on
     toxic pollutants will continue as top priority, with
     a major thrust on developing national standards under
     Section 307(a) for selected priority pollutants,
     identification of additional local "hot spots" for
     regulatory emphasis, and intensive work to upgrade
     control options in geographic areas where technology-
     based controls will not be adequate to meet water
     priority goals.  Planned monitoring activities
     include continuation of FY 80 programs, plus:

        o  Upgrading of water quality based controls for
           conventional and toxic pollutants, including
           water quality criteria and standards to
           supplement technology-based controls.

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                       -  147  -
        o  Integration of multi-media,  multi-source toxic
           pollutant monitoring data systems,  and quality
           assurance programs.

        o  Provision of environmental information for
           developing Section 307(a)  standards for
           selected priority pollutants.

        o  Improvement of EPA capabilities to make assess-
           ments of public health and critical environ-
           mental concerns in the absence of local or
           State capabilities.

        o  Operation of data systems and improvement of
           access.

        o  Continuation of interagency agreements for
           toxics and conventional monitoring with the
           Fish and VJildlife Service and the Geological
           Survey.

        o  Guidance of mandatory quality assurance/quality
           control program for EPA, State, contractor, and
           permittee laboratories.

        o  Guidance of implementation of biological monitor-
           ing and data interpretation programs.

        o  Initiation of representative "before and after"
           water quality impacts of BAT.

WATER QUALITY ENFORCEMENT

     Plan and Priorities - FY 80

     The highest priority for the Enforcement Program
     during FY 1980 will be response to emergency situations
     involving substantial threats to public health and
     safety.

        o  Headquarters will provide technical and legal
           assistance in the event of an emergency
           situation.

     The program's next priority is to complete by the end
     of FY 1980 the major source enforcement effort against
     violators of the July 1, 1977, deadline, including
     municipalities.  While other than Major Source Enforce-
     ment Effort enforcement actions will continue, MSEE
     referrals will receive primary emphasis, pending
     resolution.

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                  - 148 -
   o  Headquarters will provide legal and
      technical assistance to the Regions to
      complete all cases pending with the
      U.S. Attorney and the Department of Justice.

   o  Track and expedite processing of all actions
      with the U.S. Attorney and the Department of
      Justice to their ultimate disposition.

Full compliance by all Federal facilities, major
and most minor, will be achieved no later than the
end of FY 1980.

   o  Headquarters will provide the technical and legal
      assistance required to achieve this goal,
      taking an active role, as needed, in negotiation
      of consent agreements.

   o  Track and monitor compliance status for all
      Federal facilities in delegated and non-
      delegated States.

As the MSEE effort draws near completion in FY 1980,
Headquarters will reevaluate its existing compliance
monitoring and enforcement program and plan for an
improved program designed to assure compliance from
municipal and non-municipal permittees.

   o  Review and evaluate the Compliance Monitoring
      and Inspection Program, including:

          -  CEIs

          -  CSIs;  CSIs   (Toxics)

             biomonitoring

             performance audits

             DMR quality assurance

   o  Review Regional programs for State overview
      procedures.

   o  Expand management information system  capabilities,

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                  -  149  -
      -  During the last quarter of FY 1980,
         Headquarters will become involved in
         the overview of EMS implementation in the
         NPDES States through review and evaluation
         of the audit procedures implemented by
         the Regions.  The Headquarters Compliance
         Branch will carry out this overview through
         the Regional Liaison Program and through
         special audits of the EMS.

         Continue work on developing automatic DMR
         processing capabilities.  Begin loading permit
         limitation data.  The loading of the DMR
         parametric data will follow, upon completion
         of the loading of the permit data.  The auto-
         matic violation detection capability of
         Compliance Assurance System will be
         operational in FY 1931

   o  Review and evaluate the Federal, Regional,
      and State ADP information systems.

   o  Develop a strategy for use of contractors in
      compliance monitoring activities.

   o  Examine reallocation of Headquarters and
      Regional resources (shift from MSEE to
      continuous compliance activities).

Develop and expand activities in the areas of toxic
and hazardous substances control.

   o  Develop and implement a pretreatment compliance/
      enforcement program before the end of FY 1980.

   o  Before the end of the FY 1980, begin an
      overview for implementing procedures to track
      and assure compliance with pretreatment
      requirements.

   o  Provide legal and technical support, as needed,
      for any enforcement actions involving hazardous
      materials spills.

   o  Overview monitoring and enforcement efforts for
      compliance with second-round permit requirements.

   o  Provide legal and technical support for enforce-
      ment actions involving second-round permits.

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                - 150 -
Overview phased implementation of the Municipal
Strategy, which is designed to achieve coordination
between program offices within the Agency for the
purpose of bringing municipalities into compliance
with the requirements of the Clean Water Act in the
most efficient and effective manner.

   o  Complete the PCS/GICS interface.

   o  Audit the Regions to promote maintenance of
      Enforcement/Grants interface.

   o  Track compliance by municipal facilities.

Improve program management methods by:

   o  Reviewing Quarterly Noncompliance Reports.

   o  Coordinate in developing a strategy to resolve
      second-round NPDES adjudicatory hearings.

   o  Develop and/or implement enforcement strategies
      for the following categories, coordinating
      where necessary with other programs:

         Chemicals

         Petroleum refineries

         State and local governments

         Iron and steel

         Electric utilities

         Federal facilities.

Plans and Priorities - FY 81

The Enforcement Program's highest priority during
FY 1981 will be response to emergency situations
involving substantial threats to public health and
safety.

   o  Headquarters will provide technical and  legal
      assistance in the event of an emergency
      situation.

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                  - 151 -
Following response to emergencies,  the highest
Enforcement priorities-during FY 1981, will be
referral of schedule and effluent limitation violators
to the U.S. Attorney and the Department of Justice
for enforcement action,  and resolution of pending
cases.

   o  Headquarters will focus efforts and resources
      on whatever case support is necessary to
      expedite case referral and resolution, providing
      technical and legal aid as needed.

   o  Headquarters will monitor all cases to ensure
      compliance.

   o  Headquarters will provide technical and legal
      support in enforcement cases involving non-
      compliance with pretreatment, hazardous
      substances and toxics requirements.

   o  Headquarters will overview monitoring and
      enforcement efforts for compliance with
      second-round permit limitations.

   o  Headquarters will provide legal and technical
      support for enforcement actions against non-
      complying second-round permittees.

Headquarters will continue overview of municipal policy
and strategy; provide legal and technical assistance
in carrying out strategy.

Program management methods will be improved by:

   o  Continuing audits to maintain EMS/Grants.

   o  Evaluating ONCRs.

   o  Implementing enforcement strategies for
      the following categories:

         Chemicals

      -  Petroleum refineries

         State and local governments

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                  - 152 -
Changes - FY 30

Emphasis in FY 80 will be placed on resolution
of all MSEE referrals.

Greater attention will also be directed toward
bringing Federal facilities, both major and minor,
into compliance with requirements of the Clean
Water Act.

Focus will shift to enforcement of second-round
permit limitations (BAT and BCPT requirements).

Pretreatment and revised hazardous substances, regula-
tions will be promulgated before the end of FY 79.

For those remaining major and minor Federal facilities
not in compliance, every effort will be made to
ensure that those Federal facilities are brought
into compliance with the Clean Water Act during FY 1981,.

   o  Headquarters will provide any legal and technical
      support necessary to bring these sources into
      compliance as early in the year as possible,
      taking an active role, as needed, in negotiation
      of consent agreements.

   o  Headquarters will monitor major Federal facilities
      to ensure compliance.

The Office of Enforcement will implement the improved
Compliance Monitoring and Enforcement Program to
ensure continuous compliance.  As part of this, the
following activities will be undertaken:

   o  Make adjustments, as needed, to compliance
      monitoring program procedures and guidelines.

   o  Continue reviewing Regional programs for State
      overview procedures.

   o  Implementation of a strategy for use by con-
      tractors in compliance monitoring activities.

   o  Overview expansion of management information
      system capabilities, including the following:

         Overview of EMS in NPDES States.

         Overview implementation of automatic DMR
         processing capability  (majors).

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                      -  153 -
           -  Ensure data quality for D.MR data entry
              from States.

     The Office of Enforcement will continue support to
     toxic and hazardous substances control activities,
     including the following:

        o  Overview tracking and monitoring procedures
           to assure compliance with pretreatment,
           hazardous substances. *nd toxics requirements.

     These will be the focus of new initiatives in  FY 80;
     new initiatives will cover toxics compliance
     monitoring and enforcement as well.

     Changes - FY 81

     Considerable emphasis will be placed in FY 81  on
     developing and implementing new or revised compliance
     monitoring and enforcement programs designed to
     ensure continuous compliance with requirements of
     the Clean Water and Ocean Dumping Acts.

     Alternatives for Carrying Out theProgram - FY 81

     Consider contracting out more compliance monitoring
     inspections.

WATER ENFORCEMENT - PERMITS ISSUANCE

In keeping with the Agency's objectives of implementing
toxic controls and regulatory reform efforts, the
Headquarters' plan for FY 1980/31 will focus on activities
attendant to the issuance of EAT/toxic permits and the
permits consolidation effort.

     Plans and Priorities - FY 80/31

     Priority activities for Headquarters in FY 1980/81
     will focus on toxic substance control, improving
     permitting methods through the consolidated permit
     effort, and meeting the requirements of the CWA.
     Headquarters' activities with respect to toxic control
     include finalization of the BMP regulations, develop-
     ment of the permit application form which will require
     information on the presence of toxic pollutants,  and
     issuance of guidance on primary industry permit

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                  - 154 -
reissuance.  In addition, Headquarters in FY 1980 will
manage a $2 million contract to provide assistance to
localities in developing pretreatment programs for
the control of toxic pollutants.  Additional pre-
treatment efforts in 1980 include provision of guidance
to the Regions on approving local programs and making
final approval decisions on State pretreatment
programs.

Activities relating to improved permitting methods
will focus primarily on the implementation of the
consolidated permit effort.  In FY 1980 the permits
program will focus Jon issuing guidance to the Regions
on developing consolidated permitting procedures and
writing consolidated permits.  In addition, a group
of multi-disciplinary professionals, centered in the
Permits Division at Headquarters, will be responsible
for integrating policy guidance developed for the
various consolidated permit programs nationwide.

Many of the new responsibilities imposed by the
CWA will require initial implementation efforts by
Headquarters in FY 1980.  FY 1980 will see the develop-
ment of regulations for Section 301 (c) and (g)
variances  (economic and environmental variances) and
development of regulations for Section 301 (k), innovative
technology variances.  Additionally, the Headquarters'
Permit Program will be responsible for concurring in
approvals of State 404, Underground Injection Control
(UIC) and RCRA programs,. and modifying NPDES State
programs according to the provisions of the CWA.

In addition to responding to new CWA requirements,
the Headquarters' program in FY 1980 will need to
continue ongoing program efforts such as consideration
of fundamentally different factors variances, review
and approval of requests for NPDES State program
approval, review of adjudicatory hearings stipulations,
and Headquarters assistance to Regional Offices in
responding to Section 316 requests for thermal variances.

Changes - FY 30/81

The major changes between FY 1979 Headquarters Permit?
Program efforts and those activities outlined in the
FY 1980/31 Guidance are the initiation of the Permits
Consolidation effort and the increased focus on toxic
pollutants via the pretreatment program and the
second-round permitting effort.  These changes in
program emphasis are reflected in increased Guidance

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                  -  155  -
attention to new programs such as Permits Consolidation
and pretreatment and the development of associated
regulations.  In addition, there will be some changes
in Headquarters' activities between FY 1980 and 1931.
In 1981, the Headquarters component of the permits
issuance decision unit will address the consolidation
of State permit programs.  This activity translates
into developing communications channels for States to
encourage the assumption of consolidated permit pro-
grams, providing guidance to States on acceptable
components of consolidated programs, and providing
technical assistance to States, where necessary, in
developing consolidated permits.  Additionally,
Headquarters activities in 1981 will be directed
at expanding the permit consolidation effort to
other Federal agencies.  Finally, Headquarters'
activities in 1981 will include modification of the
pretreatment and consolidated regulations to ensure
that the requirements of these programs are integrated.

Alternatives

As the majority of the permit issuance activities
at Headquarters revolve around regulation and guidance
development responsibilities, there is little room
for substitution of outside contractor personnel.
However, use of contractor personnel in making pre-
liminary determinations on the increasing number of
variance requests which must be addressed by Head-
quarters in FY 1980/1981 might be feasible.  In addition,
the Headquarters program has used, and will continue
to use, contractor support in developing program
publications which explain in layman's terms the
various regulations promulgated by the Office.  Con-
tractor support has also been used in developing
programs for necessary public participation in the
NPDES program.  In FY 1979 and continuing into FY 1980,
the Headquarters program will use contractor support
to provide assistance to localities and States in
implementing the National Pretreatment Program.  This
contractor assistance is provided in lieu of increasing
the Regional staffs to the levels which would be
required to initiate the pretreatment program.

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                       - 156 -
RESEARCH AND DEVELOPMENT

     General R&D Management

     In FY 80 and FY 81 EPA's R&D program will have three
     major management goals:

        o  Continue the integration into the main stream of
           the Agency's activities of all of ORD's research
           in support of regulation and enforcement.

        o  Enhance ORD's capability to provide better data
           for future Agency  regulatory and enforcement
           actions.

        o  Improve the quality and utility of scientific
           and technical data used by the Agency.

     Actions to be taken to achieve these goals include
     the following:

           Establish Research Committees to cover all water
           quality research in support of regulations and
           enforcement.

           Currently one Research Committee exists —
           Industrial Wastewater Research.  Three Committees
           will be established during FY 79 to cover
           essentially all research conducted in support of
           water quality regulation and enforcement.

           Water Resources (relating primarily to OWPS
           activities).

           Industrial Wastewater (broadening the existing
           Industrial Wastewater Committee).

           Municipal Wastewater, Ocean Disposal, and Spill
           Prevention (relating primarily to OWPO activi-
           ties) .

           One major concern is how to incorporate require-
           ments and views of the Regional Offices into the
           Research Committee process.  This will make it
           necessary for the Regional Offices to coordinate
           their participation and share responsibility for
           representing regional interests.

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                  - 157 -
      Develop an exploratory research effort which
      applies the Nation's best scientific capability
      to addressing future Agency problems.

      Fifteen percent of ORD resources for water quality
      will be devoted to research which has the purpose
      of applying the best available scientific capa-
      bilities to research which looks beyond immediate
      (1-3 years) Agency needs or involves higher risk
      but potentially higher pay-off than research
      normally undertaken in support of regulation or
      enforcement.  This effort will be developed by ORD
      in consultation with the scientific  community
      external to the Agency.  All plans for exploratory
      research will be reviewed by the Agency's Research
      Committees.

      Scientific peer review of Agency research projects
      and reports.

      Mechansims will be established to ensure, wherever
      feasible, scientific peer review of the plans for
      and results from individual research projects.

      Establish an environmental criteria and assess-
      ment function!

      This involves completion of the staffing and imple-
      mentation of ORD's new Office of Health and
      Environmental Assessment in order to provide consis-
      tency in the Agency's risk assessments and provide
      water quality assessments upon request by the
      Agency.

      During FY 80 and FY 81, "technology transfer"
      activities will no longer be planned and budgeted
      separately.  Plans and resources for technology
      transfer in a given program, e.g., municipal waste-
      water, are to be included in Decision Units for
      that program.

Health and Research

   o  Determine the health implications of existing
      and new technology for the treatment, disposal
      and reuse of wastewater and sludge.

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                     - 158 -
      o  Determine the health effects of priority toxic
         pollutants.

      o  Develop rapid screening tests suitable for
         extrapolation to man for characterization of
         toxic pollutants in complex effluents.

      o  Develop recreational water quality criteria.

Research will proceed as described in the FY 80 budget,
except for the following:

      o  In developing screening tests which can be
         extrapolated to man ,  mammalian and in vitro
         tests will be considered along with bioassay
         tests normally used by aquatic biologists.

      o  Current discussions may lead to a new effort
         for nonpoint sources.

Environmental Processes and Effects

Freshwater environmental effects research will focus
on the following priority areas in FY 80 and FY 81:

      o  Nonpoint source impacts, including recovery
         rates and mentoring methods .

      o  Test protocols for toxics, including mutagenic
         and carcinogenic effects.

      o  Effects evaluation of complex toxic effluents.

      o  Test methods for the bioaccumulation potential
         organics .

      o  Environmental effects of land application of
         municipal wastes.

Marine environmental effects research will address:

      o  Methods for measuring the relative "health" of
         marine ecosystems.

      o  Simulation techniques, including "microcosms" for
         predicting pollutant stress on marine biota
         and ecosystems.

      o  Effects of specific pollutants from ocean dumping,,
         outfalls, dredged materials, and other sources
         pollutant transformation products, and combina-
         tions of pollutants on marine biota and ecosystems

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                  -  159  -


   o  Questions of wetland function and importance.

Transport and fate research goals include:

   o  Expansion of selected water quality predictive
      models to include toxics and sediments.

   o  Development and joint evaluation with OWWM
      of a method for determining gross environmental
      "mass balances" for toxics.

   o  A continued, limited effort to verify selected
      water quality predictive models, primarily
      through use of existing data, with emphasis
      on utility for wasteload allocations and advanced
      waste treatment facility decisions.

   o  Studies of the transport and fate of selected
      pollutants in the marine environment.

The Great Lakes research program will in FY 80, verify
phosophorous-plankton models used in load reduction
simulations, and begin an effort to expand in FY 81,
research on the risks to man from toxics transported
through the lakes system.

The Chesapeake Bay research program will carry through
studies, just initiated, on assessing, in reference to
competing uses of the Bay, existing and projected
consequences of toxics and nutrient loadings on the
Bay system, human health and the economy of the Bay.

Measurement and Monitoring

Measurement methods research in FY 80 and FY 81 will
address:

   o  Broader spectrum and more cost-effective methods
      for screening and quantifying organics in water
      and wastewater, with increased attention in FY 81
      to nonvolatile organics.

   o  Completion in FY 81 of identification of
      volatile organics in industrial effluents  (in
      direct support of Effluent Guidelines Division,
      OUTS) .

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                   -  160  -
     o  More cost-effective multi-element and chemical
        specification methods, with emphasis in FY 81
        on techniques for soils, sediments and sus-
        pended solids.

Quality Assurance Program Activities will include:

     o  Completion in FY 80 of analytic methods and
        quality assurance materials for consent decree
        toxics in sludges, ambient waters and fish
        tissues.

     o  Evaluation of surrogate methods for toxics in
        effluents and sludges.

     o  Evaluation of alternative monitoring methods
        for enforcement.

     o  Quality assurance support for all Agency labora-
        tories and Agency sponsored contracts.

Monitoring methods and systems research will include:

     o  Correction of deficiencies and analytic methods
        for consent decree toxics in effluents, sludges
        and ambient waters.

     o  Specifications for EPA approved Regional sampling
        and monitoring instruments.

     o  Development of pathogen idenfication and
        concentration procedures.

     o  Evaluation of biological monitoring systems.

     o  Development of monitoring system concepts for
        linking Agency monitoring systems to facilitate
        correlation of monitoring data with health
        statistical data.

Technical support program will provide:

     o  Remote sensing support for spill prevention and
        emergency oil spill response activities.

     o  Monitoring and analytic support, consultation,
        and expert testimony, as needed.

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                   - 161 -
Control Technology

In FY 80 the Industrial Wastewater Control R&D program
will focus on:

     o  Optimization of available treatment methods and
        development of innovative technologies for
        control of toxic pollutants.

     o  Laboratory and pilot scale treatability studies
        for priority pollutants.

     o  Development of BMP's for industrial sources not
        readily covered by BAT or revised BAT.

     o  Technology development for control of hazardous
        materials spills,

     o  Initiation of a major program for evaluation
        and development of reuse/recycle technologies.

     o  Major effort to evaluate and establish ways in
        which to minimize intermedia impacts from
        wastewater pollution abatement practices.

In FY 81, the Industrial Wastewater Control Program
will continue the initiatives described under FY 80,
and in addition, will include:

     o  Demonstration of reuse and recycle systems for
        those industrial segments which contribute a
        high number of the 129 priority pollutants in
        their discharge.

     o  Acceleration of development of technology to
        support an Agency emergency response capability
        for the control of hazardous waste incidents
        of all types.

     o  Technology transfer of reuse/recycle technology
        to industrial users.

     o  Assessments and treatability studies on toxic
        pollutants to be added to the original list of
        priority pollutants.

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                   - 162 -



Municipal control technology priorities will include:

Sludge:

     o  Evaluation of innovative and alternative
        technology projects,

     o  Assessment of exposure levels of organics,
        metals, and pathogens from land application.

     o  Development of beneficial uses, including
        energy recovery technologies.

     o  Evaluation of detoxification methods.

Toxics:

     o  Characterization of sources and magnitude.

     o  Determination and development of predictive
        methods for treatability.

     o  Evaluation of urban-wide toxics control and
        pre-treatment strategies.

     o  Evaluation of promising control strategies.

Small flows/land treatment:

     o  Demonstration of central management of on-site
        systems.

     o  Extension of overland flow systems to colder
        climates.

     o  Evaluation of toxics management in land
        application systems.

     o  Investigation of higher rate nutrient uptake
        systems.

Process development:

     o  Treatment systems for small communities.

     o  Combined sewer overflow management and. technology.

     o  Evaluation of reuse demonstrations.

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                   - 163 -
     o  Evaluation of high rate biological systems
        for removal of specific pollutants.

     o  Development of surrogate control parameters.

Cincinnati Test and Evaluation Facility:

     o  Response to short-term needs of Regions and
        Program Offices.

Agricultural control technology will emphasize:

     o  Field evaluation of best management practices,
        in coordination with the Model Implementation
        Program and Rural Clean Water Program.

     o  Validation of recently developed pollutant
        loading models.

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                        - 164
REGIONAL GUIDANCE

Construction Grants; Municipjal Operations
Priorities; FY 80 and 81

     The Construction Grants Program Guidance covers all the
     activities necessary to administer grants for construction
     of publicly-owned treatment works, pursuant to Title II
     of the Federal Water Pollution Control Act, as amended by
     the Clean Water Act of 1911.   Regional Construction Grants
     activities cross organizational lines, and may involve
     personnel from the Water Division, Management Division,
     S&A Division,  and the Office of Civil Rights.  This
     Program Guidance also encompasses personnel performing
     environmental  reviews of construction projects, including
     preparation of EIS's, and operations and maintenance (O&M)
     related activities.  (See Guidance on Non-Regulatory
     NEPA Compliance in Interdisciplinary Media Section for
     detailed EIS guidance.)

     The specific program priorities for FY 1980 reflect the
     major emphasis toward decentralized management and
     continued program quality outlined in the Title II regu-
     lations and various Program Requirements Memoranda (PRMs)
     and Program Operations Memoranda  (POMs),    In general
     terms, the program priority continues to require that the
     obligation rate be developed consistent with the primary
     emphasis on environmental and fiscal quality and full
     implementation of the law.   For purposes of planning
     FY 1980/1981 activities, therefore, the Regions are to put
     primary emphasis on environmental management, sound pro-
     gram management, and project integrity.   The obligation
     goals are to be developed and achieved at levels that
     take account of this environmental and management emphasis.

     This primary emphasis on quality, however, does not lessen
     to any degree  the principal purpose of the program, which
     is to make grants to municipalities and to get treatment
     plants built and operational.  As more resources are made
     available to the program through State delegation and the
     Corps, obligation rates are expected to increase.  The
     Regions, in developing their operating plans based on
     limited resources, must strike a balance between the need
     to manage obligation goals  and the requirements for
     ensuring program and fiscal integrity.  Through the deve-
     lopment of the Regional operating plans,  the Regions are
     to determine that mix of activities which minimizes the

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                   - 165 -
adverse impact of tradeoffs and provides the best
balance among competing objectives.  In all cases, a
tradeoff of one activity against another should be
evaluated and analyzed in the Regional program plans
for its impact on program performance.

The development of FY 1980 program plans must explicitly
address at the outset how the limited resources available
will be utilized to meet the FY 1980/1981 objectives
outlined above.  Since the resource base has not increased
in line with the vastly increased responsiblities thrust
upon EPA under the Clean Water Act, specific activity
tradeoffs must be identified and evaluated to determine
the risk involved in incomplete program management.
Although State delegation will provide a longer term
solution to the resource problem, the resource problems
in FY 1980 are not expected to be mitigated significantly.
How each Region addresses this problem in FY 1980 should
be the central focus of the program plans to be developed.

Given the need to balance the grant objectives against
overall quality requirements, the following list of
major program areas is to be used as a guide for assessing
relative priorities among the major activities (the
highest priority efforts are listed first):

     1. Environmental Management.  The Clean Water Act
provided a great number of amendments related to the
facility planning phase, all of which are absolutely
essential for project quality and proper environmental
management.  The facility planning effort is of highest
priority, particularly assuring that facilities affording
treatment more stringent than secondary receive careful
review; that the cost-effectiveness guidelines are fully
complied with to ensure quality projects at minimum costs;
and that the use of innovative and alternative technology
approaches receives increasing emphasis in FY 1980.  The
Regions should develop a strategy that includes a mix of
front-end activities (pre-application conferences, mid-
course meetings, public participation, final review,
etc.) to ensure that the three high priority objectives
of facility planning are met.

     2. Delegation and Management of Program Activities
Under Section 205(g) and the Corps Agreement.Given
limited EPA manpower in the Construction Grants Program
to accomplish the full legislative mandate, a strategy
on resource usage that makes effective use of State,

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                   - 166 -
Corps, and EPA resources is essential as part of the
operating plan development.  Regional strategies are
to place emphasis on State delegation as the preferred
manpower alternative over the long term; thus, the
Corps effort should be gradually phased out over time
in favor of State delegation.  Regarding State delegation
policy:

     o  Regions are to continue to thoroughly evaluate
        the ability of any State to administer the
        program in full compliance with all EPA policy
        and environmental objectives prior to the award
        of the initial Section 205 (g) grant.

     o  Prior to the award of the initial grant, Regions
        must ensure that realistic and complete manpower
        planning analyses and phase-in schedules are
        provided by the State, and should take all steps
        necessary to ensure sufficient staffing by the
        States to meet the full intent of the legislation.

     o  Given the resource constraints faced by EPA,
        emphasis placed on delegation monitoring after full
        phase-in by the State should be greater on front-
        end activities and lesser on Step 2 and Step 3
        activities; the Regions should provide only the
        minimum necessary monitoring effort on grant
        related activities not related to environmental
        objectives .

Regarding Corps policy, the Regions should encourage
maximum use of the Corps resources (in lieu of State
delegation) to meet the full intent of the National
Agreement.  Where appropriate, Regions should expand their
use of the Corps to include activities such as value
engineering reviews, sewer evaluation survey reviews,
operational reviews of the plans and specifications,
project close-out, or other activities that make use of
their technical expertise.  Monitoring of the Corps
should be the minimum necessary to ensure program in-
tegrity and activity coordination, with increasing respon-
sibility given to the Corps to resolve issues previously
done by EPA.

     3. Program Planning and Management.  A continued
high priority effort must be provided by the Regions to

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                   - 167 -
improve program management and protect the fiscal and
technical integrity of the program.   This effort should
focus on the following areas:

     o  The continued high emphasis  on outlay manage-
        ment, including the estimation of realistic and
        achievable outlay estimates,  as well as the
        management of project  schedules to achieve out-
        lay targets.

     o  The setting and achievement  of obligation goals
        that reflect the existing mix of active projects
        and the need to level  out workload during the
        year, recognizing that obligation levels will
        increase as more resources (State, Corps, and
        EPA)  are brought to bear on  the program.

     o  The use of the Municipal Enforcement Strategy as
        one of the foundations for the program management
        strategy.

     o  The establishment and  maintenance of improved,
        multiple-year project  planning thru the five-
        year priority list—linked to the Needs Survey,
        the NPDES permit program, and the State Water
        Quality Management Plans.

     o  The review and use of  the priority list for day-
        to-day management of the program.  Priority list
        management will be the vehicle for Construction
        Grants program planning.

     o  The monitoring of all  Step 1  active projects to
        ensure timely completion of  the facility planning
        process.

     o  The monitoring of all  projects immediately after
        Step 3 award to ensure early  construction starts.

     o  The monitoring of all  Step 3  projects to ensure
        timely project completion, close-out, and
        resolution of audit exceptions.

     o  The maximum use of the Regional Construction
        Grants Management Information System (RCGMIS)
        for effective program  and project management.

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                   - 168 -
The resources provided through the Corps agreement and
State delegation will be the primary sources of manpower
to accomplish most of the program management initiatives.
The Regional effort should focus on long-term planning
and overall management and coordination, including
management of obligation and outlay goals.

     4. Environmental Review and EIS Preparation.  A
continued high priority should be placed on early environ-
mental review of projects during the facility plan develop-
ment through "piggybacking" and "layering" techniques to
streamline the NEPA process and ensure more sensitive
reviews.  Emphasis should also be placed on coordinating
EPA project planning with the planning efforts of other
Federal agencies to provide for better environmental
reviews of the cumulative effects of Federal actions.
While the principal objectives of the environmental
review process should be improved projects either with
or without an EIS, the Agency's output of EIS's relative
to the size of the program is still so low that we must
continue to strive to prepare more EIS's when resources
are available to do so.  Specific guidance on relative
priorities within EIS preparation is stated in the Inter-
disciplinary Media Section of this Guidance.

     5. Operations and Maintenance.  Operational require-
ments are to receive high priority in FY 1980.  Beginning
in FY 1979 and continuing through FY 1980, the Office of
Water Program Operations will be developing a series of
guidance packages to clarify operational requirements of
the Construction Grants Program.  The Regions should
ensure that construction grants are not closed-out until
there is acceptable evidence that POTW's are capable of
being operated reliably at levels set forth by their NPDES
discharge requirements.  Increased effort should also be
directed at identifying existing POTW's that do not
comply with NPDES permit requirements and conducting
performance evaluations when needed.

        Certain other program areas—such as Minority
Business Enterprise, Public Participation, EEO and
Davis-Bacon—are Agencywide or Government initiatives
and are non-discretionary.  All other activities not
specifically noted above are essential for program
integrity but of relatively lower priority.

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                        - 169 -
Activities; FY 80 and 81

     The specific Regional activities that are encompassed
     within the priority areas noted above number approximately
     75, broken principally into Step 1 activities, Step 2
     activities, Step 3 activities, delegation and Corps
     management and oversight, program planning, information
     system control, and other support activities.  The
     Construction Grants Resource Model provides this activity
     listing and its relative resource pricing.  This model
     should be used, to the maximum extent possible, in
     evaluating the resource impact of various priority options.
     (The model and technical assistance on its use are
     available from the Office of Water Program Operations.)

     Not included in the existing resource model are O&M
     related activities.  Activities necessary to support
     increased emphasis on operational requirements (as
     described above)  are as follows:

          o  Implement PRMs   (issued during FY 1979) on
             (1) use of operational checklists; (2) opera-
             tional reviews of facility plans and plans and
             specifications and (3) conditioning Step 3 grants
             or grantee compliance on plans of operation
             schedules.

          o  Use grant sanctions as necessary to ensure
             grantee response to operational requirements and
             to ensure grantee commitment to adequate O&M for
             completed projects.

          o  Conduct O&M inspections and follow-up inspections,
             as necessary, before close-out of the Step 3
             grant.

          o  Conduct one-year O&M inspections on close-out
             projects  to verify performance or flag problems.

          o  Overview  State O&M inspections and performance
             evaluations on existing POTW's.  Conduct EPA
             inspections as necessary to supplement the State
             O&M inspections programs.

          o  Coordinate with Enforcement to ensure responsive
             action to performance-related problems for both
             newly completed and existing POTW's.

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                      - 170  -




Spill Prevention and Response

     Planning Assumptions

          o  The Hazardous Substances  Regulations
             (designation, reportable  quantity), will
             become effective in May-June,  1979, and
             will require notification by the discharger
             of spill incidents  and an initial situation
             assessment.

          o  EPA will receive notice of approximately
             2,000 incidents per year  involving hazardous
             substances.   Between 700  and 1,200 will
             involve one  or  more of the 299  designated
             substances.

          o  Section 311  of  the  Clean  Water  Act (CWA)
             gives specific  authorities and  responsi-
             bilities to  the President.  Although  these
             responsibilities cannot be delegated  to
             State agencies  or to individuals, States
             can participate by  (1)  providing assistance
             to Federal operations,  (2) legislatively
             establishing their  own spill and emergency
             response capability,  and  (3)  seeking
             reimbursement under Section 311(k) of State
             funds spent  on  spill cleanup.

          o  Section 106  grant funds,  which  may become
             available as a  result of  Section 205(g)
             delegations, will be reprogrammed into high
             priority activities identified  in State/EPA
             Agreements (SEAs),  including environmental
             emergencies  and spill prevention/control
             activities.

     Priorities;  FY 80 and 81

     Regional priority in FY 1980 and  FY 1981 must be
     given to on-scene emergency responses  to spills of
     oil and/or designated hazardous substances which
     contaminate or threaten public drinking water supplies,
     which cause or threaten danger to public health and
     welfare, or which constitute an environmental
     emergency and threaten or cause severe
     damage to sensitive  ecological systems  or to  the
     spill environment.  Further,  EPA  must be prepared
     to respond to incidents involving materials other
     than oil and designated hazardous substances  that cause
     or threaten to cause health or environmental  damage.

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                  •- 17.1. -


The specific priori i-jes for FY 1,980 are listed below
in descending order of priority:

     o  Expand, uti li z'big  i-esources available from
        increased resource allocations, Technical
        Assistance Teams (^2,  or more personnel)
        and the ERT (8 member team) capabilities
        for on-scene response to major spills of
        oil and hazardous  substances that threaten
        public health  arid  welfare or sensitive
        ecological areas,  with particular emphasis
        on drinking water  supplies.

     o  Respond on-scene to direct Federal cleanup/
        litigation or  monitor cleanup/litigation
        actions taken  by a discharger to all reported
        spills and environmental  emergencies within
        resource capabilities.

     o  Respond within the limits of available
        resources and  mandated program responsi-
        bilities to those  environmental emergencies
        involving non-311  substances that threaten
        life, public health and welfare,,

     o  Conduct prevention compliance inspections
        and other prevention related projects at  a
        lower priority than ori-scene response actions.

     o  Provide technical  assistance and support  as
        requested by Federal Emergency Management
        Administration during declared disaster
        episodes.

     o  Revise Regional contingency plans for incor-
        poration of hazardous substances response
        mechanisms.

     o  Give environmental  damage assessments and
        technical assistance to other Federal
        agencies,  States,  and site restoration
        operations lower priority until additional
        resources permit greater activity.

     o  Review resources assigned to the. Regional
        spill prevention and control decision unit
        to determine the maximum utilization of
        positions for  qualified On-Scene Coordi-
        nators, and mimize assignment of personnel

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                  - 172 -
        to administrative/clerical operations or
        to actions outside the Spill Prevention
        and Control Program.
Activities; FY 80 and 81

     o  Maintain a capability to receive immediate
        notification of spills of oil, hazardous
        substances, and other environmental emer-
        gencies on a 24-hour a day basis.

     o  Encourage dischargers to assume cleanup/
        litigation responsibility.

     o  Respond to major spill incidents,  providing
        qualified, on-scene coordinators (OSC)  to
        coordinate the response and maintain adequate
        surveillance to determine that removal
        actions are being properly carried out.

     o  Implement within available resources an
        aggressive spill prevention program for non-
        transportation related facilities,  including
        compliance inspections, review and amendment
        of Spill Prevention Control and Counter-
        measure CSPCC) plans, aerial surveillance,
        and timely issuance of notices of  violation.

     o  Prepare, revise and update on a continuing
        basis local, State, Regional contingency plans.

     o  Plan and coordinate the resources  necessary
        to respond to requests for assistance during
        Federally-declared disasters to include
        planning,  field damage surveys, and cost
        estimating assistance.

     o  Work aggressively with the State governments
        to prepare them to assume a more active role
        in the Spill Response Program, in accordance
        with the recommendations of the EPA Task
        Force on Environmental Emergencies.

     o  Urge States to develop adequate emergency
        authority, contingency plans, and draft
        enabling legislation that includes permission
        for contingency funds for environmental
        emergencies and Spill  Response Programs;
        urge inclusion as high priority items in
        State/EPA Agreements  (SEAs) and in Section

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                       -  173  -


             106 grant applications of Spill Prevention
             and Control  and Emergency Response program
             activities.

Ocean Disposal and Permits

     Planning Assumptions

          o  All interim  permits are to  phase  out by the
             end of 1981,  by regulation.   All  dumping of
             harmful sewage sludge is to stop  by the end
             of 1981,  by  statute.

          o  Ocean Dumping under special permits is
             expected to  attain a slightly higher level
             in FY 1980/1981 as a result of implementation
             of the Resource Conservation and  Recovery
             Act, the elimination of marginal  and unsatis-
             factory disposal of harmful sewage sludge,
             and an increase in incineration-at-sea
             applications  which will require site designa-
             tions and monitoring.

          o  Probable changes in the International Ocean
             Dumping Convention will require changes in
             U.S. Ocean Dumping criteria during the  next
             few years, particularly in  radioactive  waste
             disposal and incineration-at-sea.   The
             program is responsible for  both international
             negotiation  and changing criteria.

          o  New and changing ocean technologies,  i.e.,
             in situ at-sea incineration,  deep ocean
             dTilling, deep sea mining,  ocean  thermal
             emergy conversion,  and operations near
             marine sanctuary areas, require development
             of industry  specific environmental guide-
             lines and site specific disposal  permit
             conditions.

     Priorities, FY 80 and 81

     Major Regional goals  and priorities  are the following:

     An overall increase  in Ocean Dumping program activity
     is expected over the  next few years,  not  a decrease.
     The phase-out of interim permits is  a minor part of
     the overall program  and has little  resource impact,
     (less than 5% of total volume dumped, including
     dredged material).   Regions'  and Headquarter's

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                  -  174 -
workloads will not be reduced over the next few
years because of continued litigation and enforce-
ment action toward major interim permittees (e.g.,
Philadelphia, New York); an increase in ocean-dumped,
dredge material permit activity by the Corps,  as a
result of new channel deepening projects; and
litigation on present permit actions requiring our
review for compliance with EPA criteria.  (Estimate
ocean dumping of dredge materials at rates 10  times
present annual rates.)  The Corps has provided $6
million for the next three years for EPA to perform
field surveys to designate 15 of 127 dredged spill
disposal sites by the January, 1980 court deadline.
Given this context, the following provide the major
program priorities in FY 1980 and FY 1981.

     o  Because of the statutorily required termi-
        nation of ocean dumping of harmful sewage
        sludge as well as the termination of all
        interim permits by the end of 1981,  emphasis
        on overseeing the implementation of alter-
        native disposal practices must continue and
        increase through 1981.

     o  A major continuing effort is to push interim
        permittees into implementing acceptable
        alternatives by the end of 1981.  Alternative
        methods of disposal of sewage sludge on land
        or land utilization should become part of the
        201 and 208 planning process, and those
        responsible for 201 and 208 implementation
        should be made aware of the land utilization/
        land disposal alternatives which must be
        considered as part of the required phcise-out
        of sludge dumping by December 31, 1981.

     o  Review of applications for special permits
        for ocean dumping should continue at present
        or slightly higher levels.

     o  Critical review of dredged material permit
        actions by the Corps of Engineers should
        continue to receive major emphasis.

Activities;  FY 80 and 81

     o  Act on interim and special permit applications.

     o  Review Corps of Engineers dredged material
        permit/project applications.

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              -  175 -
o  Evaluate permittees' monitoring reports.

o  Provide inputs to Headquarters for the annual
   report on Ocean Dumping.

o  Provide inputs to Headquarters for the annual
   report to Congress and the Ocean Dumping
   Convention.

o  Refer emergency permit requests/situations to
   Headquarters for action.

o  Evaluate offshore industrial activities to
   determine the need for special discharge
   guidance or development of other pollution
   control regulatory mechanisms, e.g.,
   discharges from ocean thermal energy conversion
   (OTEC) or discharges involving hypersalinity.
   Particular attention should be given to
   activities that may impact areas of special
   sensitivity and/or concern.  Necessary
   actions should be initiated for the develop-
   ment by Headquarters of any such needed
   guidance.

o  Participate in Department of Interior  (DOI)
   Regional Committees for inputs to outer
   continental shelf (DCS) lease sales.

o  Identify Regional R&D priorities related to
   off-shore energy and other resource develop-
   ment activities.

o  Advice on marine sanctuaries:  Respond to
   requests from the National Oceanic and
   Atmospheric Administration (NOAA) (as
   specified in Title II of Marine Protection
   Research and Sanctuaries Act  (MPRSA) and from
   other agencies for EPA advice on nominations
   of sites for potential designation as marine
   sanctuaries, and nominate sites for
   designation as marine sanctuaries.

o  Develop an inventory and data on sites for
   potential inclusion in the national system of
   sanctuaries and rank them in terms of
   Regional/national priorities.  This should be
   coordinated with other concerned agencies
   so that there is no duplication of effort.

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                      - 176 -
Water Quality Training

Priorities, FY 80 and 81

     As a result of the reduction in training positions,
     the Regional training function will be limited to
     liaison and coordination between State and local
     training programs and the National Training and
     Technology Center (NTOTC).   Only limited assistance
     and support will be required by NTOTC in the conduct
     of Section 205 program courses and for coordinating
     EPA/State training needs assessments.

Activities; FY 80 and 81

     Regional activities include coordination with State
     and local agencies and assistance to NTOTC ori:

          o  Section 205 training programs

          o  Instructor training

          o  POTW operator training programs

          o  Section 109(b) State training program
             development

          o  Delivery of NTOTC and other available                 ™
             training courses

          o  Instructional Resources Center Services needs

          o  Assistance to States in development of
             State Joint Training Coordinating Committees

          o  Assessments of EPA/State training needs

Secondary Treatment Modification for Marine Discharge

     Section 301 (h) of the Clean Water Act established a
     provision which allows the Administrator to modify
     secondary treatment requirements on a case-by-case
     basis for POTWs which discharge into marine waters
     and which meet other stringent criteria.  The
     modification is provided through revision to the
     effluent requirements established in an NPDES permit.
     Applications for a modified permit will be reviewed            »
     by a task force composed of staff from the R&D
     Corvallis Laboratory  (Marine Division), and other
     marine biological experts from NOAA, supplemented by

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                       - 177 -
     contractor support.  Headquarters will be responsible
     for technical review of applications.   Following
     preparation of tentative determinations on each
     application/ Regional EPA staff will be responsible
     for carrying out all the permit issuance activities,
     including such things as public notices, public
     hearings, and maintenance of records associated with
     the issuance of modified permits.

Water Quality Management

Priorities; FY 80

     The Regional Water Quality Management and Standards
     Program emphasizes the implementation and overview
     of local water quality management, grants management,
     and institutional controls. Regional priorities
     include the following:

          Management

          o  Develop fully the WQM portions of the FY 81
             State/EPA Agreements.  These Agreements
             will cover not only the Water Quality
             Programs, but also the Solid Waste and
             Drinking Water Programs.  Work with the
             States to ensure development of adequate
             five-year strategies, water quality problem
             assessments, and FY 81 work plans.

          o  Ensure more effective Statewide management
             and coordination of planning and implementa-
             tion.  States are ultimately responsible for
             Statewide planning.

          o  Improve financial and fiscal planning com-
             ponents of the WQM work programs and plans,
             and work with State and local officials in
             overcoming financial barriers to imple-
             mentation.

          o  Participate actively and continuously in the
             management of FY 79-funded WQM planning
             projects of designated State and areawide
             agencies.  Specifically, Regional staff must
             aggressively manage identified national
             priority projects concerning urban storm
             runoff, agricultural runoff, advanced waste
             treatment, groundwater, and other priority
             public health and environmental problems
             identified in SEAs.

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             - 178 -
o  Ensure that each State Rural Clean Water
   Program (RCWP) Committee oversees imple-
   mentation of cost-sharing of approved
   agricultural BMPs.

o Provide for, encourage, and assist public
   participation in the above priorities
   consistent with 40 CFR, Part 25 and 35.

106 Grants

o  Work with the States to develop adequate
   emergency authority and to ensure adequate
   progress in developing contingency plans,
   and to draft legislation for contingency
   funds for environmental emergencies under
   Section 504 in FY 80.

o  Award grants to States from 106 allotments
   based on demonstrated needs determined in the
   negotiation of the State/EPA Agreement.
   Use general State allotments as targets.

o  Ensure that funds which become available as
   a result of 205 Cg) delegations are repro-
   grammed into high priority activities
   identified in SEAs , especially hazardous
   and toxic materials, monitoring and spill
   prevention, implementation of WQM plans,
   and support to State compliance and enforce-
   ment activities.

208 Grants

o  Grants in FY 80 are intended solely for
   development of nonpoint source control pro-
   grams with principal emphasis on agricultural
   runoff, construction runoff, groundwater
   septic regulation, noncoal mining, and
   silviculture .

o  Promptly approve, as appropriate, certified
   portions of State or areawide WQM plans
   addressing agricultural pollution so that
   the control measures  (BMPs) identified can
   be eligible for cost-sharing under the
   RCWP  (208 (j)) administed by USDA.

o  Continue to provide for, encourage and assist
   public participation in WQM.

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                       - 179 -
          Clean Lakes Grants

          o  Assist States in implementing the Section 304
             program regulations and developing complete,
             technically sound Clean Lakes grant proposals

          o  Provide optimum grants administration to
             awarded grants to ensure projects are being
             conducted according to approved grant agree-
             ments and attached grant conditions,  thereby
             ensuring the Agency is not mismanaging the
             millions of dollars attached to the Clean
             Lakes Program.
Activities;  FY 80

          Management
          o  Work with the States to ensure that WQM
             activities under Sections 106, 208, 314 and
             206 (g) are integrated in the State/EPA
             Agreements for FY 80.  These Agreements will
             cover not only the Water Quality Program,
             but also the Solid Waste and Drinking Water
             Programs.  Encourage the States to develop a
             single consolidated work plan.

          o  Review and provide comments on early drafts of
             State/EPA Agreements and annual work plans to
             ensure the final agreements are complete and
             that they correctly include the regulatory
             requirements of the Clean Lakes Program for
             those States wishing to participate.  This
             is particularly important because of the
             requirement that all States that wish to
             participate must have completed and submitted
             to the Agency by January 1, 1982, a classifi-
             cation of their significant, publicly-owned
             freshwater lakes in need of pollution
             protection or enhancement, along with a
             priority listing of such actions.

          o  Ensure work programs for continuing funding
             under Section 208 contain measurable outputs
             leading to technically, politically, and
             financially implementable solutions for
             identified priority problems areas in the
             State.

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            -  180  -
o  Consistent with SEAs, award early in the year
   106 State and interstate program grants and
   208 grants to successful agencies.  Ensure
   that 208 agencies lacking evidence of signi-
   ficant implementation of initial plans do
   not receive additional funds.

o  Complete EPA review and approval requirements
   for all initial plans.

o  Provide continuing (including off-site)
   technical assistance with respect to priority
   problem activities, including fiscal manage-
   ment aspects of planning and implementation.

o  Provide continuing evaluation of Approved
   Management Agency performance,  particularly
   those responsible for National priority
   program areas and for implementation of
   regulatory programs.

o  Ensure effective public participation in
   State and areawide agency activities con-
   sistent with 40 CFR 25 and 35,  Subpart G.

o  Review all State-proposed revisions of WQS
   for compliance with EPA regulations and
   policy guidance.

o  Approve or disapprove WQS revisions.

o  Give special attention to working with States
   still attempting to complete the previous
   triennial review of WQS.

o  With Headquarters and the States, select
   State and areawide WQM agencies to conduct
   AWT reviews and develop construction and
   septic system NPS regulatory programs.

o  Participate in the review of NPDES Permits,
   AWT projects and Water Quality Management
   Plans to ensure the achievement of, or
   implementation of Water Quality Standards.

o  Review 301 (h) waiver applications.

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             - 181 -
106 Grants

o  Evaluate accomplishments at mid-year and
   end-of-year, and reallocate funds among
   States and interstate agencies where
   appropriate.

208 Grants

o  With Headquarters, manage 15-20 demonstra-
   tions of implementation of urban storm
   runoff control programs in FY 80.

o  With Headquarters, manage selected ground-
   water protection/aquifer designation
   demonstration projects.

o  Manage: seven on-going Model Implementation
   Programs  (MIP) and initiate 12 to 15 new
   MIPs.

Clean Lakes Grants

o  Integrate Clean Lakes projects to the
   greatest practicable extent with other EPA
   and other Agency programs to maximize the
   effectiveness of the limited amount of avail-
   able resources.  Particular attention should
   be paid to the Model Implementation Program
   (MIP) and the Nationwide Urban Runoff Program,
   and many of the Office of Research and
   Development demonstration activities to
   improve existing nonpoint source pollution
   detection and control technology.

o  Receive and technically, as well as admini-
   stratively, review Clean Lakes grant appli-
   cations, and award or deny grants based on
   funding recommendations from Headquarters
   and other technical comments received.
   Regions need to supply Headquarters a copy of
   each proposal received after a grant number
   is assigned by the Regional grants office.
   Priority consideration should be given to
   State lake classification proposals, then to
   grant applications that will likely lead to
   quick positive funding decisons, ordering
   proposals for processing so that those which
   will provide the greatest public benefit are
   started through the funding decision process

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                        -  182  -
             first.  Those proposals which will likely
             end in a non-award decision should be
             processed last.

             Assist Headquarters in tracking the process
             of the Clean Lakes Program and provide input
             to further improve program operations.

             Compile and submit tc Headquarters (Criteria
             and Standards Division) by October 1 of each
             fiscal year, the resource needs by State and
             project priority for lake restoration
             requirements, as reflected in State/EPA
             Agreements and work plans submitted to the
             Regional Administrator pursuant to the
             regulatory requirements.
Dredge and Fill

Priorities;  FY 80
          First Priority

          o  Assist States in the development of State 404
             programs by providing information on appli-
             cable Federal regulations,  procedures,  and
             funding mechanisms;  provide   direct support
             in terms of consultation on existing State
             Dredge and Fill/wetlands programs, draft
             legislation or regulations, and other program
             development;  provide   information or testimony
             before State legislative or executive bodies;
             provide   assistance to approved States in
             starting up program operations by helping to
             establish coordinating procedures, data
             bases, advisory bodies or the like.  These
             actions should be coordinated with, and
             assisted by,  when possible, the Headquarters
             404 staff.

          o  Review State 404 program submissions to ensure
             that the statutory requirements of Section 404
             (g, hf and j) and the regulatory requirements
             of 40 CFR 122-4 are met.  Document the review
             and transmit the results of the evaluation
             with recommendation for approval/denial to
             Headquarters.  Coordinate with, and seek
             necessary assistance from,  Headquarters.

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           - 183 -
Review Environmental Impact Statements submitted
with the intent of seeking a 404 (r) exemption
from permitting.  Participate in project planning,
environmental impact assessment, public hearings
and other activities with the objective of ensuring
that the factors and criteria of the 404(b)(1)
guidelines are adequately considered in environ-
mental assessment and project design and implemen-
tation.  Review and document the degree to which
the 404(b)(l) guidelines are adequately considered
in the EIS, and provide recommendations to the
Regional Federal Activities staff on the environ-
mental merits of the project.  As needed,  seek
assistance from and coordinate with Headquarters.

Provide assistance to Regional General Counsel in
litigation involving Section 404 where EPA is the
defendant by providing supplementary analysis for
litigation reports, assisting with the preparation
of briefs, and providing other support necessary
for an effective government defense.

Assist the Water Quality Management Program in
the review of State regulatory programs and best
management practices submitted under Section 208
(b)(4).  Review should emphasize both the internal
quality of the proposed program/BMPs  and the
degree of consistency with State 404 programs.
Coordinate with Headquarters as appropriate.

Manage and coordinate the Federal agency review of
State 404 permits in accordance with 404 (j) and
the applicable portions of 40 CFR 122-4.  Ensure
that the Federal review provides meaningful
information and comment to the States and that the
system is operated in such a manner as to preserve
the integrity of Federal agency responsibilities.

Review "major" Cor-ps and State permits and carry
out those actions necessary to a meaningful
evaluation and recommendation, such as site visits,
participation in public hearings, EIS review, and
consultation with appropriate agencies and organi-
zations.  Coordinate, as needed, with Headquarters
on controversial and especially critical cases,
and solicit Headquarters assistance when appro-
priate.

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              -  184 -
Second Priority

o  Review "important" permits as described above for
   "major" permits.

o  Review Federal or State general permits as
   described above for "major" permits, placing
   special emphasis on the need to provide sufficient
   data and analysis to make a meaningful assessment
   of cumulative and aggregate environmental impact.
   To the extent possible, participate with the Corps
   Districts, and States in the development and
   assessment of proposed general permits.

o  Increase efforts in enforcement against unauthor-
   ized dredge or fill activities or permit violations
   by providing increased technical support of
   administrative actions under Section 309 and/or
   litigation by EPA enforcement attorneys and admin-
   istrative actions/litigation by District Engineers
   under Section 404 (s).   Such support should include
   site evaluation and technical assessments, record
   development, preparation of action documents (e.g.
   A.O.s, T.R.O.s), or other support.  Coordinate
   with, or seek assistance from, Headquarters as
   appropriate.

o  Conduct field inspections to ascertain the state
   of compliance for permitted activities, to detect
   unauthorized activities, and to evaluate cumulative
   impacts of activities conducted under general
   permits or 208(b)(4) BMPs.  This activity will
   normally be carried out in conjunction with EPA,
   Corps, or State enforcement officers using land,
   water, or aerial surveillance methods and involves
   preplanning, field work, documentation, and ini-
   tiation of follow-up action, as appropriate.

Third Priority

o  Provide assistance to States in the development of
   State 208 (b) (4) regulatory programs and best
   management practices.   Activities will be in
   support of 208 program personnel who have the lead
   in this area and in coordination with the Fish and
   Wildlife Service which is mandated to provide tech-
   nical assistance to States pursuant to Section
   208 (i) .

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              - 185 -
o  Review "minor" permits and provide comments and
   recommendations to the Corps or States.

o  Review EISs submitted with a Section 404 or
   Section 9/10 permit application or which involve
   wetland resources or 404-type activities even
   when no such permit is required.  To the extent
   feasible, participate in project planning,
   environmental impact assessment, public hearings,
   and other activities with the objective of
   ensuring both compliance with 404(b)(1), when
   applicable, compliance with the Wetlands Protection
   and Floodplains Management Executive Orders, the
   EPA Wetlands Policy, and other applicable EPA
   policies.

o  Working with Headquarters, identify needs in
   terms of policy/technical guidance, research,
   monitoring and evaluation, information and data
   systems, and other program support areas and
   develop plans for or take actions to address
   these needs, soliciting Headquarters assistance
   where needed.

o  With Headquarters assistance, expand activities
   involved with increasing the level of information
   about the 404 program and the level of public
   awareness and understanding of the value of the
   aquatic resources, especially wetlands.  Activi-
   ties may include the development and dissemination
   of materials for information, education, or
   training; participation in public meetings such
   as conferences and symposia; or conducting edu-
   cational programs with schools or citizens groups.

o  Participate in plan formulation, review, evaluation,
   and comment on special area management plans under
   the Coastal Zone Management Act (CZMA), 208 area-
   wide plans, and GREAT plans  (under WRDA) or ad hoc
   plans which deal with regional environmental
   assessments and/or land use plans.

o  As appropriate, exercise the EPA veto power of
   Section 404 (c) in accordance with the procedures
   of 40 CFR 231 and any supplemental guidance.  This
   would include pre-initiation site and record

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                        - 186 -
             development, preparation of action documents,
             support of public hearings, and support of
             adjudicatory hearings (if held).

             Review, evaluate, and comment on regulations,
             guidelines, Executive Orders, and other policy
             documents, research reports, and other studies.
             Includes participating in and reviewing develop-
             ment of new/revised regulations and guidance
             published under Section 404.  This may involve
             the review of other regulations affecting 404
             programs, such as EPA's Solid Waste Regulations,
             NEPA regulations, and Section 402 Regulations, or
             regulations and reports published by the Corps,
             Fish and Wildlife Service, National Marine
             Fisheries Service, Coastal Zone Managment Agencies,
             State Environmental Agencies, River Basin Agencies,
             and others.
Activities; FY 80
             Monitor awarded projects to ensure that milestones
             are accomplished,  time requirements are met, and
             special grant conditions are handled properly,
             particularly those involving Section 404 Dredge
             and Fill permit requirements and those of State
             Water Quality Standards.  Those grants that are
             monetarily large and have significant potential
             for adverse environmental impact, such as dredging,
             should be given priority attention.  A copy of
             quarterly reports required on all grants must be
             submitted to Headquarters as they are received
             by Regional project officers.

             Complete on a quarterly basis a standardized coding
             and reporting form for water quality and grants
             administration data on each project, and input this
             information or have it entered into the STORET and
             GIGS systems.  The water quality data will be
             continually reviewed to assess the effectiveness
             of the program and for preparing reports for admin-
             istration officals to be used before Congress and
             the public.  Copies of the quarterly reports must
             be sent to Headquarters on a quarterly basis for
             this purpose.

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                        - 187 -
          o  Provide Headquarters a brief  (approximately one
             page) summary of each project on October 1 of
             each fiscal year, describing the project status,
             water quality impacts, and public benefits
             derived in relationship to the costs incurred.

          o  Carry out 404 (c) "pre-designation" activities for
             the advanced designation of areas subject to
             EPA's authority under that section.  This in-
             cludes participation in plan formulation, review,
             evaluation, and comment on plans which specify
             particular areas subject to 404 (c) designation.
             It may involve site visits, technical assess-
             ments, interagency and inter-office coordination
             within Regions or between Headquarters, and
             participation in meetings and public hearings.

     Region-Specific Guidance/404

     Two specific problem areas which warrant extraordinary
     attention because of anticipated future difficulities,
     are:

          Alaska, which is characterized by conflicting
          public interests in a resource-rich, but relatively
          little understood ecoregion.  (Much research is
          needed on the unique ecosystems, and special
          policies/procedures may need to be developed to
          deal with the unique and often large-scale problems
          likely to be encountered.)

          The arid Western States, where increasing compe-
          tition for scarce water resources will require
          greater involvement in State-Regional planning
          and the development of special policies/procedures.

Effluent Standards and Guidelines

Priorities;  FY 80

     It is expected that 24 sets of toxic control effluent
     regulations will be promulgated during FY 80.  These
     regulations will incorporate the "fundamentally different
     factors" (PDF) variance clauses into BAT, BCT and NSPS
     as a general provision of all regulations.  Because of
     the sensitive and highly complex nature of the regula-
     tions and the supporting "record",  Headquarters expects

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                        - 188 -


     that the Regions will consult fully the Effluent Guide-         ^
     lines Division  (EGD)  on any FDF variance requests.  All         f
     such requests, whether approved or disapproved by the
     Regional Administrator, are to be forwarded to EGD for
     concurrence prior to final action.  Any FDF variance
     thus submitted will be in writing and supported by
     copies of all relevant data and information upon which
     the decision was based.

     BAT Regulations Public Hearings

          o  Encourage public participation at public hearings
             in review of proposed effluent guidelines.

          o  Ensure that all data conform to the Agency's
             Quality Assurance Policy and Management Plan
             and are properly stored in STORET.

Water Quality Monitoring and Analysis

Priorities; FY 80

          o  Assess and solve multi-media, multi-source
             problems e.g.,  waste disposal sites and related
             ground and surface water problems, and ensure
             that multi-media toxic chemical data are entered
             into STORET.

          o  Review Advanced Waste Treatment (AWT)  and
             Advanced Secondary Treatment (AST) proposals,
             and improved technical capabilities for conducting
             and reviewing Wasteload Allocations (WLAs).

          o  Guide and direct State monitoring activities
             within the framework of the Basic Water Monitoring
             Program.

          o  Review Section 301(h)  waiver applications for
             technical accuracy.

          o  Coordinate Federal monitoring efforts.

     Data Collection Support Priorities

     Headquarters will expect significantly increased support
     and assistance by all Regions in 1980 in the effluent
     guidelines process.

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                   - 189 -
Headquarters generally expects continued, in some
cases expanded, assistance by Regional S&A Divisions
to conduct monitoring activities of various industrial
facilities or POTWs in support of vastly expanded data
gathering efforts.  In this regard, the Regions can
expect requests for specific assistance in obtaining
data on sludge, waste, spill, and runoff from industrial
sites as well as POTWs, and general assistance and
advice on impacts of BAT and RCRA, monitoring problems,
technology issues and the like.

     o  Collect and analyze toxic chemical data to
        support Sections 301, 302, 304, 306, 307(a)(l)
        and (2), 307 (b) (1) and 405(d) of the Clean Water
        Act of 1977 and the revised NRDC/EP Settlement
        Agreement.  These data will be used to develop
        BAT, New Source Performance  (NSP) and Pretreat-
        ment Regulations, and BPWTT for POTWs, and to
        develop programs for specific areas where control
        more stringent than BAT is necessary.

     o  Improve the toxic chemical analytic capabilities
        of the States.

     o  Develop the use of biological monitoring,
        especially as a screening tool for toxic chemicals
        and other problem identification.

     o  Maintain a minimum proficiency for conducting
        toxic chemical laboratory analysis.  This is
        required to support the Agency's Quality
        Assurance Policy and Management Plan.

     o  Collect and analyze priority pollutant samples
        shown in Table 1 and store the resulting data in
        STORET for use by the Monitoring an^ Data
        Support Division (MDSD) for support of effluen-t
        regulation development, and for conducting
        exposure/risk studies, fate studies, and studies
        to determine the instream effects of specific
        effluent levels  (dilution studies).  For this
        effort, the Region should recommend a monitoring
        plan which includes sampling sites and schedules.
        The Regions will be responsible for sample
        collection, laboratory analysis, quality assurance,
        data handling, data entry into STORET and progress
        reports submitted bimonthly to Headquarters.
        Headquarters will review the Regional toxic
        monitoring plans, and may elect to collect addi-
        tional samples for toxic chemical analysis under
        contract.

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                       - 190  -
          o  Since the toxics chemical monitoring effort
             will ultimately require State involvement (e.g.,
             compliance monitoring, water quality-based
             effluent limitations etc.),  the Regions should
             work with its States to develop a plan for
             analyzing toxic chemicals, using any combination
             of Regional, State, or contractual support.
             Emphasis should be placed on improving the toxic
             chemical analytic capabilities of those States
             showing potential, and improving the proficiency
             of those States which have fully developed their
             capabilities, e.g., effort should be made to
             ensure that all laboratories within a State
             integrate sample analyses, where possible, to
             meet multi-media needs.

Activities, FY 80

     The Regional monitoring program will engage in the
     following activities:

          o  Participate fully in the Agency's Quality
             Assurance Policy and Management Plan.  Parti-
             cipation will be mandatory and each program
             and laboratory should make the permanent
             commitment of manpower necessary for this effort.
             The Regions should also evaluate State, local,
             and contractor laboratory quality assurance
             performance and ensure that they conform to the
             Agency's QA plan.  Continuing emphasis must be
             placed on acquiring technically sound and
             legally-defensible data.

          o  Conduct problem assessments, including ground
             water, surface water, and biological sampling,
             at those hazardous waste disposal sites known
             or suspected of posing a threat to public
             health or sensitive aquatic ecosystems.  Store
             all data in STORET.  These data will be used to
             identify problem areas and will serve as a
             basis for defining Water Quality Management
             priorities and necessary remedial actions.

          o  Provide technical review of wasteload allocations
             (WLA) and AWT/AST proposals.  In FY 80, much more
             attention will be placed on the adequacy of
             monitoring activities conducted to support WLA

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                  - 191 -
        and AWT/AST decisions.  Since each Region
        will be expected to review and concur with
        wasteload allocations—including intensive
        survey designs, monitoring or related data,
        and modeling results—it is important that
        the Region provide adequate capabilities in
        this area.

     o  Oversee and guide State implementation of the
        Basic Water Monitoring Program.  Each Region
        must evaluate State conformance with this
        program and negotiate specific work plans
        with the States through the State/EPA
        Agreement process.  Emphasis should be
        placed on intensive surveys, especially for
        multi-media problem assessments, biological
        studies of specific ecosystems, and wasteload
        allocations; operating the national ambient
        monitoring station network under the Basic
        Program; following EPA's quality assurance
        program; entering data into STORET; and,
        expanding the Section 305 (b) reports.

     o  Operate the STORET system and support States
        storing data in STORET.  To assist in this
        effort, each Region should designate a
        high level professional in a technical divison
        as a STORET data base manager to be responsible
        for the transfer of all Regional/State data,
        including multi-media toxics data into STORET.

     o  Summarize and evaluate State Section 305 (b)
        reports.  Each Region should guide and assist
        the States in preparing these reports and
        transmit them to EPA Headquarters by
        April 1, 1980.

     o  Review Section 301(h) waiver applications for
        technical accuracy.

Region Specific Guidance

The Water Quality Monitoring Program requires the
following:

     o  Each Region is expected to include any Regional
        output not presently identified in this
        Guidance package.  Examples include:  preparing
        special data reports and responding to
        inquiries and requests from State and local

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                       - 192 -

             governments; coordinating with other Federal
             agencies;  modeling activities to support
             specific programs, etc.

Water Quality Enforcement

Regional Priorities and Activities;   FY 80

     I.  Initiate enforcement actions in emergency
         situations involving substantial threats to
         public health and safety.

          o  Respond to extreme emergency situations
             under Section 504.

    II.  Conclude all enforcement actions involving major
         source enforcement effort cases, including
         municipalities and Federal facilities.

          o  Work with the respective U.S. Attorney
             conducting technical and legal activities
             necessary to resolve all pending referrals,
             including municipal and Federal facilities.

   III.  Enforce against violators of the Clean Water and
         Ocean Dumping Acts (other than MSEE).

          o  Conduct pre-enforcement evaluations of self-
             monitoring reports from permittees  for whom
             EPA has primacy.

          o  Conduct an enforcement evaluation (technical)
             of self-monitoring reports from permittees
             for whom EPA has primacy.

          o  Conduct sampling inspections of major
             permittees.

          o  Conduct compliance evaluation inspections of
             major permittees (see PPA 5&6 explanation,
             following Enforcement PPA list).

          o  Issue administrative orders and notices of
             violations to violators of National Pollution
             Discharge Elimination System (NPDES) permits.

          o  Refer and follow-up NPDES cases .

          o  Assess civil penalties against significant
             ocean dumping and SPCC violations.

          o  Take enforcement actions against oil spill
             cases,

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                   - 193 -
      o  Prepare NPDES quarterly noncompliance
         reports.

      o  Maintain and improve Regional ADP systems
         to support tracking of compliance with the
         NPDES program).

      o  Monitor and enforce Section 404 violations,
         minimally.

      o  Re-evaluate and if necessary, rewrite existing
         Memoranda of Agreement to reflect changes in
         NPDES regulations.

IV.  Expand toxics and hazardous substances control
     programs.

      o  Begin implementation of the toxics compliance/
         enforcement program.

      o  Conduct compliance sampling inspections using
         bioassay screening for toxic substances.

      o  Conduct compliance sampling inspections for
         toxic substances for secondary permittees.

      o  Begin the pretreatment monitoring program.

      o  Implement the pretreatment monitoring program.

      o  Take enforcement actions against violators of
         hazardous substances regulations.

 V.  Implement the Municipal Policy and Strategy.

      o  Implement designated phases of the municipal
         policy and strategy;  coordinate with States
         and Headquarters in carrying out the strategy.

             PCS/GIGS interface.

VI.  Improve enforcement methods.

      o  Conduct audits and/or overview of NPDES
         States, including review of States NPDES
         quarterly noncompliance reports.

      o  Update the Discharge Monitoring Report  (DMR)
         quality assurance program (see PPA 11
         explanation, following Enforcement PPA list).

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             - 194 -


o  Implement updated Enforcement Management             "
   System (EMS) procedures.

o  Coordinate with Headquarters re-evaluation
   of existing compliance monitoring and
   enforcement programs (continuous compliance
   effort).

o  Implement enforcement strategies for
   specified categories (i.e., electric utilities,
   iron & steel/ etc.).

o  Load permit limitation data for Compliance
   Assurance System (CAS), beginning in early
   part of FY 80; loading of DMR parametric
   data will follow upon the completion of the
   loading of the permit data; the automatic
   violation detection capability of CAS will
   be operational in FY 1981.

o  Assure States CAS data quality.

o  Assist/overview NPDES States implementation
   Of EMS.

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                        - 195 -

Water Enforcement - Permits Issuance

Regional Priorities and Activities; FY 80

     Permits Issuance Program will focus on the development
     and implementation of toxic controls through the second-
     round permit effort and the pretreatment effort, reissuing
     major municipal permits in accordance with the National
     Municipal Strategy, and on streamlining the permit pro-
     cess through the initiation of the Permits Consolidation
     effort.  Priority activities are broken down as follows:

          o  Reissue Major Industrial Permits - One of the
             more resource intensive activities in FY 1980
             will be the introduction of BAT/toxic controls
             in industrial NPDES permits.  As the BAT/toxic
             guidelines are promulgated towards the end of
             FY 1979 and the early part of FY 1980, Regional
             Permits Program personnel will be required to
             incorporate these revised limitations into
             existing NPDES permits.  In addition, where BAT
             controls are not promulgated (largely for
             "secondary" industries), the Permit program will
             be responsib?.<3 for developing toxic limitations
             for these sources based on best engineering
             judgement (BEJ).  This is a very time and
             resource-consuming process.

          o  Reissue Major Municipal Permits - The National
             Municipal Policy published in FY 1979 sets forth
             the priorities for issuing expiring major
             municipal permits.  This policy, developed by an
             Agency-wide task force, requires that reissued
             municipal permits incorporate the results of
             301(i)  determinations which allow POTWs an
             extended compliance schedule for installing
             secondary treatment.  In addition, the Policy
             dictates that reissued major municipal permits
             include the requirement to develop a pretreatment
             program where appropriate.  The incorporation of
             these two requirements will entail increased
             resources over those needed in previous years to
             reissue major municipal permits.

          o  Permit Consolidation - FY 1980 will witness the
             development of consolidated permit-writing units
             in the Regional offices.  These permit-writing
             organizations will contain positions for permit

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             196
drafting, paper flow, and an initial point of
contact for issuing consolidated permit
relating to the NPDES, Hazardous Waste,
Underground Injection Control, Ocean Dumping,
New Source, and other permit-like programs.
In addition, the first consolidated NPDES-RCRA
permits should be issued by the Regional offices
in FY 1980,

Pretreatment Program Approval - In FY 1980,
considerable Regional resources must be devoted
to reviewing and approving or denying requests
for local pretreatment program approval. In the
24 States which have not received NPDES approval,
EPA will be responsible for making an initial
determination on the requests for State pre-
treatment program approval, and forwarding
recommendations to Headquarters for the Admini-
strator's final determination.

Overview State Programs - Regional resources
devoted to overviewing "approved NPDES State
programs will remain fairly constant from FY 1979
to FY 1980.  In FY 1980, it is anticipated that
three additional States will receive NPDES
approval.  Studies conducted by the Headquarters
and Regional offices have determined that dele-
gation of State programs will reduce Regional
office resources    a base level beyond which
no further resource reduction is possible.  In
the NPDES program, we have witnessed a general
reduction of Permit Program resources from a
high of 490 positions in FY 1974 to the FY 1980
level of 237 positions.   This reduction in permit
issuance resources is largely attributable to
the delegation of State NPDES programs.  As work
load analyses indicate,  however, a base level of
Regional personnel must be maintained to insure
sufficient overview of State programs.  This base
level amounts to approximately 162 Regional posi-
tions nationwide.  As most Regions are currently
functioning at this base level, increased re-
ductions due to State delegations are not antici-
pated.  In addition, the nature of the State
programs to be overviewed becomes increasingly
complex as additional programs, such as RCRA,
UIC, and 404 are assumed by the States,,  As
these State programs become more complicated,
the task of the Regional personnel in overviewing
the State programs similarly becomes more
difficult and resource intensive.

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                        - 197 -
          o  Conduct Adjudicatory Hearings - In order to
             clear the way for the new enforcement initiatives
             envisioned by the FY 1980/1981 Office of Enforce-
             ment priorities, it will be necessary for Regional
             offices to address as many high priority adjudi-
             catory hearings as possible.  Enforcement pro-
             ceedings are stayed pending the resolution of
             such hearings.

     In addition to the above enumerated priorities, the
     Regional Offices should, where resources permit, continue
     other significant, yet lower priority, activities such
     as review of Dredge and Fill permits; issuance of New
     Source permits, based on New Source Performance Standards;
     and development of preliminary determinations on requests
     for 301 (c)  and (g) economic and water quality variances,
     316 thermal variances, and fundamentally different
     factors variances.

Region Specific Guidance

     While the Regional Offices should generally follow the
     priorities set forth in the previous sections, the
     order of priority may change from Region to Region.  The
     top priorities set forth in this guidance may not be
     resource intensive for some Regions, and thus they may
     wish to devote resources to other activities because of
     the importance of the activity within the Region.  For
     example,  certain 316 requests for variance may be
     sufficiently beneficial to the environment to justify
     Regional resource expenditures.  The following Regions
     should ensure that significant priority is given to the
     listed activities:

          o  Region I - Particular attention should be given
             to 301(h) marine waivers in Region I.  The
             Region should ensure that resources are available
             to incorporate the results of 301(h) determina-
             tions into NPDES permits.  In addition, the
             Region should devote considerable attention to
             ensuring that POTWs in Massachusetts develop
             pretreatment programs where appropriate as the
             Regional Office will be primarily responsible
             for overseeing the implementation of the pre-
             treatment effort in this State, since it has
             not yet received its NPDES delegation.
             Massachusetts is anticipated to have a signi-
             ficant number of industrial users subject to
             Federal pretreatment standards.  Region I should
             similarly focus on ensuring that second round
             permits with BAT/toxic controls are issued to
             industrial sources in Massachusetts.

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              - 198 -
o  Region Ii - Region II should focus special
   attention on ensuring that pretreatment programs
   are developed by appropriate POTWs in the State
   of New Jersey.  New Jersey is expected to have
   large numbers of indirect dischargers subject
   to pretreatment requirements and since the State
   has not received NPDES delegation, the Regional
   Office will be responsible for ensuring that
   such standards are complied with by industrial
   users and that appropriate POTWs are required
   to develop programs to control the discharge
   of pollutants by these industrial users.  In
   addition, Region II should place priority on
   issuing direct discharge BAT/toxic permits in
   the State of New Jersey,  Finally, Region II
   has the largest number of outstanding adjudi-
   catory hearings to address.  Priority should
   be given to resolving these hearings.

o  Region III - Region III should ensure that
   resources are provided to work with the Regional
   404 (Dredge and Fill Program) Office in assisting
   States to develop 404 programs.  Regional NPDES
   personnel are particularly capable of providing
   this type of assistance since the 404 State
   program requirements are virtually identical in
   most cases to the 402 NPDES State program re-
   quirements .

°  Region IV - Region IV, like Region III, has a
   significant number of wetland areas and should
   work with the Regional 404 Office in ensuring
   that State 404 programs are efficiently and
   effectively developed.  In addition, Region IV
   should give high priority to issuing second
   round BAT/toxic permits to those sources for
   which it is responsible.,  This Region has the
   largest workload of EPA issued BAT/toxic permits.,

o  Region V - Since the States in Region V have all
   received NPDES approval,, priority in this Region
   should be given to approving State pretreatment
   programs where appropriate, and overviewing
   State programs.

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           - 199 -

Region VI - As none of the States in Region VI
have received NPDES delegation, Region VI
activities should focus on issuing BAT/toxic
permits to industrial sources in these States
and ensuring that appropriate POTWs in these
States develop pretreatment programs.  In
addition, because of the significant number of
wetland areas in Region VI, the Permits in
this Region should work with the 404 program
office to ensure that the Region VI States
develop efficient and effective 404 State
programs.

Regions IX and X - As both of these Regions
have jurisdiction over large coastal areas,
their priorities are similar.  Regions IX and
X should ensure that resources are available
to incorporate the results of Section 301(h)
marine variance determinations into NPDES
permits.  In addition, the Permits personnel
in both Regions should work with the Regional
404 program offices in ensuring that the States
in these Regions develop efficient and effective
404 State programs.

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                        - 200 -
PROJECTED PROGRAM ACCOMPLISHMENTS

B230 - MUNICIPAL WASTE TREATMENT FACILITY CONSTRUCTION

The following set of PPA's are to be included in the
operating plan to be submitted by the Regions.  Final
determinations on whether the PPA will be an output
commitment or an activity indicator will be made at a
later date.  (Further PPAs may be required for FY 1980
related to delegation progress, and will be included by
separate memorandum.)

                    (Construction Grants PPAs)

1.  Gross dollar obligations.  This is a cumulative
    quarterly estimate for FY 1980 of the gross rate of
    obligations by State excluding  P.L. 84-660 and 206(a)
    reimbursable fund.

2.  Gross dollar deobligations.  This is a cumulative
    quarterly estimate for FY 1980 of the deobligations
    made to prior grants during the year, excluding
    deobligations from Section 206(a) awards.

3.  Number of new awards by step.  This is a cumulative
    quarterly estimate for FY 1980 of the number of new
    awards (excluding amendments) by State by step.

4.  Number of completions by step.  This is a cumulative
    quarterly estimate for FY 1980 of the number of
    completions by State by step.

5.  Outlays.   This is a cumulative monthly estimate for FY
    1980 of the dollar amount of outlays by State.

6.  Number of new step 1 awards which have had an individual,
    or joint, preapplication conference.  This is a
    cumulative quarterly estimate for FY 1980 by State, of
    the number of new step 1 awards for which individual,
    or joint, preapplication conferences have been held
    prior to  or immediately after the award of the Step 1
    grant.

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                          -  201  -
 7.  Number of step 1 completions which have had midcourse
     facility planning meetings.   This is a cumulative
     quarterly estimate for FY 1980 by State, of the
     number of step 1 completions for which midcourse
     facility meetings have been held.,

 8.  Date five-year priority list is accepted by EPA and
     input into the GIGS system.   This is the estimated
     date for FY 1980 by State, when a priority list
     (meeting all regulatory requirements under section
     35.915 and section 39.915-1 and policy guidance under
     PRM #78-13) is accepted and input into GIGS.

 9.  Number of EISs initiated, related to construction
     grants project.  This is a cumulative estimate for FY
     1980 by State, of the number of environmental impact
     statements (EIS) related to construction grants
     projects that were required by issuance of a "notice
     of intent" during the period.

10.  Number of new step 1 awards with "full scale public
     participation programs."  This is a cumulative
     quarterly estimate for FY 1980 by State, of the
     number of Step 1 awards for which a "Full Scale
     Public Participation Program", as defined in section
     35.917-5(e) of the proposed regulations on Public
     Participation, will be initiated.

11.  Percent and dollar amount of new step 1, 2, 3 dollars
     awarded to minority business enterprise (MBEs).
     This is a cumulative quarterly estimate for FY 1980
     by Region, of the percent of A/E and construction
     contract dollars awarded to MBEs.,

12.  Date for awarding construction management assistance
     grant to State.  This is the estimated date for FY
     1980 when each State (where applicable) will sign
     a Construction Management Assistance Grant (CMAG)
     Agreement with EPA.

13.  Number of work-years oif Corps of Engineers personnel
     under the step 3 management agreement.  This is
     the workyear estimate for FY 1980 by State, of

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                          - 202 -
     the number of workyears of Corps of Engineers employees
     involved in the EPA construction grants program under
     the step 3 management IAG.

14.  Dollar value of the innovative/alternative technology
     used in construction grants projects.  This is the
     dollar estimate for FY 1980 by State of the eligible
     cost of the innovative or alternative portion of
     construction grants projects qualifying for the 2%
     set-aside under section 35.915-l(b).

15.  Dollar value of small community projects using
     altenative technology.  This is a dollar estimate for
     FY 1980 by State of the total eligible cost of small
     community projects using innovative or alternative
     technologies, which qualify for the 4% set-aside
     under section 35.915-l(e).

16.  Number of AWT projects reviewed and the number of
     these plans changed because of review.  This is an
     annual estimate for FY 1980.

17.  Number of facility plans reviewed which include
     Innovative and Alternative technology.  This is an
     annual estimate for FY 1980.

                 (Operations & Maintenance PPAs)

18.  Number 1 Step 1 and Step 2 projects receiving operational
     reviews.  This is an annual estimate for FY 1980
     by Region of facility plans and P&S operational reviews
     intended to remove unneeded upgrade projects from
     State priority lists and to identify major influent
     control and design deficiency problems for grantee
     correction before final grant payment.

19.  Number of projects receiving strict operations
     checklist application.  This is a quarterly estimate
     for FY 1980 by Region of major projects and selected
     minor projects to which the operations checklist will
     be applied.

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                          -  203  -
20.   Number of Step 3 grant awards conditioned on timely
     completion of approved plan of operation schedules.
     This is an annual estimate for FY 1980 by Region
     of projects for which plan of operation schedules
     will be strictly enforced.

21.   Number of Step 3 grants awarded with separately
     identified start-up service subagreements.  This
     is an annual estimate for FY 1980 by Region.

22.   Number of O&M inspections of new and upgraded
     Federally-funded treatment plants.  This is a
     cumulative quarterly estimate for FY 1980 by State of
     the number of O&M inspections of each new or upgraded
     plant conducted by EPA Regions or States before Step
     3 close-out; also, approximately one year after
     start-up, and documented on a completed EPA Form
     #7500-5. Actual inspections are to be identified
     by project number for input to the O&M Data system.

23.   Number of O&M inspections of existing plants.
     This is a cumulative quarterly estimate for FY 1980
     by State of the number of O&M inspections of each
     existing plant conducted by the State and reported on
     EPA Form #7500-5.  EPA accompanies the States on 15
     percent or more of these inspections.  (One-third of
     each State's operating POTWs are to receive such an
     inspection each year.)  Actual inspections are
     identified in the O&M Data System by project number.

24.   Number of problem plant follow-up inspections.  This
     is a cumulative quarterly estimate for FY 1980 by
     Region of the number of State or EPA Region inspections
     on existing plants with known operationl problems
     (identified through prior inspections, review of
     operating records, or referral from other sources)
     to verify corrective action previously required
     or to specify probable causes of the problems.
     The actual number of inspections will be reported
     manually through the Formal Reporting System.

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                         -  204 -
25.   Number of POTWs brought into compliance through
     coordinated enforcement and assistance actions.  This
     is a cumulative quarterly estimate for FY 1980 by
     Region of the number of on-site assistance projects
     (by private contract, States, or EPA and coordinated
     with enforcement), which will yield reliable compliance
     with NPDES permit effluent limits.

B212 - Spill Prevention and Response

1.   Number of spills into inland waters of the U.S. at
     which a qualified EPA On-Scene Coordinator (OSC) was
     present on-scene to direct removal mitigation actions:

             Oil spills
             Hazardous subtances spills
             Other environmental emergencies
             (not included above)

2.   Number of spills into inland waters of the U.S. at
     which a qualified EPA OSC was present on-scene to
     monitor removal/ mitigation actions:

             Oil spills
             Hazardous substances spills
             Other environmental emergencies
             (not included above)

3.   Number of responses by a qualified OSC, for which his
     presence was not required, but for which resources(s)
     were expended (e.g., telephone monitoring, coordination,
     State actions, environmental response team (ERT)
     on-scene, etc.)

4.   Number of spill prevention inspections of all types
     conducted by Regional staff technical assistance team
     (TAT), or ERT personnel at non-transportation related
     facilities.

5.   Number of workyears of technical assistance provided
     to States for training field personnel in responding
     to environmental emergencies.

6.   Number of Federal Disaster Assistance Administrator
     mission assignments to assist or provide technical
     support in a Federally declared disaster to which EPA
     responded.

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                        - 205 -
Water Quality Training
          o  Completed State assessments of Section 205
             program related training needs.

          o  Number of State Agency personnel training in
             Section 205 curricula.

          o  State assessment of POTW training needs.

          o  Number of POTW personnel receiving training. .
             total and at Section 109(b) training centers.

          o  Number of States with:

                Completed 109 (b) training centers

                Operator Training Coordinating Committees

          o  Number of Direct Training courses and trainees

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                             -  206  -
B203 - WATER QUALITY MANAGEMENT - SECTION 208/106

(Reporting Requirement:  SL-Start Level; M-Monthly; Q-Quarterly;
        3A-3emi-Annually;  A-Annually; R-Regional only;
                 S-by-S -  State-by-State)

1.  Number of FY 1981 State/EPA Agreements concluded. (SL, M,
    S-by-S)

2.  Number 208 planning grants awarded covering AWT Planning.
    (SL, A, R)

3.  Amount of 208 funds obligated for planning covering AWT
    Planning.  (SL,A, R)

4.  Number of 208 planning grants awarded covering Otner
    Facilities Planning (SL, A, R)

5.  Amount of 208 funds obligated for planning covering Other
    Facilities Planning (3L, A, R)

6.  Number of 208 planning grants awarded covering Septics (SL,
    A, R)

7.  Amount of 208 funds obligated for planning covering Septics
    (SL, A, R)

8.  Number 208 planning grants awarded covering Urban Runoff
    (SL, Q, R)

9.  Amount of 208 funds obligated for planning covering Urban
    Runoff (SL, Q, R)

10. Number of 208 planning grants awarded covering Construction
    Runoff (SL, Q,R)

11. Amount of 208 funds obligated for planning covering Construc-
    tion Runoff (SL, Q, R)

12. Number 208 planning grants awarded covering Agriculture NP3
    (SL, Q, R)

13. Amount of 208 funds obligated for planning covering Agriculture
    NPS (SL,  Q, R)

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                             - 207 -
14. Number of 208 planning grants awarded covering other NFS
    (SL, Q, R)

15. Amount of 208 funds obligated for planning covering other NFS
    (SL, Q, R)

16. Number of 208 planning grants awarded covering Groundwater
    (SL,Q, R)

17. Amount of 208 funds obligated for planning covering Groundwater
    (SL, Q, R)

18. Number of State agencies funded for FY 1980 under a consolidated
    105/208/314 work plan  (SL, Q, R)

19. Number of FY 1980 State 106  programs approved   (SL, Q, R)

20. Number of FY 1981 State 106 programs approved (A, R)

21. Amount of FY 1980 State 106 funds obligated  (SL, Q, R)

22. Increase, FY 1980 over FY 1979, in State 106 funds committed
    in approved or amended State programs for implementation of
    NFS controls under approved 208 plans or parts of plans.
    (SL, Q, R)

23. Decrease, FY 1980 vs. FY 1979, in State 106 funds committed
    in approved or amended State programs for support of Construction
    Grants Program Management. (SL, Q, R)


24. Number of 208 planning outputs (recommended pollution control
    measures) approved by EPA for national priority problem cate-
    gories (AWT, septics, urban storm runoff, construction runoff,
    and agriculture, groundwater, mining, and silviculture NFS)
    (SL, SA,  R)

25. Number of 208 planning outputs approved by EPA for other
    than national priority problem categorties.

26. Number of tfaste Load Allocations approved as an output of
    208 planning  (SL, SA, R)

27. Number of population projections approved as an output of
    208 planning  (SL, SA, R)

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                            -  208 -



28. Number of WQM plans (as defined  in Section 35.1521)  certified
    and approved within 150 days of  submission  (Q,  3-by-S).

29. Number of EPA approved designated management agencies imple-
    menting approved plans or  parts  of plans for control of national
    oriority problem categories (AWT, septics, urban storm runof,
    construction runoff,  and agriculture,  groundwater, raining, and
    silviculture NFS)  (SL, SA, R)

30. dumber of EPA approved designated management agencies implemen-
    ting approved plans or parts of  plans  for control of other
    problem categories  (SL, S, R)

31. Number of Regional person  years  for designated management
    agency oversight  (SA, R) .

32. Number of Regional person   years for all other WQM program
    mangement  (208/106).  (SA,  R)

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                             - 209 -



   B253 - Ocean Disposal and Permits

   1.   Number of interim permit applications acted upon.

   2.   Number of special permit applications acted upon.

   3.   Number of implementation schedules of interim
        permittees monitored.

   4.   Number of Corps of Engineers dredged material permit/
        project applications reviewed.

   5.   Number of offshore industrial activities evaluated.

   6.   Number of sanctuary sites identified.

   7.   Number of sanctuary sites studied.

        (Reporting Requirements:  SL-Start Level; M-Monthly;
        Q-Quarterly; SA-Semi-Annually; A-Annually; R-Regional
        only; S-by-S - State-by-State)

B244 - Clean Lakes

1.  Number of State/EPA Agreements and work plans reviewed and
    commented on.

2.  Number of State lakes classification grants awarded

3.  Number of State lakes grant applications processed for award.

4.  Number of clean lakes grant aplications processed for non-award.

5.  Number of clean lakes projects completed.

6.  Number of quarterly progress reports received, reviewed and
    approved.

7.. Number of standardized 3TORET and GIC3 reporting forms completed
    and the information put in the computer systems.

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                           - 210 -
B209 - Dredge and Fill

(Reoorting Requirement:   SL-Start level;  M-Monthly; Q-Quarterly;
R-Regional only; and 3-State only)


1.  Major Permit Review.   Review, evaluation, comment on, and
    other actions related to the processing of major federal or
    state individual Section 404 and/or Section 9/10 permit appli-
    cations.  May include site visits and participation in hearings.
    Major permits are deemed to constitute 14% of total individual
    permits based upon the average over 10 regions of the categori-
    cal breakdown using the criteria established in FY '79 (see
    attachment).  The actual work element for PPAs 1-3 is public
    notices received.  (SL-M-R)

2.  Important Permit Review.  As  in 1, for important permits
    established as 51% of all individual permits.  Less likely to
    involve site visits or hearings.  (SL-M-R)

3.  Minor Permit Review.   As in 1, for minor permits established
    as 35% of allIndividual permits.  Will not normally involve
    site visits or hearings.  (SL-M-R)

4.  404(c) Actions.   Activities concerning exercise of the EPA
    "veto" power of Section 404(c).  Pre-initiation site and
    record evaluation, initiation of action, additional site
    evaluation, record development, preparation of action documents,
    support of public hearing, and support of adjudicatory hearing
    (if held). "(M-R)

5.  General Permit Review.  Review, evaluation, comment on and
    other actions related to the processing of federal or state
    general Section 404 permits.  (Q-R)

6.  Enforcement Support  Activities in support of EPA or Corps of
    Engineers enforcement actions with regard to either noncompliance
    with permit conditions or unauthorized  activities  (non-permitted).
    May involve site evaluation, record development, preparation
    of action documents,  and support of administrative actions
    under Section 309 and/or litigation by Office of Enforcement,
    the Corps, or the Department of Justice.  (Q-R)

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                             - 211 -
7.  Compliance Monitoring.  Field inspections to ascertain state
    of compliance for permitted activities, to detect unauthorized
    activities, and to evaluate cumulative impacts of activities
    conducted under general permits or 208(b)(4) BMPs.  Will
    normallv be carried out in conjunction with EPA or Corps
    enforcement officers using land, water, or aerial surveillance
    methods.  Pricing includes preplanning, field work, documenta-
    tion, and initiation of follow-up action if (any).  (Q-R)

8.  State 404 Program Transfer Assistance.  All activities involved
    with transfer to qualified states of the 404 program including
    pre-submittal consultation and assistance, review of program
    submissions, documentation of findings and recommendations,
    coordination with headquarters and other agencies, assistance
    with needed revisions, and assistance in early phases of program
    operation. (Q-R)

9-  State 208(b)(4)  Program Transfer Assistance.  As in 8, with
    regard to State 208('o)(4)  regulatory programs plus the review
    of State-submitted Best Management Practices for classes and
    categories of appropriate activities.  Activities here will
    be in support of 208 program personnnel who have the lead in
    this area and in coordination with the Fish and Wildlife
    Service which is mandated to provide technical assistance to
    States pursuant to Section 208(i).   (SL-Q-S)

10. EIS Review - non-404(r).  Pre-planning oarticipation, review,
    and comment on environmental impact  assessments, statements,
    and related documents submitted along with a 404 and or Section
    9/10 permit application or which involve wetland resources or
    404-type activities even when no such permit is required.  Does
    not include EIS 's submitted with the intent of seeking a 404(r)
    exemption for major federal projects.  May involve participation
    in public hearings anc< litigation.   (SL-Q-R)

11. FIS Review - 404(r).  As in ]0( exceot for those EIS's submitted
    with the intent "of seek-.ng 3 404(r)  exemption from permitting.
    The scopeP complexity controversy,  and political interest
    inherent in these major congressionally-authorized projects  is
    much greater than for other projects and a commensurately higher
    level of resources Is 'required to adequately evaluate and
    document the degree to whjer the EIS adequately considers the
    factors and criteria of the 40^(b) environmental guidelines.
    Includes coordination with headquarters, CEQ, and other agencies,
    (SL-Q-R)

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12. CZM Plan Review.  Particioation in plan formulation, review,
    evaluation of, and comment on State Plans under the Coastal
    Zone Management Act and the Special Area Management Plans
    which soecify the detailed land use Plans for particular
    coastal areas.  Objectives include assisting with planning
    for the wise use of aquatic resources and ensuring that the
    Plans comply with Clean T^ater Act provisions in accordance
    with the consistency mandate of Section 307(f)  of the CZMA.
    Participation in public hearings and litigation (if any).
    (SL-Q-3)

13. Administrative and Program^ Management and Overhead.  All other
    activities at the regional level necessary for  the effective
    operation of the 404 Program, including:

    °   administration - supervision, personnel action, contracting,
       budget preparation and funds management, recruiting, training,
       etc.


    0   technical review and comment on regulations  and other policy
       documents, research reports, and other studies,

    0   review of 208 and other regional plans not covered above

    0   coordination with/assistance to the Fish and Wildlife Service's •
       National Wetlands Inventory.

    °   development of regional guidelines or supplements to
       national regulations/policies

    °   public information and education

    0   general coordination with headquarters, the  Corps of Engineers,
       NOAA, States, Interstate and River Sasin agencies, and others.
       (Not applicable as reportable requirement)

3303-Water Enforcement

  PROJECTED PROGRAM ACCOMPLISHMENTS DEFINITIONS
                                                                        4
(PPVs which have not been defined are considered to be self-expla-
natory - the numbers refer to PPA's for FY 1980)

    The term "compliance monitoring" is a generic term meant to
cover  all activities taken to ascertain a discharger's compliance
status.  This includes, but is not limited to, compliance inspec-
tions  -- NPDES Compliance Evaluation Inspections and NPDE3 Sampling
Inspections, and compliance review -- the review of discharge
monitoring reports and compliance schedule reports.  The main
function of NPOES compliance inspections is to verify self-monitor-    M

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                             - 213 -


ing information and develop the basis for possible follow-up
enforcement action.  "Compliance monitoring" may also include
aerial monitoring and special site visits for other non-NPDES
enforcement purposes but compliance monitoring resources have
not been provided to support these efforts.  All inspection
activity is to be conducted on the premise that it may lead to
enforcement action.

    PPA 1+2.  Pre-enforcement evaluation is the initial evaluation
of compliance information to arrange the noncomplying sources in
sequence for subsequent enforcement review.  This is essentially a
routine process for the preliminary screening an3 prioritizing of
noncompliance within an established procedural framework.

    Techical enforcement evaluation takes place following the
pre-enforcement evaluation.  It is a substantive, technical eval-
uation of noncompliance identified as other than routine violations.
This evaluation is done to determine the appropriate level of
enforcement action to be taken.

    PPA 3-5.  A visit to a facility for compliance inspection
is to be counted in only one of the categories listed.  Thus, a
single visit cannot be counted as a compliance evaluation inpsection
as well as a sampling inspection.  It must be one or the other.

    PPft 3+4.  Sampling Inspections are inspections at which
representative  composite sample (s) of a permittee's effluent is
collected and analyzed to verify the accuracy of the Permittee's
discharge monitoring reports.  This activity also includes the same
objectives as a compliance evaluation inspection, and where appro-
priate, mav serve to gather detailed information for the possible
institution of legal action against the permittee. However, credit
is to be given to only one type of inspection.  In this case
it would be Eor a sampling inspection.  We recognize that sampling
inspect ions are considerably more resource intensive than compliance
evaluation inspections.

    A "representative composite sample" consists of a series of
aliquots or discrete samples collected during the course of an
operating day, collected at the location specified in the permit or
appropriate representative location chosen by the inspector, and
appropriately weighed for variations in flow and/or concentration to
be representative of the effluent discharged during the sampling
period.

    A grab sample may be taken to satisfy this definition only in
those situations when the inspector has sufficient knowledge of the
manufacturing process and wastewater treatment facility to ensure
that a grab sample will be representative of the permittee1s discharge

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*,
    A FY 80 priority will be given to the utilization of sampling
resources more directly in support of enforcement needs.  That is,
case development and followup in support of the major source enforce-
ment drive will receive first priority.  In allocating resources,
the next highest priority will be given to ensuring that municipal
permittees operating under 301(i) extensions are achieving full
compliance with their extensions schedules.  Finally, remaining
sampling resources should be allocated to ensure the continued
compliance of major permitees with 3PT or secondary limitations.


    It is expected that every major Permittee meeting statutory
effluent limitations should be sampled annually, by either EPA
or the State.  Priority will be given to sampling permittees achiev-
ing statutory effluent limits and for verification for continued
compliance with statutory effluents limits once achieved.

    A sampling inspection is considered complete only when the
sampling inspection is followed by the completion of the appropriate
sections of a Compliance Inspection Report (EPA Form 3560-3).
Guidance for conducting sampling inspections and for submitting the
appropriate report forms are contained in the "NPDES Compliance
Sampling Inspection Manual" which has previously been provided to
EPA Reaions and States.

    In FY 80 review of DMR data will be automated utilizing a
computerized data management system which will be called the Compli-
ance Analysis System (CAS).  When CAS becomes operational in the
Regions, parametric data from samples collected and analyzed as part
of a CSI will be entered into the system as a requirement for the
crediting of a completed CSI.

    PPA 5 + 5.  Each major municipal and nonmunicipal facility
should be inspected by the State or EPA a minimum of once annually
during the compliance schedule period and more often during critical
phases of construction.  In addition, those permittees that have
online treatment facilities should be inspected to verify the
adequacy of their self-monitoring program and records and to assure
that their operation and maintenance program is being conducted in a
manner that will ensure permit compliance.  In summary, compliance
evaluation inspections are undertaken for one or more of the follow-
ino purooses:

    1.  observe the status of construction required
        by the permit;

    2. assess adequacy of the  permittee's self-
       monitoring and reporting program;

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                             - 215 -


    3. check the completeness and accuracy of
       permittee's performance/compliance records;

    4. evaluate the permittee's operation and
       maintenance activities; and

    5. express concern that permit requirements
       be met.

In FY 80 EPA will provide major permittees with an annual set
of performance samples.  The series of samples sent the permittee
will be governed by the effluent limits contained in the permit,
and at a maximum will contain samples for minerals, demand, suspended
solids, metals and nutrients.  As one of the stated purposes of
a CEI is to "assess the adequacy of the permittee's self-monitoring
and reoorting orogram," CEIs will be employed to follow-up on
permittees who do not perform within an acceptable range of error on
one or more of the performance samples.

    To ensure that the above outlined objectives are met, a Compliance
Evaluation Inspection of a municipal or nonmunicipal facility is
considered complete onlv when the site inspection is followed by the
completion and submission of the appropriate portions of a Compliance
Inspection Report Form (EPA 3560-3).

    Guidance for conducting CEIs and submitting the appropriate
report forms are contained in the NPDES Compliance Evaluation
Inspections Manual (revised 1/78) which has previously been provided
to EPA Regions and States.

    Compliance Evaluation Inspections of municipal facilities, as in
FY 79, have as one of their primary purposes the evaluation of the
permittees operation and maintenance activities as they relate to
present and future permit compliance.  CEIs do not serve as the
means of obtaining operation and maintenance information for the
annual Section 210 report to Congress.  Operation and maintenance
data for the Section 210 report is derived from operation and
maintenance inspections utilizing EPA Form 7500-5.  It is recognized
however, that in many EPA Regions the personnel performing compliance
inspections are also the same personnel who perform operation and
maintenance inspections.  Efficient utilization of scarce resources
dictates that for inspections of major municipal facilities that
fall within the program guidance priorities of OWE and OWPO, that
bot i EPA Forms 3560-3 and 7500-5 be completed and counted in FPRS.

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                             - 216 -
    In FY 80 an Interagency agreement with the Corps of Engineers may
be completed whereby the Corps will perform Compliance Evaluation
Inspections for construction purposes on major POTWs being financed
under the construction grants program.  The Corps will complete a
modified version of the Compliance Inspection Report (EPA Form
3650-3) and the appropriate inspection tracking data will be entered
by the Regions in PCS. CEIs performed by the Corps will not be
counted against the Regions CEI commitment.

    PPA. 7.  In FY 80 we will make a significant increase in the
number of compliance sampling inspections using biomonitoring to
screen for toxic substances in the discharges from permittees in the
primary industrial classifications.  The objectives of the boimoni-
toring program are to:

    1. Identify those permittees who may be meeting BPT or secondary
       treatment effluent limitations but whose level of treatment
       is not sufficient to ensure the biological integrity of the
       receiving waters.

    2. Identify those permittees who may have potential toxicants
       in their discharge (s) that have not been identified in
       their permit.

    3. Evaluate compliance with permit toxicity limit requirements.

    In those instances where biomonitoring reveals the presence of
toxic substances not addressed in the issued permit, the permittee
may be required through the 308 process to chemically and/or physical-
ly characterize the composition of the discharge to identify and
quantify the toxic substances or substances.

    All Agency comoliance sampling inspections using acute toxicity
bioassay techniques for determining permit compliance and/or toxicity
levels must do so in strict adherence with the methods and materials
described in "Methods for Measuring the Acute Toxicity of Effluents
to Aquatic Organisms" (EPA-600/4-78-012; Revised July"1978).
Identification of the inspection as a biomonitoring inspection
should be made by placing the letter B in the inspection type box
(#18) located at the top of page 1 of Form 3560-3.

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                             - 217 -


    In the near future, the above referenced technical manual
will become an appendix of a larger Agency biomonitoring manual.
Once published, this manual will become the Agency's official
NPDES Biomonitoring Compliance Evaluation Manual.  The manual is
expected to be completed by September 1979.

    PPA 8.  Compliance Sampling Inspections for Toxic Substances

    In recognition of the increased laboratory support required
for compliance monitoring of permittees with discharges to toxic
substances other than heavy metals, phenols and cyanides, we
have created a separate PPA for CSIs that require such laboratory
support.  These inspections have the same overall objectives as a
conventional CSI, but are approximately 17% more expensive to
perform than an industrial CSI.  To identify the inspection as  a
toxics CSI, place the letter X in the inspection type box (#18),
located at the too of page 1 of the compliance Inspection Report
Form 3560-3.

    PPA 9 + 10.  Performance Audit Inspections Conducted by Regions

    In FY 80 we will begin a shift in emphasis away from routine
compliance monitoring inspections to more specific support of
enforcement needs by our inspection resources.  This change in
emohasis will not effect our basic inspection goal of having each
major permittee inspected by EPA at least once during the five-year
life of the permit.  To accomplish this shift in emphasis within
the framework of our basic inspection policy, a third type of
compliance inspection will be added to the two types of compliance
inspections now performed by the Regions. This third type of
compliance inspection, to be known as a "Performance Audit
Inspection" (PAI, requires on the average only 37.6% of the
resources now utilized for the performance of conventional CSIs.
A PAI has as its primary objective the verification of the
permittee's self-monitoring program.  This does not differ from
the primary objective of our other two types of compliance
inspections.  However, how this objective is achieved differs
from the techniques used in a CSI or CEI.  In conducting a PAI
the inspector(s) will verify the permittee's program by observing
the permittee perform all the steps in the self-monitoring process
-- from sample collection and flow measurent to laboratory
analyses and data workshop and reporting.  The procedures develop-
ed for PAIs will be equally applicable to verification of both
chemical and biological self-monitoring data.

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                             - 218 -


    Guidance on the objectives of a PAI and procedures on how
a PAI shall be conducted will be forthcoming from Headquarters
orior to the beginning of FY 80.  For planning purposes, a
PAI will require on the average 12 work days or require 5.45 work
years to perform 100 PAIs.

    PPA 11.  DMR Quality Assurance Program

    In FY 80 EPA will provide each major permittee with an annual
set of performance samples.  The series of samples sent the
permittees willbe governed by the Effluent limitations contained
in the permit, and at a maximum, will contain samples for minerals,
demand, suspended solids, metals and nutrients. Permittees
will be required to analyze the samples and return the data to
the local coordinator (EPA or State) within a fixed time period,
generally 30 days.  Followup on non-acceptable performance may
range from a letter and/or telephone notification, laboratory
evaluation, AO issuance, to formal legal action, depending on the
cause of the nonacceptable performance.

    As one of the stated purposes of a CEI is to "assess the
adequacy of the permittee^ self-monitoring and reporting program,"
CEIs will be employed to follow-up on nonacceptable performance
by permittees in those cases where a laboratory inspection is
necessary. CEIs used for followup on the DMR Quality Assurance
program have been set out as a separate PPA.  It is anticipated
that the initial nonacceptable rate for permittees will be 60%
and that 1/3 of the nonacceptable permittee1 s laboratories will
require on-site followup inspections. More specific guidance on
the objectives and procedures of the DMR Assurance Program will
be forthcoming from Headquarters prior to the beginning of FY
80.

    PPA 12.  Construction Verification Inspections Conducted by
the Corps of Engineers

    In FY 80 an Interagency Agreement with the Corps of Engineers
will be comoleted whereby the Corps will perform CEI on major
municipal wastewater treatment facilities being financed under
the construction grants program. The objective of these CEIs will
be to verify construction progress.  The Corps will complete a
modified version of the Compliance Inspection Report (EPA Form
3560-3) and the appropriate inspection tracking data will be
entered by the Regions into PCS through the interface with
GICS.

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                             - 219 -


    Although CEIs performed by the Corps will not be counted
against the Region's CEI commitment, this activity has been
designated as a separate PPA to better identify and track the
number of CEIs performed by the Corps for this specific purpose.
It is anticipated that the Corps will be able to perform approxi-
mately one-third of the municipal CEIs now performed by EPA. The
resource saving from this activity may now be shifted into
oerforining CEIs from DMR Quality Assurance followup.

    PPA 13.  Pretreatment Compliance Evaluation Inspections

    In FY 80 we will begin a modest program to verify compliance
with pretreatment requirements for major contributing industries.
Compliance Evaluation Inspections will be used to verify permit
pretreatment requirements and completion of the appropriate
portions of the standard NPDES Compliance Inspection Report will
be required. Identification of the inspection as a pretreatment
evaluation should be made by placing the letter P in the inspec-
ion tvpe box (#18) located at the top of page 1 of form 3560-3.

    PPA 14.  Dredge and Fill Compliance Evaluation Inspections

    In FY 80 we will conduct a modest number of site visits to
verify compliance with section 404 dredge and fill permits.
Compliance Evaluation Inspections will be used to verify section
404 permit conditions and completion of the appropriate portions
of the standard NPDES Compliance Inspection Report will be
required. Identifcation of the inspection as a section 404 dredge
and fill evaluation should be made by placing the letter D in the
inspection type box (418) located at the top of  page 1 of Form
3560-3.

    PPA 15.  National State Overview Program

    The National State Overview Program has been developed to
assure that the States which have been delegated the primary
authority for the administration of the NPDES program, exercise
their enforcement perogatives in a consistent manner.  Under the
Act, the Agency has a continuing responsibility to make certain
that these State-run programs operate in accordance with National
standards.  The State Overview program is a fulfillment of the
Agency's regulatory responsibiities and insures that the regulated
puD.lic receives equitable treatment in meeting the requirements
of their <^PDSS oermits.  The program identifies a number of
overview activities which will establish a base level of Agency
presence in each State to ascertain whether NPDES requirements
are being met.  Since the costs associated

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                           - 220 -
with these activities cannot be accurately measured using the
Water Quality Enforcement model, a separate State Overview model
has been developed for issuance with specific Regional guidance
on the administration of a State Overview Program.  This guidance
will be issued prior to the beginning of PY 80 and require the
development of annual State Overview plans which describe Region-
al overview activities and their associated costs based on the
new model.

                PLANNED PROGRAM ACCOMPLISHMENTS

1.  Number of pre-enforcement evaluations of  self-monitoring
reports.

2.  Number of technical enforcement evaluationsof self-monitoring
reports.

3.  Number of compliance sampling inspections of major municipal
oermittees. (commitment - quarterly)

4.  Number of compliance sampling inspections  of major nonmuni-
cipal permittees, (commitment - quarterly)

5.  Number of compliance evaluation inspections of major nonmuni-
cipal permittees, (commitment - quarterly)

6.  Number of compliance evaluation inspections of major nonmuni-
cioal permittees, (commitment - quarterly)

7.  Number of compliance sampling inspections conducted using
biomonitoring screening for toxic substances.  (commitment -
quarterly)

8.  Number of compliance sampling inspections for toxic substances,
(commitment-quarterly)

9.  Number of performance audit inspections of major municipal
permi ttees.  (commitment-quarterly)

10. Number of performance audit inspections of major nonmunicipal
permittees.  (commitment - quarterly)

11. Number of compliance evaluation inspections conducted for
DMR QA followup.   (commitment - quarterly)

12. Number of municioal construction evaluation inspections
performed by the  Corps of Engineers.  (commitment - semi-annual)

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                           - 221 -
13. Number of compliance evaluation inspections for pretreatment
conducted.  (commitment - semi-annual)

14. Number of compliance evaluation inspections conducted to
monitor compliance with major dredge and fill permits.  (commit-
ment - semi-annual)

15. Number of NPDES AOs and NOVs issued.

16. Number of municipal NPDES cases referred to Headquarters.
(commitment quarterly)

17. Number of nonmunicipal NPDES cases referred to Headquarters.
(commitment - quarterly)

18. Number of SPCC (no plan) actions initiated by the Regions.
(commitment - quarterly)

19. Number of Ocean Dumping actions initiated by the Regions.
(commitment - quarterly)

20. Number of oil spill violations referred to the CG and U.S.
Attorney, (commitment - quarterly)

21. Number of hazardous substance violation referrals to Head-
quarters, (commitment - quarterly)

22. Number of section 404 enforcement actions taken by the
Peqions. (commitment - quarterly)

23. Number of Quarterly Noncompliance Reports prepared.

24. Number of audit and/or overview of State NPDES program
conducted, (commitment - quarterly)

25. Number of pretreatment AOs and NOVs issued.  (commitment
- quarterly)

26. Number of pretreatment referrals to Headquarters, (commitment
- quarterly)

27. Number of Regional referrals of noncomplying Federal facili-
ties,  (commitment - quarterly)

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                           - 222 -
28. Average amount of time (days) it will take the Region to
respond to major NPDES permit violations.  (commitment - quarterly)

29. Number of major municipal permittees not in compliance with
schedule requirements.  (commitment - quarterly)

30. Number of major municipal permittees not in compliance with
effluent  requirements.   (commitment - quarterly)

31. Number of major nonmunicipal permittees not in compliance
with schedule requirements.  (commitment - quarterly)
32. Number of major
with effluent r
    nonmunicipal permittees not in compliance
quirements.   (commitment - quarterly)

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                           - 223 -
3306 - Permit Issuance

1.  Number of major permits in "primary industries" reissued or
extended.

2.  Number of major permits in "primary industries" reissued by
BAT guidelines.

3.  Number of major permits in "secondary industries" reissued.

4.  Number of major permits in "secondary industries" reissued by
best engineering judgement (no BAT guidelines)

5.  Number of major funded POTW permits issued or reissued, (not
301(i) modifications)

6.  Number of ajudicatory hearings for major industrial and
municipal permits initiated in previous FY, denied, conducted
and/or settled

7.  Number of ajudicatory hearings for major industrial and
municipal permits initiated in current FY, denied, and/or settled.


8.  Number of dredge and fill materials discharge permits reviewed,

9.  Number of new source permits based on NSPS issued

10. Number of exoiring major municipal permits modified to
incorporate compliance schedule time extensions pursuant to
section  301(i)

11. Number of municipal POTW pretreatment programs to be develop-
ed and approved.

12. Number of major municipal (POTW) dischargers  that must have a
permit.

13. Number of major industrial permits issued and in effect (not
expired).

14. Number of major municipal permits  issued and  in effect (not
expired).

15. Number of major primary industrial dischargers that must have
a permit.

16. Number of major secondary industrial dischargers that must
have a permit.

17. Number of major Federal facility permits issued and in effect
(not expired.)

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1980/1981 DRINKING WATER MEDIA GUIDANCE

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                       DRINKING WATER

MEDIA OVERVIEW

     The goal of the drinking water program is to
protect the public health by assuring the safety
of the drinking water.

     Assuring the safety of drinking water is primarily
the responsibility of State and local governments.
However, Congress has determined that the Federal
Government should share in this responsibility by
assisting, reinforcing, and setting standards for
State and local efforts.

     The Safe Drinking Water Act requires (1) primary
health related drinking water regulations requisite
to protect the public health,  (2)  public water systems
supervision programs  (PWS) to assure compliance with
the regulations, (3) underground injection control
programs  (UIC) to protect underground sources of
drinking water, and  (4) the provision of emergency
assistance.  The Act envisioned that the States would
have primary enforcement responsibility for both the
PWS and UIC programs.  Moreover, the Act is designed
to encourage voluntary compliance with the regulations.

     The program activities will focus on implementation
of the primary drinking water regulations in non-primacy
States and on Indian lands, assistance on the implementation
of the trihalomethane and synthetic organics regulations;
maintaining a strong management program in primacy States
to assure primacy implementation;  continuing efforts to
encourage non-primacy States to assume primacy; emergency
assistance; financial assistance to States; research,
development and implementation of additional regulations
to control other contaminants in drinking water; implementation
of a program to protect underground sources of drinking water;
the initiation of enforcement actions to ensure compliance
and implementation of State/EPA agreements.

     Activities within each major area involve at least
two of the program offices.  The assignment of program office
responsibilities is based on program expertise.  In general,
the Office of Drinking Water and its Regional counterparts
will be responsible for the program activities involving
on-going communications with the public, the water systems,
injection facility operators, and the States.  The responsi-

-------
                           - 228 -


bilities also include laboratory certification, technical
assistance and evaluations, standards development, technicail
expertise in regard to variance and exemption applications
and other legal action, data handling and evaluation, UIC
primacy application review, technical evaluation of
permit applications, and sole source petitions reviews.

     Drinking Water Enforcement positions in Headquarters
will be devoted to the following activities:  permitting
and enforcement guidance for the UIC program; coordination;
budget and administrative efforts; legal strategies for
regional and State overview programs, including guidance on
compliance monitoring and inspection; enforcement and legal
assistance for regional PWS programs; and legal support for
actions initiated in response to emergency situations.

     Regional Drinking Water Enforcement staff will participate
with Drinking Water program offices in legal aspects of
issuing variances and exemptions by assisting in developing
compliance schedules and interim reporting and monitoring
requirements to be included in variances and exemptions to
be approved by the Regional Administrator (unless otherwise
delegated); providing legal and administrative support in
initiating formal enforcement actions; working with ODW to
ensure enforceability of compliance actions or other require-
ments imposed on public water systems; issuing UIC permits
to facilities disposing of wastes underground; investigating
and initiating civil and criminal actions for violations of
the UIC regulations; and providing technical and legal support
in legal actions initiated in response to emergency situations.

     The Research program will relate to:   (1) causes,
diagnoses, and prevention of diseases and other impairments
in man resulting directly or indirectly from contaminants
found in drinking water; (2) the treatment and control of
those contaminants; and (3) the provision of dependable,
economical, and safe supplies of water, including the
protection of underground sources of drinking water.
Research will also be conducted to develop and implement
quality assurance procedures and protocols for water supply
laboratories to assure that laboratory analytical data are
accurate and valid.

Planning Assumptions

     The planning and operating guidance for FY 1980
is based upon the following assumptions.  For consistency
purposes, the Regions are requested to adopt similar
assumptions in preparing their submissions.

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                           -  229  -

          o  Currently proposed organic regulations
             will be promulgated in Summer,  1979.
          o  Revised drinking water regulations
             will be proposed in early FY 1980.
          o  UIC regulations will promulgated by
             January, 1980.
          o  By FY 1981,  all 57 States will be listed
             as requiring underground injection
             control programs.  They will then become
             eligible for grants.  The following list
             shows for each year, the number of States
             first becoming eligible in that year:

               -  FY 1979 - 23
               -  FY 1980 - 18
               -  FY 1981 - 16

          o  Consolidated permit regulations
             will be in effect in FY 1980.
          o  EPA itself will utilize the grant allo-
             cation for underground water source
             protection of listed States that  (1)  do
             not apply for grants or (2) indicate
             that they will not assume primacy for the
             UIC program.
          o  Sole/principal Source Aquifer (1424(e))
             regulations will be promulgated in
             Spring, 1979.
          o  In FY 1980,  EPA will implement public
             water systems supervision programs in
             12 States:  Indiana, Pennsylvania, Oregon,
             District of Columbia,  South Dakota, Utah
             Wyoming, Illinois, Vermont, North Carolina,
             American Samoa, and Northern Marianas.
          o  A legislative amendment extending the
             compliance schedule for exemptions will
             be adopted.

     These assumptions represent the best projections
based upon information available to Headquarters at
this time.  There undoubtedly will be changes; however,
for consistency these assumptions should be reflected
in Regional operating plans.

Media Priorities

     The media priorities for FY 1980 and FY 1981
provide general guidance reflecting the National
Program Managers' high priority items.  These
priorities may differ from one Region to another
depending upon each Region's particular situation.
Regions maintain the flexibility to pursue priorities
which satisfy the needs of their unique situations.

-------
                 -  230  -
°  Priority 1 activities are:

        to establish maximum contaminant
        levels and/or treatment techniques
        to assure the safety of drinking
        water.
        to implement the organics regulations.
        to initiate enforcement actions and
        respond to emergency situations
        involving substantial threats to
        public health.
        to take enforcement actions, as
        necessary, in non-primacy States.
        to maintain a strong management
        program in primacy States including
        overview of State enforcement
        activities and grants administration.
        to develop a coordinated ground-water
        policy and strategy by the third
        quarter of FY 80.
        to encourage State assumption of
        primacy for PWS and UIC programs.
        to implement and enforce a program
        for assuring compliance with the
        primary drinking water regulations
        in non-primacy States and on Indian
        lands.
        to conduct research into the health
        effects and treatment of trace
        organics and investigate alternative
        disinfectant techniques.
        to maximize program effectiveness and
        integration through the consolidated
        permits program, the State/EPA agreements,
        etc.
        to complete the assessment of surface
        impoundments.

o  Priority 2 activities are:

        to protect designated sole source
        aquifers.
        to develop UIC implementation plans
        where necessary.
        to investigate the relationship of
        inorganic contaminants and asbestos
        fibers on health.
        to provide technical and legal
        assistance for enforcement actions
        in primacy States.
        to increase public awareness and
        public participation.

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                          -  231 -

          °  Priority 3 activities are:

                  to develop a coordinated ground-
                  water research program.
                  to conduct research on direct and
                  indirect additives.
                  to conduct studies on home water
                  treatment devices.
                  to initiate enforcement actions
                  in primacy States, as appropriate,
                  where a State is unable to or fails
                  to do so.

HEADQUARTERS PLANS

Abatement and Control

     Headquarters Plans and Priorities — The Headquarters
     plans and priorities(which involve Regional and State
     involvement) for FY 1980/1981 focus on the protection
     of the public health through the establishment of
     drinking water standards that assure the safety of
     the drinking water, protection of underground sources
     of drinking water and management of State delegations
     and EPA's continued implementation of the public water
     systems supervision and underground injection
     control programs.

          FY 1980 planned activities fall into the
     following three priority levels:

          o  Priority 1 activities include:

                  Development of drinking water
                  regulations which address pathogens
                  and radiological contaminants;
                  establishment of maximum contaminant
                  levels for particular organic compounds
                  and proposal of Revised Drinking Water
                  regulations for inorganic contaminants.
                  Management of the implementation
                  of the organics standards.
                  Conduct of economic analyses in
                  support of regulations development.
                  Headquarters coordination with Regions
                  to encourage non-primacy States to
                  assume primacy.
                  Analysis of the financial impact
                  of the drinking water program and the
                  subsidy issue.
                  National oversight of the implementation
                  of the public water systems supervision
                  program based upon Federal Reporting Data
                  Systems data.

-------
                 -  232  -
        Promulgation of the underground
        injection control program regulations.
        Development of a coordinated ground-
        water policy and implementation
        strategy with Regional and State
        participation.
        Development of technical guidance
        documents relating to implementation
        of the UIC program.
        Initiation of public awareness and
        public participation activities for
        the ground water program.
        Review of primacy applications.
        Issuance of toxicological opinions
        relating to spills and emergencies.
        ADP in support of regulation changes.
        Guidance on SEAs to implement program
        integration goals.

o  Priority 2 activities include:

        Development of a mandatory laboratory
        certification program.
        Review of water treatment additives.
     -  Analytical support relating to spills
        and emergencies.
        Development of UlC-related training
        program for Regional and State personnel
        Analysis of the surface impoundment
        assessment data.
        Public participation activities
        related to the public water systems
        supervision program.
     -  Guidance on UIC program implementation
        on Indian lands.

o  Priority 3 activities include:

        Development of drinking water
        criteria applicable to land treat-
        ment, hazardous waste, etc.
        Development of a policy relating to
        home water treatment devices.
        Recommendations based upon the
        Rural Water Survey.
        ADP system enhancements.

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                          - 233 -
          FY 1981 projected activities and priorities
     will include in addition to the continuing FY 1980
     activities:   (1)  promulgation of new bacterial
     standards, (2)  promulgation of the Revised Drinking
     Water Regulations, (3) development of a regulatory
     strategy to control corrosivity of water in distri-
     bution systems, (4) preliminary activities directed
     at the establishment of wastewater reuse criteria,
     (5) a major new initiative  for regulating  drinking water
     additives through use of TSCA authorities.  These
     activities will primarily be included as Priority 1
     activities,  subject to resource constraints.

     Changes (FY 1980)  -- EPA intends to list all
     57 States as requiring underground injection
     control programs  by FY 1981.  By FY 1980,  a total
     of 41 States will be listed (the original assumption
     was based upon 22 States being listed).

     Alternatives for  carrying out the program — In
     non-primacy States, the use of contractors/grantees
     to implement operational activities such as
     conducting inventories, sanitary surveys,  data
     processing should be considered.  Resources for these
     contracts/grants  are available in the FY 80 budget.
     The feasibility of using term employees to implement
     EPA enforcement responsibilities in non-primacy
     States which will eventually assume primacy may
     be investigated.

     Modification of PWS grant regulations to allow
     use of grant funds in non-primacy States will
     be considered.
Enforcement
     Priority 1

     The Drinking Water Enforcement program's first
     priority for FY 80 will be response to emergency
     situations involving substantial threats to public
     health.

          o    Headquarters will provide any assistance
               required by the Regions for preparation of
               enforcement cases initiated in response to
               emergency situations involving substantial
               threats to public health.

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                     - 234  -
Priority 2

Plans will include preparation of guidance necessary
to conduct programs required under the Safe Drinking
Water Act.

     o    Develop an enforcement manual to address
          how and when enforcement actions should
          be taken where non-compliance with Public
          Water System requirements has been identi-
          fied.  (Estimated distribution date for
          final document:  2nd quarter, FY 80)
     o    Develop guidance for implementation of an
          Underground Injection Control Enforcement
          Program to control underground injections,
          including toxic substances (Estimated
          distribution of final document:  3rd quarter,
          FY 80).
     o    Develop guidance for issuing Notices of
          Violation (Estimated final distribution:
          1st quarter, FY 80).
     o    Develop compliance assurance guidance covering
          compliance monitoring and inspection activities
          for the Public Water System Program (Estimated
          final distribution:  3rd quarter, FY 80).
     o    Develop guidance for Regions overviewing
          State Underground Injection Control Programs,
          addressing enforcement actions and assessing
          adequacy of control of underground injection
          of toxic substances (Estimated final distri-
          bution: 4th quarter, FY 80).

Priority 3

Headquarter will overview enforcement actions and
assist where necessary to assure compliance with
requirements of the Act.

     o    Review all referrals to the Department of
          Justice and provide legal assistance to the
          Regions in the preparation of major enforcement
          actions concerning violations of National
          Interim Primary Drinking Water Regulations,
          including organics.
                                                              4

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                          -  235  -


FY 81 - Plans and Priorities

     Priority 1

     The first priority for FY 81 will continue to be
     response to emergency situations involving substantial
     threats to public health.

          o    Headquarters will provide legal and technical
               support, as requested, to Regions initiating
               enforcement actions in response to emergency
               situations.

     Priority 2

     As a second priority, Headquarters will prepare guidance
     for conducting those programs required under the Safe
     Drinking Water Act.

          o    Develop guidance on enforcement actions
               covering non-compliance with variances
               and exemptions, including non-compliance
               with the January 1, 1981 Interim Primary
               Drinking Water Standards deadline (Estimated
               final distribution:  1st quarter, FY 81).
          o    Develop guidance covering compliance
               monitoring and inspection procedures for
               a UIC enforcement program (Estimated final
               distribution:  2nd quarter,  FY 81).

     Priority 3

     As a third priority, Headquarters will overview
     enforcement actions and assist where necessary to
     assure compliance with requirements of the Act.

          o    Review all referrals to DOJ and provide
               legal assistance to the Regions in the
               preparation of major enforcement actions
               concerning violations of National Interim
               Primary Drinking Water Regulations,  including
               organics.

FY 80 - Changes

     More attention will focus on assessing the adequacy of
State Public Water System Enforcement Program.  Initial
effort will also be directed in FY 80 to phasing in the
Revised Primary Drinking Water Standards.

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                       -  236  -
     FY 81 - Changes

          Attention will  focus  in FY  81 on  compliance with
     Interim Primary  Drinking Water Standards and on enforce-
     ment actions necessary  to  assure compliance.  EPA will
     also begin to assess State Underground Injection Control
     Enforcement Programs for adequacy.
Research and Development

           The Safe Drinking Water Act is reasonably speci-
     fic in setting forth the Agency's responsibilities, so
     it has been possible to develop a drinking water
     strategy with a "step-by-step" schedule of future
     activities.  One major element of this strategy is to
     conduct research to improve the scientific and tech-
     nical basis for Primary and Secondary Drinking Water
     Regulations (especially regulations based on Maximum
     Contaminant Levels — MCL's), and regulations to protect
     the quality of ground water.  The issues have been
     reviewed by a non-government advisory committee formed
     to update the 1962 U.S. Public Health Service Drinking
     Water Standards, an ad hoc group of the Agency's Science
     Advisory Board, the National Drinking Water Advisory
     Council and by the Drinking Water Research Committee
     during its deliberations on FY 80 research activities,.
     These groups and others from within the Agency's
     Operating and Research Offices determined that research
     was necessary to help answer the following basic
     questions:

           1.  What substances occur in drinking water
               supplies at a sufficient number of locations
               to warrant regulation?

           2.  What are the effects of these substances
               on human health?

           3.  What analytical procedures should be used
               to monitor water to assure that the Revised
               Primary Drinking Water Regulations are
               met?

           4.  Because some of these substances are formed
               during transport, storage, treatment and
               distribution, what changes in treatment
               practices would be appropriate to minimize
               the formation of these compounds in water
               delivered at the consumer's tap?

           5.  What treatment technology must be applied
               to reduce contaminant levels to the concen-
               trations specified in the Regulations?

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                  - 237 -
      The Agency has decided to focus on these broad
questions in order to develop a defensible basis for
standards.  These same questions apply to wastewater
when it is being considered as a water source for
drinking.  Underlying this research is a quality
assurance effort that also plays an important role in
the certification of non-EPA laboratories and, generally,
in assuring the reliability and accuracy of laboratory
analyses of drinking water samples.

      The setting of research priorities has resulted
primarily from the interpretations by the Office of
Drinking Water and the Drinking Water Research
Committee of the regulatory requirements set forth in
the Safe Drinking Water Act in light of the target
dates specified in that Act.  These groups have given
full consideration to the  gaps in existing information
and to the principal problems referred to them for
action by the Regions, the National Drinking Water
Advisory Council, and the National Academy of Sciences.
The research staff, however, plays a major role in
setting priorities due to their insight (derived from
experience)  regarding the general feasibility of broad
classes of analytical measurements, the time it takes
to conduct health effects and engineering experiments,
and the cost of generating additional research data.

      These deliberations resulted in a balanced
research program that includes studies of short- and
long-range health effects studies, as well as efforts
to improve analytic methods and treatment techniques.
Approximately 45 percent of the budget will go to health
effects projects (many of which are conducted jointly
with the Department of Health, Education and Welfare),
40 percent to the development of treamtment technology,
6.5 percent to improvement of analytical methods, and
8.5 percent to groundwater concerns.  These allocations
may change as a result of the Drinking Water Research
Committee's deliberations for FY 81.

      Trace organics are still the least understood
and most troublesome drinking water contaminants, so
approximately 43 percent of the funds are directed
toward that problem.  Research into trace organics
will examine their health effects, and will also
focus on development of appropriate monitoring and
treatment technology.  The second highest priority

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                  - 238 -
is the impact of inorganic contaminants, particularly
asbestos fibers, on health, so a large effort will be
made in this area, too.  We will also closely examine
the implications of the difference in the incidence of
cardiovascular disease between those consumers drinking
soft water and those drinking hard water.  Determining
the incidence and effects of microbial contamination as
well as developing appropriate monitoring and treatment
technology for such contaminants will remain a relatively
high public health priority because outbreaks of
water-borne disease still occur in the United States,
especially in poorly operated distribution systems.  We
will also study the causes of corrosion in distribution
systems and possible methods for controlling it, and we
will give greater attention to the development of
cost-effective treatment techniques for removing
contaminants from small water supplies.

      The various elements of the program have been
arrayed in priority order for FY 80/81.

      In the short term, our highest priority will be
technology development and assuring the quality of
analytical methods now in use.  In the long term,
emphasis will be placed on health effects, development
of improved analytical methods, and ground-water
research.

      The research strategy has been designed to
develop information from which EPA can determine if
there is a need to regulate additional drinking water
contaminants.  Furthermore, if regulations are deemed
appropriate, our research information can help
establish the levels at which standards should be set.
Our drinking water research data will also be used
by EPA's Office of Drinking Water to evaluate insti-
tutional solutions to some drinking water problems.
Some of the pertinent areas are regionalized water
supply systems to serve the small scale user, aid to
states regarding the economics of water supply, and
the management of water supply systems.

Better Methods to Identify and Quantify Contaminants
    In the absence of reliable contaminant measure-
ment and monitoring methods, it will be impossible to
provide scientifically valid and legally defensible
data to support and enforce the regulations issued

-------
                  - 239 -
under the authority of the Safe Drinking Water Act.
Consequently, primary emphasis will be placed on
continuing our quality assurance program in EPA,
state, local, and contract laboratories.
        Objectives

Priority 1

    Continuing quality
    assurance functions
    Analytical methods
    for organics
    Surrogate methods for
    measurement of classes
    of organics
Priority 2
    Analytical methods
    for microbial
    contaminants
Major Research
Quality assurance
program to supporu
monitoring require-
ments for Safe
Drinking Water Act
performance evalua-
tions, etc.

Analytical methods
for nonpurgeable
organics.

Surrogate methods
for measurement of
volatile organic
compounds.
Methods to determine
presence of cysts
and viruses.

Radiometric methods
for detection of
sanitary indicator
microorganisms in
treated water.

Analysis of ATP
(adenosine
triphosphate)
methods for moni-
toring bacterial
levels.

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                  - 240 -
Priority 3
    Multielement analytical     -   Comparison of
    techniques                      several methods
                                    of multielement
                                    analysis, i.e.,
                                    optical emission
                                    spectrometry with
                                    an inductively
                                    coupled plasma
                                    source and x-ray
                                    fluorescence.
Better Treatment Technology for Drinking Water —
The lack of unequivocal health effects data related
to organic contaminants in drinking water does not
relieve EPA of responsibility for developing appro-
priate treatment methods when reasonable doubt about
health effects exists and monitoring is not practical.
The development of treatment processes to control
organic compounds will be the first priority in the
area of treatment technology.  Organic contaminants
selected for study will be identified in surveys that
quantify the prevalence of the compounds and identify
available health effects data.  Treatment processes
will then be developed through bench and pilot-scale
studies and will be studied in field evaluations.
We will attempt to adopt some processes now used in
larger treatment systems for use in the smaller
systems.  In doing so, our objectives will be to keep
the technology simple enough so that the training
required for operators will be minimal.

      The two immediate needs in the inorganics area
are:  to develop treatment processes that will enable
small systems to meet regulations economically, and
to evaluate treatment processes for removal of asbesti-
forms.  A further objective will be the development of
treatment processes to control other inorganic
compounds in small systems, with primary emphasis on
the more troublesome inorganics such as nitrates,
arsenic, fluorides, and selenium.

-------
                  - 241 -
      The major thrust in the area of treatment tech-
nology to reduce microbial contaminants will be the
evaluation of alternative disinfection methods with
emphasis on (1) small systems and (2) preventing the
deterioration of water quality in distribution systems
        Objectives

Priority 1

    Processes for organics
    control including
    alternative disin-
    fection technology


Priority 2

-   Processes for inorganics
    control with emphasis
    on small systems
Major Research
Field studies
involving carbon
adsorption methods
for organics con-
trol.
Bench-scale studies
of techniques for
controlling fluo-
ride, arsenic,
nitrates and selenium,

Field studies to
evaluate full scale
operations of
promising
inorganics control
methods that were
successful at. bench
scale.

Field studies to
evaluate processes
for removing asbesin-
forms .

Special studies to
provide treatment
methods for small
systems, e.g.,
reverse osmosis,,
ion exchangef
activated alumina.,

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                  - 242 -
Priority 3
    Microbial control
    technology
                                    Virus and parasite
                                    removal.

                                    Identification of
                                    factors affecting
                                    growth of micro--
                                    organisms in
                                    distribution
                                    systems.

                                -   Development and
                                    evaluation of
                                    alternative
                                    indicators of
                                    disinfection
                                    efficiency.

Health Effects — As of April 1978, 698 organic com-
pounds had been identified in drinking water within
the United States. While important information on
incidence, concentrations, and health effects still
needs to be developed, a number of these compounds
are already strongly suspected to be detrimental to
health.  Therefore, we will first attempt to assess
the health effects of certain of these organic com-
pounds.  The focus of this health effect research
will be on potential carcinogenicity.  Because there
is such a large number of compounds, our research will
follow two distinct avenues of investigation.  First,
we will examine those compounds which have already
been identified as potential human health hazards.
Our second avenue of investigations will focus on
various groupings of compounds selected on the basis
of their high observed concentrations and high fre-
quency of occurrence, in conjunction with preliminary
determinations of significant hazard based either on
available data or on short-term bioassays.

      Considerable attention has been given to the
relationship between the presence of inorganic compounds
in drinking water and cardiovascular disease.  The
National Academy of Sciences predicted a possible 15%
reduction in heart disease mortality by manipulation
of the hardness of the nation's water supplies but

-------
                  - 243 -
stressed that the specific alterations that would be
appropriate have yet to be determined.  The Council on
Environmental Quality has also published information
that suggests a correlation between water softness and
heart disease.  As with organics, we will continue to
develop health effects information on these various
inorganic compounds.
        Objectives

Priority 1

    Health effects of
    organic compounds
    and alternative dis-
    infection techniques
Major Research
Concentration and
chemical character-
izations of organic
compounds from tap
water in five
cities.

Selection and
evaluation of
indices  of
organics
significant to
health.

Association between
cancer and exposure
to drinking water
contaminants.

Selection of
organic  parameters
which can be used
for standard
setting.

Toxicological and
epidemiological
studies  to validate
the health signi-
figance  of organic
parameters.

Health impacts of
the use  of alter-
native disinfection
techniques.

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                  - 244 -
Priority 2
    Health effects of
    inorganic compounds
    Health effects of
    additives used in
    treatment and distri-
    bution of drinking
    water
Priority 3
    Protect drinking
    water from micro-
    bial contamination
Health effects of
arsenic.

Neurochemical
effects of lead.

Carcinogenic poten-
tial of nitrate.

Health effects of
asbestiforms.

Inorganics and
cardiovascular
disease.

Assistance in
developing
protocols and
implementing
the program.
Annual review of
waterborne disease
outbreaks.

Characterization oi:
the etiological
agents of viral
gastroenteritis
and giardiasis.
Scientific Basis for Protecting Ground Water Quality
    A primary objective of the program is to identify
major problems in the protection of ground water and to
provide the appropriate assessment methods to States
and communities.  A corollary objective is to develop
scientific and engineering guidelines on which we can
base source control criteria.  Work on assessment

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                  - 245 -
methods will include development of biological and
chemical indicators of ground-water pollution, methods
to detect pressure increases resulting from well
injections, and protocols for determining, in any given
locality, the probable impact of specified activities
with known pollution potential.
        Objectives

Priority 1

    Assessment methods for
    monitoring the trans-
    port and transformation
    of ground water contami-
    nants
Priority 2
    Establish scientific
    basis for controlling
    various classes of
    pollutant sources
Priority 3
    Identification of
    major ground-water
    pollution problems
Major Research
Biological and
chemical indicators
of ground-water
pollution.
                                    Pressure increases
                                    resulting from well
                                    injections.

                                    Transport and
                                    transformation of
                                    hazardous materials,
Petroleum explora-
tion and development.

Land application of
waste.

Artificial recharge.

Agricultural practices
Extension of State-
specific studies
from the current 34
States to 50 States.

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                  - 246 -
Changes Anticipated - FY 80/81

o   The ORD public health initiative for FY 80 includes
    an increase of nearly $5 million over the FY 79
    level for health research.  These resources will
    be used to intensify our research into the health
    risks posed by organic, inorganic, and microbial
    contaminants.  A strong emphasis will be placed
    on organic compounds and their carcinogenic poten-
    tial.  ORD will initiate the development of an
    investigative strategy which will help address
    systematically the numerous organic compounds- that:
    have been identified as being of potential concern.
    Emphasis on the public health initiative will
    continue in FY 81.

o   In FY 80 and 81, we will emphasize field evaluations
    of modular treatment methods for control of
    organics. Information from these field evaluations
    will be used to guide regulation development and
    implementation.

o   In accordance with a congressional mandate, ORD
    expanded research into the reuse of wastewater for
    potable purposes by $8 million in FY 1979. $1
    million for the reuse program is in the FY 80
    research budget for drinking water.  ORD plans to
    budget the $1 million for FY 81 within the research
    budget for water quality.

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                           247 -
REGIONAL PLANS

Abatement and Control

     Regional Priorities f_or_ the Ground Water Protection
     Program — The Regional priorities for the ground water
     protection program center on the implementation of the
     underground injection control regulations, implementation
     of State/EPA agreements which encourage program inte-
     gration and completion of the surface impoundment
     assessment and protection of sole/principal sources
     of drinking water.  The FY 1980 planned activities fall
     into the following three priority levels:

          o  Priority 1 activities are:

               -  Emergency response to ground-water
                  contamination incidents.
                  Administration of the underground water
                  source protection grants.
               -  Providing technical assistance to States
                  to assume primary enforcement responsi-
                  bility by assisting in the review of
                  exis.ting legislation and regulations,
                  revising current State programs, etc.
                  Continuing oversight of grantees and
                  contractors conducting the Surface
                  Impoundment Assessment  (SIA) program.
                  Implement State/EPA agreements through
                  program .integration with RCRA, 208,
                  Environmental Impact Statements and NPDES
                  programs.

          °  Priority 2 activities are:

                  Processing petitions and project reviews
                  and preparing Memoranda of Understanding
                  (MODs) regarding Section 1424(e) - sole
                  source aquifer actions.
               -  Initiating UIC activities in non-primacy
                  States arc Indian lands such as inventories
                  for Class IV wells, aquifer mapping, inven-
                  tories and assessments for injection wells
                  ana negotiating interagency agreements
                  regarding program implementation on Indian
                  lando,

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                    - 248 -

             Promoting public participation in
             the UIC program and public awareness
             of statutory and regulatory requirements.

     °  Priority 3 activity is:

             Implementing data handling and storage
            procedures to process inventory data.

Regional Priorities for the Public Water Systems
Supervision Program — The Regional priorities focus
on implementation of the Interim Primary Drinking
Water Regulations including the organics regulations,
management of the State delegation and implementing
State/EPA agreeements.  The FY 1980 planned activities
fall into the following three priority levels:

     o  Priority 1

     Maintain and enforce a program for assuring
     compliance with the National Primary Drinking
     Water Regulations (NPDWR) in non-primacy States,
     Indian lands and over interstate carriers.

             Conduct sanitary surveys of high
             priority systems impacting public
             health.
             Implement Interagency Agreements  (lAGs)
             with the Indian Health Service (IHS).
             Conduct public hearings on exemption
             compliance schedules for community
             systems.
             Coordinate with the Enforcement Division.
             Issue and follow-up on violation notifi-
             cations .
             Implement non-community systems strategy
             plan.
             Manage the laboratory certification program.
             Maintain data management system.
             Provide training and public education.

     Provide emergency assistance after spills and
     ground-water contamination and situations involving
     imminent and subtantial health endangerment to public
     water supplies and underground water supplies.

             Supply technical assistance as needed.

     Administer grants to States to implement and
     maintain their public water system program.

             Award grants in timely manner.
             Conduct mid-year review of program plans.

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               - 249 -
        Provide data for national grant
        program.

Develop a strong oversight program for primacy
States to assure maintenance of primacy.

        Continue quality assurance for
        certified laboratories.
        Perform State-by-State management
        review and information exchange
        (evaluation).

Emphasize State/EPA Agreements with respect to
201, 208,  and National Pollutant Discharge
Elimination System  (NPDES) coordination.

        Encourage States to assume primacy.

o  Priority 2

Provide technical assistance to the States in
the implementation of the organics regulation.

        Implement monitoring of trihalomethane
        (THM) in cities over 10,000 (assuming
        the regulation  promulgated is the same
        as that proposed).
        Participate in training and public
        awareness forums in both primacy and
        non-primacy States.
        Assist States in revising regulations.

Provide technical assistance for synthetic
organics and the processing of variances and
exemptions to the organic regulations  (as promulgated)

        Participate in training and public
        awareness forums in both primacy and
        non-primacy States on monitoring and
        health effects of Granular Activated
        Carbon  (GAC) regulations.
        Assist States in processing variances
        and exemptions.
        Assist States in revising regulations.
        Review approach for GAC facilities.
        Provide analytical assistance/lab
        certification.
        Coordinate with Enforcement Division.

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                         - 250  -
          o  Priority 3

          Coordinate the public water system program
          with other environmental programs.
Enforcement
     Priority 1
          o    Initiate enforcement actions in response
               to emergency situations involving substantial
               threats to public health.
          o    Take enforcement actions,  as necessary,  in
               non-primacy States.
          o    Maintain overview of State enforcement
               activities.
          o    Respond to emergency actions involving
               imminent and substantial endangerment to health,
     Priority 2
          o    Provide technical and legal assistance for
               enforcement actions in primacy States.
          o    Develop a UIC enforcement program in
               the Regional office where designated States
               will not assume primary enforcement responsi-
               bility.
          o    Enforce the health related Primary
               Drinking Water Regulations including
               significant violations of MCLs,  reporting
               requirements, and public notification
               requirements. (Some actions will be contin-
               uation of actions initiated in FY 79.)
          o    Provide enforcement assistance to States
               having primary enforcement responsibility
               but which have requested EPA assistance in
               initiating enforcement action against
               violators of health-related primary
               drinking water regulations.
     Priority 3
          o    Initiate enforcement actions in primacy
               States where a State is unable to or
               fails to do so.
          o    Begin implementing a management information
               system designed to track compliance
               monitoring inspection and enforcement
               information.
          o    Overview State issued variances and exemptions
               and State initiated enforcement actions.

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          - 251 -
Work with designated UIC States on development
of a State ground water protection program
including an Underground Injection Control
(UIC) permit and enforcement program.
Issue Notices of Violation and initiate
appropriate follow up action in primacy
States that have not adequately enforced
the SDWA.

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1980/1981 SOLID K!ASTE MEDIA GUIDANCE

-------
                    SOLID WASTE
MEDIA OVERVIEW

     The Solid Waste Media is concerned with the national
management of three Resource Conservation and Recovery Act
(RCRA) programs:  the Subtitle C (hazardous waste) program;
the Subtitle D program for the management of wastes not
classified as hazardous; and the Technical Assistance Panels
program, designed to support the two foregoing efforts by
providing implementation assistance.

Media Priorities

     The first priority of the Solid Waste Media is the
national management of the hazardous waste program.  All
Subtitle C regulations are expected to be promulgated by
December 31, 1979, and to become effective in July 1980.
The major hazardous waste activities of the Solid Waste
Media are responding to emergencies (highest priority),
issuing guidance for implementing the regulations, assisting
in the defense of the regulations against court challenges,
authorizing and overseeing State programs, conducting
Federal enforcement activities, and identifying, evaluating
and enforcing against facilities which may pose imminent
hazards (to be referred to as problem sites).

     The second priority is the national management of the
Subtitle D program.  In 1980, high priority activities will
include management of the land disposal site inventory,
State program development and management of grants under the
President's Urban Policy program.

     The third priority is the Technical Assistance Panels
program.

Plann_ir]g__ Assumptions

     The Solid Waste Guidance for 1980 is based upon the
1980 President's Budget.  This budget does not include
adequate resources to handle the priority activities listed
earlier.  There are substantial resource shortages in many
areas, but particularly for identifying, evaluating and
enforcing against abandoned or problem hazardous waste
sites.  There are, however, several uncertainties regarding
resources for handling abandoned or problem sites that could
significantly alter this Guidance.  This section will describe
the assumptions used within the limits of the 1980 President's
budget, and will also describe in some detail the uncertainties
that exist regarding resources for solid waste in FY 1980.

-------
                      - 256 -


Base Level Assumptions

     o    Schedule of Regulations:

                                   Promulgation
     Section of RCRA                   Date

     3001, 3002, 3003, 3004         12/31/79

     3005, 3006                     10/31/79

     4004 and 1008(a)(3)             07/31/79

     1008(a)(1)                     01/31/80

     4002(b)                         06/30/79

     405  (Clean Water Act)           08/31/80

     0    FY 1980 Grant Levels:

               Hazardous waste - $18,600,000

               Solid waste - $10,000,000

               Urban Policy program - $13,950,000

                (See Table 1 for State allocations)

     0    Subtitle D grant funding:

                    Declining at a rate of $2 million
                    per year for 5 years

                    To fund high priority activities
                    only (inventory, State regulatory
                    program, State plan development)

                    No pass-through unless clearly
                    supporting high priority activities

     0    Permitting function will be split in all
          budget documents  (irrespective of Regional
          organization)

                    Abatement and Control will handle
                    technical reviews

                    Enforcement will handle administrative
                    processing and compliance monitoring

-------
                          -  257  -
                  FY 1?80 Statr  Grant Allocations

ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLU'IBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
•NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
AMERICAN SAMOA
GUAM
PUERTO RICO
NORTHERN MARIANAS
VIRGIN ISLANDS
Subtitle C
362,323
160,146
235,348
125,736
1,472,562
183,604
222,084
93,000
93,000
433,414
316,944
93,000
103,044
870,108
572,880
173,724
164,610
322,524
610,080
93,000
253,890
395,994
761,856
223,385
127,224
290,160
106,764
93,136
93,000
93,000
553,722
93,000
1,043,083
365,118
93,000
1,015,188
172,794
245,334
1,014,816
121,272
272,862
93,000
478,020
1,855,722
119,040
93,000
237,150
271,932
343,542
353,028
93,000
93,000
93,000
105,276
93,000
93,000
Subtitle D
159,100
50,000
81 ,300
88,300
921 ,300
102,000
140,000
50,000
50,000
313,500
212,000
50,000
50,000
513,400
239,900
130,500
103,800
148,700
167,700
50,000
181,200
262,800
410,000
175,800
102,400
216,000
50,000
68,500
50,000
50,000
331,100
50,000
842,400
234,700
50,000
492,000
118,200
96,500
544,900
50,000
119,700
50,000
181,200
517,200
50,000
50,000
214,700
157,500
80,600
204,100
50,000
50,000
50,000
125,300
50,000
50,000








C D

REGION I 1,018,350 602,800

REGION II 1,795,086 1,348,800

REGION III 2,035,398 1,121,400

REGION IV 2,728,434 1,471,400

REGION V 3.79,'i, 446 2,035,200

REGION VI 2.857,332 941,900

REGION VII 721,680 518,800

REGION VIII 693.408 352,000

REGION IX 2,173,410 1,253,600

REGION X 78.0,456 354,100

TOTAL 18,600,000 10,000,000


























TOTAL
18,600,000    10,000,000

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                     -  258  -
     0    Penalty policies,  enforcement strategies
          and implementation plans will be prepared
          during FY 1980

     0    No specific funding is provided in 1980
          President's budget for the discovery and
          evaluation of abandoned and problem hazardous
          waste sites

1979 Reprogramming -- Although no specific funds have
been provided in either the 1979 or 1980 budget for the
discovery, evaluation and enforcement activities associated
with abandoned hazardous waste sites, considerable
activity of this type is presently ongoing.  It has
been estimated that approximately 30 workyears of
effort are being expended on this activity, utilizing
Headquarters and Regional solid waste enforcement, and
surveillance and analysis resources.  The effort is not
spread evenly among the Regions, but appears to be
related to the number of problem sites per Region.

     Two enforcement cases related to problem or
abandoned sites have currently been filed, and eight
more are expected within FY 1979.  In the next 18
months, it is anticipated that another 12 to 18 cases
will be evaluated, and remedied either through voluntary
action by the owner or through Federal and/or State
actions, including litigation.  An increase in resources,,
estimated at an additional 20 manyears of effort, will
likely be expended on this effort.  This would bring
the total Regional effort on problem abandoned sites to
50 manyears.  It appears that even without official
recognition of this priority charge, the current
reprogrammed resources will continue to function on the
abandoned site problem.  This implies, however, that
resources will be unavailable to implement the regulatory
program.

Request for Supplemental Funds — EPA is requesting
supplemental resources of $108.8 million and 113 positions
for FY 1980 to undertake an active program of discovering
and investigating, as well as responding to emergency
actions and conducting enforcement actions concerning
abandoned and inactive hazardous waste facilities that
present an imminent hazard to public health or the
environment.

     The proposed program will have five parts:  discovery,
reconnaissance investigation, full investigation,
enforcement and where essential, emergency action.  The
program will be implemented by the EPA's Regions and,
in fact, by the States wherever possible.  To accomplish

-------
                     - 259 -
this, EPA has already established a new institutional
structure of national and Regional coordinators and has
issued a change in programmatic priorities that will
result in the reprogramming of approximately 50 workyears
into this program.  Also, EPA is preparing to convene a
three-day workshop to orient the appointed coordinators
and train participating personnel.  Although EPA has
some experience in acting on abandoned/inactive site
incidents, the techniques for investigating cases,
protecting the safety of investigating personnel,
documenting data and preparing cases are still to be
perfected and many of the personnel that will be investigating
and bringing enforcement action on abandoned/inactive
sites will need additional training and experience.

     The discovery of abandoned/inactive sites will
basically involve receiving  (or otherwise obtaining)
and recording leads on suspected sites.  Currently
there is no formal mechanism for the discovery of
problem sites.  Most of the known problem sites have
been identified through informal communications with
States and through citizen complaints.  This portion of
the program will systematize the documentation of
information received from various sources.  It will
also involve several low-cost efforts to search for
undiscovered sites.  The discovery component of the
program will be institutionalized and carried out
throughout the 18 months of the program and thereafter.

     The reconnaissance investigation component of
the program will involve making a preliminary investigation
of those sites identified as suspected problem sites in
the discovery phase of the program.  Supplemental funds
of $1.5 million in FY80 are requested for this work.

     The full investigation component of the program
involves conducting extensive field investigations, in-depth
sampling and analysis, and other related studies on
sites identified by the reconnaissance investigation as
being potential significant hazards.

     It is projected that approximately 300 sites can
and should be investigated over the next 18 months.  At
a cost of 5.5 workyears per site, this workload  (930
workyears) would far exceed the current resource capacity
of EPA and would even exceed EPA's capacity to hire and
train personnel if additional personnel were authorized.
Accordingly, it is proposed to use as many as 30 contractors
under level-of-effort contracts to supplement State and

-------
                      -  260  -
Regional resources under case-by-case task orders to
conduct full investigations.   There are contractors
available for such an effort.

     It is assumed that 225 sites can be investigated
by the States, but with varying amounts of EPA assistance
from the above-described contracts.  The remaining 75
sites would be fully investigated by EPA also using
contractors.  It is further assumed that all of this
effort would be performed in FY 1980 following discovery
and reconnaissance activities  in FY 1979.  Using these
assumptions, the full investigation component of the
program will cost $53.2 million.  To manage the contractual
effort, and provide quality assurance, a limited number
of in-house experts, 43 additional positions and $1.7
million will be required.  Accordingly, supplemental
resources of 43 positions and $54.9 million are requested
for FY 1980.

     The enforcement component of the program will
involve bringing suits to require responsible parties
to take corrective actions.  This phase encompasses the
preparation of legal cases and the additional technical
work and investigations necessary to support such
cases.  It is assumed that following full investigations,
the States will assume responsibility for enforcement
action through State courts in 50 cases, with varying
amounts of EPA assistance, and that EPA will pursue
action on 50 cases under Federal authorities.  Using
workload experience to date in similar enforcement
actions, 60 additional personnel and $2.4 million will
be required in supplemental funding for FY 1980.

     The emergency response component of the program
will involve Federal funding of clean-up actions deemed
necessary to immediately contain extremely hazardous
situations.  This will include action such as the
removal of drums of chemical wastes from navigable
waters and drainages into navigable waters (e.g.,
Louisville, Kentucky), the segregation and removal of
drums of chemicals that pose a fire or explosion threat
or which are leaking into the environment, and the
temporary containment of subsurface migration of toxic
chemicals through the construction of drains or other
means  (e.g., Love Canal).  These actions will not cover
permanent remedy.  They will be employed where
a responsible party is not available or refuses to take
the emergency action.  Whenever possible, recovery of
costs will be sought from available responsible parties.
Also, enforcement/injunction actions will be concurrently
taken wherever possible.

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                      - 261 -
     Of the projected 300 sites that will be fully
investigated, it is assumed that 20 sites will require
critical emergency response.  At an assumed average
cost of $2 million, $40 million will be required.  It
is proposed that 75 percent of these 20 emergency actions
can be taken under the response authority of Section
311 of the Clean Water Act and that the remainder will
have to be addressed under Section 504 of that Act.
Accordingly, $30 million is requested to supplement the
Section 311 fund and $10 million is requested to fund
the Section 504 authority.  Five additional positions
are requested to manage these clean-up actions which
are very complex and long-term compared to oil and
hazardous materials spills.

     In addition, it is assumed that at least five
sites will require emergency response requiring application
of innovative technology.  The La Bounty site in
Charles City, Iowa, is a good example.  To deal with
these situations, 5 additional positions and $10 million
are requested.

     In summary, 10 positions and $50 million are
requested for emergency response actions.

     Overall, the following supplemental resources are
requested for the proposed program:

                                   FY 1980
Component                        pos     $1,000

Discovery

Reconnaissance Investigation      -       1,500

Full Investigation               43      54,900

Enforcement                      60       2,400

Emergency Response               10      50,000
                                TIT     108,800

     It should be noted that this proposed 18 month
program is designed to address only a small part (300)
of the estimated potential universe of significantly
hazardous abandoned/inactive sites.  Continuing activity
beyond FY 1980, at the same or higher level, is expected.

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                          - 262 -
HEADQUARTERS PLAN

Abatement and Control

     In Fiscal Year 1980, the Office of Solid Waste will
undertake a new programmatic direction.  Most of the major
regulations under the Resource Conservation and Recovery Act
will be promulgated by January 1980.  With the promulgation
of these regulations, OSW will move into an implementation
phase of its hazardous and non-hazardous waste programs.

     The national management of Subtitle C requirements will
continue to be the highest priority during FY80 and 81.
Major activities will include developing program guidance
for implementing the regulations;  providing oversight of and
assistance to the State delegation program; providing technical
support for the litigation expected after the regulations
are promulgated; and developing guidance and guidelines for
specific industries and special wastes.

     FY80 will begin the five-year phase down of Federal
financial assistance under Subtitle D of RCRA.  The Headquarters
program will concentrate on national management of the
disposal site inventory; litigation support for promulgated
regulations; development of sludge management regulations;
and development of guidelines and manuals to assist Regional
Offices and the States in their control of non-hazardous
wastes.

     National management of the technical assistance program,
the President's Urban Policy resource recovery program, and
evaluations of existing resource recovery technologies will
continue as at present.

     Plans and Emphasis

          o    Subtitle C Activities

               OSW will concentrate on promulgating the
               Subtitle C regulations during the first
               quarter of FY80.  Upon promulgation of the
               regulations, we expect that a significant
               number of law suits will be filed.   Two areas
               where significant litigation support will be
               necessary are:  (1) proposals of additional
               listing and de-listing of hazardous wastes
               under Section 3001, and (2)  defense and
               revisions of facility standards under Section
               3004 of RCRA.   OSW will devote efforts to
               this throughout FY80 and 81.

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                 - 263 -
     OSW will also .be refining and developing
     additional technical guidance documents under
     Section 3004, outlining appropriate treatment,
     scorage and disposal methods for specific
     wastes, and will be considering amendments to
     Section 3001 lists and criteria.

     Day-to-day guidance will be provided to
     Regional and State solid waste officials on
     technical and procedural requirements of the
     promulgated regulations,

     Depending on Congressional action on our
     proposed legislation, OSW will develop regulations
     for a program to provide funds for dealing
     with the problems of inactive and abandoned
     disposal sites posing a threat to public
     health or the environment.  OSW will concentrate
     on this activity during the latter part of
     FY80.

o    Subtitle^ D Activities

     In FY80; OSW will provide consultation for and
     national program management of the land
     disposal site inventory, including training
     sessions to facilitate Regional and State
     understanding of the Section 4004 requirements.
     The first inventory will be compiled and
     published in January 1981.  OSW anticipates
     that litigation could also occur in response
     to the Section 4004 regulations.  In the
     event challenges occur, OSW will devote
        oir.s toward response.
     Guidelines under Section 1008 for landfilling
     will be promulgated in January 1980.  Guidelines
     wii.l be proposed for surface impoundments and
     specific design and operating manuals and
     monitoring manuals will be developed in FY80
     to accompany these guidelines.

     EPA will prcpcse regulations for sludge
     management uncle c Section 405 of the Clean
     Water Act during ?Y79.  Promulgation is
     scheduled for August 30, 1980,  In FY81,
     efforts will J:>e concentrated on possible
     1 i~c iga.t..Lon in response to these regulations.
     OSW will also provide consultation with the
     Regions, and develop and issue a variety of
     guidance documents to accompany these regulations

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                      - 264 -
          Technical Assistance Activities

          National program management of the president's
          Urban Policy resource recovery grant program
          will be provided by OSW during FY80 and 81.
          Headquarters will maintain an oversight
          responsibility for the financial and programmatic
          aspects of the Urban Policy program.

          Technical evaluations of resource recovery
          systems will continue.  Three or four in-
          depth evaluations will be conducted in each
          FY80 and 81.

          National program management of the Technical
          Assistance Program will be provided by OSW
          during FY80 and 81, although little, if any,
          direct technical assistance will be provided.

          Federal procurement guidelines will be promulgated
          in FY80 for fly ash as a cement supplement,
          recycled paper products and composted sewage
          sludge as a soil conditioner/fertilizer.
          Guidelines will be proposed for recycled
          construction materials and insulation products
          using recovered materials.

          Public Participation/Information

          The four-year public education program on
          RCRA implementation, Waste Alert, will continue
          during FY80 and 81.  The program will include
          Regional and State conferences, and the
          development and distribution of information
          materials.  The problem of siting, which is
          an impediment to rapid improvement of solid
          waste disposal practices, will be an area of
          major emphasis in this program.  Training
          modules will be available in 1980 to orient
          new Federal and State employees to RCRA
          regulations and requirements.
Changes

     o    Reorganization
          In anticipation of implementation of the
          hazardous and non-hazardous waste programs,
          the Office of Solid Waste will undergo a
          reorganization.  The new organization will
          provide a balance of responsibilities among
          the divisions, the bulk of which center on
          the Subtitle C regulations.  It will also

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            - 265 -
concentrate on meeting both short-term and
future requirements outlined in the regulations
and other policies, and facilitate integration
and coordination of related efforts.   As an
example, the development of control technologies
and disposal alternatives for both hazardous
and non-hazardous wastes will be handled by a
single organizational unit.

The new organization will be composed of
three divisions.  The State Programs and
Resource Recovery Division will provide
integrated guidance and assistance to Regional
offices, States and local governments as
EPA implements RCRA's regulations and programs.
The Land Disposal Division will be responsible
for a national program to control the disposal
of all solid and hazardous wastes.  The
Hazardous and Industrial Waste Division will
characterize and list wastes under Section
3001, provide regulations and guidelines for
the storage, treatment and recovery of industrial
wastes, and manage economic and environmental
assessments of Subtitles C and D of RCRA.
The Management and Information Staff will
continue to be responsible for basic budget,
planning, analysis and administrative functions;
public participation and education activities;
and production and dissemination of technical
information.

RCRA Amendments

EPA will submit proposals to Congress in
FY79 for amendments to RCRA.  This is also
necessitated by OSWs new programmatic direction,
along with the increased understanding of
problems of hazardous and non-hazardous waste
management.  Of the number of amendments to
be proposed, the major ones include:

     Funding mechanisms to deal with post-
     closure costs and liabilities of permitted
     hazardous waste facilities.

     Strengthening the Federal enforcement
     capability by authorizing the Administrator
     to take immediate action against violators
     of hazardous waste provisions and regulations
     without 30 days notice to the violator
     or the State.

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                          - 266 -
                    Extending funding authorization beyond
                    1979 to ensure implementation of the
                    mandates of RCRA and the promulgated
                    regulations.
Enforcement
     Plans and Emphases — In FY 1980 the solid waste enforcement
     program will emphasize taking enforcement actions in
     imminent hazard situations involving substantial threats
     to public health or the environment and in developing a
     long-term national program to evaluate the industrial
     waste disposal practices engaged in by selected companies,
     industries or geographical areas.   A second broad
     priority will be the development of regulations and
     enforcement policies.  This will include the development
     of a plan for enforcement under the overall regulatory
     program, and appropriate enforcement strategies (including
     priority setting) for monitoring compliance with standards
     imposed upon persons who generate,  transport, store,
     treat or dispose of hazardous waste.  Thirdly,  assistance
     will be provided to the Regions in  reviewing and concurring
     in authorizing State hazardous waste programs.   Fourthly,
     Headquarters will assist OSW in establishing necessary
     ADP capability.  Finally, Headquarters staff will be             •
     responsible for concurring in specific Regional enforcement
     actions, and in developing necessary program policies
     and guidance.

     In FY 1981, emergency response and  imminent hazard
     action from the investigation of abandoned/inactive
     hazardous waste disposal sites will continue as the
     most important priority.  Other priorities will include
     policy development, guidance development, preparation
     of Solid Waste Enforcement Policy Statements, and
     assisting with State program oversight and operating
     programs for unauthorized States.

     Changes — In FY 1980, the Pesticides and Toxic Substances
     Enforcement Division, in which the  solid waste enforcement        -«
     program resides, will undergo a reorganization.  The
     four present branches (three pesticides-related and one
     for toxic substances and solid waste) will be realigned
     into three branches.  Each branch will discharge duties
     along functional rather than media  lines.  There will
     be branches for policy and strategy development,
     compliance monitoring, and case development and litigation.
     Each branch will consist of two sections with more
     narrowly-defined duties.  All branches will be responsible
     for the pesticides, toxic substances, and solid waste
     enforcement programs within their functional areas.

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                           - 267 -
Research and Development

     The Resource Conservation and Recovery Act requires
that hazardous waste be identified, separated and managed
so as to assure environmental protection.  Because of the
relatively small amount of research in the past, the
information available on the quantities and characteristics
of hazardous wastes and on the costs and capabilities of
environmental control options is limited.

     The awareness of and concern over hazardous wastes
has increased very substantially.  As the Agency has moved
to use the authorities of the new legislation, information
on the actual size of the hazardous waste problem has
begun to be available.  Several aspects emerge as parti-
cularly acute.  First, an appreciation has developed for
the number and size of unaccpetable facilities that are
now in operation or have been abandoned.  Second, the long
term environmental consequences of storage~i disposal or
destruction alternatives is quite uncertain.  The costs of
these different alternatives can vary considerably.  Third,
a desirable degree of general knowledge or accuracy in
characterizing wastes and control options does not exist.
At the present time each individual waste and the proposed
management practices must be evaluated separately to
establish costs and performance.  Without detailed studies
in each specific case, projections of acutal operating
characteristics are presently impossible.  Fourth, as the
requirements and costs for managing hazardous wastes
increase, present waste generation patterns and practices
will change.  Our understanding of how waste generators,
transporters, and disposers will respond to increased
costs are limited.  For example, a regional liquid and
solid waste management facility may be the least expensive
and most effective option for metal plating and finishing
firms.  However, the costs of a facility designed for an
existing situation may affect the economics of these firms
enough to change their operations.

     The purpose of this section is to present issues and
questions inherent in the current planning of EPA's research
effort in hazardous waste management.  The concerns raised
here are meant to stimulate thought and discussion to produce
a better designed and executed research and development
program.

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                         - 268 -
     Program Office Views on Research and Development

     The Office of Solid Waste has not and does not rely
upon or assign high priority to research in solving the
hazardous waste problem.  Their position is founded upon
four separate points.

     o   Effective programs for dealing with hazardous
         wastes and rectifying unaccepatable or abandoned
         sites will cost tens of billions of dollars.
         The technological problens in establishing
         these programs are remarkably small compared with
         the problems of obtaining the necessary financial
         and institutional commitment.

     o   The Office of Management and Budget has decided
         that EPA will not undertake a grant program to
         either plan or site hazardous waste facilities
         or to finance their construction.

     o   RCRA calls upon EPA to establish rules for the
         disposal of future wastes.  Research results will
         not be available on a schedule compatible with the
         legislated requirement. Resources to generate the
         information for rule making are S20 million less
         than that required, resources for research should
         therefore be minimal.

     o   Research and development efforts cannot yield
         results quickly enough to respond to the problems
         of abandoned or unacceptable facilities.  These
         facilities must be addressed with presently available
         technology.

     Is objective information available that establishes that
aspects of dealing with the hazardous v/astes are, in fact,
critically limited by lack of knowledge?  Are there cogent
reasons to believe that Federal R&D should generate that
knowledge?

     Research Required

     An effective research program for solving the problems of
managing hazardous wastes must address a variety of subjects.
Planning such a program must systematically identify these
problems.  One approach is to divide the research into three
general areas:

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                          - 269 -
     o   The costs and capabilities of alternative hazardous
         wastes disposal options are not well documented.
         Options include storage or landfilling, fixation,
         detoxification, and incineration.  Efficient pro-
         cedures for dealing with various types of wastes
         have not been demonstrated.

     o   The characteristics and quantities of wastes from
         various sources have not been well documented.  The
         properties of wastes that must be known to allow safe
         and effective disposal have not been catalogued in
         a comprehensive fashion.

     o   Regional hazardous waste problems at abandoned,
         existing and future sites nay differ.  Techniques
         have yet to be developed that will lead to efficient
         regional waste management or minimization systems.

     What structure should be used in planning a research and
development program?  What types of problems and activities
should be included?

     Other Solid Waste Research

     ORD's research program now includes activities in both
hazardous and municipal solid waste.  In addition, the
activities are directed to defining environmental problems
as well as to solving them.  The problem definition research
activities include health effects, measurement and environ-
mental assessment.  The problem-solving activity includes
technology research, development, demonstration, evaluation
and technology transfer.

     Is the scope of research program inappropriate?  Should
research on specific topics be terminated?  Should research
be initiated on new topics?

     Research Management

     At the present time, three separate laboratories conduct
research on solving hazardous wastes.  The mission of the two
lERL's is defined by industrial sector and deals with all
environmental problems, including hazardous wastes.  Within
the lERL's the organizational structure follows industrial
sectors.  At the MERL solid wastes are assigned to a single
division and the division's structure reflects alternative
control technolgies.

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     ORD has not specifically addressed the problems of
designing a research program on hazardous wastes and has
not clarified divisions between organizations' respon-
sibility.  How might such a clarification be accomplished.

     What structure should be used in planning a research
and development program?  What types of problems and
activities should be included?

     Research Planning

     The Office of Research and Development is reexamining
thoroughly all of its present research in solid waste and
the emerging R&D needs of the Agency.  This examination
includes all facets of research and development activity and
will not be restricted to present, or proposed technology
program.

     The activities will be divided into categories:

         Municipal Solid Wastes
         Waste-as-Fuel (Energy Funding)
         Health Research
         Transport and Fate of Pollutants
         Quality Assurance, Measurement and Monitoring
         High Volume Mining Wastes
         High Volume Energy Wastes (Energy Funding)
         Thermal Decompostion
         Hazardous Waste Treatment
         Containment
         Waste Characterization
         Regional Hazardous Waste Management
         Abandoned Facilities Response

     Documents are being developed in each area that will
define the research needs, goals and outputs.  These
documents also define alternative program levels in each of
the thirteen areas.  The Office of Solid Waste and other
interested parties will evaluate and rank the program
options.  This ranking will provide the direction for the
FY-80 and FY-81 research programs.

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                          - 271 -
REGIONAL GUIDANCE

Abatement and Control

     In Fiscal Year 1980 and 1981, the Regions will be
required to play a major implementation role in the manage-
ment of RCRA's mandated programs.  Emergency response and
management and oversight of State hazardous waste program
development and operation will be the Regions' highest
priorities throughout FY80 and 81.  The major activities
include enabling States to qualify for full or interim
authorization; overseeing authorized State programs; handling
notification activities; notifying on interim permit status;
and assisting in response to emergencies and imminent hazards.

     Oversight and assistance in the development of State
Subtitle D programs will also continue.  Major activities
will include managing the disposal site inventory; managing
development and implementation of State regulatory powers;
managing the resource recovery grants awarded under the
President's Urban Policy program; and overseeing the State
planning process.  The Regions will also continue to operate
the Technical Assistance Panels programs.

Subtitle C Activities

     The highest priority under Subtitle C for FY 1980 and
81 will be to work aggressively with the States to enable as
many as possible to qualify for full or interim authorization.
EPA Regions will concentrate during the first three quarters
of FY 1980 on assisting the States to develop appropriate
legislation and regulations, set up operating programs, and
write applications for authorization.  During the second
through fourth quarters, Regions will review and approve or
deny applications for authorization.  These efforts are
essential if we are to maximize the number of States authorized
early in the program.  In FY 1981, oversight of authorized
State programs will be of equal priority.  Particularly fox-
States with interim authorization, it will be important to
verify that the regulations are being administered as intended
and that the States are continuing to develop their programs
so that they can move toward obtaining full authorization.

     In FY 1980 and 81, EPA Regions will begin to administer
those portions of the Subtitle C regulations for which EPA
has responsibility.  Specifically, this means notification
for all States in FY 1980 and review of manifest reports and
issuance of permits for unauthorized States in FY 1981.

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                           -  272  -
     Section 3010 regulations originally provided limited
interim authorization to allow States to handle notification
activities.  It has now been decided that the Regions will
handle all notification activities.  Insufficient resources
are currently available for notification activities.  It is
expected that notifications will be handled with a combina-
tion of other-than-permanent-full-time employees and contract
dollars obtained through the Agency's overtarget process.
All notifications must be submitted to Regional Offices in
the 90 days from January 1 to March 31, 1980.

     Part A of the permit applications are due no later than
180 days after the Section 3001 regulations are promulgated.
As the current projection for promulgation is December 30,
1979, the Part A applications are due by the end of June
1980.  Notices of interim permit status must be issued to
all applicants, and the Part A applications ranked.  The
ranking is the basis for determining when the full permit
application (Part B) is due.  Requests from the Regional
Administrator for submission of Part B must provide a
minimum of 6 months for preparation.  It may be possible to
initiate work on some permits in FY 1980.  The full permit
process will not begin, in most cases, until FY 1981.

     The regulations describing the manifest system will
become effective June 31, 1980.  The quarterly manifest
exception reports and annual manifest reports from hazardous
waste generators are not due until 30 days after the close
of each quarter or the close of each year, making the first
reports (both annual and quarterly) due October 31, 1980.
Therefore, review of manifest reports also will not begin
until FY 1981.

     The third major area of responsibility under Subtitle
C will be to assist in responding to emergencies and imminent
hazards.  The lead responsibility for emergencies, i.e., a
sudden, urgent, unforeseen occurrence requiring immediate
action, will rest with the Oil and Hazardous Response Teams.
The responsibility of the Solid Waste Branches will be to
provide technical advice on containing the hazardous sub-
stance to mitigate the emergency; assist in finding a permanent
remedy; and follow up to assure that the remedy is applied
and is effective.  Under imminent hazard situations, those
where legal action has been taken or is contemplated by the
Office of Enforcement, the Regional Solid Waste Branches
will assist OE by making technical evaluations and will help
in developing evidential data.  The Office of Enforcement
has the lead for developing imminent hazard cases.  In
FY 1980 the Regions will continue to actively seek out,

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                           - 273 -
identify, and screen hazardous waste sites to determine
whether they pose a threat to public health or the environment.
Those suspected of constituting an imminent hazard should be
referred to the Office of Enforcement for appropriate legal
action.  Technical remedies should be proposed for these
sites.  However, for those sites for which there is no
financially responsible party, unless and until Congress
approves legislation for a clean-up fund, Federal funding
will not be available to implement appropriate remedies.

Subtitle D Activities

     Grant funds to the States under Subtitle D  (which will
be awarded under State/EPA Agreements)  will be phased out
over a five year period starting in FY 1980.  During this
five year period, States will be encouraged to develop self-
supporting programs based on a system of user charges.  The
decreased level of Federal funding will not provide for
addressing all the objectives of Subtitle D.  Federal funds
will be directed toward funding only the highest priority
activities under Subtitle D - the open dump inventory;
development and implementation of State non-hazardous waste
regulatory programs; and substantial forward progress in
development of State solid waste plans.  Local and Regional
planning and implementation will be a low priority in FY
1980 and 81.  Grants under Section 4008 (a) (1) will be made
for those purposes only if maximum progress on the high
priority activities is being achieved.   Beyond FY 1981, we
anticipate that no Federal funds will be available for local
and regional planning and implementation.

     The three major activities in FY 1980 and 81 under
Subtitle D will be to manage the disposal site inventory,
oversee the development of State regulatory powers, and
manage the Urban Policy grants.  The first installment of
the inventory is expected to be published in January 1981.
The Regions will assist the States in developing inventory
protocols and will monitor conduct of the inventory.  As
Headquarters will merely be compiling and publishing the
lists sent by the Regions, a particularly important aspect
of inventory management will be to monitor State inventory
activities.  This should include a thorough review of State
inventory procedures and occasional site visits with State
personnel to land disposal facilities to ascertain that
facility evaluation procedures are being accurately followed.
A site classification manual and additional guidance will be
issued to help the States classify facilities and to help
the Regions evaluate State inventory programs.  A review of
State regulatory powers will be undertaken, and actions to
help the States remedy deficiencies will be taken, as necessary,

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                           -  274
     By the end of FY 1979,  40 to 60 grantees will have been
selected and work plans approved under the Urban Policy
Grant program.  In FY 1980,  the Regions will manage these
grants; help select an additional 40 to 60 grantees (some of
which will be continuing projects started in FY 1979);  and
work with the new grantees to develop acceptable work plans.
The same activities are anticipated for FY 1981, and by the
end of that year there will  be 60 to 80 active grants.
Contractors will be available to assist in the management of
these grants.

Technical Assistance Activities

     Management of the technical assistance program will
continue as at present.  Except in rare circumstances,
Headquarters will not provide direct technical assistance
beyond FY 1979.  In FY 1980  and beyond, assistance will be
provided solely by contractors, peer match, or Regional
staff.  Demand for technical assistance has, to date,  been
lower than expected.  Regions are encouraged to use the
Panels as a supplementary resource when assisting in the
development and operation of State hazardous and non-hazardous
waste regulatory programs.  The Panels should be used inno-
vatively whenever possible for State hazardous waste programs
and for conducting the inventory.  They may also be used to
provide help to Regions in managing Urban Policy grants.

Enforcement

     In FY 1980 and 1981 the Regional Offices will have as
their most important activity the taking of enforcement
actions in situations involving substantial threats to
health or the environment.  A second important activity will
be compliance monitoring of  all hazardous waste handlers to
insure that all such persons have notified EPA of their
activities.  The Regions will work to encourage voluntary
compliance with provisions of RCRA on the part of industry
through contacts with industry and State representatives.
Procedures for enforcement oversight in authorized States
and Federal enforcement operations in unauthorized States
will be established.  State  hazardous waste management plans
will be reviewed for enforcement adequacy and compliance
with the RCRA manifest system will be monitored.

     Since regulations will  not be in place and enforceable
until late in FY 1980, only  minimal compliance monitoring
activities and initiation of enforcement actions will take
place through most of the year.  The major compliance monitoring
priority for FY 1980 and 1981 will be to ensure that all
hazardous waste generators have notified and are properly
complying with the requirements of regulations under Section
3002.  Most enforcement activities are expected to be conducted

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                           - 275 -
in response to emergency incidents or in accordance with the
affirmative action plan developed by Headquarters to determine
where imminent hazards may exist by investigating selected
companies, industries, or geographical areas.

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                          -  276 -
PROJECTED PROGRAM ACCOMPLISHMENTS - Abatement and Control

(All are for 1980 and 1981 unless noted otherwise)

Solid Waste Management

  *1.     Number of State plans under review
  *2.     Number of State plans approved (by State)
  *3.     Number of Urban Policy grants being managed

Hazardous Waste Management

  *1.     Number of States receiving interim authorization
  *2.     Number of States receiving full authorization
  *3.     Number of notifications processed
  *4.     Number of notices of interim permit status
          issued
  *5.     Number of emergencies for which assistance; was
          provided
  *6.     Number of abandoned/problem sites identified
 *°7.     Number of reconnaissance investigations of
          abandoned/problem sites  (in process) (completed)
 *°8.     Number of full investigations of abandoned/problem
          sites (in process) (completed)
 *°9.     Number of Part B applications (being) reviewed
          for completeness  (1981)
 °10.     Number of Part B applications being reviewed
          for draft permit  (1981)
 *11.     Number of draft permits issued (1981)
*°12.     Number of Part B applications (in)  (completed)
          comment period (1981)
 °13.     Number of Part B applications being reviewed
          for final permit issuance (1981)
 *14.     Number of final permits issued (1981)
 *15.     Number of special permits issued  (1981)
*°16.     Number of permit decisions appealed to the
          Administrator (1981)
*°17.     Number of permits (under) (completed) judicial
          review (1981)
 *18.     Number of appealed permits issued (1981)
 *19.     Number of permits (in each unauthorized State)
          suspended, denied, revoked (1981)
 *20.     Number of permits (in each unauthorized State)
          modified  (1981)
 *21.     Number of facilities (in each unauthorized State)
          which were closed/ceased operation
 *22.     Number of State permit applications/draft permits
          reviewed  (in each authorized State)
 *23.     Number of State permit applications/draft permits
          which were formally commented on  (in each authorized
          State)

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                           - 277 -
 *24.     Number of manifest exceptions (in each unauthorized
          State)
 *25.     Number of international shipments (by receiving
          country)

Technical Assistance

  *1.     Number of peer matches completed
  *2.     Number of contractor TA efforts completed
  *3.     Number of Regional personnel TA efforts completed
  *4.     Number of requests pending
*Quarterly and/or annual totals
°In process,  as of (end of quarter and/or end of year)

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                          -  278 -


PROJECTED PROGRAM ACCOMPLISHMENTS  - Enforcement                     "

(All are for 1980 and 1981 unless  noted otherwise)

   1.     Number of imminent hazard actions initiated
          pursuant to RCRA Section 7003
   2.     Number of civil court actions initiated under
          RCRA Section 3Q08
   3.     Total number of inspections
               Number of inspections of generators who
               treat, store  or dispose on-site
               Number of inspections of generators who
               treat, store  or dispose off-site
            -  Number of inspections of treatment,  storage
               and disposal  facilities
               Number of inspections of transporters,
               including inspections by DOT
   4.     Number of Notices  of Violation issued
   5.     Number of Informal Notices of Warning sent
   6.     Number of compliance orders issued under RCRA
          Section 3008
   7.     Number of administrative/enforcement hearings
          held pursuant to RCRA Section 3008
   8.     Number of criminal prosecutions initiated
   9.     Number of state emergency actions initiated
  10.     Number of activities conducted so as to promote
          voluntary compliance on  the part of industry
          with RCRA requirements
  11.     Number of state oversight inspections (1981)
  12.     Number of state plans for interim authorization
          reviewed for adequacy of enforcement
  13.     Number of state plans for full authorization
          reviewed for adequacy of enforcement
  14.     Number of violations detected
  15.     Number of sites determined to pose an imminent
          hazard
  16.     Number of sites which have begun to come into
          compliance

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1980/1981 TOXIC SUBSTANCES MEDIA GUIDANCE

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                     TOXIC SUBSTANCES

MEDIA OVERVIEW

Planning Assumptions

     The FY 1980 toxic substances abatement and control'
program activities and outputs are based on assumptions
about resource status and on program activity level.
The significant programmatic assumptions are related
to actions external to the toxic substances program.
The major one is that we will receive 400 premanufacture
notifications annually for review.  We expect that the
Interagency Testing Committee will continue to make
recommendations for priority testing up to the statutory
limit of 50 chemicals.  We are assuming that we will
receive industry substantial risk notifications at the
same rate as up to now.  Requirements for industry
assistance are assumed to remain fairly constant
overall.  We expect that many of the actions the
Agency takes initially will be the subject of petitions
and suits and that this will require significant pro-
gram effort to respond.  We have assumed that section 28
State grant authority and funding authorizations will
not be extended beyond FY 1979 by Congress.  We assume
that imminent hazard actions under TSCA section 7 will
be nonexistent or nearly so.  These assumptions will also
apply to FY 1981.  No legislative changes are assumed
for FY 1980.

     Abatement and control resources for the Regions
will provide for a minimal program level.  Only a
small amount of resources are provided for necessary
actions resulting from regulations.  Coordinative
resources are provided for Regional integration, but
it is assumed that other media will provide resources
for activities to control toxic chemicals which are
being integrated.  No resources are provided for toxic
chemical emergencies or other activities not required
to support legislatively mandated functions.

     Output levels are based on the assumption that the
program operates at the full programmed resource
level in both FY 1979 and FY 1980.  This assumes that
we will be able to locate, hire, and integrate into
our organization large numbers of people with neces-
sary skills and use our contract money effectively.
This in turn depends on having adequate space when
needed and necessary administrative support.

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                     - 282 -
     Finally, because this is a new program, we
have had to base many output levels on models of
resource needs and projections of program design rather
than on actual experience.

     The toxic substances enforcement program antici-
pates that by the end of FY 1980, the Agency will have
promulgated several TSCA section 4 testing standards,
including oncogenicity, chronic toxicity, and combined
oncogenicity and chronic toxicity standards.  In addi-
tion, a section 4 testing rule, requiring the submis-
sion of test results data relating to health and
environmental effects, will have been promulgated and
20-30 chemicals selected for testing under this regu-
lation.  Standards for providing test data in support
of a premanufacturing notice under section 5 will also
have been promulgated, and a number of section 5(e)
and 5(f) rules or orders will have been issued.  An
additional section 6 rule is expected to become effective
by the end of FY 1980.  Under section 8(a), the Agency
will have promulgated a use/exposure rule gathering
information on 2000-3000 chemicals.  In addition to
individual section 8(a) information rules for a few
selected new chemicals, model rules will be issued under
sections 8(a), (c), and (d).  Finally, regulations
governing the importation of chemicals will be in
place.

     FY 1981 will bring additional chemical control
regulations under section 6.  New section 4 testing
rules and new rules and orders under section 5(e) and
5(f)  are also expected.  Furthermore, additional
section 8(a) reporting regulations will be finalized
by the close of FY 1981.

     The enforcement resources necessary to adequately
monitor compliance with these program activities will,
for the most part, be cumulative.  We assume that
resource allocations to existing programs will decrease
with time.  The net effect of the promulgation schedule,
however, will be to increase the demand for enforcement
resources.

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                      -  283  -
     Research and development planning assumptions will
be identified through the research committee mechanism
which is being established presently for the toxic sub-
stances media.

Media Priorities

     The FY 1980 and 1981 toxic substances programs re-
flect increasing levels of program activities and out-
puts.  These expanding activities are based on the
necessary foundations for program operation such as a
chemical selection and priority setting system, assess-
ment process, premanufacture review process, including
testing guidelines for new chemicals, and data manage-
ment systems and capabilities for the most part being
in place and functioning.  These activity levels also
require that expedited procedures be in place for such
activities as reporting and recordkeeping rulemaking
and for control actions on new chemicals, which must be
taken quickly in order to be effective.

     In FY 1980, we will continue establishing these
toxic substances abatement and control program founda-
tions while more fully operating most aspects of the
program.  We will put priority on making the premanufacture
review program fully operational, in order to review
new chemicals and take action on those that may be
hazardous before their release into the environment.
We will also emphasize development of rules to obtain
testing data upon which to make chemical assessments
in support of regulatory actions.  We will begin to
increase our emphasis on control of existing chemicals
which are identified as hazards through our assessment
process.  We will operate a priority setting system
for choosing chemicals for testing and regulation under
TSCA and other statutes, in conjunction with the Toxic
Substances Priorities Committee.  In FY 1981, we will
emphasize full operation of all major program components.
We will place a balanced emphasis on regulation of new
and existing chemicals based upon the information base
we establish in FY 1979 and 1980.  We will operate an
integrated priority setting system for choosing chemicals
for testing and regulation under TSCA and other statutes
in conjunction with the Toxic Substances Priorities
Committee.   Public participation in these key programs
will be emphasized in both years.

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                     - 284 -
     The Office of Enforcement will concentrate its
FY 1980 and FY 1981 resources on the enforcement of
those regulatory programs which provide the most
effective means of (a)  abating threats to public
health or the environment due to chemical contami-
nants, (b)  gathering accurate and comprehensive data
concerning the universe of potentially harmful sub-
stances,  and (c)  monitoring compliance with existing
standards to determine that regulated chemicals are
handled as required, and (d)  assuring the integrity
of the regulatory program.  Based on these criteria,
the following priority hierarchy has been established.

     Emergency Response — Since emergency situations
     by definition present a direct and substantial
     threat to public health or the environment, co-
     ordinating Agency response to such imminent
     hazards will be the highest priority for the
     Office of Enforcement.  The Office of Enforcement
     will bring actions under section 7 of TSCA
     for such injunctive relief as may be necessary
     to remedy the risk at hand.  Moreover, the
     Office of Enforcement will actively enforce the
     requirement under TSCA section 8(e)  that persons
     immediately report any emergency incidents of
     environmental contamination.  Finally, every
     effort will be made to use, where appropriate,
     emergency response tools available under other
     environmental statutes such as the Solid Waste
     Disposal Act.

     Premanufacture Notification - TSCA Section 5 —
     Because the premanufacture notification require-
     ment contained in section 5 of TSCA can be used
     both to gather information and to reduce the
     risk of hazardous chemicals being introduced into
     commerce,  monitoring compliance with this require-
     ment is a high priority.  The proper implementation
     of the section 5 screening mechanism will allow
     the Agency (a) to prevent hazardous substances
     from reaching the marketplace, and (b) develop a
     more accurate profile of the chemical industry.

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                - 285 -
Chemical Control Actions - TSCA Sections 6, 5(e),
and 5(f) — Chemical control regulations con-
stitute the primary means by which the Agency
directly controls risks to public health and
the environment.  Section 6 rules on PCBs, CFCs,
and any other substances in effect will receive
special attention.  Since rules or orders
issued under TSCA section 5(e) and 5(f) (in con-
junction with the review of premanufacture notices)
also impose chemical-specific controls, the en-
forcement of the terms of such rules or orders
will receive the same priority as that assigned
to other chemical control enforcement activities.

Information Gathering - TSCA Sections 4 and 8 —
TSCA sections 4 and 8 provide the principal
authority for obtaining information regarding
chemical toxicity and exposure.  Since a violation
of section 4 or section 8 does not directly
endanger health or the environment the enforcement
of these programs receives a lower ranking than
the compliance monitoring activities described
above.  The Office of Enforcement recognizes,
however, that since the success of other TSCA
sections depends upon the integrity of the data
received under sections 4 and 8, the Office of
Enforcement must provide the resources necessary
to assure that the information received under
these programs is valid and complete.

Imported Chemicals Control - TSCA Section 13 —
A smaller portion of resources will be used
to inspect imported chemicals at U.S. ports of
entry.  The Office of Enforcement will monitor
imported chemicals in cooperation with the U.S.
Customs Bureau.  Developing a specific protocol
to control imported substances will also be a
part of the strategies devised to enforce each
of the programs listed above.

Federal Facility Enforcement — By the end of
FY 1980, it is expected that all, or almost all,
Federal facilities which are major sources will
be in compliance with applicable TSCA regulations
and most minor source Federal facilities will
also be in compliance.  Regions should assure

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                      - 286 -
     that all Federal facilities do indeed come into
     compliance as soon as possible, and no later
     than the end of FY 1980.

     Apart from the enforcement of the substantive
mandates of TSCA, the Office of Enforcement will enhance
the efficiency of its compliance monitoring management
system during FY 1980 and 1981.  Among the many pro-
grams which will be implemented to achieve this objec-
tive, the Office of Enforcement will focus on the
following activities.

     Multi-Media Enforcement — The Office of
     Enforcement plans to implement an intra-agency
     multi-media approach to toxic substances enforce-
     ment.  As appropriate, the Office of Enforcement
     will use both the enforcement tools and
     the resources available under other EPA-
     administered programs to integrate compliance
     monitoring and enforcement activities.

     Inter-Agency Cooperation — To further expand
     inspectional resources, the Office of Enforcement
     will work with participating agencies of the
     Interagency Regulatory Liaison Group  (IRLG) to
     (a) develop cooperative joint, referral, and
     crossover inspection programs, and (b) coordinate
     complementary compliance monitoring programs.

     Evaluation of the TSCA Enforcement Program —
     The Office of Enforcement will continue to
     evaluate and refine its compliance monitoring
     and enforcement programs in FY 1981.  As part
     of this procedure, the Office of Enforcement
     will establish a formal, automated system of
     processing information generated through
     compliance monitoring and enforcement activities.
     It will also conduct a periodic review of
     Regional programs and will establish a Regional
     team to evaluate Headquarters performance.

     Research and development priorities for toxic
substances will be established jointly by the research
committee participants.

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                     - 287 -
Major Objectives

     The abatement and control program objectives are
to implement the Toxic Substances Control Act's
policy that (1) adequate data should be developed with
respect to the effect of chemicals on health and the
environment and that the development of such data should
be the responsibility of those who manufacture and
process the chemicals, and (2) adequate authority should
exist to regulate chemicals which present an unreasonable
risk of injury to health or the environment.  These
objectives include the information related activities
of developing test standards and applying them to
specific chemicals by rule to obtain test data from
industry, establishing reporting and recordkeeping
requirements to obtain existing information on chemical
substances, setting requirements for submission of
information by industry on new chemicals and significant
new uses, monitoring for field data, implementing
and operating data management systems, and exchanging
nonconfidential information with other programs,
Federal agencies, States, public interest groups, and
the general public.  It also includes scientific assess-
ments of effects, exposures, and risks for new and
existing chemicals based upon this information and
technical determinations of control options, including
economic considerations.  Control related activities
include taking formal actions on the manufacturing,
processing, distribution, use, and disposal of new
and existing chemicals under TSCA authorities, refer-
ring action to other programs or agencies, and taking
nonregulatory approaches.

     The fundamental objective of the toxic substances
enforcement program is to protect public health and
the environment from unreasonable risks posed by
chemical substances regulated under the Toxic Substances
Control Act.  The risk abatement process will be
accomplished through:

     (1)   The implementation of a program to prevent
or respond to toxic substances emergencies and notices
of substantial risk,

     (2)   The achievement of compliance with the substan-
tive requirements of TSCA and regulations promulgated
thereunder,

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                     - 288 -
     (3)  Assuring that information gathered under TSCA
is accurate and complete so that correct assessments
of toxicity and exposure can be made, and

     (4)  The expansion of inspectional resources
and improvement of the TSCA enforcement management
system.

     Research and development objectives will be
established through the research committee for toxic
substances.

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                     -  289 -
HEADQUARTERS PLANS

Abatement and Control

     Plans and Priorities
               Premanufacture Review

                    In FY 1980, as part of the priority
                    we place on premanufacture review of
                    new chemicals, our highest priority
                    objective will be to fully operate
                    the notification review process and
                    to take actions to prevent or control
                    the manufacture of new chemicals, as
                    required.  A high priority objective
                    will be to promulgate the final test-
                    ing guidelines for premanufacture
                    notification.  Another high priority
                    will be to further develop and begin
                    to use generic follow-up systems for
                    significant new use rules and
                    section 8(a)  information rules for
                    new chemicals.

                    In FY 1981, our highest priority
                    objective will be to fully operate
                    the premanufacture notification proc-
                    ess at an improved level and con-
                    tinue to take control actions on
                    new chemicals as required.   As a
                    high priority we will revise the
                    testing guidelines for premanufac-
                    ture notification to provide more
                    specific guidance.   Another high
                    priority will be routine use of
                    generic follow-up systems for signi-
                    ficant new use rules and section 8(a)
                    information rules for new chemicals.

               Testing

                    In FY 1980, as part of the priority
                    we place on development of testing
                    data,  we will promulgate the test
                    rule proposed in FY 1979 and will
                    propose and promulgate additional
                    test rules.  As a high priority we
                    will promulgate the full set of

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      - 290 -
     health effects test standards and
     the fate and ecological effects test
     standards proposed in FY 1979 and
     will propose additional fate and
     ecological effects test standards.
     Other activities will include beginning
     to review existing test standards.

     In FY 1981, our highest priority
     will be to continue promulgating
     testing rules to obtain data in
     support of assessment and regulation.
     As a high priority we will complete
     the fate and ecological effects test
     standards and review existing test
     standards.

Existing Chemicals

     In FY 1980, our highest priority
     will be to promulgate regulations
     proposed in FY 1979 banning or limit-
     ing the use of one chemical and to
     propose regulations for several addi-
     tional existing chemicals.  A high
     priority will be to develop proposed
     regulations implementing generic
     approaches to regulation of existing
     chemicals.

     In FY 1981, as our highest priority
     we will promulgate and propose regu-
     lations with greater emphasis on
     generic approaches, banning or limit-
     ing the use of a significantly greater
     number of existing chemicals that
     pose unreasonable risks to public
     health.

Information

     In FY 1980, our highest priority
     will be to promulgate the section 8(a)
     information rule on 2-3,000 chemicals
     proposed in FY 1979.  As a high pri-
     ority we will propose and promulgate
     model rules under section 8(a) and
     will promulgate 8(c) and 8(d) model
     rules.  We will also publish the
     revised chemical substances inventory
     and will maintain the integrity of

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       -  291  -
     the inventory.  Another high priority
     will be to begin partial operation
     of TSCA and interagency chemical
     information systems and data bases
     and to continue systems development.

     In FY 1981, the highest priority
     will be to continue promulgating
     rules under section 8 to obtain data
     to support assessment and regulation.
     As a high priority we will complete
     chemical information systems develop-
     ment and operate systems, services
     and data bases at full scale.

Regulations Support

     In FY 1980, our highest priority
     will be to conduct health and environ-
     mental effects assessments, monitor-
     ing and economic impact analyses to
     support regulation of new and exist-
     ing chemicals.

     In FY 1981, our highest priority
     will continue to be to conduct health
     and environmental effects assessments,
     monitoring and economic impact anal-
     yses to support regulation of new and
     existing chemicals.

Other Priority Activities

-    In FY 1980, other priority activities
     are to review and act expeditiously
     on carcinogens, mutagens, and tera-
     togens under section 4(f); begin
     review of the overall economic and
     innovation impacts of TSCA; assist
     industry regarding toxics program
     requirements; continue development of
     public participation programs; and
     support OECD and other planned inter-
     national harmonization programs.

     In FY 1981, other priority activities
     are to continue actions under
     section 4(f); maintain industry
     assistance; continue TSCA overall

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                 - 292 -
               economic and innovation impact studies;
               operate public participation programs;
               support international harmonization
               programs; and evaluate and refine our
               operating programs.

Changes — The FY 1980 headquarters abatement and
control program plans and priorities are consistent
with those outlined in the FY 1980 President's budget.
These plans and emphases represent a logical progres-
sion of FY 1979 activities into FY 1980 as the TSCA
program matures.

The major change for FY 1981 will be significantly
increased emphasis on control actions for existing
chemicals which will be based upon the information
and assessment activities emphasized in FY 1979
and 1980.  Information, testing and assessment, acti-
vities will be maintained at the levels necessary
to support the greater number of control actions.

Alternatives — Alternatives which will be considered
in development of headquarters abatement and control
program plans and budgets include:

     o    Use of contracts, grants and interagency
          agreements as a substitute or supplement
          for inhouse resources

     o    Use of consultants, IPA's, interns and
          other types of other-than-permanent
          personnel to provide specialized skills
          or fill temporary needs

     o    Use of other programs and agencies to
          take action where most appropriate

     o    Use of regional and State/local expertise
          where most effective

     o    Use of other program methods to accomplish
          objectives more efficiently and effectively,
          such as generic approaches to regulation,
          expedited rulemaking, automated systems,
          nonregulatory approaches to control, etc.

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                      -  293  -
Enforcement
     Plans and Priorities — The following is a list of
     priority Headquarters activities for FY 1980 and
     FY 1981.  It should be noted that Headquarters func-
     tions will include specific participation in on-site
     inspectional activities in such areas as enforcement
     of premanufacture notification, enforcement of
     section 8(e) requirements, and enforcement of
     section 4 and 8 (a) requirements.

          o    First Priority

                    Coordinate response to toxic sub-
                    stances emergencies

               -    Ensure compliance with the section 8(e)
                    requirement to immediately inform the
                    Administrator of emergency incidents
                    of environmental contamination

                    Target facilities for compliance
                    monitoring under the premanufacture
                    notification requirement, and parti-
                    cipate in appropriate inspectional
                    activities

               -    Develop strategies for the enforce-
                    ment of premanufacture notification
                    and chemical control regulations.

          o    Second Priority

               -    Develop a multi-media compliance
                    monitoring and enforcement program

               -    Develop an outreach program and other
                    methods to induce voluntary compliance
                    with TSCA

                    Target facilities for compliance
                    monitoring activities under sections 4
                    and 8(a), and participate in appro-
                    priate inspectional activities

               -    Develop strategies for the enforce-
                    ment of the information-gathering
                    provisions of sections 4 and 8(a)

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                 - 294 -
               Coordinate the development of coop-
               erative inspectional programs between
               IRLG member agencies

               Evaluate and refine existing compli-
               ance monitoring and enforcement
               strategies and procedures

     o    Third Priority

          -    Actively participate in the TSCA
               regulations-development process

               Develop a strategy for the enforce-
               ment of the section 13 import
               regulations

          -    Identify areas of potential inter-
               national cooperation in monitoring
               the movement and control of toxic
               substances

               Develop an ADP system for processing
               information received through compli-
               ance monitoring and enforcement
               activities.

In FY 1980 and FY 1981, the Headquarters toxic sub-
stances enforcement program will coordinate the res-
ponse to toxic substances emergencies and substantial
risk situations, and will actively pursue enforcement
actions in appropriate instances.  Headquarters staff
will also participate in on-site inspectional functions
in enforcement of premanufacturing notification,
section 8(e) requirements, and section 4 and 8(«i)
requirements.  Other priority programs will continue to
include establishing enforcement policy and providing
Regional guidance regarding compliance monitoring and
enforcement of chemical control regulations; developing
and implementing cooperative Headquarters/Regional com-
pliance monitoring strategies for the enforcement of
testing rules and premanufacturing notification require-
ments promulgated under TSCA; implementing a multimedia
enforcement approach as an integrated response to
chemical risk situations; assisting the Regions in
reviewing and providing concurrence on enforcement
litigation; and evaluating and refining existing TSCA
compliance monitoring strategies.  Other activities
will include monitoring initial efforts to enforce

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                 - 295 -
import and export requirements, reporting requirements,
and conceiving and implementing outreach programs to
induce voluntary industry compliance. Increased coop-
eration will be sought in developing complementary
mechanisms to monitor the international movement and
control of toxic chemicals.  Headquarters will conceive
and implement additional mechanisms for cooperative
compliance monitoring and enforcement through the IRLG.
The Headquarters toxic substances enforcement program
will establish and implement policies and operating
procedures for conducting all categories of inspec-
tions, assessing civil penalties, and preparing and
prosecuting civil and criminal cases.  Finally, Head-
quarters will assist in the design and implementation
of an ADP system to record appropriate compliance and
enforcement information regarding firms subject to TSCA
regulations.

Protection of public health and the environment will
continue to be the criteria upon which compliance
monitoring and enforcement programs will be developed
in FY 1981.  The toxic substances enforcement program
will expand in scope to monitor compliance with addi-
tional chemical control,  testing, and information-
gathering regulations.  Upon critical evaluation of
monitoring information developed in the execution of
the toxic substances enforcement program, a portion of
the compliance monitoring effort may be targeted to
firms, industries, or geographical areas which on the
basis of prior history of compliance, demonstrated
human or environmental risk, exposure, or epidemi-
ological data, warrant priority enforcement attention.
Additionally, such monitoring data will be used by
enforcement personnel to help focus future TSCA rule-
making activities.

Changes — This toxic substances enforcement guidance
has been changed to reflect revision of the Office of
Toxic Substances regulation-development calendar.  This
revised calendar contains a different mix of rulemaking
activities than had been projected for FY 1980.  In
addition, plans for the establishment of a cooperative
enforcement grant-in-aid program with the States,
expected to be initiated in FY 1979 and to continue
indefinitely thereafter, have been suspended.  Insofar
as this program is not put into effect and the toxic
substances enforcement program is to be conducted
entirely by Federal personnel, adjustments in the
program plans and resource needs for this program in
FY 1980 and FY 1981 will have to be made.

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                - 296 -
By FY 1980, the Pesticides and Toxic Substances Enforce-
ment Division will have undergone an internal reor-
ganization.  The four present branches (three pesti-
cides-related and one for toxic substances solid waste)
will be realigned into three branches.  The duties of
these branches will be assigned along functional rather
than media lines.  There will be branches for policy
and strategy development, compliance monitoring, and
case development and litigation. Each branch will
consist of two sections with more narrowly-defined
duties.  All branches will be responsible for the
development and management of pesticides, toxic sub-
stances, and solid waste enforcement programs within
their functional areas.

Alternatives — The Office of Enforcement is consider-
ing several alternative methods of discharging its
responsibilities under TSCA.  Each alternative is
designed to maximize available resources, and thus
will impact the FY 1980/1981 ZBB process.

     o    Cooperative Agreements with the States —
          The Office of Enforcement has considered
          initiating a cooperative enforcement grant-
          in-aid program with the States.  Under such
          a program, selected State agencies would
          cooperate with EPA in monitoring compli-
          ance with certain TSCA regulations.  As
          noted above, plans for the commencement of
          this program are presently suspended.

     o    Contractor Support -- In many cases it may
          be practicable to employ contractors to
          assist EPA personnel in performing compli-
          ance monitoring activities under the Act.
          Contractors would complement Agency inspec-
          tion teams by providing specialized exper-
          tise in the detection and prosecution of
          violations.  Given adequate funding, the
          use of contractors could significantly
          augment existing inspection-related resources,

     o    Headquarters Affirmative Compliance
          Monitoring — Evaluating the compliance
          status of firms subject to certain TSCA
          regulatory programs,  (such as those under
          TSCA sections 4, 5(a), and 8(e)), will
          require sophisticated technical judgments
          which will be made at Headquarters by the

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                      - 297 -
               Office of Toxic Substances.  Since Head-
               quarters Enforcement is required to work
               closely with the Office of Toxic Substances
               in developing such cases, program efficien-
               cies argue for vesting in Headquarters an
               important part of the responsibility for
               directing these compliance monitoring and
               enforcement programs.
Research and Development

     Plans and Priorities/Changes — In FY 1980 and and
     FY 1981, EPA's R&D program will focus on three manage-
     ment priorities:

          o    Continue the integration of ORD's research
               into the Agency's activities.

          o    Enhance ORD's capability to improve the
               scientific and technological data for future
               Agency regulatory and enforcement actions.

          o    Improve the quality and utility of the
               scientific and technical data used by the
               Agency.

     Plans for accomplishing these priorities include the
     following:

          o    Establish research committees to oversee the
               joint planning of all toxic substances
               research in support of regulations and
               enforcement.  Three committees are proposed:

                    Pesticides established in FY 1978
                    (relating primarily to the Office of
                    Pesticide Programs).

                    Testing and Assessment to be estab-
                    lished in FY 1979  (relating primarily
                    to the Office of Testing and Evalua-
                    tion and the Office of Program Inte-
                    gration and Information).

                    Chemical Control, deferred (relating
                    primarily to the Office of Chemical
                    Control).

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       -  298  -
These committees will develop multi-year
research strategies and will incorporate
requirements and reviews of the Regional
Offices.  To accomplish this, it will be
necessary for the Regional Offices to coor-
dinate their participation and share respon-
sibility for representing Regional interests.

Review all longer-term research efforts
underway in ORD to assure that the best
scientific capabilities are being directed
toward the most important future problems.
Fifteen percent of ORD resources for toxic
substances R&D will be devoted to existing
and future broader-based, longer-term re-
 search efforts to build an improved data
base.

Plan  and implement the Agency's Public
Health Initiative which will provide an
integrated data base for assessing the
significance of human exposure and adverse
human health effects from chemicals and
chemical mixtures released into the
environment.  This will include the estab-
lishment of a National Neurotoxicology
Research Facility to serve, particularly,
the Federal agencies forming the Inter-
agency Regulatory Liaison Group.  Also
within this initiative are cooperative
programs which include NCI, OTS, and ORD.
These programs involve research to develop
enough basic data relating to chemicals,
animal species, and biological mechanisms
to permit estimates of human effects.

Establish mechanisms to assure, wherever
feasible, peer scientific review of the
plans for and results from individual
research projects, bringing to bear on
the program design the best scientific
advice available.

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                      - 299 -
          o    Establish an environmental criteria and
               assessment function to provide quality
               control for the Agency's risk assessments
               and develop a program for quality assur-
               ance of biological research and testing.

FY 1980 Health Research

     The health research program will focus on develop-
ing new and improved techniques for rapid, reliable and
economical screening of toxic substances to provide
scientific data for regulating new and existing chemicals
in the marketplace.  Efforts will also be directed toward
improving the reliability of studies on the carcinogenic
effects of ultraviolet rays.  These plans include the
following priorities:

     o    Perform epidemiological studies of the reaction
          of human populations to environmental toxic
          chemicals, for example, epidemiology in the
          area of human reproduction and sterilant effects,

     o    Develop methods for analytically determining
          the exposure history of specific populations
          to chemicals in general.

     o    Develop screening techniques for determining
          means of detecting the effects of toxic
          substances on the nervous system and evaluate
          the significance to humans.

     o    Develop rapid, reliable and low-cost screening
          techniques using bioindicators for assessment
          of the commercial chemicals reaching the
          environment.

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                      - 300 -
                                                                   4
     o    Develop testing procedures and techniques  to
          measure effects of toxic substances on the
          immune system.

     o    Examine the feasibility of using the toxicology
          of aquatic and mammalian organisms as short-
          term testing indicators of human health effects.

     o    Apply the time-to-tumor model to reduce time
          required for obtaining carcinogenicity test
          results.

     o    Test personal dosimeters, develop models to
          forecast UV-B skin cancer incidence and compare
          the economic value of reduced risk of skin
          cancer to future generations.

FY 1981 Health Research

     The FY 1981 research plan will include the continua-
tion of the research identified for FY 1980 and will
expand the parameters to support development of testing
standards for existing chemicals as required under
TSCA section 4.

FY 1980 Changes

     Research will proceed as described in the FY 1980
budget with the following exceptions:

     o    The immune system research will be broadened
          in scope to include other aspects of host defense
          systems such as whole organs (lung and liver)
          and whole organisms.

     o    Screening with short-term testing using bio-
          logical indicators will include end points
          relating to mutagenic, carcinogenic, and
          reproductive hazards.

     o    Analytical chemical procedures may incorporate
          development of quality assurance procedures to
          be used in determining human exposure levels.

FY 1981 Changes

     No changes are anticipated at this time.

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                      - 301 -
FY 1980 Environmental Processes and Effects Research

     Transport and Fate -- The research work under the
     plan will focus on the development of exposure
     assessment models for toxic chemicals in multimedia
     environments, development of improved protocols to
     be used in testing of toxic chemicals, and techni-
     cal assistance to OTS on complex problems.  The
     following are priorities:

          o    Develop exposure assessment models to
               predict the concentration of toxic chemi-
               cals in air, water and soil/sediment
               environments.  Incorporate single media
               models for the development of a multimedia
               exposure model.

          o    Investigate complex environmental trans-
               formation processes such as photolysis
               (in air, soil, sediments)  and microbial
               degradation for the development of proto-
               cols for toxic chemical testing.

          o    Investigate complex transport processes
               such as leaching and partition coefficient
               for the development of testing protocols
               to be used in exposure assessment models.

          o    Develop model ecosystems and smog chambers
               for the validation of exposure assessment
               models and for screening of toxic chemicals.

          o    Characterize and select soils and sediments
               to be used in testing of toxic chemicals
               and to determine the feasibility of a soil/
               sediment bank.

          o    Validate and develop a representative
               chemical or benchmark concept to predict
               the behavior of toxic chemicals in the
               environment.

     Ecological Effects Research -- The major emphasis
     of research in this area is to develop screening
     procedures and protocols for testing of toxic chemical
     effects on living organisms in freshwater, marine
     and terrestrial environments.  Under this plan, a
     major effort on the Public Health Initiative will be

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                - 302 -
initiated to develop a better understanding of the
effects of exposure and develop methods to predict
human exposure to environmental toxicants.  Specific
priorities include the following:

     o    Develop, refine, validate, and calibrate
          ecological screening procedures for defin-
          ing the effects of toxic substances on
          organisms and ecosystems.

     o    Conduct round-robin testing of methods
          such as acute bioassay and bioconcentra-
          tion tests, for assessing toxic chemicals.

     o    Develop predictive techniques and methods
          to determine levels of human exposure to
          environmental toxic chemicals.  This will
          involve validation of existing exposure
          models and initiation of "benchmark" and
          structure activity concepts for predicting
          toxic chemical behavior.  The development
          of exposure models will require a better
          understanding of transport and transforma-
          tion processes, biochemical transformation
          into the food chain, validation of exposure
          models into laboratory model ecosystems and
          microcosms.  These models will be used in
          the screening of toxic chemicals.

     o    Delineate evaluative methods to determine
          human exposure to toxic chemicals at
          environmental levels to validate exposure
          models.  The work will involve monitoring
          and field surveys.

     o    Develop the data base on human exposure.  The
          work will include the evaluation and analy-
          sis of the exposure data currently availa-
          ble at the Federal and State level.

     o    Initiate experiments on photosynthesis
          reactions of field crops to UV-B.

Characterization and Measurement Methods Development
— The main thrust of the research plan under this
program is to develop improved methods for the
characterization and quantification of toxic chemicals
in air, water, soils and sediments.  Such methods

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                       -  303  -
     are needed in determining exposure to toxic
     chemicals, monitoring toxics and carrying out
     transport, fate and effects studies on toxic sub-
     stances in the environment.  Furthermore, TSCA
     requires regulation of large numbers of chemicals.
     For many chemicals, especially new chemicals, adequate
     methods for characterization do not exist.  The
     specific priorities are as follows:

          o    Develop improved methods for the charac-
               terization of toxic chemicals in air using
               such methods as resins, high pressure liquid
               chromatography and mass-spectrometry.

          o    Develop improved collection devices for
               toxic chemicals to be used in determining
               exposure concentrations of toxics in air.

          o    Develop methods for separation and charac-
               terization of toxic chemicals in soil/
               sediments.  Although soil/sediments repre-
               sent a major sink for toxics, the current
               state of the art for measuring and identi-
               fying toxics in soil/sediments are extremely
               limited.

FY 1981 Environmental Processes and Effects

     Transport and Fate -- The research plan for FY 1981
     will involve the continuation of the work identified
     for FY 1980 with the following modifications:

          o    Acceleration of work on methods develop-
               ment for exposure assessment of toxic
               chemicals in multimedia environments.

          o    Initiation of work on transport and trans-
               formation of chemicals in marine and terres-
               trial environments.

     Ecological Effects — The research plan for FY 1981
     will involve the continuation of the work identified
     for FY 1980 with the following modifications:

          o    Termination of the work on development of
               acute bioassay testing methods for use in
               evaluating toxic chemicals.

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                 -  304 -
     o    Initiation of chronic effects testing for
          toxic chemicals on organisms and the aquatic
          ecosystem.

Characterization and Measurement Methods Development
— The research plan for FY 1981 will involve
continuation of the work identified for FY 1980
with the following modifications:
opr
thl
     o    Expansion and acceleration of work on the
          development of methods for characterization
          and quantification of toxic chemicals in
          soil/sediment environments.

FY 1980 Measurement and Monitoring Research —
The measurement and monitoring research will focus
on the areas of biological laboratory quality eissur-
ance and technical support related to data collection
capabilities.  The priorities include:

     o    Develop reference and quality control
          materials, and prepare technical guidelines
          pertaining to methodology and biological
          laboratory testing.

     o    Develop a laboratory intercomparison
          studies program and evaluate laboratories
          and laboratory procedures.

     o    Develop a training program comprising
          quality assurance procedures and method-
          ologies .

     o    Determine the nature and extent of toxic emis-
          sions to the atmosphere through fenceline
          monitoring studies around chemical complexes.

     o    Provide aerial sampling, photography and
          interpretation to identify and assess the
          nature, extent and source of toxics in
          the environment resulting from the manufacture,
          processing and disposal of toxic substances.

FY 1981 Measurement and Monitoring — In FY 1981
this program will focus on quality assurance for
biological testing which will be sufficiently
developed to stock and operate a repository of
biological testing and reference materials.  This

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                 - 305 -
will allow interlabor^tory testing of biological
testing protocols to be conducted on a routine basis.
It will facilitate conducting evaluations on a routine
basis.  It will also permit an assessment of the
proficiency of analyses and the performance of techni-
cians conducting biological tests.  Technical assist-
ance support will be maintained in essentially the same
areas as were identified in FY 1980.

FY 1980 Changes — The FY 1980 plan for quality assur-
ance of biological laboratory testing is a new start. A
small program has been in existence which demonstrated
the feasibility of in vivo incorporation of inorganic
toxics into plant tissues which could be used as
biological testing reference materials.  This initial
program indicates the probability of the success of the
development of organic toxic materials into tissue
samples is good.  No changes are anticipated in the
technical support program to provide data collection
capabilities in the area of toxics monitoring.

FY 1981 Changes — No changes are anticipated.

FY 1980 Control Technology Research — In FY 1980
emphasis will be placed on expansion of the regulatory
data base, specifically the development and expansion
of the predictive model for chemical manufacturing.
The plan includes the following priorities:

     o    Use process expertise in the manufac-
          ture of existing chemicals to provide and
          predict information on the occurrence of
          toxics as contaminants in intermediates,
          by-products, products and wastes.

     o    Develop marketing and use information to
          provide a basis for identifying substitute
          chemicals and alternative process routes
          including recovery reuse and recycling of
          toxic wastes.

     o    Develop a predictive model for new chemical
          manufacture to identify anticipated processes
          and expected releases of toxics.

FY 1981 Control Technology Research — This program
which originated in FY 1978 and is approaching critical
mass in FY 1980, will be expanded in FY 1981.  The

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                      - 306 -
     major emphasis will be to support manufactur-
     ing regulations development as well as control of
     existing chemicals, emergency response techniques
     and assistance to the regions.  The predictive model
     for new chemical manufacture to identify anticipated
     processes and expected releases of toxics will also
     be expanded.

Alternatives — An alternative to the planned
method of operation (a balance between in-house and
extramural) is an all extramural effort.  This was
rejected because:

     o    EPA has now established expertise in terms
          of both facilities and highly specialized
          interdisciplinary personnel.

     o    Additional cost of extramural work.

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                      - 307 -
REGIONAL GUIDANCE

Abatement and Control

     Overview

     This guidance describes recommended Regional Toxics
Program activities and anticipated outputs for the re-
mainder of FY 1979 and for FY 1980.  All of these
activities support the development and implementation of
either TSCA programs in particular or of integrated
Regional toxics programs in general.  The guidance does
not discuss the development of a Regional organization
or strategy for the control of toxics, since that issue
has already been addressed by most Regions through the
development of coordinating mechanisms such as policy
committees or staff working groups.  Those Regions
which have not yet established such mechanisms, however,
should do so, as the integration of Regional toxics
programs and activities continues to be an extremely
important effort in FY 1979/80, as it has been before.

     Regional Priorities

     The Regional activities included here are essential
both to the implementation of TSCA programs and to the
more general task of providing a systematic and integra-
ted Regional approach to toxic substances control.
The recommended activities are:  (1) TSCA Program Imple-
mentation (including the School Asbestos Control Pro-
gram) ; (2)  Development and Implementation of Integrated
Regional Toxic Substances Programs; (3) Industry Assist-
ance;  (4)  Public Participation and Information;
(5) State Financial and Program Assistance; and,
(6) TSCA Regulations Development.

     Regions may find it necessary to vary the priority
of these activities to reflect any unique or unusual
problems or characteristics of their areas.  If, for
example, a TSCA regulation will affect only a segment
of the chemical industry not represented in a given Re-
gion,  that Region may choose not to become deeply in-
volved with its development or implementation.  On the
other hand,  if the Region were the principal locale for
the regulated segment of the chemical industry, more
active involvement would seem useful to both OTS and to

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                     - 308 -
the Region.  Similarly, if the Region has neither a
State cooperative agreement under Section 28 nor a
Headquarters-funded public participation program, there
will be minimal need to devote Regional resources to
those areas.  And finally, readers should note that
the higher priority activities will not necessarily
demand the most Regional resources, nor will the lower
priority ones necessarily demand the least.

     The following sections describe the resource re-
quirements, program components, and associated outputs
for each activity.  The activities discussed are not in-
tended to represent all feasible approaches, and crea-
tive alternative approaches are encouraged.

     Principal Regional Activities

(1)  TSCA Program Implementation  — TSCA implementation
activities for FY 1979/80 should emphasize the School
Asbestos Control Program; the PCS marking and disposal
regulations; and, the Section 5 Premanufacture Notifica-
tion Program.

     (a)   During the second half of FY 1979 and early FY
1980, the highest priority aspect of TSCA program imple-
mentation for Regional Offices is the development of
State Voluntary School Asbestos Control Programs.  This
is because the School Asbestos Control Program addresses
an immediate problem which appears solvable by an inten-
sive effort over a relatively short period.

     Therefore, each Regional Toxics Program should
actively encourage State and local participation in this
program.   Headquarters has developed an asbestos guid-
ance document which provides basic information concern-
ing identification and mitigation of the problem.  The
Regional Toxics Program should disseminate information
on the program widely, especially to other Federal,
State or local governmental bodies, both by distributing
the document and by participating in whatever public
forums may be available.

     This effort will probably require considerable
attention from Regional staff, especially in responding
to inquiries from affected State and local organizations
(e.g.,  school boards); but it also is probable that most
of this attention will be concentrated in the six months

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                      -  309  -
immediately after initiation of the program on March 16,
1979, a period roughly corresponding to the second half
of FY 1979.

     (b)  TSCA program implementation should also empha-
size the PCB marking and disposal regulations.  Regional
staff should develop familiarity with the facility appro-
val process, and participate in the decisionmaking.  It
is especially important that Regional Toxics Staff iden-
tify and forward to Headquarters any problems or issues
related to the permitting process, including those re-
lated to facility siting and public opposition.

     (c)  The Premanufacturing Notification Process under
Section 5 will demand time and attention from Regional
Toxics Programs, but neither the dimensions nor timing
of this demand can be predicted with precision yet.
Regional staff may be involved in at least two distinct
roles:   (1) assisting the affected industries in under-
standing and complying with Section 5; and, (2) assist-
ing Headquarters in conducting site-specific or plant-
specific assessments.

     The first of these roles is included in the Regional
Toxics Programs' activities under Program Implementa-
tion.  The impact of the second role remains unclear,
since the number and distribution of Section 5 notices
cannot be predicted.  The type of assistance involved
will include responding to Headquarters requests for in-
formation on the site or plant at which a new chemical
is to be produced, including whatever information may be
available from other parts of the Regional Office or
from the appropriate State.

     This second role may require a significant share of
Regional toxics resources but that will not be clear for
some time.  The distribution of resources and the prior-
ities in this Guidance will be revised if necessary at
such time as the impact of this activity on the Regions
is clearer.

(2)   Development and Implementation of an EPA and
Interagency Integrated Toxics Substances Program — The
development and implementation of a coordinated Regional
toxic substances control program which integrates all

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                      - 310 -
relevant Federal control activities continues to be a
major activity for the Regional Offices during FY 1979/80,
Most Regions have already implemented coordinating
mechanisms in the form of policy committees or staff
working groups or are planning to do so shortly.  The
Regional Toxics Program should actively participate in
such groups, and through that participation assist the
group in:  defining specific toxic substances problems;
coordinating effective and efficient use of resources
in solving those problems; identifying data needs;
acquiring and analyzing data; and, establishing working
relationships with EPA Headquarters and with other
governmental entities.  The Regional toxics staff role
should be coordinative, however, as the resources to
carry out the group's recommendations will be from air,
water, solid waste, etc.

     The Regional Toxics Programs could also assist their
Regional coordinating groups by identifying chemical manu-
facturers and processors.  Most of this information is
contained in data submitted under the Inventory Reporting
Regulation (Section 8(b)).  Regional Toxic Staffs will
need to receive clearance and to develop safeguards for
the handling of such information, as access to, and use
of, some of it is restricted due to confidentiality
claims.*  Further, OTS will provide summaries of Section
8(e) reports to the Regions periodically, and this in-
formation also may prove useful in helping the Region
identify potential problems.  Similarly, compliance
monitoring data and records of enforcement actions can
help identify problem sites, both potential and actual.

     Other useful activities include:  helping the group
to identify key contacts in their Regions, both in EPA
and in other Federal Agencies; compiling a list of avail-
able toxics information; and developing information on
current or planned contracts in relevant subject areas.

     Interagency program coordination (through coordina-
ting groups, for example) can have the effect of provid-
ing additional resources and information to the Regional
Office, although over the near terra this coordination
may involve only the IRLG.  The IRLG is responsible for
*C1D has already provided Regions with detailed require-
ments and procedures for this.

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                      - 311 -
coordinating the activities of its five member agencies:
OSHA, CPSC, FDA, FSQS (USDA), and EPA.  (Each Regional
Office has designated an IRLG contact.)  Examples of
Regional IRLG activities include:  personnel exchanges,
joint inspections, referral of consumer complaints, shar-
ing of investigative equipment and facilities, exchange
of chemical hazard information, and public information
and education.  The Regional Toxics Program should examine
IRLG activities to determine how they can best con-
tribute to the Regional coordination effort.

     OTS has not accorded spill response a high priority
and, therefore, the Regional Toxics Program should
attempt to minimize active involvement in on-site
response.  Since TSCA does not provide for funding to
support the mitigation or clean-up of spills or other
environmental incidents, these actions should be left to
the various media offices or to the Regional Spill
Coordinator.  The Regional Toxics Staff can help most
effectively by providing technical information concerning
the health and environmental risks of spilled (or in
situ) toxic chemicals, and in order to do this, the~
Regional Toxics Program may need access to information
sources available at Headquarters.  OTS has not yet
developed criteria or procedures for ordering and choosing
among Regional requests for this kind of Headquarters
assistance, although the Program Integration Division plans
to develop such a mechanism during the last quarter of
FY 1979.

(3)  Industry Assistance — The Regional Toxics Program
should serve as a local liaison between EPA and industry
by providing technical assistance, disseminating infor-
mation, and referring any requests they cannot fulfill
to the appropriate media programs or Agencies.

     The Regional Toxics Program can further TSCA pro-
gram implementation by providing industry with informa-
tion on TSCA regulations and related activities.  Two
ways this information can be provided are through parti-
cipation in compliance training programs developed and
conducted by Headquarters and by answering questions
from individuals concerning the various TSCA regulations,
Premanufacture Notification forms and processor reports.

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                      -  312  -
     The Headquarters Industry Assistance Office also
provides this important service to industry and has
established a toll-free telephone number as part of its
program.  Most calls to the Regional Office will seek
forms or publications or raise general questions about
toxic substances.  As many callers as possible should,
therefore, be directed to the toll-free number so as not
to consume limited resources in the Regions.

(4)  Public Participation -- Public participation has
become an increasingly important part of EPA's decision-
making, in large part because EPA's experience has shown
that an informed public can and does improve the quality
of that decisionmaking.  The success of toxic substances
control will depend, at least in part, upon the public's
perception that proposed controls are reasonable, well-
designed, and cost-effective.  Allowing the public to
participate in, and have an impact on, the toxic sub-
stances decisionmaking process can only foster a better
understanding of the issues and provide support for EPA
actions.

     OTS has a commitment to involve grass-roots organi-
zations in its public participation program.  During FY
1979, a pilot public participation program has been
developed in Region II to increase public participation
under TSCA, as well as to build public awareness of
toxics problems which may be controlled under other
Federal, as well as State and local authorities.  Head-
quarters plans to select two or three other Regions in
FY 1979 to develop public participation programs through
two-year grants from Headquarters.  Development of public
participation programs in the remaining six Regions is
planned for FY 1980/81.  Two of the criteria for selection
of grantees are:  (1)  a commitment by the Regional
Office to finance the project during its third year; and,
(2) a willingness to work towards institutionalizing the
concept of public participation in the Region.  Further
criteria for selection of grantees, and guidance on
grant monitoring, will be developed by the Program
Integration Division during the third quarter of FY 1979.

     Regional Toxics Programs are encouraged to support
the development of public participation components in
State applications for funding under Section 28 of TSCA
as a further means for involving citizens in toxics plan-
ning, control, and decisionmaking.  Those regions not in-
volved in Headquarters-funded programs are nevertheless

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                      -  313 -
encouraged to develop coordinated, innovative Regional
public participation plans and programs of their own.
Detailed guidance for this activity will be developed by
the Program Integration Division during the fourth
quarter of FY 1979.

(5)  State Financial and Program Assistance — During FY
1979/80 the Regional Toxics Programs should focus their
State Financial and Program Assistance activities on:
(a) managing such State cooperative agreements as are
awarded in their Regions;  (b) providing information and
assistance on the Federal program, especially with re-
spect to available information and information manage-
ment systems; (c) identifying the key people and agencies
for toxics control in their States; and, (d) developing
data on State programs, including State legislation,
regulations, and information resources.

     (a)  TSCA Section 28 authorizes State grants to con-
trol toxic substances.  Two rounds of competition will
be held during FY 1979.  The Regional Toxics Program
should provide information to States on the availability of
these grants, including making them aware of the May 27,
1979, closing date for the second round.  If TSCA appears
to be the appropriate source of funds, the Regional Toxics
Program should assist interested States in developing
their proposals, consistent with the National objectives
for the program as expressed in the August 28, 1978,
Federal Register.  The appropriate Regional Toxics Pro-
grams will also participate in the selection process by
reviewing and rating any proposals from their respective
regions.

     Affected Regions will, of course, need to monitor
the progress of grantees within their Region after award.
The grantee State will be required to provide quarterly
and annual reports to the EPA Project Officer.  The
Project Officer, in turn, in conjunction with State
Officials, should prepare and forward to the Program
Integration Division semi-annual evaluations of the grant
which include a copy of the State's annual report and
an evaluation of the grant's impact on the public, and
on State and local governments.  The evaluation should
address:  (1) the transferability to other State Programs
of techniques or procedures developed by the project,
and any attempts already made to transfer them; (2)  the
extent to which the project has complemented or otherwise

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                      -  314  -
impacted upon Regional Office toxics programs; and (3)
possible ramifications of the project for future Head-
quarters policy, procedures, rulemaking, etc.  The
Project Officer should use these evaluations to work
with State officials to guide the projects toward fitting
Regional needs.  Evaluation reports should, of course,
include any modifications agreed to by EPA and the State.

     (b)  Regional Toxics Programs should provide in-
formation and assistance on the Federal program.  The
purpose of this is to ensure that States develop pro-
grams which complement that of EPA and which are reason-
ably consistent from one State to another.

     For example, several States have already developed,
or are currently in the process of developing, toxics
information systems.  These systems may well duplicate,
or be incompatible with, the information systems being
developed by EPA, other Federal agencies, and even those
of other States.  States should be made aware of Federal
information systems, so as to minimize the chance of
their investing time, money, and effort in their own
systems unnecessarily.  The Program Integration Division is
procuring contractor support to train State and Regional
staff on the availability and use of all relevant infor-
mation systems.  This training should be available by
early FY 1980.

     (c)  The identification of key people and Agencies
is especially important in FY 1979/80, as both the Federal
and State toxics programs are in early stages of develop-
ment.  The Regions' need to convey information and ren-
der program assistance to the States requires that they
quickly learn who the "players" are in each State and
establish contact with them.

     (d)  The National Wildlife Federation is currently
conducting a survey of State Toxics Substances Programs
under a grant from the Program Integration Division.
Their survey will produce considerable information on
State legislation and regulations for toxics management
and control.  Regional toxics programs should supplement
that base by developing information on State organiza-
tional and staffing patterns, and on State resources
such as information systems, laboratory capabilities,
etc.  All of this data should be distilled into a "State
Profile" which serves two major purposes:  (1) it will
help the Regional staff to identify both the capabilities

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                      - 315 -
and the limitations of their State programs; and,  (2) it
will help Headquarters assess and assist the development
of State toxics programs over the next 3-5 years.
Regional Toxics Programs should send copies of these pro-
files to the Program Integration Division as they  are
completed.  In addition, Regional toxics staffs should
be aware of, if not participants in, non-Federal toxics
planning in their Regions to ensure consistency with the
Federal program and policies.

(6)  TSCA Regulations Development — During FY 1979/80,
OTS regulatory activities will focus on:  Section  4
Testing Rules; Section 5 Premanufacture Notification and
Review; Section 6 Rules  (PCBs and possibly asbestos);
TSCA Section 8 Rules; and, one or two existing chemicals
or generic rule areas yet to be identified.

     The Regional Toxics Programs are responsible  for
reviewing draft and proposed TSCA rules to provide a
Regional perspective to the rulemaking process.  The
Regional input will take the form of either active
participation in the work group process (including
attendance at work group meetings) or review of the draft
and proposed regulations.

     Each work group will include at least one Regional
Toxics Program representative (the "lead Region").  The
lead Region will be responsible for keeping the other
Regional Toxics Programs informed of the relevant  issues
concerning the developing regulations and for soliciting
their comments on all drafts.  The lead Region will then
provide the Headquarters working group with the resulting
comments, and will raise issues identified by the  other
Regional Toxics Programs for attention from the work group.

     Regional Toxics Programs should ensure that all
relevant information is brought before the work group,
especially where a regulation is designed to address a
problem of special interest to one or more Region(s).
Further, each Region should solicit input and comments
from the other Regional Media offices, State offices,
and public organizations.  Public input and comments
from individuals and organizations should be solicited
through existing public participation mechanisms (includ-
ing Headquarters-funded activities).  Formal or informal
meetings comprise one such mechanism.  The lead Region

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                     -  316 -
4
should ensure that all inputs obtained are compiled and
forwarded to the working group for inclusion in the rule-
making record.

     Region-Specific Guidance

     Specific guidance for those Regions having Head-
quarters-funded public participation and/or State
cooperative agreement programs is provided in the
discussion of Principal Regional Activities for public
participation and State financial and program assistance..

     Resource Requirements

     Regional needs for each Regional Toxics Program
(Table I) will vary depending upon such factors as the
number of States in the Region, the extent to which all
program elements are undertaken and the program's level
of involvement in each.  A Regional Toxics Program of
the kind and level described here will require approxi-
mately 3.5 to 5 person years.  Regions in which Head-
quarters-funded public participation projects are con-
ducted will need to devote about one additional person
year to their projects and each of these programs would
therefore require approximately 4.5 to 6 person years of
effort.  This level of required resources exceeds what
will actually be available in FY 1979 or FY 1980.  OTS
will augment Regional Staff by contracting for the services
of ten civil engineers, and assigning one to each Region
to assist with the School Asbestos Control Program.
Because these are contract resources, they are riot shown
in Table I, and are in addition to the 46.5 person years
listed there.

     Reports

     OTS expects to implement a Regional reporting system
in the third quarter of FY 1979.  This system will allow
the Regions to inform Headquarters, and each other, of
significant problems and issues affecting their imple-
mentation of the program described in this Guidance.  The
reports will also enable Headquarters to make such
adjustments to the program as may be called for in light
of the Regions' experiences in implementing it.

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                      - 317 -
     The report should be submitted monthly to the
Program Integration Division (TS-793) and should cover
at least the following:

     (1)(a)  School Asbestos Control Program;

     State contact (if changed); problems or complaints
from States; significant developments, including major
news coverage; activities in State legislatures; and,
any additional comments the Regional Staff thinks useful.

     (1)(b)  Other TSCA Program Implementation;

     Any significant problems or issues.

     (2)  Toxics Integration;

     Information on Regional coordinating groups should
include descriptions of their format (if changed from
what was initially reported); objectives; planned activi-
ties and schedule; and, planned outputs.

     A summary of IRLG and other interagency activity
should also be included.

     (3)  Industry Assistance;

     A log of industry assistance activities such as
phone calls, literature provided, industry consultations,
meetings or seminars attended,  etc., should be kept to
document Regional involvement and to establish Regional
resource requirements.  A summary of these activities
should be included in the monthly report submitted to
the Program Integration Division, which will then inform
the Industry Assistance Office.  The summary should in-
clude:   numbers of telephone inquiries received, meetings
attended,  and major questions or issues raised.

     (4)  Public Participation/Information;

     Any significant problems or issues.

     (5)  State Financial and Program Assistance;

     Any significant problems or issues.  (Regions moni-
toring  cooperative agreements should report semi-annually

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                     - 318 -
as described in Part 111(5)  of this Guidance.  Signifi-
cant problems or issues between these reports should be
identified in the monthly report.)

     (6)   TSCA Regulations Development;

     Any significant problems or issues.

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                     - 319 -
                      Table 1

              Regional Toxics Program


  Distribution of Available Resources by Activity


                                          Aggregate
     Activity                      Resource Requirements

1.  TSCA Program Implementation
    a.  School Asbestos Control Program      7.5
    b.  Other (PCB, CFC, etc.)              13.0

2.  Development and Implementation          10.0
      of Integrated Toxics Programs

3.  Industry Assistance                      6.0

4.  Public Participation                     4.0

5.  State Financial Assistance               2.0

6.  TSCA Regulations Development             3.0

7.  State Program Assistance                 1.0

                              Total         46.5
Note:     These are aggregate figures for the ten Regions.
          Those Regions with Cooperative Agreements and/or
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          and remaining Regions for less, of the resources
          estimated for Activities 4 and 5 above.
     The total for Activity 6 is presumably divided among
all the Regions equally since no Region will be "lead
Region" for all the sets of regulations developed during
FY 1979/80.

-------
- 320 -





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                      - 322 -
Enforcement

     Regional Priorities

     The following Regional enforcement activities
will be given highest priority in FY 1980:

     o    First Priority

          -    Initiate investigations and prosecute
               enforcement actions in response to
               toxic substances emergencies

               Conduct compliance monitoring programs
               and initiate enforcement actions in
               support of premanufacture notification
               regulations under section 5

               Conduct compliance monitoring programs
               and initiate enforcement actions in
               support of chemical control regulations
               under section 6 (including PCBs, CFCs,
               and any others in effect)  and rules or
               orders issued under sections 5(e)  or
               5(f) .

     o    Second Priority

          -    Implement multi-media compliance
               monitoring and enforcement program

          -    Coordinate regulatory and information
               gathering strategies with Regional OSHA,
               FDA,  and CPSC offices

               Implement public outreach programs and
               other methods to induce voluntary compliance
               with TSCA

          -    Conduct compliance monitoring programs
               and initiate enforcement actions in
               support of testing rules and reporting
               regulations promulgated under section 4
               and section 8(a)

               Conduct compliance monitoring programs
               and initiate enforcement actions in
               support of import regulations under
               section 13

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                     - 323 -
     o    Third Priority

               Conduct compliance monitoring programs
               and initiate enforcement actions in
               support of reporting requirements under
               sections 8{c) and 8(d)

               Participate in TSCA rulemaking and enforce-
               ment strategy development activities

     Principal Regional Activities

     In FY 1980, the highest priority Regional activity
will be responding to emergency situations involving
substantial threats to public health and safety and
initiating enforcement actions where appropriate.
Additional priority activities will include inspections
of facilities subject to rules or orders issued under
sections 5(e), 5(f), or to chemical control regulations
(specifically PCBs, CFCs, and any other regulations in
effect in FY 1980), and those firms which are subject
to section 5 premanufacture notification requirements.
Inspections of facilities subject to section 4 testing
rules and section 8 reporting requirements will be
conducted in close coordination with the screening process
conducted at Headquarters.  The Regions will monitor
compliance with section 13 importing regulations in
cooperation with local personnel of the U. S. Customs
Bureau.  Regional enforcement offices will perform the
case preparation and case prosecution functions needed
to successfully prosecute actions arising from the
aforementioned investigatory programs.  The Regions
will also implement intra-agency multi-media enforcement
programs, and public outreach programs and other means
to encourage voluntary compliance with TSCA requirements.
In addition, Regional personnel will participate in
the development of enforcement strategy and policy.

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                     - 324 -
PROJECTED PROGRAM ACCOMPLISHMENTS  (PPAs)

- Number of enforcement actions  initiated  in  response
  to toxic substances emergencies

- Number of inspections of facilities  subject  to
  Section 6 rules on PCBs

- Number of inspections of facilities  subject  to
  Section 6 rules on CFCs

- Number of inspections of facilities  subject  to
  Sections 5(e) and 5(f) rules

- Number of inspections of facilities  subject  to
  Section 4 rules

- Number of inspections of facilities  subject  to
  Section 5(a) rules

- Number of inspections of facilities  subject  to
  Section 8 rules

- Number of inspections of facilities  subject  to
  Section 13 rules

- Number of enforcement actions  initiated  against
  violators of Section 6 rules on  PCBs

- Number of enforcement actions  initiated  against
  violators of Section 6 rules on  CFCs

- Number of enforcement actions  initiated  against
  violators of Sections 5(e) and 5(f)  rules

- Number of enforcement actions  initiated  against
  violators of Section 4 rules

- Number of enforcement actions  initiated  against
  violators of Section 5(a) rules

- Number of enforcement actions  initiated  against
  violators of Section 8 rules

- Number of enforcement actions  initiated  against
  violators of Section 13 rules

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                      -  325  -
Number of intra-agency multi-media inspections
conducted

Number of IRLG referrals

Number of inspections conducted under IRLG guidelines

Number of program activities conducted to encourage
support for voluntary compliance with TSCA require-
ments

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1980/1981 PESTICIDES MEDIA GUIDANCE

-------
                    PESTICIDES


KEPIA OVERVIEW

Planning Assumptions

     The Federal Pesticide Act of 1978, which amended
the Federal Insecticide, Fungicide and Rodent icicle Act
(FIFRA), will make the regulation of pesticides nore
efficient, more effective, and more timely.  All
registration (section 3) guidelines will be completed
and in force by the second quarter of FY 30 and new
regulations, where appropriate, will he in effect at
this time and fully enforceable.  The following
assumptions reflect the new directions and resumed
activities that those amendments have made possible.

     Studies required by the FIFRA as amended on methods
of pesticide applications and minor use pesticides will
be completed the third quarter of FY 79, but at this
time, we do not anticipate the results to cause any
major realigning of OPP's regulatory activities.  Ef-
forts to refine and improve the Agency's tolerance-
setting mechanisms will continue through FY 80 and
FY 81; no radical departures affecting Agency or
registrant resources are anticipated.  Legal chal-
lenges to the trade secrets and data compensation
provisions in the 1978 FIFRA amendments are anticipated.
OPP and the Office of General Counsel expect these to
be resolved in FPA's favor.

     The Generic Standard development process will be
fully productive by the beginning of FY 80.  RPAR will
be merged into the neneric standards in FY 81 when the
original RPAR commitment to 65 chemicals has been
completed.

     Until pesticide generic standards are developed,
I1PA will be granting conditional registrations.  Con-
ditional registrations will allow the Agency to process
applications for registration of new products which
are like one already registered.  Ultimately, OPP will
review all products comprehensively when they are
reregistered under generic pesticide registration
standards.

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                        -  330  -
     "Me-too" products and new uses of "old" chemicals
will he eligible for conditional registration if EPA
determines that enough information is available to
evaluate unique hazards that nay be posed by the new
uses.  The Agency will also issue conditional registra-
tion of new chemicals in the public interest if risk
during the period required to complete and subnit
additional studies is not unreasonable.

     States will have broader authority and responsi-
bility for registering Section 24(c) "Special Local
Needs" pesticides without requiring EPA'S approval.
Regions will assist States in establishing their 24(c)
programs and will provide early guidance and screening
to States on individual 24(c) applications.  Final
review/disapproval will remain a headquarter's function.

     EPA will use broad discretion granted by the 1978
amendments to waive the submission of efficacy data.
OPP will evaluate this during 1980 and, if it does not
prove to be effective, will reconsider this approach.
In any case, the Agency will continue to consider
efficacy when performance of the product bears upon
public health.

     In FY 1980 EPA will complete (except for updating)
the process of classifying uses by regulation, apart
fron the registration process.  This will help to
realize the objectives of the applicator certification
prograii with regards to restricted use products.

     The effort to develop grants-in-aid with States
and Territories for enforcement will be continued.  By
the end of FY 1980, 43 States will have cooperative
grants-in-aid, and by FY 1981 the number of grants will
increase to 50.

     The Office of Enforcement will initiate a new pro-
gram (Investigations of Nationally Targeted Pesticides
Public Health Incidents) during FY 1979 to focus upon
all aspects of the manufacture, distribution, use, and
disposal of certain restricted use pesticides.  This
effort will be given continued empahsis in FY 1980.

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                     - 331 -
     By the end of FY 19110, it i.s expected that all, or
alriost all, Federal facilities which are najor sources
will l>e in conpliance and nost ninor source Federal
facilities d£ well.  Reqions should see to it that all
Federal facilities uo intend cone into conpliance as
soon as possible, and no later than the end of FY 1980.

     Research and Developnent will be integrated into
supnortino pesticide activities in 1980.  Furthermore,
OKD will receive its planning priorities fron the
Pesticide Research Connittee and specific requirements
fror. OPP.

     The Federal Certification proyran in Colorado and
Nebraska will continue at least through FY 1981.

     GPP will he staffed up to budgeted levels with
qualified professional and support personnel.  Both
Regional HPAR and Special Registration Decision Units
are eliminated convene ing in l^HH.

Priorities

     FY &G priorities will enphasize the completion of
the rendining RP*\P reviews, conpletion of registration
standards initiated in FY 7(' and reregistration of
existing pesticides based on these registration stand-
ards, registration of new environmentally protective
pesticide products for which conplete hazard data are
submitted, expanded enforcerent involveraent on the
;)art of the States, and increased rt?sponse to eiaerqericy
situations which involve substantial threats to public
health and safety.

     FY 1081 priorities for the pesticide pronran will
be similar to those for FY 1980.  PPAR will be substan-
tially completed and integrate'' into the registration
standards j'rocess.  highest priority will bp registra-
tion of new environmentally protective pesticide
products.  Continued completion of registration standards
and reregistration of existing pesticides based on then
will also be emphasized.  Cooperative enforcement grants-
in-aid are expected to he developed in all or i.iost States
by the end of FY 1981.

-------
                    - 332 -
     In those States which have Federal certificetior
programs, enforcement activities v/ill be in support of
efforts directed toward developing approved plans.

Federal personnel will continue to be responsible for
enforcenent of applicator certification in Colorado and
Nebraska.

Major Objectives

     In FY 80 the Agency plans to review benefits and
risks of 12-17 RPAP compounds identified as posing
potentially unreasonable adverse effects and reach 15-20
final risk/benefit determinations on PPAR compounds;
irplenent the conditional registration progran; give
registration priority to new chemicals for which con-
plete hazard data are subnitted; reregister 1,c-OP-l f 400
products fron available generic standards; complete the
generic standards initiated last year and initiate the
preparation of 40-50 generic standards, including the
reassessnent of associated tolerances.

     !"ajor objectives, reflective of the special
registration progran, will be for Peg ions and Head-
quarters to provide tir.ely ancl responsive guidance to
the States relative to their Section 5(f) experimental
use pemits and review 180-24G Section 5 registrations
in a median turnaround time of 120 days; review 1,000-
1,500 Section 24(c) special local needs registrations
and conduct overview activities on their final actions;
review 170-220 Section 18 emergency exemptions in a
median turnaround tine of 4 weeks including full scien-
tific review of pertinent data.

Guidelines for biological pesticides will be promul-
gated.  The Agency will establish 80-120 pesticide
residue tolerances and review 75-100 amendments for food
and aninal feed crops after review of data and risk/
benefit analyses in a median turnaround tine of 105 days.

     The laboratory audit program will he continued;
50-70 laboratories will be audited.

     FOI requests will be given an initial response
wiH'in 10 days followed by a final response as quicKly
as possible.  Monitoring for hazard prediction and
significance of potential problems v;ill continue, but
will be more closely tuned to support the regulatory
process.

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                     - 333 -
     The abatenent and control objectives  for 1981 re-
nain the sane as for 1980 except that the  RPAR process
wi.ll be integrated into the generic standards process
and increased eiv.pahsis will be given to reqistration
of innovative, environmentally protective  compounds.

     The Federal Fnforcer.ent role v.'ill continue to be
one of oversight, guidance, an support of  non-Federal
enforcement effects in States and Territories.  The
procjran will also focus upon all aspects of  the nanu-
facture, distribution, use, and disposal of  certain
restricted use pesticides.

     During the next two years, four riajor objectives
will be driving the F;nvironr.ental Protection Agency's
research and development program.  These are (1) con-
tinuing the integration of the Office of Research and
r.evelopment into the nainstrean of the pesticide
activities by supporting the Pesticide Research
Cor.T^ittee thet was jointly developed by OKD, OPt>,
Office of Enforcement and regional representation,
(2) enhancing the Office's capability to improve the
scientific ami technological data for use  in future
regulatory and enforcement actions, (3) inproving
that data through scientific peer review of  research
procedures and results, quality control of risk assess-
ments, and cruality assurance of monitoring data, and
(4) providing specific data in response to OPP's
innediate needs.

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                    -  334  -
HEADQUARTERS PLANS

Abatement and Control

     Plans and Emphases

          In 1980, the Registration Standards program
     will cement the standards production rate and
     maintenance process as a workable regulatory
     m.eans of reregistering, in roughly a decade,
     approximately 40,000 pesticides.  Based on the
     initial experience with the prototype standard,
     OPP expects development of each standard to take
     13 to 14 months.  Thus, the first standards
     initiated in FY 79 will be conpleted in FY 80
     and an estimated 48 standards will be initiated
     annually thereafter.

          The subtasks involved in the development of
     a generic standard include screening all published
     literature, company submitted data and other un-
     published information; bibliography preparation;
     data evaluation and assessment of fate effects
     and exposure risks and benefits; preparing a
     regulatory rationale and position; seeking public
     comment and participation; preparing and publish-
     ing the standard document; and managing records
     with the necessary ADP and micrographic support.

          During FY 1980 EPA will be maintaining the
     prototype standard completed during FY l'J79 as
     well as initiating maintenance on new standards
     as they are completed.  The subtasks involved in
     maintaining completed generic standards include
     screening all newly published literature, new
     company, laboratory, monitoring, and accident
     data and updating the standard, as necessary,
     from this material.  In particular, this effort
     covers updating standards to include new uses,
     new tolerances, new special registrations and
     new data.  Reregistration of existing pesticides
     will be initiated upon completion of appropriate
     generic standards.

          In 1981 there will be a continuation of the
     1980 program in which standards will be completed
     from the previous year and new standards will be
     initiated.

-------
                - 335 -
     In 1'^BO the rebuttable presumption against
registration process will be completed on the
majority of the 65 chenicals originally listed
as RPAR candidates.  Final decision documents
including environmental impact statements will
be prepared for 15-20 chemical classes on which
a rebuttable presumption has already been declared
because these chenicals are suspected of having
an adverse effect on nan or the environment.  In
addition, decisions on whether to issue an RPAR
will wade after data gathering for, and evaluation
of, 12-17 other chemical classes.  Two administra-
tive hearings are anticipated, for which technical
and scientific support v;ill be provided.  The Sub-
stitute Chemicals Program will be integrated into
the RPAP process since final decision documents
require the determination of feasible alternative
pest control strategies thot can be safely and
effectively substituted for RPAR chenicals.

     In the laboratory audit program 70 labora-
tories which perform tests in support of pesticide
registration and other studies will be audited
jointly by the Pood and Drug Administration and
CPA.  Primary emphasis will be placed on audits
of toxicology labs of particular importance to
the generic standard and RPAR process.  EPA head-
quarters personnel and regional PTSED inspectors
will perform Good Laboratory Practice (CLP) and
data audit inspections at environmental chemistry
and fish and wildlife testing facilities.  Two
hundred registrant validations of toxicology
studios will be evaluated.

     Similarities between the RPAR and registra-
tion processes illustrate the cost effectiveness
of combining future RPAR investigations with the
standards production.  Hence, the RPAR program
will be reoriented in 1980 for merger with
Registration Standards in 1081.

     Because of the legislative changes permitting
conditional registrations and the freeing of
strictures in the registration process, OPP will
be able to increase its regulatory decision-making
in 1980 on applications for administrative and

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               - 336 -
technical ar.endnents, new chenical registrations,
routine registrations, and tolerance petitions.
Increased resources will not only perf.it the
processing of an increased work load, but will
allow for reduction in decision miking tine and
application backloo.  No change is expected in
1981.

     Section 18 emergency exemptions will be pro-
cessed within four weeks of receipt and Experi-
nental Use Permit applications and petitions for
temporary tolerances will receive scientific and
administrative processing within 120 days of
receipt (this represents a 5U% reduction in
processing tine over FY 7H).  One hundred addi-
tional periodic RUP reports t/ill l/e reviewed
plus an additional 50 revised labels which, are
required as a condition for granting CUF's.
State-issued 24(c) registrations and 5(f) experi-
nental use pernits will be reviewed Cor less
obvious descrepancies and necessary corrective
action will be taken.  Appropriate connents and
constructive criticise will he forwarded to the
States.  In addition revised labels will bp
reviewed for eureerent v.>it>; the terns of each
special registration and a sanplinc, progran will
be established to evaluate the scientific validity
and legal adequacy of tleta subnissions.  Ijo
change is expected.

     ri'he cert if ication and training orant progran
was terminated in 1^79; however, up to $2 million
will be provided in 1980 for cooperative agreement
support to (1) States and Indian tribes which agree
to initiate and/or upgrade their certification
and training activities; (2) Statos and tribes  in
which FPA's ongoing progran evaluation justifies
continuation of federal assistance; (3) permit
continuation of Federal certification and training
activities in Colorado and Nebraska.  headquarters
will continue to appraise integrated pest manage-
ment techniques using the contract tnechani?n.
RPAK and IP^I functions will be performed at head-
quarters.  P.egistrant/public inquiries and
problens with these prograns will be directed to
the regions.  "egions will increase their public

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                    - 337 -
     av;erenesfj outreach to agricultural and other
     significant interest groups in order to build
     public understanding and acceptance of Pesticide
     pronrarrs.  Classification by rooulation of
     pesticide:-: for restricted use will be corplot^d.

     Changes

          In view of the passage of the Federal Pesti-
     cide Act of 1978 which air ended the FIFT£, no
     legislative changes are anticipated for FY 198U
     or FY 1CM1.  Organizationally, sinilar functions
     of On"'S and Opp will continue to be integrated  in
     loni.  Also, the P.PAR process will be ineruen  into
     the generic standards production process.

     Alternatives

          The primary alternative to be considered  in
     each proqran is that of contracting.  All proqrar
     olenents of non-regulatory nature should be
     examined.  Thon detenuning the possibility of
     contracts, the following will be considered:
     (1) cost effectiveness; (2) nuft.lity control;  (3)
     response4 to EPA operating programs; (4) definition
     of work scope; (5) time requirements; (6) sensi-
     tive/nonsensitive nature.  Prourans will also  be
     examined to determine if existing contract? could
     incorporate additional progran reouiranents bv
     expanding an existing contract rather than
     gene-rating new contracts.
Enforcement
     Plans and
          'J'hf i'nforcei^ont Proa ran in FY l^fio v;ill  be  a
     continuation and expansion of the treno tov/ard
     increased state involvement.  It is expected  that
     cooperative enforcenent yrants-in-aid will be
     developed in all or nost States and Territories
     l-y the end of FY 19SO.  The Federal role at the
     Regional level ir. Ftates and Territories which
     have grant s-in-aid will be that of State program
     oversight and guidance, developing and monitoring
     of State programs and activities, providing
     training to State progran staff, assisting as
     necessary in case developr ent, and initiating

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                -  338 -
Federal Enforcerient actions on the basis of State
activities where appropriate.  Consequently, in
States and Territories with grants-in-aid,
traditional Federal functions such as establish-
ment, TnarKet^lace, and use inspections will cease
or decrease significantly.  In States without
cjrants or with grants of less than comprehensive
scope, Federal inspectional activities will con-
tinue.

     The proaran area entitled "Investigations of
Nationally-Targeted Pesticide Public Health
Incidents" will continue in FY 1980, having begun
operation late in FY 7°.  It's role is primarily
to set priorities for enforcenent investigations,
emphasizing hunan health concerns.  The programs
initiation does not entail an increase in
resources, rather a reprogcanning.  It does, how-
ever, require increased coordination between OC
and OPP.

     Hnforcenent will continue to focus upon the
enforcenent of standards and requirements relating
to the certification of applicators.  Appropriate
enforcenent efforts in this area v;ill be under-
taken by most States in support of their certifi-
cation programs.  However, in those Regions in
which a State has not established an approved
certification plan, EPA will be responsible for
both applicator certification and enforcement of
such certification.  In such Regions, the Federal
pesticide enforcement progran nust include an
active enforcement effort in support of Federal
applicator certification.

     mhe laboratory audit progran will continue to
be given special emphases by the Office of
Enforcenent.  During FY 1930, the Office of Pesti-
cide Programs will expand the laboratory audit
program to include environmental data, using the
same criteria and techniques applied in the
toxicoloqical audits.  The Office of Enforcement
will provide inspection support for those audits.

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                -  339  -
Changes

     In response to the greatly expanded State
role in the pesticides enforcement program, the
Office of Enforcemnt will be reorganized along a
functionally-based organizational structure rather
than the existing nedia-oriented structure.  The
present three pesticides branches, Scientific
Support, Policy and Guidance, and Program Opera-
tions, and the one toxic substances/solid waste
branch will be replaced by three branches, each
havinq functional progran responsibilities.  Each
branch will have two sections with more narrowly
defined functions.  Personnel will administer
three statutes, the Federal Insecticide, Fungicide
and Rodenticide Act, the Toxic Substances Control
Act, and the Resource Conservation and Recovery
Act.  The reorganization will advantageously
respond to the siniliarities in all three statutes
by consolidatinq functions, responsibilities,
activities, and corresponding resources within
the same organizational elements.

Alternatives

     While the trend of the Pesticides Enforcement
Program is presently toward the continuation and
expansion of involvement on the part of the
States, it is possible that the responsibility
for enforcement could be wholly restored to the
Federal EPA.  The Office of Enforcement would
focus upon uniform* pesticide compliance among the
States and Territories.  Federal responsibility
for the enforcement of the pesticides prog rain
would, of course, necessitate a large increase
in position resources.

     The enforcement program continues to develop
grants-in-aid with States and Territories.  In
response to this growing trend, the Office of
Enforcement could administer a program which
reviews and audits the adequacy of state enforce-
ment programs.  Such a program would entail an
annual review of the efficiency and effectiveness
of State enforcement activities.

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                     - 340 -
          Presently, the participants of the Inter-
     agency Regulatory Liaison Group (IRLG)—Of.UA, FDA,
     CPSC, and EPA—are coordinated to participate in
     actual cooperative compliance and enforcenent
     activities.  As a result, the four agencies are
     involved in cooperative inspections which are
     conducted at any site or for any purpose at the
     referral, recormendation, or request of a cooper-
     ating Federal agency.  The cooperation anony the
     agencies could he extended beyond referral
     inspections to include joint inspections whenever
     and wherever appropriate.

          The laboratory audit program which is cur-
     rently conducted in EPA and FDA could be conducted
     instead by a private contractor in order to free
     Office of Enforcenent resources.  The Office of
     Enforcenent would then focus entirely upon case
     development, and determining whether allegations
     of nisconduct warrant referral of the case to the
     Department of Justice.

          Alternatively, the four agencies which par-
     ticipate in the Interagency Regulatory Liaison
     Group (IJRLG) — EPA, FDA, CPSC, and OSHA — could
     conduct the laboratory audit program.  The
     rationale for this course would be to ensure the
     nonitoring of the laboratory practices and testing
     data within the purview of the four agencies.

          ADP systems are currently operated at the
     Regional level.  Instead, these systems could be
     located at Headquarters to be conducted either by
     Headquarters personnel, or by a private contractor,
     Centralization of the systert would ensure a uni-
     form system of data gathering and analysis.

Research and Development

     Plans and Emphasis

          The Office of Research and Developnent will
     intensify efforts to develop protocols for obtain-
     ing a scientifically sound, legally defensible
     pesticide data base, to provide specific data
     requested by OPP, and to assist in assessing the
     data in relation to pos.tioide regulatory actions

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                -  341  -
required by the Agency.  Special emphasis will be
placed on a continuing integration of the Office
of Research and Development into the nainstrean
of the Agency's pesticide activities by supporting
the Pesticide Research Comnittee that was jointly
developed by ORD, OPP, Office of Enforcement and
Regional Representation.  ORD's planning and
reporting system will be synchronized with the
plans of the Research Committee and the Agency's
ZBB process.  Certain laboratory reporting
relationships will be realigned; this realignment
will enhance human health research and integrate
the environmental transport, fate, and effects
research pertaining to pesticides.

     The increased integration of ORD efforts into
the regulatory mainstream will result in an in-
crease of data and methods to support OPP's
regulatory needs.  In looking at health effects,
ORD will conduct exposure estimates on priority
compounds identified by the RPAP and generic
standards process.  Similarity, ORD will conduct
research into ecological effects in response to
near-tern regulatory needs.  This will include
data assessments, toxicoloyical tests and trans-
port and fate tests for RPAR compounds.  In
addition, ORD will develop the quality level of
analytical measurement data, expressed in terras
of precision and accuracy, to support OPP regula-
tory decisions.

     Additional activities include efforts to
build into our scientific and technological
activities appropriate review mechanisms, includ-
ing enhanced peer review for individual research
projects and systemic programmatic review for
pesticide research activities.  ORD will require,
to a greater extent than in the past, quality
assurance practices for all environmental quality
monitoring and analytical activities.

     Research activities will follow as closely
as possible the strategy and needs developed by
the Pesticide Research Committee and be responsive
to specific OPP needs.  The Committe contemplated
research required by OPP, OE, and the Regions to

-------
                -  342  -
fill knowledge and data-gaps, to develop scienti-
fic techniques for obtaining these data, and to
respond to future needs that are nore appropri-
ately anticipatory in nature.  Research needs
were discussed under three najor topics;  popula-
tions at risk, exposure assessnent, and adverse
effects.  Also included were research needs for
quality assurance, integrated pe?t nanaqenent and
technical support.  The Committee agreed that
exposure assessment should receive special
attention in FY SO and HI.

     The Integrated Pest Managenent (IPM) progran
will develop systems for use with chenical pesti-
cides to provide a necessary alternative for the
pesticide registration process.  Prinary eir.phases
v/ill he directed to najor crop ecosysters (corn,
cotton, soybeans, alfalfa, and apples) and urban
pests.  Technology transfer activities will
continue in order to educate the use community.

     The registered uses of a pesticide determine
the population group at risk.  As increased anount
of exposure data for different pesticides becone
available, it will be possible to nake accurate
and neaningful identifications of overall popula-
tions risk.  VJithin these {-opulations, attempts
will be made to pick out subgroups of persons at
relatively high risk of developing illness fron
pesticide exposure.  Extrapolation froio teratology
and reproduction studies in experimental aninals
will help to define those compounds that nay pose
a risk to oregnant wor.en as well as to the fetus
and the newborn child.  Other research will study
susceptibility to pesticides of aninal given sub-
optional diets.

     Interest in the population at risk also
includes pesticide exposed populations that nay
have incurred vulnerability to other hazards.
Hew studies to survey this orobler will include
evaluation of the inr»unoloqic competency of
aninals exposed to various pesticides and
capability of pesticide exposed aninals to with-
stand bacterial and viral challenge.  FY 7^ and

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                - 343 -
earlier research activities in pesticide exposure
studies have produced guidelines for general use
by registrants in measuring exposure of workers
to pesticides.  Emphasis in 1080 and 19B1 v;ill
be on developing and validating procedures useful
in measuring erivironnental exposure to pesticides,
particularly exposure of nearby residents to drift
fron agricultural application.  Also, research
will be begun to evaluate generic models for com-
pounds and application methodology in estimating
hunan occupational and environmental exposure to
replace study of individual situations.

     In-house and extramural studies will produce
the requisite scientific understanding, laboratory
measurement techniques, and mathematical descrip-
tions of the interactions of pesticide chemicals
v;ith air, water, and soil and the actions of
organisms on the chemicals.  This information will
then be developed into test protocols that incor-
porate necessary quality control provisions and
decision-r.aking tools to evaluate the environ-
mental transport, transformation and distribution
of pesticides.  Specifically, research on
environmental exposure will include determination
of transport processes in water, sediment of soil
and biota in terrestrial and aquatic environments.

     There will be a close coordination between
exposure research and effects to define the degree
of hazard or extent of safety of current pesti-
cide exposures for both occupationally and
environmentally exposed populations.  For many
pesticides, by-products, metabolites and biotrans-
formation products, exposure methodology is now
sensitive to levels below those known to have
toxic effects on man and the environment.  Effects
research will be carried out to continue to assure
the safety of ambient levels of pesticides or to
detect any hazardous levels that exist.  Biologi-
cal-type pesticides are a special problem and will
be given special attention.

     In addition to the usual research on effects
of specific pesticides on aquatic and terrestrial
organisms, OKD will develop the capability to

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               - 344 -
conduct subacute av ian toxicity tests on a limited
scale.   These tests will yield information unat-
tainable from other Federal agencies.

     Quality assurance, including both internal
quality control and external quality assurance,
will be nade an integral part of every protocol.
Current procedures in analytical and biochemical
projects provide for such procedures, but quality
assurance can and will be improved.  Additional
efforts will be made to ensure that in-house and
extramural pesticide laboratories are routinely
involved in quality assurance programs for
chemical analysis.

     In a closely related area, ORD will work
closely with OPP and OF to develop protocols
for "good laboratory practices" and will become
involved in transferring this information to
Regional Inspectors and others as necessary.

Changes

     Other than items addressed in the "Plans and
emphases" section, there are no najor changes
anticipated in P & D activities.

Alternatives

     Research activities are now conducted through
a mixture of in-house  and extramural activity.
Alternatives to this approach include accomplish-
ing research activity through grant and contracts
only or through in-house activity only.

     Grant and contract v/ork permits exclusive
control over planning and implementation of
desired research but often requires even longer
lead-times than now required.  This approach does
not furnish the agency with required data analysis
and necessary expert testimony at regulatory
hearings.

     The office of Research and Development is
not able to maintain under present resource allo-
cations, the necessary skills mix or expertise  to

-------
               - 345 -
address the entire scope of scientific questions
that arise v/ithin the Acjency.  Also, it is scien-
tifically advisable to maintain close contact
with academic and private sectors.

     Therefore, a research operation which is
either exclusively in-house or conducted throuqh
grants and contracts is not feasible.

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                         - 346 -
RFC-1 PEAL CUITW7CF

Abatement and Control

     The Agency has recently decided to allocate 55
positions to the Regional Offices for abatement and
control activities.  However, in order to provide
perspective to Regional priorities and activities at
the 55 position level, the guidance addresses four
levels of resources: (1) 10 positions, relating to
special circumstances; (2) 25 positions, reflecting
the FY 'BO President's Budget; (3) 55 positions, re-
flecting the actual resource availability; and (4) 67
positions, representing the optinun level of activity.

      Regional Priorities — In general, Regional prior-
      ities are based on those functions necessary to
      the implementation of FIFPA which can nost cost-
      effectively be performed at the Penional level.
      The specific activity prioritization which
      follows in the Principal Regional Activities
      part of this guidance is further premised on two
      factors: (1) some activities are "denand" acti-
      vities which the Renions must perform reqardless
      of resource level, assuming a resource base
      greater than zero; and (2)  various "non-demand"
      activities vhich the Regions must undertake,
      given additional resources, before they expand
      their efforts the "denand"  activity areas beyond
      a passive "response" mode to "moderate" or
      "active outreach" levels. The distinctions among
      these terms will become clear through the regional
      Activities section which follows.

      Regional Activities -- mhe  activities discussed
      here are set out by cumulative resource levels
      — 10 positions, 25, 55, and 67.  Further, acti-
      vities are discussed in priority and resource
      increment order within each cumulative level,
      with priorities proceeding  sequentially from
      each resource level to the  noxt.  Finally, the
      discussions deal with national resource aggre-
      gates and not Region-specific resource levels,
      as allocation of positions  will be accomplished
      through the workload analysis process.

          o  10 Regional post ions.  These positions,
           divided equally between Regions VII and
           VIII, will support the Federal certifica-
           tion program in Hebraska and Colorado.

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                - 347 -
o  25 Regional position.  A,t this level (the
   FY '80 budget level), the Regions can
   expect to provide response capability
   in the following areas:

         Respond to Conoressional and Fre-
         edom of Information inquiries;
         respond to inquiries fron the press,
         public, and other institutions.

         Provide support to Federal, State,
         and local government aqencies,
         responding particularly to requests
         for assistance with specific problems
         and to reviewing and connenting on
         FIR's, Sec. 20R plans, disposal plans
         and siniliar activities.

         Assure public health and safety,
         particularly in relation to assisting
         in dealing with pesticide spills
         and fires; supporting migrant and
         other farr, worker safety programs;
         assisting poison control centers,
         hospitals, physicians, and worker
         clinics; and evaluating health
         and safety implications of Sec.
         24(c) registrations and Section.
         is requests.

         Provide product reoistration and
         compliance assistance chiefly by
         responding to registrant requests
         for information and guidance.

o  55 Regional positions.  At this level
   (the presumed FY '80 level), the Reqions
   can expect to perform a wider range of
   activities with a greater degree of out-
   reach effort (NOTE:  Some activities
   are listed two or three times, with
   variances in the described activity.  The
   reader should recall that each described
   activity represents an incremental re-
   source increase from the activiy prece-
   eding it.  The concept of increments is
   retained within the 55 resource discussion
   section as a contingency against a lesser
   actual resource availability.)  Activities
   within the 55 position level are:

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         - 348 -
Participate in intra-Agency, inter-
media coordination and planning
activities, including support to the
IRLG, Sec. 208 plans, FIS processes,
Headquarters task forces and Agency
public hearings.

Provide preliminary guidance to
States on Sec. 18 and Sec. 24(c)
activities, and screen Sec. 24(c)
reqistratons and  Sec. 18 requests for
obvious improprieties.  (Final review
and/or disapproval to occur at Head-
quarters. )

Complete State Certification plan
development and process plan amend-
ments .

Pespond to Indian Tribes' requests
for assistance with pesticides pro-
blems and issues.

Provide certification grants admini-
stration at a level necessary to neet
minimum grants requirements.

Provide expanded  level level of sup-
port to reoistrants and others subject
to or impacted by registration require-
ments.

Fxpand public interface activities
to include:  greater information
flow to the public; speeches before
associations; groups and organiza-
tions; and broader understanding
of Agency policies and decisions.

Increase State certification and
training activity to include program
monitoring for compliance with regula-
tions and plan requirements, and to
assure continuation of State programs.

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        - 349 -
Fxpancl State Certification and train-
ing activity to cooperative anroenent
level to achieve maxima] qualitative
levels in all States.

Fxpand Fee. 24(c) and Sec. IB acti-
vities to include full ranne of
guidance and assistance to States
in the administration of the pro-
qrams.  (This activity would not
include final Aqency determination
on individual Sec. 24 (c) product
reqistrations, hut would serve to
linit the burden on Feadauarters
resources to those reqistrations of
auestioriable validity requiring
in-depth scientific review.)

Peview and issue supplemental reqi-
strations.

Provide full range of guidance and
assistance to States in the deve-
lopment and implementation of Sec.
5(f) State
Fxpand Sec. IB activities to in-
clude monitoring of all exemptions
granted .

Provide full range of support ser-
vice to Headquarters in the moni-
torinq of EPA-issued Sec. 5 experi
mental use permits.

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                - 350 -
67 Eeqional positions -- These positions
represent the number with which Regions
would be able to undertake all activities
potentially operable at the Peqional
level.  The additional activities are:

      Provide outreach capability for
      registrations compliance assistance,
      including "road shows" to reach all
      registrants, distributors, and
      dealers.

      Monitor Sec. 5{f) State plans for
      compliance.

   -  Provide public and special inte-
      rest group outreach.

      Provide final Agency review capa-
      bility on all Sec. 24(c) product
      registrations.

   -  Support the Pesticide Incident
      Monitoring Systen (PIUS) through
      such activities as coordination of
      investigations, and reports, assis-
      tance in nedical diagnosis and
      evaluation, and preventive educa-
      tion.

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                     -  351  -
     Region-Specific Guidance — Since the above pri-
     orities and activities are all-inclusive and
     inter-Regionally applicable, no additional
     guidance aimed at specific Regions is necessary
     here.
Enforcement
     Regional Priorities

          The Office of Enforcement v;ill continue to
     bring enforcement actions in emergency situations
     where the use, supply, and disposal of pesticides
     involves substantial threat to public health and
     safety.

          The Pesticides Enforcement Program will con-
     tinue to encourage the increased involvement of the
     States and Territories.  The program expects to
     establish cooperative enforcement grants-in-aid
     in all or nost States and Territories.

          In  order to fulfill their role in the
     Investigations of Nationally-targeted Pesticide
     Pub.lic Kealth Incidents, the Regions will convey
     information on select restricted use products
     and their production sites to the States, and
     provide  oversight, guidance, and support in
     implernentating and conducting the program.
     State personnel and FPA personnel in States
     without  cooperative enforcement agreements will
     initiate establishment, books, and records
     inspections at all producing sites; conduct
     use observations; and pay careful attention to
     disposal practices.  Emergency situations or
     incidents of misuse involving these products will
     of course, take precedence over all other
     situations„

          The Office of Enforcement will continue to
     emphasize Regional involvement in the conduct of
     the joint FDA-EPA laooratory audit program.  in
     cases in which the Agencj.' has reason to believe
     that data deficiencies or falsifications exist,
     the Regions will investigate such alienations of
     data fraud and develop and provide evidence in
     the event of an1' subsequent enforcement action.

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                - 352 -
The Regions will work closely with Headquarters
to determine if a specific case should be referred
to the Department of Justice of a U.S. Attorney's
office for prosecution.  In conjunction with the
laboratory audit program, Headquarters will con-
tinue to emphasize a program consistinq of four
courses designed to train regional pesticides
inspectors for participation in the audit nrogran.
The training will provide inspectors with a back-
ground in the basics of scientific theory and
practice in toxicology £«nd chemistry.

Regional Activities

     Despite the increase in State enforcement
activities, certain functions will continue as
Regional responsibilities.  Included anong these
are laboratory data audits, nonitoring of
Section 18 emergency exemptions of States and
Federal agencies, cooperative interagency
activities, and enforcement overview of State
certification programs.  In conjunction with
OSHA, CPSC, and FL'A, the CP/1 is committed to
developing and implementinq joint cooperative
enforcement activities.

     FPA will maintain an enforcement overview of
State conducted applicator certification programs
to assure that appropriate enforcement programs
are conducted by the states.  Finally, Section 18
nonitoring activities will remain a Federal
function even in States cooperating in the grant
program; it is not appropriate for States to
monitor exemptions granted to themselves.
Section 5(f) of the new amendments to FIFRA
authorized the States to issue Experimental Use
Permits (EUPs).  ™he Regional role will be to
conduct use observations for Experimental Use
Permits (EUPs).  In the first year, it is
anticipated that 5-10 States will establish
authorized FUP issuance programs.

     Should the decision be made that the £DP
systems will continue to be supported by the
Regions, it is expected that the Regions will be
called upon to continue to assume the responsi-
bilities necessarv for that function.

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                -  353  -
     The pesticides enforcement prog ran will con-
tinue to Monitor the importation of pesticide
products in order to determine that imported
products meet the same requirements imposed upon
donestic pesticide Manufacturers.  In addition,
the progran will monitor the content, destination,
and intended uses of exported pesticides.  Pesti-
cide nanufacturers are required to keep records
of the chenical content, quantities, purchasers,
and dates of shipment and receipt of all exports.
Regional responsibilities will include assuring
that these records are maintained, and inspecting
products ready for distribution.  Furthermore,
the 1978 amendments to FIFRA require exporters
to label unregistered pesticides as such and to
obtain statenents from importing countries that
they understand the product cannot be used in
the U.S.  Pegional personnel will inspect
producer records to assure that pesticides are
exported in accordance with FIFRA.

Region-Specific Guidance

     Enforcement of Federal certification programs
in States without approved certification plans,
anong Indian tribes, and anony Federal agencies
has been the major responsibility of the regional
pesticides enforcement program.  In States which
do not have approved certification plans, Federal
certification programs will continue.  High
priority therefore, will be given to an active
and assertive Federal certification enforcement
effort in any Region having nonparticipating
States.  Such an effort demonstrates the Agency's
commitment to maintain the credibility of the
certification program in general, and any Federal
certification program in particular.  Therefore,
it is essential that Regional VII and VIII pursue
Federal enforcement of federal certification
programs in Nebraska and Colorado, respectively.

-------
                       - 354 -
PROJECTED PROCRAfl ACCOMPLISHMENTS (PPA's)

Abatement and Control

     Registration Standards

     Number of active ingredient standards initiated

     Kunber of active ingredient standards completed

     RPAR Decisions

     Uunber of decisions to RPAP

     Number c><: tinal RPAR decisions

     Number of toxicology lab audits

     Registration

     Number of adninistrative/technical amendments
     processed

     Number of new chenical registrations processed

     Number of routine/intrastate registrations
     processed

     Number of reregistrations [processed

     Special Registrations

     Number of Section 18 registrations/median
     processing time in weeks

     number of Section 5 registrations/median
     processing time in days

     1,'umber of flection 24 (c) reoistrations processed

     Tolerances

     Number of tolerance petitions/turnaround time in
     days

     Number of amendments processed

     Number of inert ingredient requests

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                       - 355 -
     Pesticides Use Management

     lumber of State certification and traininq plans
     approved

     Number of federal agency plans approved

     t:unber of restricted uses classified

Enforcement

     Pesticides Enforcement

     Number of States awarded qrants-in-aid

     Number of State inspectors trained

     Timber of State-conducted investigations of
     nationally-targeted pesticide public health
     incidents

     Number of State-conducted use inspections

     l;unber of State-conducted establishment
     inspections

     Number of State-conducted marketplace
     inspections

     "umber of FPA-conducted investigations of
     nationally-targeted pesticide public health
     incidents

     Number of EPA-conducted use inspections

     Number of EPA-conducted establ ishm.ent
     inspections

     Number of EPA-conduoted marketplace inspections

     Number of pesticide dealers monitored by States

     Number of pesticide dealers monitored by EPA

     Number of State applicator certification programs
     monitored for enforcement adequacy

     Number of import entry documents reviewed by EPA

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                       - 356 -
     !•.unher of State-conducted inport inspections

     number of KPA-conduoted inport inspections

     Nunber of laboratory data audits

     number of Section 18 monitoring;:

     Pesticides Knforcenent (Continued)

     tiunber of interaqency cooperative inspections
     (IRLC)

     Nunber of civil actions

     tiunber of criminal prosecutions

     Nunber of stop sale, use, or renoval orders

     Mumber of Feet ion 9(c) warnings

     I.'unber of Section 14(a)(2) warnings

     Kumber of inport detentions

     Nunber of samples collected

     Nunber of Section 5

Research and Development

     Health Effects

     Completion time for the development of improved
     detection 5;ystens for pesticide compounds and
     residues

     Completion time for review and evaluation of
     available information to determine pesticide use
     hazards

     Completion time for development of methods for
     analyzing and determining the effects of new
     pesticide control agents

     Completion time to develop prediction models for
     determining potential human effects from use
     exposure to pesticides

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                  - 357 -
Ecological Effects

Number of P.PAR Data assessments

Number of toxicolog ical tests conducted for
RPAR

Number of transport and fate tests conducted
for RPAR

Completion tine for developnent of toxicoloqical
and transport and fate testing nethods

Completion tine for development of exposure and
hazard assessment models

Pesticide Management (Industrial)

Completion tine for IPM studies for major crop,
urban, and other selected ecosystems

Number of technoloqy transfer conferences and
seminars

Quality Assurance

Number of analytical methods performance evalua-
tions completed

Number of analytical methods performance evalua-
tions initiated

Number of new pesticide reference materials added
to repository

Hours devoted to Quality assurance assistance to
upqrade residue lab performance

Number of samples distributed from repository

Number of interlaboratory performance evaluations
of pesticide residue labs

Transport, Fate, and Exposure

Number of exposure models and analyses of RPAR
pesticides in multimedia and estuarine environ-
ments

-------
                    -  358  -
                                                              <
IJunber of protocols developed for testing of
pesticides in soils, v/ater, and sedinents

Completion tine for developing improved
terrestrial microcosms for pesticide testing

Nunber of reports issued on transport and
transformation of selected pesticides in water,
soil and marine environments

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1980/1931 RADIATION MEDIA GUIDANCE

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                      RADIATION
MEDIA OVERVIEW

     The Environmental Protection Agency is responsible
for protecting the public and the environment from the
adverse effects of unnecessary radiation.  Recent Con-
gressional and Executive mandates have directed EPA to
focus on the following specific radiation sources and
pathways:

     o  The Resource Conservation and Recovery Act
        (RCRA)  and the Uranium Mill Tailings Radiation
        Control Act  (UMTRCA) charge EPA with providing
        standards for protection from waste materials
        with radioactive content.

     o  The Interagency Review Group on Nuclear Waste
        Management (IRQ) identifies EPA as the standard
        setter for the various classes of waste in its
        Report to the President.

     o  The Clean Air Act Amendments of 1977 require
        EPA to protect public health and the environ-
        ment from harmful radioactive airborn effluents.

These specific authorities dictate the major emphases
which EPA's radiation program will pursue in FY 1980-81.

Planning Assumptions

     FY 1980 -- The Radiation Guidance assumes the passage
     of no new legislation, but does assume endorsement
     by the President of the agency roles and work
     schedules proposed in the IRG Report.  In addition,
     Guidance assumes that:

          o  EPA will promulgate the standard for disposal
             of high-level radioactive waste in FY 1980.

          o  The Agency will complete its cancer policy.

          o  No major changes in Federal energy policy
             will be made.

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                           -  362  -
          o  No major natural or man-made event will
             occur or be discovered to require imme-
             diate EPA action to prevent or mitigate
             serious acute population exposure to
             radiation.  If such an event does occur,
             EPA will provide required support by
             diverting efforts from lower priority
             projects.

          o  The Office of Radiation Programs will
             determine sources or substances requiring
             control under the Clean Air Act Amendments
             of 1977 by the beginning of FY 1980.

     FY 1981 — The following additional assumptions
     apply to FY 1981:

          o  EPA will promulgate standards for three
             major source categories under CAA.  Atten-
             tion can then focus on other sources.

          o  EPA will issue the standard for inactive
             uranium mill tailings.

          o  EPA, other Federal agencies, and the Con-
             gress will agree on EPA's role in develop-
             ing Federal Radiation Guidance.

Media Priorities

     Two priorities are proposed for FY 1980: developing
standards for radioactive wastes and airborne radioactive
emissions; and establishing organizational roles and
procedures to enforce these standards.  In FY 1981, the
Radiation Program will continue to emphasize standards
activities, while implementing an effective standards
enforcement program.

Media Objectives

     In FY 1980, ORP will give top priority to developing
standards for inactive uranium mill tailings, with imme-
diate transfer of that effort to developing standards for
active uranium mill tailings as it becomes possible to do
so.  The Interagency Review Group schedules will serve as
a guide to planning the EPA program for developing
standards for transuranics waste (TRU), land and sea dis-
posal of low-level wastes, and the decommissioning and
                                                                    4

-------
                         -  363  -
decontamination of nuclear facilities.  Work will progress
in all of those areas with resource commitments generally
in the amounts specified in the IRG Subgroup II Report
on Involvement.  ORP will pursue these efforts through
both FY 1980 and 1981, on the assumption that this level
of effort will continue until the recommended IRG
schedules are completed.

     To the extent possible, the Radiation Program will
support international efforts to harmonize radiation pro-
tection policies for environmentally sound nuclear
activities.

     Of equal importance are continued efforts to imple-
ment the Clean Air Act.  ORP will issue the first stan-
dards for CAA radioactive effluents in FY 1980, and the
Office of Enforcement will begin planning for enforcement
of these standards.

     EPA will continue to perform its Federal Guidance
functions as prescribed by the Atomic Energy Act.  Both
ORP and ORD will continue to study the prevalence of and
health effects caused by nonionizing radiation.  The
degree to which this role is pursued is the subject of a
separate paper for the Administrator's Analytical Agenda.
Precisely how EPA exercises this authority will affect
ORP's resource requirements.

     ORP will give second priority to operating the
Environmental Radiation Ambient Monitoring System (ERAMS),
and identifying potential hazards through a limited pro-
gram of special studies and assessment of emerging
technology.  Headquarters and Regional personnel will
review significant Federal actions as required under the
National Environmental Policy Act (NEPA).

     ORP will limit technical assistance to States to
localized problems which have wider ranging significance
and can be accommodated in the work schedules for higher
priority efforts.  These priorities may change, however,
if specific situations are found to pose significant
hazards.

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                         -  364  -
HEADQUARTERS PLAN

Abatement and Control

     Plans and Emphases — As indicated in the program
     priorities, ORP will emphasize developing standards
     as required by the Clean Air Act, and accelerating
     the pace of standards development for radioactive
     wastes to meet the needs of the other Federal.
     agencies.

     Changes — ORP will rely increasingly on the work of
     contractors due to the greater availability of
     contract dollars than in-house staff.  Also,
     enforcement of radiation standards within EPA may
     require significant resources for the first time
     in FY 1981.  The Agency will determine the impact
     of this change on the Regional Radiation Program
     role and requisite staffing in the course of
     developing the FY 1981 ZBB.

     Alternatives — The Agency has typically used con-
     tracts as a means of accelerating the development
     of regulations and avoiding the need for very large
     in-house staffs.  This approach has worked well in
     the areas of air and water pollution abatement and
     control, where the Agency is the largest single
     force affecting the universe of contractors.  In
     the radiation field, however, the Department of
     Energy dominates the contracts market, and EPA is a
     relatively small competitor.  Contractors who
     depend on DOE for their principal source of funding
     are not always willing or able to undertake work
     which EPA needs to write regulations.  The DOE
     National Laboratories (Argonne, Brookhaven, Oak
     Ridge, et al) have the capability of performing
     much of EPA's requirements, but Congress raised
     the question of conflict of interest when these
     Laboratories performed work for the Nuclear
     Regulatory Commission.

     The Agency could increase its in-house staff and
     reduce reliance on contractors as an alternative
     to the dual problem of competing with DOE and
     avoiding the appearance of conflict of interest.

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                         -  365  -
Research and Developmenc

     Plans and Emphases
          °  Mgnioni z ing Radiation (NIR)
                  -     "~ Experimental animal research
                on the teratologic, mutagenic, immuno-
                logic. behavioral,  and neurophysiologic
                effec'. s of low power density, chronic
                exposure to frequencies of environmental
                significance.   Investigations of the
                mechanisms of interaction of NIR with
                biological systems using microwave
                spectroscopy ,  experimental studies of
                effects of NIR and amplitude-modulated
                MIR on iroembranes and isolated systems.
                Initiate pilot epidemiological studies
                of selected populations.  Begin to
                develop a competence in thermoregulatory
                physiology and the dosimetry of partial
                body resonance.

                £Y_19_B.l — Thermal physiology research to
                determine the biological correlates of
                localized heating in animals; investiga-
                tions of the interspecies comparisons of
                thermoregulatory systems; computer
                modeling of human thermoregulatory
                systems.  Conduct experimental and theore-
                tical studies of the interaction of NIR
                with biological membranes, directed
                towards mechanisms of interaction.
                Investig£\te amplitude-modulated NIR
                phenomena in whole animal systems.  If
                warrant-eel , conduct full-scale retro-
                spective epidemiologic studies and
                initiate pilot prospective studies.

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                    -  366  -
     o  Ionizing Radiation

        -  FY 1980 — The ORD reimbursable program
           provides comprehensive off-site support
           to the Department of Energy programs at
           the Nevada Test Site (NTS)  and other
           sites.  This support will include mobile
           and aerial radiological surveillance of
           each nuclear test and radiation monitor-
           ing of groundwater, animals, and other
           types of samples in and around NTS.
           A new emphasis for FY 1980  will be in
           the development of exposure and dose
           estimates for the population in the
           vicinity of NTS as a result of all pre-
           vious nuclear tests.  The quality
           assurance program provides  radioactive
           reference standards and samples, the
           development of quality control guides,
           and on-site inspection and interlaboratory
           tests to determine the capability and per-
           formance of measurement systems and
           operations.

           FY 1981 — The Agency will  consider
           initiating a program of research for
           ionizing radiation.

Changes Anticipated

     o  Nonionizing Radiation  (NIR)

        -  FY 1980 — An ORD Public Health Initiative
           in FY 1980 will provide $2.0 million and
           3 man-years to expand research on the
           mechanisms of interaction,  to develop
           exposure systems for long-term experi-
           mental animal studies, to begin epide-
           miological studies , and increase our
           knowledge of the ambient radiofrequency
           environment.

        -  FY 1981 — None anticipated.

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                    -  367 -
     o  Ionizing Radiation

        -  FY 1980 — Over the past two years the
           Off-site Program has been extensively
           reviewed up through OMB.  The present
           program is the minimum satisfactory
           product resulting from these reviews.
           No further changes are anticipated in
           this or the quality assurance program.

           FY 1981 — The Agency anticipates no
           changes at this time.  An Analytic
           Agenda Issue will consider a research
           program for ionizing radiation.  The
           Agency will also review again how the
           Off-site Program should be operated.
Alternatives
     o  Nonionizing Radiation (NIR)

        Elimination of this R&D program either out-
        right or through contracting out in toto
        would likely cost the Agency its expertise
        in nonionizing radiation health effects,
        an area of growing public concern.

     o  Ionizing Radiation

        There are three alternatives for the
        operation of the Off-site Program.  The
        first is that ORD continue to operate
        the program in its present mode.  The
        second alternative is for EPA to discon-
        tinue support to DOE's testing program.
        These two alternatives have been widely
        discussed previously, and they will
        necessarily be treated in the ranking
        process of Radiation Decision Units.
        The third alternative is for EPA to accept
        full responsibility for design, operation,
        and funding oJ the Off-site Program.

        The Agency has not conducted a research
        program for ionizing radiation since 1976.
        An Analytic Agenda Issue will examine the
        alternative of starting such a research
        program again.

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                         - 368 -
REGIONAL GUIDANCE

     Given the major role of the Radiation Program is to
reduce the public health impact of human radiation expo-
sure by reducing unnecessary exposures,  Regional Programs
must participate in activities related to locating poten-
tial sources of unnecessary radiation exposure and in the
prioritization of remedial programs.  These activities
place the Regional Programs in the position of being
both an extension of Headquarters Programs and the prin-
cipal radiation advisor of the Regional  Administrator.

     Through this mechanism , the Regional Programs are
expected to provide input to Headquarters on matters
related to future standard setting.  It  is essential that
the Regional Program develop competence  and working
relationships with State Programs to ensure that remedial
actions are adequately implemented.  Working relations
with other involved Federal agencies must also be devel-
oped for similar reasons.  Headquarters  liaison is also
essential so that problems can be acted upon and applic-
able guidance can be interpreted.

     Often Regional Programs must respond quickly to
rapidly developing issues caused by the  discoveries of
new sources or other problems.  Because  of this, programs
must develop the ability to reprogram resources from
lower priority work areas to handle these contingencies.
Also, utilizing State Program resources  and available
ORP resources should be a means for handling these con-
tingencies.  This further requires strong State Program
development and liaison.

     To achieve these objectives the Regional Radiation
Program must involve itself in certain areas:

Priority One

     1.  The characterization of various radiation
         sources within the Region is an important func-
         tion of the Regional Program.  Each Region
         should have up-to-date status reports on the
         various sources which include a quantifica-
         tion of the health effects consequences of
         the source.  This task should be directly
         related to ORP guidance and standard setting
         in too priority areas  (i.e., UMTRCA, Radwaste

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                - 369 -
Criteria, High-Level Standards for Radwaste, and
CAA) .   MED/AEC sites, phosphate sites, and
radium contaminated sites are specific sources
that should receive attention for providing
input to ORP priority standard setting.

Regional representation on working groups, to
consider proposed radiation standard or guid-
ance,  is an Agency requirement.  From a program
perspective it is also desirable, since it pro-
vides an opportunity for consideration of direct
Regional experience and concerns gained through
1 above, especially with regard to implementa-
tion.   Regions should identify working groups
in which there is special Regional interest and
expertise and communicate this to ORP.  Working
groups dealing with top priority standard and
guidance setting (i.e., all Radwaste work,
phosphate guidance, and PAG guidance) should
receive substantive input from Regional Programs
based on experience gained in 1 above.  Input
will be channeled through lead Regional Repre-
sentatives as outlined in ORIO's procedures.

The uranium fuel cycle (UFC) is one area where
unnecessary radiation exposures may be
encountered.  Environmental Impact Statements
(EIS)  for Light-Water Reactors (LWR) and  for
other nuclear fuel cycle facilities  (e.g.,
waste disposal-related facilities) are prime
mechanisms for pinpointing UFC exposures.
Review of these statements fulfills EPA's NEPA
requirements and requires a very specific know-
ledge of local conditions, concerns, and  sen-
sitivities.  For these reasons, this function
was transferred to the Regions in the past.
While this is a high priority item, the work-
load is not necessarily distributed evenly
among the Regions.   Alsc- radiation Federal
Facility inspections are performed under  the
same context as the EIS review function.

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                           -  370  -
Priority Two
     4.  Radiological Emergency Response Planning (RERP)
         for fixed facilities and for transportation is
         an extremely important function for the Regional
         Radiation Program because it is the prime means
         for controlling unnecessary exposures to the
         public due to possible incidents and emer-
         gencies.   This consists of reviewing and con-
         curring in State emergency response plans,
         assurring that plans are up-to-date, and test-
         ing and critiquing existing plans.   The Regions
         must ensure an adequate ability to respond and
         protect the public by ensuring that State plans
         incorporate and implement PAG guidance.

     5.  The Environmental Radiation Ambient Monitoring
         System (ERAMS) and other radiation monitoring
         and surveillance activities are an important
         Regional  Radiation Program responsibility
         because these are the prime means by which the
         radiological quality of the environment can be
         monitored and problem sources identified.
         Headquarters ERAMS functions are also a priority
         two item.  The Regions must assure that the
         ERAMS stations are maintained and operated for
         the Agency by State and local governments and
         are operable during emergencies whenever cind
         wherever  required.  Some of the States operate
         monitoring systems continuously, providing
         data to the Agency on environmental radiation
         levels and trends.  Most are in standby mode,
         being activated in time of emergency or when
         unusual levels of ambient radiation are
         expected, such as from an above-ground
         nuclear detonation.  The system basically pro-
         vides data for the air and water media programs.
         In addition to ERAMS, other Federal, State and
         local monitoring and surveillance programs may
         be in existence which might aid the Agency with
         its radiation protection responsibilities.
         The Regions should identify these,  evaluate
         them in accordance with Agency criteria, and
         determine the feasibility and mechanisms for
         incorporating them into the Agency's overall
         monitoring and surveillance effort.

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                         -  371 -
         Assisting other media programs with enforcement
         activities is another requirement made of the
         Regional Radiation Program.  The extent of such
         assistance is dependent upon the technological
         complexities involved.  Certain Regional Pro-
         grams must also provide support by acting as
         Regional Radiation Safety Officer.  For FY 1980,
         much of this function is expected to be directed
         at assuring full compliance with the Safe Drink-
         ing Water Act.   Regional Radiation Program efforts
         would be directed at State and local program
         reviews, laboratory reviews, and assistance
         with compliance actions.
Priority Three
     7.  The development and strengthening of State and
         local Radiation Control Programs is a very
         necessary Regional function.  To a very great
         extent, the Agency must rely on competent and
         capable State and local programs to assist with
         the National effort of protecting the public
         from unnecessary radiation exposures.  These
         programs provide the immediate interface with
         individuals and groups that might be impacted
         by radiation exposure situations or by Agency
         regulations.  It is very necessary that sound
         and harmonious working relationships be
         developed between the Agency and State and
         local programs.  The Region should foster
         such a relationship by supporting State and
         local programs with technical assistance,
         information exchanges, training opportunities,
         and an annual Regional meeting of Radiation
         Control Program Directors.

     8.  Providing a source of information for the general
         public on radiation matters is a necessary Regional
         function.  Many individual concerns relate
         to very specific situations that require
         local knowledge to enable development of a
         meaningful response.  The Region should be able
         to acquire and provide this type of input.  In
         addition, the Region should also have the
         capability for relating National policies and
         procedures to practical, local situations.

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                         - 372 -







PROJECTED PROGRAM ACCOMPLISHMENTS (PPAs)



Nuclear Power PlantsJEISs



     *No. of draft statements reviewed



      No. of final statements reviewed




     *Percent of statements reviewed on time



     *No. of statements with an Environmental



      Reservation rating



     *No. of Statements with an Environmentally



      Unacceptable rating



Uranium Fuel Cycle EISs



     *No. of draft statements reviewed



     *No. of final statements reviewed



     *Percent of statements reviewed on time



     *No. of statements with an Environmental



      Reservation rating



     *No. of statements with an Environmentally



      Unacceptable rating



Generic EISs



     *No. of draft statements reviewed



     *No. of final statements reviewed




     *Percent of statements reviewed on time



     *No. of statements with an Environmental



      Reservation rating



     *No. of statements with an Environmentally



      Unacceptable rating

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                         - 373 -







Radiation Sources (other than operating reactors)



     *No. of source-specific reports reviewed




     *No. of reports written characterizing



      source-specific sites




Radiological Emergency Response Planning



     *No. of States with adequate plans



      No. of State plans reviewed



      No. of emergency response tests observed



      No. of critiques supplied to NRC on emergency



      response tests observed



Radiological Emergencies



     *No.of emergencies and/or incidents in Region



     *No. of emergencies and/or incidents with



      Regional response



     *No. of transportation accidents and/or incidents




     *No. of fixed-facilities accidents and/or



      incidents



Environmental Radiation Ambient Monitoring Systems  (ERAMS)



     *No. of continuous ERAMS stations in Region



     *Percent of continuous ERAMS stations in



      operating condition



     *No. of standby ERAMS stations in Region



      *Percent of standby ERAMS stations in



       operating condition

-------
                           - 374  -
                                                                    <
Radiation Standards Setting
     *No. of Regional input reports to working groups
     *No. of working group meetings attended
State Radiation Program Development
      State Program Control Directors Regional
      Meeting (one per year)
Response to Public Requests for Information or
Assistance
*Quarterly Reporting

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1980/1981 NOISE MEDIA GUIDANCE

-------
                       NOISE
MEDIA OVERVIEW

Goal

     The goal of the EPA noise control program is to
eliminate as much exposure as possible to levels of
noise harmful to public health and welfare.  The noise
program uses two principal means to achieve this:
regulation of noise emissions from products which the
Agency has identified as major noise sources; and
control of noise by State and local governments.

Planning Assumptions

     For FY 1980 and 1981, the EPA noise control
program assumes that:  (1) work will continue on
completing the noise emission regulations begun in
previous years with no new starts in FY 1980.  Depending
on the successful completion of work in progress, new
efforts in surface transportation and consumer products
will begin in FY 1981, along with continuing related
technology investigations.  (2) One new product emission
regulation (trash compactors) and one product labeling
regulation (hearing protectors, along with labeling
general provisions) will become effective in FY 1980.
Regulations for buses and motorcycles (including
replacement exhaust systems) will become effective in FY
1981.  These regulations will result in related
enforcement activities in FY 1980 and FY 1981 (see
Appendix 1 which shows the Agency's current noise
regulatory schedule and additional products to be
studied).  (3) The Agency will aggressively implement
the new authorities contained in the Quiet Communities
Act in FY 1980 and 1981 (including expanded assistance
to States and localities in enforcing noise control
laws), with a resulting increase in the number of State
and local programs in FY 1980 and FY 1981.   (4) The
Agency will expand its research on noise health effects
in these two fiscal yeatrs.  (5) All appropriate facets
of the noise control program will be involved in an
increasing effort to address urban noise problems,
particularly in concert with the urban-related programs
from other Federal agencies.  (6) The Noise Enforcement
Division will order remedial actions by manufacturers
and seek criminal and civil penalties from manufacturers

-------
                         -  378  -
for non-compliance under the Noise Control Act.  (7) In
FY 1980 and FY 1981 no organizational changes are
anticipated; various changes were implemented in FY 1979
as a result of the Quiet Communities Act.

Media Priorities

     The four key priorities of the EPA noise control
effort for FY 1980 and 1981 are:   (1) completing
regulations begun in previous years, which are now
overdue; (2) enforcing those existing regulations which
will achieve the greatest reduction in levels of
environmental noise; (3) implementing the  Quiet
Communities Act so as to achieve the 1985  objective of
400 active local and 40 State noise control programs,
including enforcement assistance to States and
localities; and (4) expanding efforts in the
investigation of noise health effects, particularly
non-auditory effects.

-------
                         - 379  -
HEADQUARTERS PLAN

Abatement and Control

     In the noise abatement and control program, the
FY 1980 and 1981 plan will involve efforts in noise
emission regulation and labeling, related investigations
into noise pollution abatement technology, efforts to
promote the development of effective State and local
noise control programs, and studies of noise health
effects.

     Noise Emission Regulation and Labeling

     In FY 1980 the Agency should issue Notices of
Proposed Rule Making for pavement breakers and rock
drills, and lawnmowers,  and final noise emission
regulations for motorcycles and buses.  A final noise
emission regulation for truck-mounted trash compactors
will be issued in FY 1979.  In FY 1981 no Notices of
Proposed Rule Making  will be issued, and Notices of
Rule Making  will be issued for pavement breakers/rock
drills and wheel and crawler tractors.

     These efforts will continue the phase of noise
emission regulations begun in 1975 which was
supplemented by the identification of lawnmowers and
pavement breakers/rock drills in 1977.  FY 1981 will
mark the transition into the next phase of noise
emission regulation.  This involves addressing the
remaining surface transportation sources which are not
controlled, i.e., light vehicles and tires.  (It should
be noted that at the present time the Agency has not yet
committed to any specific control strategy for these
products and that the study effort now going on will
determine whether emission regulation, labeling,
State/local control or some mix of these is the most
appropriate course of action.)  Another initiative in FY
1981 will be to continue and accelerate work in consumer
product noise control.  It is expected that a final
labeling regulation will be promulgated for one consumer
product in FY 1981, and the Agency will continue to
review other products for potential emission control or
labeling.  Finally, the Agency in FY 1980 and 1981 will
continue and accelerate its study of the noise problem
and control strategies regarding industrial machinery.

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                         - 380 -
     Technology Investigations

     The Agency will also continue technology
investigations, which are oriented toward future
possible rule making in the surface transportation area.
If the noise exposure relief experienced as a result of
the Interstate Motor Carrier regulation and the
introduction of quieter heavy and medium trucks in
compliance with EPA regulations is to be maintained or
further reduced, the permissible noise levels of future
(post-1985) new trucks and buses will have to be reduced
periodically.  In order to determine what future levels
may be achievable, the Agency is acquiring and modifying
trucks and placing them in fleet service.  These will be
tested for noise level reliability and cost of
maintenance.  In another technology program, the Agency
is reviewing types of internal combustion engines and
correlating them to noise levels.  This may result in
further investigation of various noise-reducing
modifications for internal combustion engines.  Another
project in FY 1980 will review tire designs, and may
lead to a technology demonstration if various designs
generate significantly lower noise levels.

     State and Local Assistance

     EPA's State and local control efforts are carried
out both at Headquarters and in the Regional Offices.
They are oriented toward producing 400 active local
noise control programs, 40 State programs, and the
addition of 400 new noise control "components" to
existing local  programs.

     The goal of 400 active local programs is generally
targeted to communities over 50,000 population since
noise problems tend to be greater in more highly
populated areas.  However, some smaller communities that
are a part of larger urban aggregates will also be
included in some instances since they share "urban"
characteristics.  The 40 State programs should include
the 40 most populous States, although the Agency will be
willing to assist less populated States with special
problems if EPA resources permit.  The criteria for an
"active" program include: noise legislation covering at
least one of the local noise control "components" listed
below; the allocation of personnel and funds;
instrumentation; and the institution of enforcement
actions.  The "components" include (1) motor vehicle

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                       - 381 -
control, (2) stationary source control,  (3)  construction
noise control, (4) control of noise through  abatement
planning and prevention, and (5)  public  information.   At
the present time, EPA has identified 43  active local
programs and 12 active State programs.  The  Agency is in
the process of analyzing this survey more extensively
and also checking directly through the Regions as to
program status.  Therefore, this  number  is expected to
change.

     In FY 1980,  EPA plans to directly assist
approximately 37  communities and  13 States through
"start-up" financial and technical assistance and
agreements with States whereby the State will take over
or prepare to take over the EPA-run ECHO program in the
State.  In addition, approximately 30 other  communities
will receive assistance through the EPA-run  ECHO
program.  In FY 1981 the Agency hopes to be  able to
provide direct financial assistance to additional
communities and expand the ECHO program to additional
States.

     EPA will also continue to carry out noise control
demonstrations.  These will include comprehensive
demonstrations (the Quiet Communities program
experiments), demonstrations involving control of one
noise source, such as motor vehicles, and transportation
planning demonstrations.  These demonstrations are
primarily designed to provide EPA with information on
the most effective control measures for noise pollution
This information can then be distributed nationwide.
Obviously, however, the communities where such demon-
strations are carried out will generally benefit, and an
active noise control program will result or  be expanded.

     In general,  the thrust of local program development
efforts should be in motor vehicle control,  which is
consistent with the national priority.  We anticipate
that program development efforts  will be toward the
following (in priority order):  motor vehicle control,
stationary source control, control of noise  through
abatement planning and prevention, and control of
construction noise.  As new programs are started and
components are added to existing programs, the Regions
will have to keep records on the  types of components
which are adopted; it is expected that the

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                     -  382 -

results will generally be consistent with the national
priorities and each Region's strategy for achieving
active State and local programs.  We further expect that.
quarterly reporting of active program components and
components added to existing programs will be required
when the Regional reporting requirements for FY 1980 are
made final by EPA management.

     The Agency will also attempt to add noise as a
major component to EPA air projects and other Federal
agency (non-noise) projects, particularly urban projects
on a demonstration basis.  Examples might include partic-
ipation in the Department of Energy "weatherization"
program,  in HUD housing rehabilitation efforts, or the
air pollution vehicle control programs.

Health Effects Research

     The basic objective in undertaking noise health
effects research is to generate information and data,
especially in the area of quantified dose-responses to
noise exposures, which can be used in developing
regulatory actions, community noise control measures,
and cost-benefit analyses and evaluations.  It is also
important to inform the public about these effects, so
that individuals can take action on their own to avoid
excess noise.

     It is generally accepted that noise effects are
fairly well documented in areas of hearing impairment,
annoyance, and activity interference.  Information and
evidence generated from studies during the past 3 to 5
years suggests that there may be non-auditory effects
at levels lower than those harmful to hearing.  This
is still not clear, however, and more sophisticated
and controlled studies are needed in this area.

     In determining its noise research needs, EPA has
carefully "tracked" the scientific community to assess
the state-of-the-art on health effects due to noise
exposure.  It is now clear  that there  is a consensus of
findings and recommendations  regarding research
initiatives.  Assessments have  been  completed by the
following:  Department of Health,  Education and
Welfare/National Institute  for  Environmental Health
Sciences; National Academy  of Sciences;  Federal Inter-
Noise Effects Research Panel; National Academy of
Sciences/Committee on Hearing and  Bioacoustics Draft
Report WG 81 (Effects of Long-term Exposure to Noise
Upon Human Health);  International  Commission on the
Biological Effects of Noise;  and the  Interagency
Regulatory Liaison Group  (EPA,  CPSC,  FDA,  OSHA)

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                    - 383 -

     The consensus of conclusions and recommendations
is that non-auditory effects need to be studied in more
detail with emphasis on:

          o  Noise as a possible factor in
             cardiovascular disease;

          o  Long-term, controlled studies using
             subhuman primates to see if chronic
             deleterious non-auditory health effects
             ensue from representative occupational and
             social noise exposures;

          o  Noise events and sleep disturbance—general
             health effects;

          o  Reproductive effects of noise exposures in
             women; and

          o  Interactive effects of other factors with
             noise, such as chemical and physical
             agents, and other stressors.

     These conclusions have been provided to both
the executive and legislative branches of the Federal
Government.

     The Quiet Communities Act (QCA) of 1978 reflects
the concern of Congress with respect to these research
needs.  Section 2 of the QCA amends Section 14 of the
Noise Control Act to emphasize the need to "conduct
research ...  to investigate psychological and
physiological effects of noise on humans .  . . with
special emphasis on the non-auditory effects of noise."

     Further research on the non-auditory health effects
of noise is needed because  (a) there is a substantial
body of work only in the area of cardiovascular effects,
and not in the endocrinological, immunological,
reproductive and other areas, and (b) the cardiovascular
literature, while strongly suggesting an association
between high noise exposure and hypertension, is
incomplete.  Work in 1330 will be directed toward
demonstrating or clarifying this association.  In FY
1980, 1981, and beyond, if an association between noise
and cardiovascular disease has been clearly
demonstrated, research will be directed toward
establishing a cause and effect relationship through
appropriate prospective, intervention studies.  The
ultimate requirement is for a dose-response criterion to
quantify this cardiovascular effect, and other
non-auditory health effects of noise.

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                        - 384  -

     It is EPA's plan to move forward with a health
effects research program which emphasizes the possible
effects of noise on the cardiovascular system in
addition to continuing some work in progress on hearing
loss in children.  In FY 1979, health effects research
plans include:

          o  University of Miami study—assessment of
             the effects of protracted noise exposure on
             cardiovascular function using rhesus
             monkeys.  Long-term research employing
             detailed specification of the auditory
             environment and sophisticated monitoring of
             physiological  function.  (Second year of a
             four-year  study; co-support with NIEHS).

          o  Pels Institute (Long-range study)—under
             subcontract to determine the effects of
             environmental noise on children.  This
             information will assist in the development
             of hearing loss criteria for children and a
             better understanding of the susceptibility
             of children to noise.   (NINCDS will
             co-support in FY 80.)

     Plans for an expanded FY 1980  health effects
research program include:

          p  University of Miami Study (Third year)

          o  Epidemiological Study—Examine the
             long-term effects of noise exposure on the
             cardiovascular status  of workers.  (Two
             year study—possible co-support with
             NHLBI).

          o  Investigate teratogenic and reproductive
             effects  of noise exposure.  (DHEW/CDC may
             co-support.)

          o  Studies  regarding perception of intrusive
             noise, pure tones,  impulsiveness, and
             temporal factors.

          o  PELS Study—Environmental noise on children
             (continuing).

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                         - 385 -

          Projected plans for FY 1981 health effects
     research,  assuming resources are available,  will  include
     the continuation of (1)  a major epidemiological study,
     and (2)  the University of Miami animal  study.   In
     addition,  the initiation of some new studies should
     cover areas such as subjective  and  behavioral  responses,
     effects  on children, and the effects on sleep  and
     related  general health.
     Alternatives

          During the  ZBB,  the Agency will want  to  consider
     the following operational alternatives  for carrying out
     the noise  control program.   (1) Continue the  present
     relatively low level  of direct financial support  (or a
     lower  level) or  expand this  as the primary means  of
     developing State and  local noise control.   (2) As a
     means  of improving performance on issuing  regulations
     and State  and local assistance, increase the  level of
     Federal staffing or continue the very high rate of
     contracting out.   (3) Change the relative  priority of
     new regulatory initiatives and related  technology
     investigations as compared with other facets  of the
     program.
Enforcement
     Plans and Emphases — In FY 80, EPA's Noise Enforcement
     Division plans to enforce those new product noise
     standards which will most reduce environmental noise.
     This means that standards effective in FY 80 will be
     ranked on the basis of their estimated effect on
     noise.  The Division will enforce information labeling
     requirements only to the extent that its limited
     resources permit.  The noise enforcement program will
     also develop the enforcement strategies and attendant
     regulations necessary to support the Office of Noise
     Abatement and Control's regulatory development schedule,

          With respect to the Quiet Communities Act of
     1978, the noise enforcement program, in concert with
     the overall EPA noise program, plans to expand its
     assistance and guidance to State and local noise
     enforcement programs.  This includes  developing
     additional State/local noise enforcement procedures and
     guidance on the role of State and local programs in
     enforcing Federal information labeling requirements.
     The Noise Enforcement Division will also provide

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                 - 386 -

guidance on specific State and local noise enforce-
ment problems as they arise.  NED plans to develop and
distribute several general enforcement guidance packages
to assist State and local noise enforcement activities.

     In FY 81, the Noise Enforcement Division will
emphasize the enforcement of those new product noise
emission standards which became effective in prior
years, while continuing any enforcement activities
initiated in FY 80.  Enforcement strategies for additional
actions will be developed according to a schedule
established by the Office of Noise Abatement and
Control.  The noise enforcement program plans to review
its assistance and guidance to State and local noise
enforcement programs to ensure that its activities
provide necessary information and support.  If necessary,
some redirection could occur to address other or
additional enforcement needs to State and local noise
enforcement programs.  The Noise Enforcement Division
will coordinate with ONAC in this area to avoid any
duplication of Federal efforts.
Changes —  In FY 79, the noise enforcement program has
acquired the authority to seek civil penalties for
violation of §10(a)(l), (3), (5), or (6) of the Noise
Control Act.  This provision provides for increased
effectiveness in the enforcement of new product
standards and information labeling requirements.

     In FY 80, the §6 new product noise emission
standard for compactors will become effective.  Also,
the information labeling requirement of hearing protectors
becomes effective.

     In FY 80, under the authority of the Quiet
Communities Act of 1978, the Noise Enforcement Division,
will provide increased State and local noise enforcement.
guidance assistance through demonstration grants,
training programs and related activities.

Alternatives

     0  Eliminate product verification (PV) testing;
        rely only on selective enforcement audit (SEA)
        tests with a simplified sampling plan.

     0  Replace single PV test with a simple statistical
        test program prior to distribution of products
        in commerce.

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           - 387 -

Use of a contractor to handle required submittals
under regulations for information labeling
requirements.

Eliminate PV testing; use a certification
program similar to that used by the Office
of Mobile Source Air Pollution Control.

It may be possible to assign other than
permanent full time personnel to work for
an equivalent of 1 to 10 man years on State
and local noise enforcement activities at
one or more Regional Office locations.
Potential Regional noise enforcement
responsibilities are:  (1) conducting
noise enforcement training workshops;
(2) assisting in development and review of
enforcement procedures and of enforcement
provisions of new State legislation and
local enforcement programs; (4) monitoring
and analyzing enforcement data from State and
local programs; (5) collecting and analyzing
information about States and local enforcement
problems and procedures; (6) developing and
assisting in implementing State and local
enforcement activities which directly complement
Federal enforcement activity;  (7) conducting
Federal tampering investigations; (8) coordinating
with the Regional Noise Program Staff in
briefing of State and local prosecutors; and,
judges in noise control and enforcement; and,
(9) reviewing and commenting on headquarters
Enforcement Division documents.

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                       - 388 -
REGIONAL GUIDANCE

     The key Regional priority for FY 1980 and 1981,
as in the greater parts of FY 1979,  will be to manage
regional noise resources so as to make significant
progress toward the Agency's 1985 goals of 40 active
State programs, 400 active local programs, and the
addition of noise control components to 400 active
programs.  As stated in the Headquarters Plan, these
targets are oriented toward cities over 50,000
population and the 40 most populous States.  The Office
of Noise Abatement and Control will be sending out
soon a list of all cities over 50,000 population and
between 25,000 and 50,000 in each Region, along with
data on individual city population and population
density.  Also, ONAC will send the results of its
1977-78 survey indicating which of these cities have
active programs and legislation, and are interested in
EPA assistance.  Finally ONAC, with Regional assistance,
will be developing a workload projection model for
Regional use in planning for FY 1980 and FY 1981.

     The Quiet Communities Act of 1978 provides the
Agency with a number of tools and programs by which
the program's goals can be achieved.  It is intended
that the Regions have as much discretion as possible in
using these tools to obtain their objectives in each
Region.  In FY 1980, it is expected that all financial
assistance, except demonstration assistance and
transportation planning assistance will be directly
awarded by the Regions rather than Headquarters in FY
1980.  This continues the trend seen in FY 1979, when
most of the decisions will be made in the Regions
although the actual paperwork will be signed in
Headquarters.

     Each Region should develop a five-year strategy as
soon as possible for using all of its noise control
resources to meet the 1985 State and local program
development goals, with special emphasis on meeting the
goal of active State programs as early as possible so as
to facilitate the achievement of the community goals in
later years.  As a first step, the Regions will have to
review survey data and assess through other means the
number and identity of local programs that meet the
Agency definition of "active" programs.  Then each
Region should indicate what portion of the national
program goals will be achieved in the Region by 1985.
The Regions should use State/community population and
population density as general criteria for deciding

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                       - 389 -
where to "target" initial efforts, along with the
national program priorities (motor vehicle control,
etc.) mentioned in the Headquarters Plan.  However,  each
Region will also have to consider a number of other
factors including State/local interest, fiscal
condition, etc. in deciding where to focus its program
development efforts in FY 1980 and 1981.  The major
tools and programs which the Regions can use in FY 1980
and FY 1981 are as follows:

     Regional technical centers

          These centers should be established in most
     Regions in FY 1979, and be operating fully in FY
     1980 and 1981.  They will provide technical
     assistance and training to States and localities
     under the guidance of the Regional offices.

     State support and guidance

          Financial assistance is available to help
     States start up noise control programs and once
     underway, to assume the delegated function of
     running the ECHO (Each Community Helps Others)
     within the State.  This will relieve the Regional
     office of the task of servicing the communities of
     that State from the Regional ECHO program, and will
     allow the Region to assist communities through ECHO
     in States where there is no active State program.

     Community support

          Financial assistance will be available to
     enable communities to start up noise programs and
     to add components to existing programs.
     Other assistance programs which the Regions can use
     are:  workshops (probably through the Regional
     Technical Centers) and mandated E.O. 11752
     responses to State/local requests for assistance
     with non-complying Federal facilities.

     It is important for the Regions to develop for use
in FY 1980 a noise component in the State/EPA
agreements.  At a minimum, such noise components should
be contained in all State/EPA agreements where there is
an active State noise control program.  However, the
Regions should try to write in components even in those
States where there is not an active program in order to
lay the ground work for further work with the State
environmental agency, and to provide a framework for the

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                         -  390  -


assistance which the Region is providing to communities
in that State through such mechanisms as direct
technical assistance, ECHO, the Technical Assistance
Center, and financial assistance.

     By FY 1980, at least nine States will be running
tbe ECHO program within their jurisdiction and four more
States will be developing an active noise control
program.  Although regulatory activity by some States
may be appropriate in the area of motor vehicle control
and growth management, the principal focus of most State
programs should be the provision of assistance to
developing community noise control programs.   The
Regions will also have to continue to provide assistance
to Headquarters in regulations development, perform
various public information functions, and review EIS's
for noise impact.

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                       - 391 -
NOISE PROJECTED PROGRAM ACCOMPLISHMENTS (PPA'S)

     The Media Task Group has conscientiously reduced
the number of PPA's to enable each Regional Office to
develop plans to achieve its portion of the national
noise program through flexible use of the tools
contained in the Quiet Communities Act.  Therefore, each
Region will be participating in some of these programs,
e.g., the ECHO program, "start-up" financial assistance,
and the QCP experiment, although all of these have been
dropped as PPA's.  The details of each Region's use of
these tools will have to be worked out in internal
Regional planning, which will be oriented to the
achievement of the national objectives.  Further, in
what is presently a one-person per Region program, there
are necessarily a great many "overhead" activities, such
as EIS review, planning, public response, etc., which
will have to be considered in planning for FY 1980 and
FY 1981, although this work is not included as a PPA.
PPA's will be used for FY 1980 Operating Plan and FY
1981 Budget.

Noise Regional Program Implementation (G210) D.U.

1. Number of active State noise programs

2. Number of active local noise programs

3. Number of "components" added to existing local noise
    control programs

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                        -  392  -
                       APPENDIX 1

                   REGULATORY ACTIONS
    Product

Wheel & Crawler
Tractor

Buses

Trash Compactors

Motorcycles

Lawnmowers

Truck Transport
Refrigeration
Units

Pavement Breakers
 Proposed
Regulation
  (NPRM)
   7/77

   9/77

   8/77

   3/78

 (3QFY80)



 Deferred
  Final
Regulation
  (NRM)
 (2QFY81)

 (2QFY80)

 (4QFY79)

 (2QFY80)

 (3QFY81)
Medium & Heavy
Truck
 (FY 1982)
 (FY 1983)
Earliest
Possible
Effective
  Date*
 FY 1982

 FY 1981

 4QFY80

 FY 1981

 FY 1982
& Rock Drills
LNEP
Labeling, Hearing
Protectors
Labeling, General
Provisions
Labeling, One
Consumer Product**
Interstate Rail
Carrier
(3QFY80)
2/74
6/77
6/77
(2QFY80)
(3QFY79)
(3QFY81)
(4QFY79)
(3QFY79)
(3QFY79)
(2QFY81)
(4QFY79)
FY 1982
—
3QFY80
3QFY80
FY 1982
EPA doe
                                               enforce
     *Except for labeling all dates are subject to
change depending on regulatory options approved by
Administration and other timing factors.
    **Either vacuum cleaners or air conditioners.

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                         - 393 -
                                            Earliest
                   Proposed      Final      Possible
                  Regulation   Regulation   Effective
    Product         (NPRM)       (NRM)        Date

Light Vehicles    Being studied

Tires             Being studied

Other Consumer
Products          Being studied

Chainsaws         Being studied
     Note:  In addition to the products listed, in
FY 1979 and 1980 studies on a number of products will
continue since contracts were already awarded for these
in earlier fiscal years.  These are being managed in
this fiscal year by a contractor.  When completed the
contractor studies will be available to the Agency and
the public and may become the basis for regulation in
the post-FY 1981 period.  These products are:
snowmobiles, motorboats, guided mass transit, vehicle
mufflers, portable air compressor (revision), and air
conditioner emission regulation, and earthmoving
equipment.  Except for the management contract ($80K) no
funds will be spent on these actions in FY 1980.  In
addition, a general survey study of industrial equipment
is being conducted in 1979 in order to allow the Agency
to assess its role in this area under Sections 6 and 8.
No further studies are planned for FY 1980.

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1980/1981 ENERGY MEDIA GUIDANCE

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                        ENERGY
MEDIA OVERVIEW

     The Energy/Environment research and development program
was initiated in FY 75 following the recommendations of two
OMB/CEQ task forces -- one on pollution control technology
and the other on the environmental processes and effects of
energy pollutants.  These recommendations were based on a
desire to develop needed control technology and health and
effects data necessary to help avoid an irreconcilable conflict
between energy supply and environmental protection interests.
Such a conflict seemed likely since it appeared that the nation
would necessarily be relying more heavily on the "dirtier" fuels
such as coal and oil shale and less on the cleaner domestic
gaseous and liquid fuels.  This trend has been accelerated by
our national energy policy, which although only slowly evolving,
calls for a widespread conversion of utility and industrial
power facilities from scarce oil and gas to plentiful coal,
decreased fuel consumption, and in the longer term, the use
of technologies that are only now beginning to emerge for the
production of liquid and gaseous fuels from coal and oil shale.

     Projections indicate that total U.S. coal mining activities
will increase from today's annual production of 700 million tons
to nearly 1 billion tons by 1985 and will more than double by
the year 2000.  In 2000, conversion of existing utility and
industrial facilities from oil and gas to coal coupled with
construction of new conventional and advanced coal utilization
facilities will consume approximately 1.4 billion tons of coal
annually.  Although conventional combustion of coal will
predominate, by the year 2000 emerging coal-based technologies
are projected to consume 300 million tons of coal per year.

     These shifts in energy development and use pose potential
significant threats to human health in the next two decades.
Massive increases in coal and oil shale mining, off-shore
oil and gas prodution, and uranium extraction are all projected
by the year 2000.  Intensified mining activity will create
erosion problems and generate runoff which can contaminate
surface waters.  Aquifers may also be polluted as a result
of leachate or drainage from the mines themselves, or from
the improper disposal of mining wastes.  Increased use of
coal by utilities, industries, and new technologies will
produce more air pollution and solid waste residue than are
currently produced.  The pollutants expected to increase
are nitrogen and sulfur oxides, ashes, and sludges.  Because
of the way they are formed, pollutants emitted from new
technologies can be varied and complex and may prove to be
even more harmful to human health than those emitted from
current technologies.

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                           -  398  -


     To address the environmental threat associated with
energy and industrial pollution EPA's enabling legislation
has been toughened with the aim of tightening effluent and
emission limitations.  The Clean Air Amendments of 1977,
the Resource Conservation Recovery Act and the Federal
Water Pollution Control Act Amendments will require improved
control of emissions, effluents and solid residuals.

     The trend toward increased reliance on coal and other
potentially damaging fuels and technologies can only occur
without massive environmental impact if the necessary data
base is available to quantify effects and if affordable
control technology can be applied in a timeframe consistent
with technology utilization.

     The following discusses major priorities of the FY 80-811
program in the control technology and effects programs.

CONTROL TECHNOLOGY

     EPA's energy control technology program has the overall
goal of providing information of the types and quantities of
pollutants released by current and emerging energy supply
activities and where necessary, to develop control options.
The following delineates major research priorities in the
FY 80-81 timeframe for the six control technology subpro-
grams: flue gas sulfur control, nitrogen oxide control,
particulate control, environmental impacts of conventional
and advanced energy systems,  fuel extraction and fuel
processing.

Flue Gas Sulfur Control

     This program includes sulfur oxide pollution control
research and development relating to electric utility and
industrial power generation.   Technology improvement is
important since EPA regulations are expected to require
from $2-4 billion in annual expenditures on relatively
immature SOX removal technology in the 1990's.  Major
efforts are directed towards flue gas desulfurization
(FGD)  technology development and assessment; assessment of
the capital and operating costs of FGD systems; research
and development directed towards increasing FGD system
reliability, reducing sulfur oxide emission levels and
reducing capital and operating costs.  Special attention
should be paid on transferring information to the public
sector.

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                           - 399 -

     o    Research Priorities (Air)

          1.  Continue to issue quarterly updates of the
              performance and status of existing FGD
              systems for new FGD installations in the
              U.S., Japan and Europe.  Also continue
              technology transfer program via symposia,
              data books and seminars.

          2.  Document the full scale evaluation of the
              adipic acid modified limestone FGD process
              evaluation.  Special attention will be given
              to the economic impacts of this process
              modification and any secondary operational or
              environmental factors.  Preliminary testing
              indicates such an approach offers potential
              of greater than 95% SOX control capability
              at costs lower than current technology.

          3.  Complete the duel alkali evaluation program at
              Louisville Gas and Electric.  The final report
              will provide an evaluation of performance and
              economic factors;  this technology offers
              potential for cost and reliability advantages
              over commercial lime and limestone FGD systems.

          4.  Complete the preliminary evaluation of dry
              sulfur oxide control processes.  Such processes
              offer the promise of low cost energy-efficient
              alternatives to commercial FGD systems,
              particularly for low to moderate sulfur coals.

Nitrogen Oxide Control

     This program includes research and development relating
to nitrogen oxide control from electric utility boilers,
industrial boilers, process furnaces, and other stationary
sources.  Successful conduct of such a program is important
since NOX emissions from stationary sources are projected
to increase at an alarming rate over the next two decades.
This is primarily due to the projected increased combustion
of coal and the current absence of cost effective NOX control
technology.

     o    Research Priorities (Air)
              Document the status of NOX control for utility
              and industrial boilers to support the 1982/1983
              review of the Standard of Performance for NOX,
              as required by the Clean Air Act Amendments of
              1977.

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                          - 400 -
          2.  Demonstrate the low NOX coal burner on two
              industrial boilers and a utility boiler.
              The program goal is an emission rate of 0.2
              pounds of NOX per million BTU in a timeframe
              compatible with possible revised NSPS in
              the 1982/1983 timeframe.

          3.  Evaluate dry NOX control technology for
              Stationary, high efficiency gas turbines
              to support the Congressionally-mandated
              review of the New Source Performance
              Standard for Gas Turbines.

          4.  Demonstrate combustion modification concepts
              to simultaneously reduce NOX and particulate
              emissions from stationary internal combustion
              engines.

          5.  Conduct assessment and applications testing of
              combustion modification technology for stoker
              coal-fired commercial and industrial boilers.

          6.  Continue bench-scale research and assistance
              to California on the technical and economic
              factors relating to flue gas treatment for
              NOX and simultaneous NOX/SOX control.  Such
              processes offer the potential of greater than
              90% NOX control albeit at substantial costs.

Particulate Control

     The overall objective is to assess, improve and develop
technological methods for the control of all forms of man-made
(and induced) particulate matter; especially those controls
effective at minimizing emissions of inhalable size particu-
lates.

     o    Research Priorities (Air)
              Characterize inhalable particulate matter
              emissions from important energy and industrial
              sources.  Such information will be required to
              allow selection of the appropriate control
              technology to achieve a possible ambient '
              inhalable particulate matter (fine) particulate
              standard.  Such a revised ambient standard is
              under active evaluation by EPA.

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                        - 401 -

          2.   Evaluate the sources and controls  for urban
              fugitive dusts.   Such sources are  major
              contributors to total suspended particulates
              in certain urban locations.

          3.   Review the industrial and utility  boiler
              particulate control  technology adequacy in
              order to help the Air Program Office evaluate
              the appropriateness  of revising the  NSPS in
              1982/1983 timeframe.

          4.   Complete evaluation  of a full scale  baghouse
              on low sulfur coal utility boilers,  and continue
              assessment of electrostatic enhancement of
              fabric filtration for baghouse applications.
              Baghouses represent  the most cost-effective
              control alternative  for stringent  particulate
              emission limitations particularly  for low
              sulfur coal applications where ESPs  are costly.

          5.   Complete the initial evaluation of after-treat-
              ment particulate trapping devices  for mobile
              source diesel emission control, and assess the
              prospect of their use to support an emission
              standard for autos and trucks.

          6.   Continue assessment  and development of flue gas
              conditioning additives and the engineering
              evaluation of a 30,000 SCFM electrostatic
              precipitator (ESP) precharger for  enhanced
              particulate control.  Subsequently,  perform
              evaluation of control enhancement  options for
              low sulfur coal boilers with low performance
              ESPs.

          7.   Continue evaluation  of optimized  (S0x-Particu-
              lates) mini-plant wet scrubber with the
              objective of achieving the proposed 1979
              Utility NSPS for particulates and  SOX with
              a single low-cost control device.

Environmental Impact of Conventional and Advanced
 Energy Systems

     The program includes the following four subprograms:

     o    Conventional combustion environmental assessments;
          define environmental impacts of unregulated
          pollutants from utility, industrial, commercial
          and residential sources.

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              - 402 -

Waste and water: define the impact and where
required evaluate/develop controls for the solid
waste and water residuals associated with coal
and oil combustion sources.

Conservation and advanced energy systems:
environmentally assess wastes-as-fuel, geothermal,
solar and other emerging non-fossil fuel energy
systems.

Integrated technology assessments: identify
environmentally, socially and economically
acceptable alternatives for meeting national
energy objectives.

Research Priorities

     Air

     1.  Define the environmental impact of POMs,
         heavy metals and direct sulfate emissions
         from selected coal and oil combustion
         sources.

     2.  Complete combustion source chemical and
         bioassay studies for utility and industrial
         coal and oil sources, aimed at comprehen-
         sive screening for unregulated air
         pollutants.

     3.  Define the environmental impact of
         increased wood burning in industrial,
         commercial and residential sources.

     4.  Define the air impact and evaluate control
         of commercial and near-commercial waste
          (municipal refuse) - as-fuel systems.

     5.  Define air impact and evaluate controls
         for geothermal energy systems.
     Water
         Continue regulatory support efforts to
         provide characterization data and control
         technology information for the promulgation
         and implementation of effluent guidelines
         for the electric utility industry.

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         - 403 -

2.  Complete comprehensive combustion source
    chemical and bioassay studies for utility
    and industrial coal and oil sources aimed
    at comprehensive screening for water
    pollutants.

3.  Continue limited assessment and control
    technology evaluation for waste-as-fuel
    and geothermal water pollution problems.

Solid Waste

1.  Complete regulatory support program to
    obtain sufficient data and information to
    enable promulgation of guidelines or
    regulations under RCRA for the storage,
    treatment and disposal of coal ash and
    scrubber waste from coal-fired electric
    generators.

2.  Evaluate second generation ash and scrubber
    waste disposal approaches with the aim of
    identifying more affordable and effective
    techniques.

Multi-Media

1.  Perform congressional-mandated analysis of
    the Federal energy/environmental and con-
    servation programs; present annual findings
    to the Congress.

2.  Extend coal technology, electric utility,
    coal development and oil shale development,
    integrated technology assessments  (ITAs)
    to evaluate impacts of energy conversion
    technologies and development strategies
    on residuals disposal, toxic and trace
    elements levels and water use.

3.  Extend the regional ITA of the Ohio River
    Basin and Appalachia to identify energy-
    development policy options for local,
    state and regional governments.

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                         - 404 -

Fuel Processing, Preparation and Advanced Combustion

     The program includes the characterization of effluents
and emissions, assessment of related environmental impacts,
and development and evaluation of necessary pollution control
technology for various emerging coal, oil shale and biomass
fuel processes.  The results of this effort are used as input
on the Agency's standard setting process.  Fuel processes
assessed include: (1)  coal cleaning, (2)  fluidized bed
combustion, and  (3)  synthetic fuels generation from coal,
biomass and oil shale.

     o    Research Priorities (Multi-Media)

          1.  Continue improving methods for sampling,
              analysis and continuous monitoring of air,
              water and solid waste effluents/residuals to
              quantify total organics,  characterize toxics
              and determine inorganic compounds for coal
              processing technologies .

          2.  Update multi-media pollution control guidance
              document and environmental assessment report
               (EAR)  for first generation above ground and
              in-situ oil shale processes.

          3.  Prepare multi-media pollution control guidance
              document and environmental assessment reports
              for low/high BTU coal gasification, coal
              liquefaction and fluidized bed combustion
              processes.

          4.  Evaluate air, water and solid waste environ-
              mental problems and controls for coal
              preparation  (cleaning) plants.

          5.  Evaluate environmental problems and controls
              for first generation biomass energy systems.

Extraction

     The general objective of the extraction research program
is to assess, develop, identify, and verify control technology
for solid fuel, oil and gas extraction which will assure that
the recovery of  the nation's fuel reserves is conducted in an
environmentally acceptable manner.  To this end, equipment,
methods, and technology are assessed and developed to prevent,
control, and abate the discharge of environmental pollutants
from both point and non-point sources.   Pollution sources
include facilities for exploration, production, storage, and
transportation of coal, uranium, oil shale, oil, and gas.
Both normal operations and accidental spills are examined.

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               - 405 -

Research Priorities

     Air

     1.  Characterize fugitive particulates by size
         and chemical composition in extractive
         processes.

     2.  Relate ambient particulates to sources.

     3.  Conduct fate and effect studies related for
         extractive processes.

     4.  Evaluate fugitive process particulate
         controls.

     5.  Evaluate the role of natural hydrocarbons
         on 03 and aerosol problems.

     Water

     1.  Evaluate the effects of Western coal and
         oil shale extraction on surface and ground-
         water quality.

     2.  Develop water quality monitoring network in
         Western energy development areas.

     3.  Determine the best management practices for
         surface mine sediment control.

     4.  Develop techniques for removal of toxic
         materials from mine drainage.

     5.  Identify the best available technology for
         the treatability of effluents.

     Solid Waste

     1.  Determine adverse effects of solid waste
         from mining.

     2.  Determine the best management practices
         for solid waste from mining.

     3.  Assess methods for mining waste reduction,
         recovery and reuse.

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                         - 406 -
HEALTH EFFECTS

     The major thrust of the second five year effort should be
to respond to specific EPA and other agency research require-
ments.  This trust will strengthen the utility and effective-
ness of the program.  The second five year effort should be
closely coordinated with the base research programs both in
EPA and the other agencies.

     During the course of the Interagency Steering Committee
Meetings helping to plan the FY 80-85 program, the non-EPA
members have voiced concern that appropriate sensitivity to
the interagency character of the program be recognized during
EPA's ZBB process.  They remind us of their feelings that EPA's
ZBB process may not adequately reflect the priorities and
needs of other agencies participating in the program.  The
research program should be sensitive to these concerns.

     The following are the research objectives of the programs
identified by the four major subdivisions: Ecological Fate and
Effects, Air Transport and Fate, Monitoring and Instrumentation,
and Health Effects.

Ecological Fate and Effects - Research Priorities

     Toxics

          1.  Development and validation of quick and
              economical methodologies to test the biological
              effects of toxic energy-related chemicals in
              support of TOSCA's requirements to regulate
              hazardous chemical substances and mixtures.
     Air
     Water
              Evaluate the effects of energy-related air
              pollutants on aquatic and terrestrial ecosystems
              and their components in support of the Clean Air
              Act requirements to prevent the significant
              deterioration of air quality and the development.
              of national ambient air quality standards.
              Identify techniques to prevent adverse environ-
              mental effects from coal mining operations in
              support of the permanent regulation of the
              Office of Surface Mining (DOI) and the develop-
              ment of best management practices in support of
              EPA's national water standards for the coal
              mining industry.

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                        - 407 -


          2.  Assess the impact of energy-related consent
              decree pollutants on various ecosystems in
              support of EPA's development of the water
              quality criteria documents.

          3.  Evaluate the effects of offshore oil and gas
              exploration and extraction of marine environments
              in support of EPA's requirements pertaining to
              the National Pollutant Discharge Elimination
              System permit program.

Air Transport and Fate - Research Priorities

     Air

          1.  Development of complex terrain air pollution
              dispersion models to support the Agency's
              efforts to establish environmental standards
              based on sound scientific information and to
              develop and evaluate abatement programs.

          2.  Development of regional  (long-range) transport
              and dispersion model to support Agency efforts
              to understand the atmospheric transformation
              and impact on visibility of pollutants origina-
              ting from energy sources and to develop
              standards and abatement strategies.

          3.  Fine particulates - studies to characterize
              their formation, transport and affect visibility.
              Output to support Agency fine particulate stand-
              ard development.

          4.  Pollutant behavior studies - chemical and
              physical atmospheric processes, field and chamber
              studies.  Output information for use in model
              development.  This includes studies of scrubbed
              and unscrubbed plumes and of nucleation and
              cloud phenomena.

Monitoring and Instrumentation - Research Priorities

     Toxics

          1.  MAS - Master Analytical Scheme.  Continuation of
              development of this comprehensive and ultra-
              sensitive GC/MS system for analysis of complex
              organic molecules.  The computerized detection
              module of this sytem has a library of 50,000
              fingerprints of the organic species most likely

-------
Air
                    -  408  -

         to be found in environmental samples, including
         many that are toxic or carcinogenic.  This
         powerful tool will be used by the Agency in
         pseudo mass-balance studies to identify the
         major sources of particular toxic substances
         to assure that regulatory initiatives are
         realistic and effective.
     1.  Visibility monitoring in Federal Class I areas
         in support of Agency efforts to implement Clean
         Air Act mandates for prevention of significant
         deterioration.

     2.  Acid precipitation and dry deposition monitoring
         in support of Agency efforts to identify the
         ecological and economic impacts of acid
         precipitation.

     3.  Fine Particulates - development of methodology
         for monitoring the organic and nitrate fractions
         in support of the Agency's efforts to understand
         atmospheric transport and transformation of these
         pollutants.  The monitoring methodology also
         supports agency efforts to devise and evaluate
         abatement strategies.

     4.  Air quality baseline documentation for the
         western area where intense energy development
         activity is projected to occur by 1985 -
         summaries and analysis of data obtained during
         the first five years.  This data will enable the
         Agency to see and prove the environmental impacts
         of energy developments.
Water
         Development and implementation of a nationwide
         anticipatory monitoring program for toxic
         pollutants from energy developments (AMTES:
         Anticipatory Monitoring for Toxics from Energy
         Sources).   The monitoring system will be used
         to devise and evaluate abatement strategies
         and to raise alarm flags to avert potential
         catastrophes.

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                         -  409  -

              Development of advanced monitoring systems and
              strategies for particular field applications
              related to new energy developments,  e.g.,  OCS
              drilling platforms,  in-situ retorting.   These
              monitoring systems will support the  NPDES
              program.
     Water Supply
          1.  Basin studies in the western energy development
              areas to establish baseline hydrological and
              chemical groundwater data in order to predict
              impacts on groundwater of energy developments.
              Energy developments threaten both the quality
              and quantity of water supplies in the semi-arid
              regions of the West which accelerated development
              of vast energy resources is occurring.

     Multi-Media

          1.  Multi-media development of monitoring and
              instrumentation technology for energy source
              monitoring and ambient monitoring for pollutants
              from energy sources in support of Agency enforce-
              ment activities and Agency efforts to evaluate
              abatement programs.

          2.  Multi-media development of pollutant measurement
              methodology in support of health effects,
              ecological effects and transport, transformation
              and fate studies of pollutants from energy
              sources.  These studies support the Agency's
              efforts to establish environmental standards
              based on sound scientific information and to
              develop and evaluate workable and effective
              abatement strategies.

Health Effects - Research Priorities
     Toxics
              Development of techniques to identify manufactured
              agents/mixtures that can produce adverse effects
              on human health.

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Air
                     - 410 -
     2.  Development of a data base to assist in
         determining the impact on humans of specific
         manufactured energy-related chemicals (and
         mixtures) for specific biological endpoints
         (birth defects, cancer, mutagenic effects).
         These techniques/data are needed to provide
         EPA support to the Toxic Substances Control
         Act of 1976
         Development of a data base to assist EPA in
         establishing energy-related National Ambient
         Air Standards.  This data base enables the
         development of reliable estimates of human
         health damage functions for various population
         groups through a balanced program in animal
         toxicology, epidemiology and clinical studies.
Water
     1.  Development of techniques to identify waterborne
         agents/mixtures that can produce adverse effects
         on human health.

     2.  Development of a data base to assist in deter-
         mining the impact of humans of energy-related
         waterborne effluents (individual agents and
         mixtures) for specific biological endpoints
         (cancer, cardiovascular disease).
Solid Waste
     1.  Development of techniques for identification of
         energy-related hazardous wastes that can produce
         adverse effects on human health.

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1980/1981 INTERDISCIPLINARY MEDIA GUIDANCE

-------
                        - 413 -


                  INTERDISCIPLINARY
MEDIA OVERVIEW

     The past years have seen the development of a growing
recognition that the Agency must improve its exploratory
research capabilities in parallel with integrating its
research and regulatory functions.  Likewise, the development
of the regulatory decision process has come to require that
the risks, benefits and costs of EPA's regulatory decisions
be documented with improved methodologies and data.  In
response to these developments ORD established its Anticipatory
Research program as a cornerstone in the development of a
long range research program and proposed the establishment
of an Office of Health and Environmental Assessment.  During
this same period of time, operational components of the
Agency have recognized that segmented state grant mechanisms
did not always encourage innovative multimedia management
approaches for dealing with health and environmental problems.
The Agency accordingly proposed the Integrated Environmental
Assistance Act of 1979 to assure that alternative ways to
foster and support a total grant delivery approach.  Finally,
an ongoing agency activity most representative of the inte-
grative approach needed to examine environmental problems,
is the environmental impact statement.  Total NEPA compliance
and 309 Review activities relating to all media categories
are the overview responsibility of the Office of Federal
Activities.

MAJOR OBJECTIVES

     o    Develop an integrated exploratory research program
          within ORD.

     o    Fully implement a health and ecological assessment
          capability within ORD to serve program office
          requirements.

     o    Coordinate environmental training programs throughout
          the EPA by the National Workforce Development
          Staff.

     o    Integrate new Council on Environmental Quality
          regulations, Endangered Species Act regulations,
          Historic Preservation regulations and the Executive
          Orders on Floodplain Management and Wetlands
          Protection in all NEPA programs.

-------
                - 414 -
Implement the Integrated Environmental Assistance
Act emphasizing simple administration, enhanced
state program integration and flexibility and
incentives for good performance.

Develop and publish a set of Environmental Profiles,

-------
                      - 415 -

         GUIDANCE FOR FEDERAL ACTIVITIES


     This guidance relates to  the total NEPA Compliance
and 309 Review activity and relates to a number of Media
categories.  The elements in this program include (1)
the regulatory NEPA compliance program (all media)
(2) the nonregulatory NEPA compliance  program (Water
Quality Media) ,  (3)  the new source NEPA compliance and
EIS review programs in the regions (interdisciplinary
media)/ and (4)  the Office of  Federal  Activities which
has oversight over the total program (Agency and
Regional Management Media). Guidance  relating to the
regulatory EJS preparation program is  described under
the Headquarters Abatement and Control Section end
guidance for nonregulatory EIS preparation, new source
EIS preparation and EIS review under the Regional
Abatement and Control Section.  The Office of Federal
Activities oversight for these programs is described
under the Headquarters Agency  and Regional Management
Section.

Planning Assumptions

     Planning assumptions for  the total program are
generally the same as in the past with the exception
of adjustments necessary to conform to the new Council
on Environmental Quality regulations,  the Endangered
Species Act regulations, Historic Preservation regula-
tions, and the Executive Orders on Floodplain Manage-
ment and Wetlands Protection in all programs.

Media Priorities

     Priorities and constraints are contained in  the
following guidance for each program.

Major Objectives

     NEPA Compliance — to assure that EPA's decisions
concerning (a) construction grants, (b) new source
discharge permits, and  (c) selected regulatory actions
are environmentally sound and  cost-effective and  that
EPA's compliance with NEPA is  timely and efficient.

     EIS 309 Review — to assure that all Federal
actions are environmentally sound.

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                     - 416 -
HEADQUARTERS PLAN

Abatement and Control

     Plans and priorities
                       NEPA Compliance Program (Air,
            Water,  Toxics,  Noise,  Solid Waste,  Pesti-
            cides,  and Radiation)

            Program direction  for  fiscal  year 1980 is
            generally consistent with the information
            provided in the past.   Continued emphasis
            should  be placed on integrating  into EISs
            other major supporting documentation (e.g.,
            economic and health assessments)  for a given
            regulation (at  least summaries of this other
            documentation should be in the KIS) »  This
            comprehensive integrated analysis,  which is
            presented in EIS in a  style suitable for
            non-expert readers, wall contribute to
            public  understanding of Agency actions and
            increase the public awareness that EPA does
            consider a balanced set of impacts in devel-
            oping environmental regulations.

               - In order to comply with  the new CEQ
                 EIS regulations,  increased  emphasis
                 should be  put on  the analysis of mean-
                 ingful alternatives and  the preparation
                 of succinct EISs  which under the* new
                 EIS regulations should be no more
                 than 150 pages in most cases.

               - In order to comply with  the recent
                 Executive  Orders  on wetlands and flood-
                 plains and the Agency's  policy on
                 prime agricultural lands, impacts
                 affecting  these areas should be high-
                 lighted in EISs.

            EIS 309 Review  Program

            Increased emphasis on  program offices'
            review  of major Federal projects to
            insure  consistency with EPA regulatory
            programs and goals.

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                     - 41.7  -




     Changes

     No changes anticipated for  fiscal year 1981.

Agency and Regional  Management  (OFA Oversight)

     Plans and priorities

          ° Nonregulatory NEPA Compliance

               - Revise 40  CFR Part 6 in accordance
                 with new CEQ regxilations arxcl new  20J
                 construction grants regulations.

               - Review controversial EISs and  findings
                 of  no significant impact at the request
                 of  CEQ, other Federal agencies. Con-
                 gress/ or  citizens.

               - Review the NEPA program in each region
                 annually for quality, efficiency, and
                 effectiveness.

               - Develop interagency agreements for lead
                 agency EIS preparation as required.

               - Provide training conferences  for
                 regional offices.

               - Manage contracts and resources to meet
                 regional office needs for contractor
                 assistance in preparing EISs  and  NEPA-
                 related studies.

               - Revise Manual  for Preparation of  EIS
                 for 201 Construction Grants Projects
                 in  accordance with new CEQ regulations
                 and new 201 construction grants regula-
                 tions.

               - Provide guidance and assure conformance
                 with other environmental laws (Endan-
                 gered Species,  Historic Preservation,
                 Floodplain Management, and Wetlands
                 Protection).

          P New Source NEPA Compliance

               - Revision of new source regulations:

-------
         - 418 -
        — to conform  to new CEQ  regulations
        — to conform  to proposed new NPDES
           permit  regulations
        -- to require  pre-construction review
        — to encourage scoping
        — to coordinate air and  water new
           source  reviews,
        — to encourage tiering and  area-
           wide EISs

   - Complete development  of technical
     guidelines and appendices for selected
     new source industries.

   - Manage contracts  and  resources  to meet
     regional office needs for contractor
     assistance in EIS preparation.

   - Provide guidance  and  conduct new source
     EIS training  conference for  regional
     staff.

   - Provide guidance  and  assure  conformanee
     with other environmental laws (Endan-
     gered Species, Historic Preservation,
     Floodplain Management, and Wetlands
     Protection).

Regulatory NEPA Compliance

   - Continue to review  selected  EISs.
     Emphasis will be  placed on EISs pre-
     pared under more  recent laws, i.e.,
     TSCA and RCRA.

   - Finalize revision to  Regulatory EIS
     Procedures to address changes precipi-
     tated by the  new  CEQ  EIS regulations
     and continue  to provide guidance on
     compliance with the Agency's Regula-
     tory EIS Procedures.

    309 Review Program

   - Continue to review  Federal  agency
     regulations and controversial National
     level projects, clear regional  EIS

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                     - 419 -
                 comments,  conduct headquarters liaison,
                 and provide assistance to regions in
                 framing 309 determinations and other
                 significant adverse comments,  with
                 special attention to energy, water
                 resources, and major transportation
                 and community development projects.

               - Negotiate 309 referrals and follow up
                 with CEQ and sponsoring agencies.

               - Provide guidance and follow up on the
                 EPA implementation of the CEQ
                 regulations.

               - Continue development and up-dating of
                 policy (309 Review Manual)  and techni-
                 cal guidelines.

               - Provide guidance and continue  to
                 operate Official Piling System.
     Changes
     In the EIS 309 review program,  there will be
     a significant emphasis in program oversight
     related to improving the EIS assistance/review
     interface in fiscal year 1981.   In the NEPA
     compliance programs, there will only be minor
     changes in oversight activities.  In all programs,
     regulations, guidance, manuals, etc. will be re-
     vised and updated as necessary to conform to
     any revisions in existing or new laws.

REGIONAL GUIDANCE

Abatement and Control

     Regional priorities

          ° Nonregulatory NEPA Compliance

            Program direction for fiscal year 1980 is
            generally consistent with last year
            except that the regions are being allowed
            more flexibility in the design of their
            specific program to accomplish the objec-
            tives.

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              - 420  -
The principal program involves  preparation
of 201 facilities plan EISs.  208 areawide
planning grant EISs  and Clean Lakes program
EISs will be prepared only as resources
permit.

Regions should strive for early environmental
review of projects during the planning phases
and should promote the preparation of piggy-
back EISs wherever EISs are to  be prepared.
Emphasis should also be placed  on coordi-
nating EPA project planning with the planning
efforts of other Federal agencies to provide
for better environmental reviews of the
cumulative effects of Federal actions.  WhiXe
the principal objectives of the environmental
review process should be improved pro-
jects either with or without an EIS, the
Agency's output of EISs relative to the size
of the program is still so low  that we must
continue to strive to prepare more EISs when
resources are available to do so.

Even though we have  an EIS exemption on
each, some Regional  Administrators have
decided to do EISs on Clean Lakes grants and
208 areawide planning grants because of
some of the significant adverse impacts
these projects can cause.  The  general
approach on such grants should  be to have the
applicant prepare an assessment (paid for
with grant funds as  an eligible cost) and
if an EIS is prepared use the assessment as
a principal input to the EIS.  Unfortunately,
the EPA contract funds for EISs are already
assigned to the mandatory EIS programs.
Funds for Clean Lakes and 208 areawide
planning grant EISs  will be available only
if expenditure patterns in other areas are
less than planned.

Solid waste demonstration grant EIS activi-
ties are handled at  headquarters.

Consistent with available resources, each
region should develop a mix of the following
activities that will minimize the adverse
environmental impacts of proposed actions;

-------
         -  421 -
however,  EISs must be prepared on  at least
some projects.

   - Attempt to identify need for  EISs
     during Plan of Study development.  If
     not possible during this phase, do so
     as early as possible in order to
     minimize project delays.

   - Conduct pre-application (201)  confer-
     ences to identify those actions requir-
     ing EISs.

   - Prepare draft and final EISs  with
     appropriate mitigation measures.

   - Attempt to prepare piggyback  EISs for
     construction grant projects.

   - If no EIS is required, prepare findings
     of no significant impact with appropri-
     ate mitigation measures.

   - Assure that all Federal requirements
     regarding wetlands, floodplains, agri-
     cultural land, wild and scenic rivers,
     historic and archeological sites, and
     endangered species are considered for
     all projects.

   - Review and monitor NEPA compliance by
     States with 201 delegation.   Make NEPA
     decision for 201 projects for all States,

   - Obtain the review of all affected re-
     gional staffs before issuing  findings
     of no significant impact, notices of
     intent, draft EISs, and final EISs.

New Source NEPA Compliance

Program direction for fiscal year  1980 is
generally consistent with last year except
that the regions are being allowed more
flexibility in the design of their specific
program to accomplish the objectives.

Consistent with available resources, each
region should develop a mix of the following

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         - 422 -
activities that will minimize the adverse
environmental impacts of proposed actions;
however, EISs must be prepared on at least
some projects.

   - Identify potential new sources as
     early as possible.

   - Conduct pre-application conferences.

   - Coordinate with other Federal agencies,,
     organize and attend scoping meetings.

   - Make new source determinations accord-
     ing to New Source Task Force Initia-
     tives.

   - Attempt to obtain third party EISs.

   - Conduct environmental reviews of all
     new sources to determine if they will
     significantly affect the environment~

   - If it is determined that the project           "
     will not have any significant environ-
     mental effects, prepare findings of no
     significant impact fully justifying
     the decision.

   - Prepare notices of intent/ and draft
     and final EISs.

   - Obtain reviews by all affected regional
     staffs before findings of no significant,
     impact, notice of intent, draft EISs
     and final EISs.

   - Assure that all Federal requirements
     regarding wetlands, floodplains, agri-
     cultural land, wild and scenic rivers,
     historic and archeological sites, and
     endangered species are considered for
     all new sources.

   - Participate in other agency's EISs in
     accordance with negotiated lead agency
     agreements.

   - Utilize areawide EISs when appropriate.        ™

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           - 423 -
° EIS 309 Review

  Program direction  for  fiscal year 1980 is
  generally consistent with last  year except
  that the regions are being allowed more
  flexibility in the design of their specific
  program to accomplish  the objectives.   Par-
  ticularly close attention should be paid to
  pre-EIS liaison related  to highly contro-
  versial projects which involve  critical
  areas of emerging  national policy/ have
  significant and/or mult i~ media  effects,
  and/or concern several agencies.  Examples
  are coal-fired and nuclear power plants,
  transportation projects, and actions which
  involve wetlands and prime farmland.

  Consistent with available resources, each
  region should develop  a  mix of  the follow-
  ing activities that will minimize the
  adverse environmental  impacts of proposed
  actions.

     - Timely Reviews — Timely,  high quality
       reviews which make  use of  all available
       expertise.

     - Pre-Draft Liaison -- Scoping, particu-
       larly for projects  expected to have
       significant adverse environmental
       effects, e.g., energy, water resource,
       and major transportation and community
       development projects,.  ETS coox'dinators
       should be familiar  with new CEQ regula-
       tion requirements and planning systems
       and processes of  other Federal agencies

                 Liaison — Negotiating
       differences with originating agency
       which resulted from review of the draft
       EIS.   Enables EPA to be aware of timing
       of issuance of the final EIS.

     ~ CEQ Reg Ij^terpre^tations — Advise and
       assist the public and other interested
       parties on interpreting CEQ regulations,
       including deterrninirc need for EIS, etc.

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    - 424 -
Coordinating Environmental Reviews —
Develop closer link  between EIS reviews
and related environmental reviews such
as new source reviews,  109(j)  determina
tions, and 404 reviews.

Cooperating Agency — Technical assis-
tance in critical  areas where EPA's
technical input can  significantly im-
prove the quality  of an agency's plans
and projects.

Referring Bad Projects  — Refer to OFA
those projects rated "ED" or "3" at
draft EIS review stage  or "environmen-
tally unsatisfactory" at final EIS
review stage.

Post-EIS Follow-up — Selectively
follow up at the post-EIS stage on key
projects to assure that crucial mitiga-
tion measures are  incorporated as
promised in final  F.ISs; report criti-
cal discrepancies  to OFA.  Periodically
monitor projects of  a continuing nature
(e.g., navigation  projects) to acquire
new information and  identify need for
project modifications.

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                     -  425 -
      REGIONAL PROJECTED PROGRAM ACCOMPLISHEMNTS
NEPA Compliance

I/  Number of draft EISs prepared on construction, grants
    (output commitment required).

    Number of final EISs prepared on construction grants.

2/  Number of findings of no significant impact on
    construction grants.

I/  Number of draft EISs prepared on NPDES new source
    permits (output commitment required).

    Number of final EISs prepared on NPDES new source
    permits.

2/  Number of findings of no significant impact on NPDES
    new source permits.

    Number of draft EISs prepared on other regional
    office actions.

    Number of final EISs prepared on other regional
    office actions.

EIS Review

    Number of draft EISs reviewed.

    Number of final EISs reviewed.

I/  Percent of draft EISs reviewed on time (output
    commitment required).

"L/  Percent of final EISs reviewed on time (output
    commitment required).

    Number of draft EISs reviewed where the project
    was rated environmentally unsatisfactory (EU)

    Number of draft EISs reviewed where the project
    was rated environmental reservations  (ER) .

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                      -  426  -
    Number of draft  EISs reviewed where the  EIS was
    rated inadequate information  (3).

    Number of final  EISs reviewed where comments
    indicated environmental  reservations  (ER) with the
    project.

    Number of final  EISs reviewed where the  project
    was found unsatisfactory and was referred to CEQ.

    Number of final  EISs rated  unresponsive.

    Number of draft  EISs with significant scoping
    sessions.
I/  Output commitment required.                                   A

2/  Regions or GIGS must provide  this, data  — all
    other data will be provided by  OFA.

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                         -  427  -

CONSOLIDATED GRANT PROGRAMS

Implementation of Consolidated State Grant Programs

     The number of EPA state grant programs has grown from
three programs with a grant authority of $60 million in 1978
to 116 programs with grant authority of nearly $300 million.
There is growing awareness of the complexity of the cross-
media impacts of these programs as well as the seriousness
of the impacts to health and the environment.  Implementa-
tion of the Integrated Environmental Assistance Act would
enable the states to decide whether or not to apply for
integrated assistance grants and which programs to include;
would require the States to submit an integrated program
plan as part of its assistance application and to consult
with local governments as the integrated plan is developed.
It will be important to have greater opportunities for local
government to participate as part of a total state environ-
ment program.  Finally, the integrated assistance projects
must be awarded on a nationally competitive basis.

     o    Plans and Priorities - FY 80

               Develop Regulations, Policies, and Procedures
               to implement the Act in conjunction with
               regional inputs.

               Headquarters will review, rank and select
               supplemental assistance proposals.

          -    Regions will assist state and local govern-
               ments in preparing applications including
               integrated work programs.

               Regions will review applications and award
               integrated assistance.

ENVIRONMENTAL PROFILE S

     The Agency must continue to improve its communication
with the public on status and trends in environmental pollution
and its reversal.  Not only must our citizens know of the
success of their commitment to clean up their air, land, and
waterways, they n\ut also be aware of how much is left to be
done.

     EPA and its State partners collect data on ambient
levels of many pollutants.  For the most part we aggregate
these data at the national level for use in policy review
and program planning.  We have not made sufficient use of

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                         - 428 -
this unique resource to allow the public to assess for
itself whether the environment is improving, and how quickly.

     Currently, Regional staff are engaged in an intensive
review of our ambient data to design model "Environmental
Profiles," arraying status and trend information in clear,
easily used graphics to describe pollution levels in discrete
geographic areas (such as counties).  In FY 79 at least
four, and as many as six Regions will publish pilot Regional
profiles.  From these Regional reports Headquarters will
derive a partial National profile for internal review.  The
Agency will distribute the Regional publications, and 0PM
will conduct an intensive evaluation of their reception and
use by influential readers such as State legislators, news
reporters, and public interest groups.  Our purpose is to
determine if these information "gatekeepers" can use the
Profiles to communicate patterns of environmental change to
the general public on a small scale geographic basis.

     Depending upon the results of the pilot, the Adminis-
trator will decide whether to publish compatible Environ-
mental Profiles in all Regions in FY 1980 and beyond.  If he
so decides, the FY 1980 Operating Plan will change accord-
ingly.  In FY 81, Regions not involved in the pilot should
plan to devote 2.5 work years and $25,000.  Each Region
should also devote an appropriate amount for distribution.

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                             - 429 -

RESEARCH AND DEVELOPMENT

Development of an Exploratory Research Capability

     We have made important progress in the past year in
starting the process of building an exploratory research
capability.  Within the Anticipatory Research Program initi-
ation of the Center Support Program provides us with the
beginning of a long term research program in critical areas
to serve as a foundation for our applied research in support
of regulations.  It will become an increasingly important
link to the best institutions in the academic community in
the future.  Internally, the Innovative Research Program is
providing new opportunities for our own scientists to surface
basic research proposals and unique ideas.  Finally, more
mature multidisciplinary programs aimed at assessing antici-
pated problems have begun to focus on areas likely to be of
growing future concern.

     Since these advances provide the underpinnings to our
ability to ultimately get ahead of our future problems, we
must be careful of their design and assure that the best
scientific talent of the country participates in their
development.  Moreover, our efforts to identify new prob-
lems must also take advantage of the government wide re-
sources devoted to similar undertakings in offices such as
the Office of Technology Assessment, National Science Founda-
tion and Congressional Research Service.  We must articulate
our research interests to the scientific community with
increasing clarity and assure through greater competition
that the best scientific proposals are awarded.  Finally,
there remains the task of assuring that exploratory research
conducted within all media is integrated into a compre-
hensive effort.  This task must focus on identifying exploratory
research across all areas and assuring that those problem
areas in need of fundamental research are adequately supported.

     o    Plans and Priorities - FY 80

          -    Provide increased competition and improved
               peer review of EPA grant programs.

               Implement Center Support activities initiated
               in FY 79 and establish four (4) new centers
               for long-term research.

          -    Expand Innovative Research activities pro-
               viding for increased ORD participation by
               Laboratory and extramural scientists.

               Integrate Acid Rain and Cancer Program research
               programs.

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                           -  430  -

     o    Plans and Priorities - FY 81

               Integrate long range research conducted
               through the Public Health Initiative, Antici-
               patory Research and Base Programs into explora-
               tory research program.

Implementation of a Health and Ecological Assessment Capability

     The scientific assessment program is made up of two
distinct but interrelated operations: a criteria and assess-
ment development activity; and a special assessment activity
on risk and exposure.  In FY-79 OHEA (Office of Health and
Environmental Assessment) was proposed to institutionalize
both the existing Cancer Assessment Group and Environmental
Criteria and Assessment Office scientific assessment pro-
grams and the new 1979 initiatives (ECAO-CIN, Reproductive
Effects Risk Assessment, Exposure Assessment).  FY 1979 was
a start-up year for the new programs with the ECAO-CIN
developing proposed water quality criteria for the 65
Consent Decree Chemicals, the Reproductive Risk Assessment
Group developing guidelines for Agency wide adoption and the
Exposure Assessment Group initiating methodology devel-
opment.

     The entire scientific assessment program is Program
Office oriented in its outputs.  The needs are articulated
by the others and converted into work plan priorities.

     FY 1981 should see a strengthening of the Agency's
capability to develop health related assessments in a uniform
and consistent manner.  The quality control afforded by OHEA
either through the ECAO programs or the special risk groups
assessment will be apparent.   The capability for exposure
assessments, and estimating total body burdens etc. will
likely be much improved on an Agency wide basis as we approach
the end of FY-80 and look into 1981. For planning purposes
OHEA expects to receive raore requests for assistance from
the program offices in the development of assessments.
Moreover, as we approach FY 1981, ORD anticipates that
effects other than carcinogenic and reproductive impairment
will be emerging for regulatory analysis.  Pulmonary, neuro-
logical, and cardiovascular effects are likely candidate
areas.  The establishment of a special assessment group for
these health areas appears appropriate as a final step in
the development of this capability.  OHEA functional state-
ments provide for this event.

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                          - 431  -
     o    Plans and Priorities — FY 80

               Fully implement a scientific assessment
               capability in the area of Carcinogenesis and
               Reproductive Risk Assessments.

               Fully implement a scientific assessment
               capability to conduct Exposure Assessments.

     o    Plans and Priorities - FY 80

          -    Expand scientific assessment capability to
               include pulmonary, neurological and cardi-
               ovascular effects.

WORKFORCE DEVELOPMENT ACTIVITIES

     In the next two years the Office of Research and
Development will take steps in four broad areas:  (1) move
more education, employment,  and training on environmental
subjects into the self-supported systems; (2) coordinate the
full range of training in the Agency - including enforcement
related training; (3) expand the use of workforce planning
tools in Integrated Environmental Assistance and State-EPA
Agreements; and (4) determine the shortages likely to occur
in highly specialized environmental occupations.

     o    Plans and Priorities - FY 80

               Expansion of the Senior Environmental Employ-
               ment Program to all 50 States by 1980.

               Establishment of a strong Co-op Education
               Program for State and local environmental
               agencies.

               Publication of a guide to extra-agency
               resources.

               Preparation of composite training plans
               across program lines, e.g., hazardous waste
               dumps; hazardous spills, enforcement.

               Identify with the regions non-compliance
               situations related to human resource deficiencies
               and promote with the regions education and
               training on topics such as I/M, hazardous
               waste management, land application of waste
               water, and waste treatment plant operations.

     o    Plans and Priorities - FY 81

               Continue FY 80 initiatives.

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1980/1981 MANAGEMENT GUIDANCE

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                      - 435 -
                    MANAGEMENT
MANAGEMENT OVERVIEW

     The primary goal of management is to help the
Agency achieve its environmental objectives over the
long run. To accomplish this goal in the context of
a decentralized, yet effectively integrated, management
system we need to strengthen our analytic capacity
and our capacity to provide services in several areas.
The body of this Guidance addresses primarily those
priority areas which we believe must be strengthened,
recognizing that we must continue to carry out our
ongoing management activities in an effective way.

     The remainder of this overview identifies the
major planning assumptions on which this Guidance is
based, and the major priorities for FY I960 and 1981.

Planning Assumptions

     This Guidance is based on a number of planning
assumptions, most of which carry forward from the base
program. We believe, however, that we should highlight
our major assumptions because of their impact, on planning

     o  The Agency will continue to stress integrated,
        decentralized management.

     o  We must implement several key provisions of
        the Civil Service Reform Act of 1978 during
        FY 1980/81—particularly the Senior Executive
        Service, Merit Pay, Performance Appraisal and
        increased recruitment of minorities and women.

     o  we will stress increased delegation of contract
        management responsibilities to the Regions
        when volume and capacity warrant it.

     o  We will put in place a complete system of
        management information and accountability
        during FY 1979 and early in FY 1980.

     o  The ZBB process will become less resource
        intensive; its focus will shift to workload
        analysis and substantive budget justification.

     o  We will continue to work toward passage
        of the Integrated Environmental Assistance
        Act.

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                     - 436 -
     o  The Agency will continue to emphasize developing
        analytic capacity in the Regional offices.
        By the end of FY 1979, three Regions should
        have improved capabilities well under way, and
        at least two additional Regions should have
        strengthened their analytic capability in
        FY 1960.

     o  Significantly greater emphasis will be placed
        on the analysis of the benefits of environmental
        regulation in FY 1980 and 19fal.

     o  This Guidance does not reflect conclusions and
        recommendations from the Staff Offices study
        presently under way.

     o  During FY 1981, the Agency must substantially
        complete the systems development process to
        replace the present ADP capacity within
        the constraints of the OMB A-109 process.

     o  Support services estimates for FY 1981
        (including ADP Timesharing) will reflect cost
        increases attributable to inflation similar
        to that experienced in recent years.

     o  Budget estimates for basic Agency services
        (personnel, contracts, support services, etc.)
        should be based on providing services for
        current levels of employment and program
        activity.  Expansion  (or contraction) in these
        service areas to meet changing employment or
        program activity levels will be factored into
        the Agency's overall budget estimates as a
        final step in the ZBB process after overall
        budget levels are determined.

Management Priorities

     As with all programs, priority needs inevitably
outstrip resources.  As a result, it is important
to identify the areas of highest priority.  Although
the body of this Guidance describes them more
completely, the following are our highest priorities:

     o  Implementing the Civil Service Peform Act
        effectively, in order to improve our manage-
        ment accountability and performance;

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                       - 437 -
     o  Providing the information systems and evaluation
        capacity to enable us to hold ourselves, as
        well as State and local governments, accountable;

     o  Strengthening the management/analytic capa-
        bilities in the Regions to enable the Regional
        Administrators to better evaluate their programs,
        manage their Regions, deal with the increasingly
        complex job of integrating their programs, and
        participate equally in Agency-wide policy
        and management decision making;

     o  Continuing to refine ZBB to channel Agency
        energies less toward process and more toward
        substance;

     o  Developing and testing ways to improve our
        contracting process, improving responsiveness
        and cutting processing time;

     o  Developing practical alternative regulatory
        approaches to the traditional "command and
        control" model as a key contribution to
        regulatory reform;

     o  Improving the state-of-the-art in regulatory
        decision making, especially with respect to
        benefits analysis;

     o  Implementating the Integrated Environmental
        Assistance Act as a key management tool for
        integration of Agency programs in the Regions;

     o  Building stronger linkages among the management
        processes and among the 0PM analytical/management
        groups.

     Regulatory reform is an especially important part of
the management priorities, and it cuts across several
of the elements of management guidance.  The Integrated
Environmental Assistance Act will provide Regional
Administrators with a flexible negotiating tool which
should enable them to deal more effectively with the
States.  We will direct substantial analytic effort
toward generating, testing, evaluating, and implementing
ways to obtain more environmental protection at the
same or lower cost, particularly in the area of controlled
trading initiatives.  We will be renovating the Agency

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                      - 438 -
reporting system with an eye toward eliminating burden
some, duplicative and unnecessary reporting.  The
General Counsel will also place a high priority on
reform activities.

PLANNING GUIDANCE

Personnel Management

     The primary objective in personnel management  is
to help the Agency use its personnel resources in
such a way as to maximize their contribution  to our
environmental objectives over the long run.   The major
thrust of our personnel management system  through
FY 1981 will be to implement the various elements
of the new Civil Service Reform Act to improve our
management of personnel.  Four tasks rank  as  the
highest priority:

     o  Implement a system that will enable
        individuals to achieve an understanding
        with their supervisors as to the work for
        which they will be held accountable during
        the year.  Such a written understanding will
        form a rational basis for accountability,
        performance rating and rewards.

        - Establish standards for all EPA  staff by
          the middle ot the  first quarter,  FY 1980.
          This will be the result of each  person,
          working with his or her supervisor,
          deciding the details and basis for
          accountability during the year.

        - Give ratings to all staff based  on
          standards by the end of FY 1980.
          This will be the key to each indivi-
          dual's understanding of whet he  or  she
          has accomplished during the year,
          and will serve as  a basis for  rewards
          and training.

        - Using the standards developed  for FY 1980
          as a basis, develop FY  1981 standards,
          starting the latter part of FY 1980 for  all
          staff.  Complete the process by  the end
          of 1980.  These standards will govern
          employees during FY 1981.

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                 - 439 -
   - Develop systems and processes to ensure that
     the performance management system is operating
     and implemented, including development of
     monitoring procedures.

   - Design a mechanism for using the performance
     management system to identify promotion
     potential and training programs.

   - Develop policy and guidance documents dealing
     with SES, performance management, Career
     Development, Labor Relations, and the like.
     Headquarters must work closely with the
     Regions on this task.

o  Implement all aspects of the Senior Executive
   Service including classification, recruitment,
   placement, career development, and the establish-
   ment and management of two new Agency-wide boards;


   - Performance Review Board, which makes
     recommendations on performance ratings and
     on performance awards.

   - Executive Resources Board, which has responsi-
     bility for managing and establishing policy
     for managing the executive resources of the
     Agency consistent with delegations from the
     Administrator.

o  Recruit minorities and women into professional
   and high level positions.  Vve have made progress,
   but must do better at both Headquarters and
   Regional levels.  New legislation mandates
   increased efforts.  All Headquarters and
   Regional offices will need to develop detailed
   plans and goals for recruiting, working with
   the Office of Civil Rights and the Office of
   Personnel Management.

o  Examine our normal day-to-day operations to
   ensure that our programs are receiving needed
   services and that we are increasing effective-
   ness and finding efficiencies in their
   management.

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                        - 440 -
     A variety of other activities will also be
important during FY 80/81.  The new reform law allows
agencies to propose demonstrations for Office of Personnel
Management approval. The demonstrations permit testing
a variety of new approaches to improve the personnel
system, such as expansion of merit pay to employees
other than those now eligible. These demonstrations,
if we begin them, will reauire resources and must be
carefully evaluated for planning and implementation.
Labor-management relations are also affected by the
new law. We will need to be certain that our staff
understands the new elements of the law and is trained
to implement it.

     To support a stronger EPA/State/local environ-
mental regulatory effort, we should build on existing
mechanisms (e.g. group IPAs) to encourage personnel
interchange and training.  That interchange should  be
encouraged between EPA programs and Headquarters and
Regions as well as between levels of government as
a means of developing career paths.

     It will be very important that members of our
management group in fact have an opportunity to become
environmental managers through individual mobility  and
other developmental opportunities.  Advancement will be
available as individuals travel their planned career
paths and gain valuable experience in different programs
and in different geographic areas.  Individuals will
need to play a key role in the planning of their career
paths, working with Agency top management as they
fashion their futures.

     We also hope to establish an Environmental
Executive Service—a special high potential employee
program—for developing a group of highly qualified
employees in all environmental disciplines and a
parallel program for employees in some of our more
specialized areas, e.g., senior professionals in
nonmanagerial research positions and our many
attorneys.

     The Office of Personnel Management has issued
several new regulations that will affect a number
of internal policies, especially our merit promotion
plan.  The plan will need to be revised and implemented
throughout the Agency.  We will need to train all
our supervisors, managers, and employees on the new
policies and programs.

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                      - 441 -
     The Office of Personnel Management will be
generating another key activity because of the
required revision of classification standards. The
environmental engineer, mechanical engineer, chemist,
clerical, and secretarial standards have recently
been revised and the Agency must evaluate all present
positions in relation to these standards. The same
task will need to be done for most of our positions
by the end of 1961.  We will look at the possibility
of encouraging mobility between programs by building
cross-media tasks into our classification standards
in some specialties.

     Region Specific Guidance — All of the tasks
outlined have major implications for both Headquarters
workload and for all of the staff in the Regions.  As
a result of the many changing ground rules, special
strain will be placed upon the Regional personnel  staffs
who will have a major role and responsibility to assure
achievement of our objectives.  Performance appraisal
standards must be developed, ratings must be given and
standards must be updated annually.  It will be especially
important that we ensure careful and effective communi-
cation between Regions and Headquarters during these
difficult transitional reform years.

ContractsManagement

     The key contracts management objective is to
help the Agency manage its contract resources in such
a way as to maximize their contribution to our
environmental objectives over the long run.

     The major thrust in Contracts Management will
be toward improving the service to "client"
organizations. Priorities for the Contracts Management
activity during FY 1980/81 will be:

     o  Improving the responsiveness and efficiency
        of the Headquarters contract acquisition
        process;

     o  Continuing efforts to devise and intro-
        duce contract acquisition strategies
        that are more responsive to program
        needs and that promote improved
        contractor efficiency and quality of
        performance;

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                      - 442 -
     o  Strengthening Regional procurement and
        continuing the delegation of increased
        procurement authority to the Regions
        where justified by need and Regional
        capability;

     o  Developing program office capacity in
        contracts acquisition and management;

     o  Upgrading the post-award monitoring of
        contracts.

     The Headquarters Contracts Management function
will take a number of steps to improve the responsive
ness and efficiency of our contracting:

     o  Undertake during Fi 1979 an experiment in
        the use of a voucher system for allocating
        contracting staff resources. The results
        of this experiment will determine the extent
        to which a voucher system is adopted in
        Agency contracting operations  in FY 1960
        and 1961.

     o  Station resident procurement advisors
        in all Headquarters program offices that
        are major participants in the  contract
        acquisition process.

     o  Review and, as appropriate, revise contract
        policies, procedures and resource allocations
        in order to reduce procurement lead times.

     o  Develop workload measures that reflect
        variations in procurement complexity as
        well as dollar size and provide a credible
        basis for adjusting contract work force
        in response to workload increases.

     o  Revise procurement planning and reporting
        processes to —

        - Improve accountability for procurement
          activities in which program  offices
          and contracts personnel share responsi-
          bility.

        - Reorient the Headquarters contracts
          organizations and processes  to a client-
          centered mode of operation.

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                       - 443 -
     o  Continue to work with program offices to
        consolidate procurement requirements into
        broad program or mission-oriented require-
        ments rather than narrowly defined tasks.

     o  Increase use of award fee contracts and
        other strategies that are designed to
        motivate contractors to deliver the
        quality of service or product represented
        in their proposal.

     We will try to strengthen Regional procurement
further with continued delegation of increased pro-
curement authority to the Regions.  We expect to
continue and expand the delegation of procurement
authority to field units, commensurate with their
development of the requisite expertise, organizational
capacity, and needs.  We will strengthen programs
for periodic review of Regional procurement and couple
these reviews with on-site technical assistance to
address needed improvements.

     One of the most important initiatives for
improving service will be improving program office
capacity in contracts acquisition and management.
We will initiate several key activities:

     o  Conduct expanded training of project officers
        with emphasis on definition of require-
        ments, technical evaluation, and contractor
        management.

     o  Establish a pre-review process to provide
        coordination of contracts and program
        requirements at a time that permits resolution
        without risk to program priorities.

     o  Establish DAA-level review and coordination
        of major contract acquisitions to ensure
        that problem areas are speedily addressed
        before becoming major delays.

     o  Strengthen program office involvement in
        selection.

     Finally, we will upgrade the post-award
contracts monitoring function to offset loss of
traditional leverage (i.e., annual competition)
over contractor performance that is inherent in

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                       - 444 -
the mission contract concept, and we will  reinforce
project officer authority and accountability  for
contractor performance.

Resources Management

     The primary objective in Resources Management
is to help the Agency manage its total resources
in such a way as to maximize their contribution to
environmental objectives over the long run.

     There are five areas of highest priority
for Resources Management:

     o  Refining and improving the Agency's
        resource allocation process;

     o  Actively participating in inter-agency
        and cross-agency ZBB;

     o  Rebuilding the top management  information
        and accountability systems;

     o  Working toward implementing the
        Integrated Environmental Assistance
        Act;

     o  Strengthening the budget execution process.

     The following text elaborates on  the  five key
areas, and outlines the roles of Headquarters and
the Regions.  In addition, a number of other
priorities for both Headquarters and Regional
Resources Management are listed, together  with
a summary of Region-specific guidance.

     Improving Resource Allocation --  As one  of the
Agency's two critical cross-cutting decision-making
processes, Zero-Base Budgeting will continue  to be
the focus of the Agency's resource allocation. In
cooperation with the program offices and the  Regions,
0PM will continue to refine the existing system to
reduce the apparent deficiencies, paperwork burdens,
and time commitments; meet OMB requirements;  and
accommodate changes in management style or program
emphasis within EPA.  These refinements must  take
into account the need to reduce the workload  which
the ZBB now imposes on personnel at all levels within
the Agency and to streamline ZBB wherever  possible

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                      - 445 -
while maintaining it as an open process  in which
line managers participate fully in decision making.

     Previously, ZBb has focused heavily on the
process.  how that the process is well established,
it should focus more on substantive analysis.
Both headquarters and the Regions should continue
to develop analytical capabilities so that we
allocate resources using the best available
information.  To assist in this process, we will
focus this year on developing and working througn
both an analytic agenda end workload analyses.

     The Peaions shoula expect to play a major role
in assisting in the development of the analytic
agenda and various worKload analyses.  In addition,
the Regions snould become more active in regulation
development and review, especially regarding resource
issues .

     Participating in inter- and cross-agency  ZEE  --
In the FY 1960 oudget process, LFA profited signi-
ficantly from participating in OMB's initial inter-agency
ZBB (of all programs at the margin) ana  cross-agency
ZEB (of related programs).  vve expect CME's inter-agency
and cross-agency ZBB to be more sophisticated  in
f"l 19bl.  Ihis year, tnerefore, we will  identify  and
recommend new areas for cross-agency and inter-agency
Z6B--areas in which our experience tells us we should
do well.

     Because of this, CPH must also invest in
helping OftE define better and more open  processes
for conducting these ZBb efforts, and provide  staff
and otner support fcr them. This will include  identifying
specific issues useful to OhB staff and  providing
the analysis necessary to clarify and resolve  them.
The program offices, in coordination with GPM, should
be prepared to invest time in making these inter-
and cross-agency ZBE's work well, since  as a new,
lean agency we can expect to receive additional
resources from tnerc, just as we did last year.

     Renovating the Agency Reporting System — We
must give highest priority to rebuilding our management
information and accountapilitv system so that  it
will --

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                      - 446 -
     o  Provide useful information for all the
        Agency's managers in ah -.cfily understandable
        form.

     o  Reflect measures of environmental
        improvement which substantially reflect
        Agencywide goals and program achievements,
        rather than merely "count beans".

     o  Support our performance evaluation system,
        ZBB process, workload analysis, State/EPA
        agreements, and the changes which we hope
        will result when passage of the Integrated
        Environmental Assistance Act is passed.

     o  Eliminate burdensome, duplicative, and
        unnecessary reporting.

   The Assistant Administrators, Regional
Administrators, States, and localities should have
accountability systems of their own, since they must
be able to identify their own commitments and know
whether they are being achieved. The Agency-wide
system should build upon rather than duplicate these
efforts, reflecting more aggregated data than our
managers must have for their own needs.  Vie must
avoid duplicative and wasteful information gathering.

     We are too far into FY 1979 to put in place a  full-
scale reporting system.  FY 1979 will be a transition
year.  Headquarters and the Regions will submit short
reports quantifying their accomplishments and their
plans, relating them to the projected program accom-
plishments they used to justify decision unit levels
in the FY lb>79 ZBB submission.  The Regions will provide
standardized, quantifiable data but at a level reduced
from that in FY 1976.  A Regional/Headquarters work
group has begun work to define specific levels of
reporting and the measures the Regions will use.
State reporting requirements will not change.  For
FY 1980 and beyond, Headquarters and the Regions
will develop reporting requirements in coordination
with the Guidance/ZBB/Gperating Plan process.

     In conjunction with changes to our information/
accountability systems, in Fi 1980 we will also work
toward completing the  integration of our computer-based
data systems in the financial and resources management
area.

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                      - 447 -
     Implementing the Integrated Environmental Assistance
Act — Headquarters and Regional Offices must prepare
to implement the proposed "Integrated Environmental
Assistance Act of 1979."  This Act will strengthen
our State/EPA agreement effort and encourage meaningful
integration of our State and local assistance program
grants. We will develop a detailed implementation plan
during FY 1979 and I960. Regional Office staffs will
be asked to participate substantially in the work
groups assigned to these tasks.  The program offices,
working with 0PM, must develop a process for integrating
national program guidance which will be utilized by
Regions in negotiating integrated program plans under
the Act.

     Regional Administrators should carefully review
current grant operations to identify those changes
which will be necessary to implement the Integrated
Environmental Assistance Act. Regions should build
on the Regional Grants Management Task Force report
to ensure  Regional grant organization and functions
are shaped in a way best suited to accommodate and
achieve integration of our State and local assistance
programs.  Regional Administrators should accord
similar high priority to the Administrator's commit-
ment to having State/EPA agreements in place for
all programs by end of FY 1980.

     Strengthening Budget Execution  — The fifth
area of critical importance to Resources Management
is budget execution.  The top budget execution priority
for Headquarters and the Regions is strengthening
it by improving the requirements for justification
of changes, coordinating offices which are affected
by the changes, and integrating financial data with
the program accountability data.

     In addition, ORN will upgrade the object class
analysis, build it into budget development, and develop
the capacity to display all budget figures according
to authorizing category.  Throughout the process
we will strive to continue to improve our working
relationships with the various Congressional committees,
the Regions, and other Headquarters offices. Mid-year
and quarterly reviews should be stressed as highly
useful management tools.

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                      - 448 -
     In addition to the five areas of highest priority,
there are a number of other priorities in Resources
Management:

     o  Analyzing the resource implications of State/
        local delegations.

     o  Analyzing cross-cutting issues.  We must
        continue to examine the resource implications.

     o  Auditing resource use.  The quality of our
        decisions on pricing and resource allocation
        depends as much on the accuracy of the
        Agency's accounting of how it is presently
        using resources as on the relative priority
        of activities.

     o  Initiating operating efficiencies in financial
        management. Because financial management throughout
        the Agency is largely tied down by day-to-day
        operational workloads, we must find new ways—through
        automation, better use of personnel resources,
        and greater involvement of program offices—to
        reduce paperwork. Financial managers must find
        ways to divert more of their resources to support
        the larger analytical efforts in both Regional
        and Headquarters offices. Our financial resources
        can be better used in cash management, financial
        analysis, cost benefit and productivity analysis,
        and financial information assistance to program
        managers and grantees.

     o  Improving financial systems support for both
        analytical and accountability purposes.  Vve
        will improve the integration of financial and
        accounting systems to link planning, budget
        control, resource utilization, and performance
        review during both FY I960 and BY 1981.

     o  Undertaking a major effort to involve both
        programs and Regional management offices in
        the development of obligation and outlay
        plans and projections, particularly in
        construction grants.

     Region-Specific Guidance — In summary, the
highest priorities for the Regions' traditional resource
management activities will be as follows:

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                      - 449 -
     o  improving development of the operating
        plan;

     o  implementing the Full Time Equivalent
        requirement;

     o  participating in the Regional workload
        analysis;

     o  improving budget execution capacity and the
        Regions' abilities to justify changes in their
        plans;

     o  implementing a Regional and State account-
        ability system with reporting requirements
        and interfaces to financial information;

     o  participating in the revision of Headquarters
        workload and pricing analysis;

     o  implementing the Integrated Environmental
        Assistance Act;

     o  participating in an Agencywide review of
        grant procedures;

     o  cooperating with Headquarters in efforts
        to upgrade the management of construction
        grant outlays;

     o  selectively participating in analyses of the
        following budget issues:

        - grants/delegation

        - cross-cutting issues

        - Agency Ranking Committee issues

        - media issues;

     o  improving operating efficiencies in
        financial management.

Planning, Evaluation and Analysis

     The primary objective of Planning, Evaluation,
and Analysis is to provide strong, independent analytic

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                        - 450 -
and evaluative support to the Agency top management,
enabling them to manage the Agency's programs and
make decisions which will maximize progress towards
the Agency's environmental objectives.  The highest
priorities for FY 1980/81 will be —

     o  improving the planning/guidance process
        so that it is a more useful management
        tool;

     o  helping the Agency implement regulatory
        reforms which improve the effectiveness and
        reduce unnecessary costs of EPA's programs;

     o  strengthening the Regional Administrators'
        management/analytic capacity;

     o  helping improve program effectiveness through
        performance-based evaluations;

     o  supporting the analytic and project manage-
        ment needs of the Administrator and Deputy
        Administrator;

     o  helping program offices improve the quality
        of regulations developed by EPA;

     o  providing leadership for Agency analytical
        work in economic, energy, and statistical
        analysis to improve Agency decisions, defend
        the Agency's program, and protect environmental
        interests involved in other agencies' actions.

     Headquarters Specific Guidance — The key
elements for the Office of Planning and Evaluation at
Headquarters for FY 1980/81 are as follows:

     o  Manage and improve the process for develop-
        ment of practical, defensible regulations
        consistent with Administration policy and
        legal requirements:

        - improve working group effectiveness;

        - increase Regional involvement in regulation
          development;

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                  - 451 -
   - provide more timely information to top
     management on status of and issues in
     regulations under development;

   - increase public awareness of and parti-
     cipation in regulation development;

   - strengthen the linkages between regulation
     development and the budget to help ensure
     that the resource implications of new
     regulations are adequately addressed.

o  Improve analytic tools to assist top
   management regulatory decisions (the
   demonstration of the benefits of environ-
   mental regulation will be of the highest
   priority):

   - demonstrate the use of benefits
     assessment in standard-setting through
     several pilot tests each year;

   - show how risk assessment and exposure
     data can be incorporated in the setting
     of regulatory priorities and standards;

   - use marginal cost information to regulate
     more efficiently and provide useful
     perspectives in the absence of information
     on benefits.

o  Review (and assist in developing and improving)
   proposed regulatory and legislative action
   from a policy standpoint, focusing on technical
   feasibility, economic impact, energy impact,
   statistical validity, justification, implement-
   ability, impact on other programs, consistency
   with Agency goals, strategy and policies.

o  Provide project management or consulting
   services on high priority, policy-oriented
   analyses at the request of the Administrator
   or Deputy Administrator.  Respond to requests
   quickly and effectively with analysis,
   diagnosis, recommendations and implementation
   of change.  Train staff to develop project
   management skills.

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                  - 452 -
o  Manage (in conjunction with the Office of
   Resources Management) the planning process
   and make it a more useful management tool:

   - increase direct role of top management
     in priority-setting and planning;

   - reduce paperwork involved in the guidance;

   - tie guidance to evaluation of performance
     against plans;

   - improve scheduling to allow for timely
     review and comment by tne State and local
     governments and the Regional offices.

o  Coordinate implementation of the regulatory
   reform program, including improvements in both
   regulation and budget development and approaches
   to specific environmental problems:

   - coordinate Agency efforts to test,
     evaluate, and implement better environ-
     mental protection at the same or lesser
     cost;

   - serve as a catalyst for development of
     more reform proposals;

   - give highest priority emphasis to
     controlled trading initiatives (e.g.,
     marketable permits, offsets, banking) to
     examine whether more broadly applicable
     approaches would be desirable.

o  Improve program effectiveness through
   performance-based evaluations:

   - conduct 3 to 5 major evaluations each fiscal
     year, with special emphasis on Federal/
     State/local roles during FY 1980/81;

   - develop guidelines for self-evaluation
     by programs and Regions?

   - move Regional profiles from the pilot
     stage to routine use as a tool for
     assessing and improving performance,
     if warranted.                                             *

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                       - 453 -
     o  Help the Regions build their analytic
        capability to support Regional Administrator
        decision makings

        - help recruit staff and introduce them
          to available sources of assistance;

        - help develop analytic agendas for
          the Regional Management/Analytic Centers;

        - work cooperatively on selected projects.

     Region-_Sp_ecific Guidance -- Because most, of
the environmental management resources are located in
State and local governments, and because environmental
program management is rapidly becoming more complex
and interrelated, it is essential that the Regional
Administrators improve their staffs' capabilities
in the areas of planning, evaluation, and analysis.
In FY 1980 at least three regions will have Regional
Management/Analytic Centers serving as pilot studies
of how project-oriented analytic groups can assist
the Regional Administrators in managing and solving
environmental problems. If the pilot Centers are
successful, Centers should be added for most, if
not ell the Regions in FY 1981.

     Tne h i gj) e s t g• r jL o r it i_ea for the Regions' traditional
planning, evaluation, and analysis activities will
be —

     o  coordinating Regional input to the Agency's
        guidance, budget, and operating plans;

     o  providing the Regional Administrators with
        progiam evaluations which assess Regional
        performance in solving environmental problems
        and advise how to improve it;

     o  performing economic analysis for Regional
        management;

     o  ensuring productive Regional involvement
        in regulation development.

Fey Regional activities for both years will include
the following:

-------
                      - 454 -
     o  working with Headquarters and Regional
        program staff on all aspects of the guidance
        and budget development;

     o  developing Regional operating plans;

     o  evaluating Regional performance in solving
        environmental problems (perhaps with
        Regional profiles as inputs) and recommending
        changes in policy, organization, resource
        allocation, or management approaches to
        improve performance;

     o  performing economic and financial analysis
        required for all significant reaulatory
        actions, EIS's, and noncompliance penalty
        calculations;

     o  advising the Regional Administrator of
        economic impacts of individual and aggregate
        Regional actions (e.g., plant closings from
        enforcement actions; combined impacts on
        economically vulnerable industries);

     o  managing the Early Earning System
        responsibilities, including new efforts
        to avoid specific economic dislocations
        by making SBA/EDA/DOL assistance proqrams
        work better;

     o  reviewing economic and population growth
        projections;

     o  analyzing energy-related Regional issue?
        and participating in the EPA Energy Policy
        Committee through Region VIII representation;

     o  ensuring full participation by the Regions
        in Headquarters regulation development;

     o  hiring and developing analytic staff.

     Most Regions will have to markedly upgrade
their capabilities for program evaluation and
economic analysis, and both headauarters and the
Regions will have to improve efforts to work together
on regulation development.

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                       - 455 -
     Those Regions with Management/Analytic Centers
will have these additional activities:

     o  recruiting staff (FY 79/80);

     o  developing work plans cooperatively with 0PM
        and other Regions, including projects that:

        - enable RA's to manage integrated State
          environmental programs;

        - undertake demonstrations of new processes
          and reforms (e.g., consolidated permitting);

        - demonstrate analysis, solution design, and
          implementation for complex problems affecting
          several Regions (e.g., urban transportation-
          related nonattainment problems);

        - develop strategies for dealing with problem
          industries and Regions (e.g., steel in
          Region V).

     o  initiating projects to assist RA's in
        management of high priority, complex issues.

Agency Support Services

     Priorities for Agency Support in FY 1980/81
will include:

     0  Facilities Management

        - Continuing the program to identify anu
          correct health, safety,  and environmental
          deficiencies in EPA facilities in both
          Headquarters and the Regions;

        - Seeking increased EPA autonomy in space
          management;

        - Upgrading agency space planning capabilities
          to prevent the traditional "lag" between
          increased personnel and increased space.

     o  Automatic Data Processing

        - Continuing, as the highest priority, to
          provide the basic computer service now

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                 - 456 -
     represented by the Washington Computer and
     National Computer Centers;

   - Moving the Agency from its current posture
     of widely separate and sometimes duplicative
     and unsatisfactory data systems to an environ-
     ment where systems dealing with similar Agency
     programs, sets of data, or regulated industries
     can be integrated;

   - Completing the first two of four steps in
     the procurement of a data center(s) to replace
     the current system in the 1984-94 time period
     (OMB A-109 process — RFP release in FY 1980,
     contract initiation in FY 1981);

   - Improving the quality of the Agency's data flow
     from sources to the Regions and Headquarters,
     using minicomputers where appropriate.

   Regional offices will be affected by changes in
   central data center support and should participate  in
   acquisition strategy, evaluation and review panels.
   Regions will face some workload increases during
   conversion between interim data centers.  Program
   integration efforts should provide significant
   benefits to the Regions.  As a result, Regional
   offices may wish to examine their own internal ADP
   support activities to determine how best to take
   advantage of the integration and new data which
   will become more readily available.

o  Libraries

   EPA libraries in both Regions and Headquarters
   exist to ensure the availability of information
   in meeting the Agency's goals.  Priority activities
   will include:

   - Providing specialized information to satisfy
     the Agency's peculiar needs, especially
     when the information is not readily available
     elsewhere;

   - Providing assistance to EPA staff, State
     and local government staff and the general
     public in locating and utilizing information
     necessary to support EPA's goals.

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                       - 457 -
     o  Management and Organization Analysis

        - Developing increased capacity to meet the
          growing demand from program offices for
          assistance in developing and implementing
          the processes and organizational structures
          required for effective inter-and intra-media
          integration of program policy.

Occupational Health and Safety

     The priority objective is to continue leadership
of an effective, decentralized occupational health
and safety program by assisting Regions in program and
resource development and through technical support.  The
principal elements of this objective are as follows:

     o  Expanding health and safety training, emphasizing
        skill development of collateral duty personnel;

     o  Developing and promoting mandatory training
        programs for supervisors, employee representatives,
        and safety committee members;

     o  Providing program audit and consultant services,
        as a high priority item, to ensure effective
        and timely response to needs;

     o  Ensuring participation by Regions in regulation
        and guidance development activities;

     o  Reviewing OSHA policies, standards, and procedures
        and advising Regions of potential impact and
        compliance needs;

     o  Expanding capability to accommodate OSHA require-
        ments by using an automated management information
        system.

     Regional priorities will be planning, implementa-
tion, and evaluation of the health and safety program.
The Office of Research and Development, Regional
Offices, and national program offices should budget
for periodic physicals for designated employees.

Legal Services

     Assuming that in FY 1980 and 1981 there will be
no major changes in our statutes, that regulatory

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                       - 458 -
activities under our current statutes will continue
to increase as implementing rules are issued and
new permit programs begin, that most of the significant
regulatory activities will be challenged in court,
and that government regulation itself will continue
to be a major public policy issue, the following
are the priorities for Legal Services:

     °  Litigation — Defensive litigation is not
        an activity we can choose to conduct. Once
        sued, we must at least do what the courts
        regard as an adequate job. Otherwise, we
        risk both our reputation with the courts
        and disruption to Agency programs from avoid-
        able defeats.  Therefore, litigation must
        be our first legal service priority.

     o  Advising on Regulatory Actions — Early legal
        advice on regulations will make them better
        and easier to defend.  Ideally, OGC should
        be drafting at least portions of the preamble
        for major regulations.  However, because
        other offices in the Agency can pick up some
        of the slack we might leave in this area
        (which is not true for litigation), legal
        review drafting of regulations is second
        priority.

     o  Regulatory Reform — EPA is under tremendous
        pressure to justify itself in terms of "regulatory
        reform," and the Administrator has made this
        a top priority.  Searching for innovations,
        however, must be secondary to ensuring that
        the actions which the Agency is going to
        take anyway are legally defensible and -.re
        defended.  For that reason, and although
        it remains a priority activity, regulatory
        reform is third priority when scarce resources
        are being distributed.

Headquarters Staff Offices

     EPA's Staff Offices perform a number of
essential functions as well as a central integrating
role.  A study is now under way to evaluate the
functions and present structure of the Staff
Offices.  The study may result in changes during

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                       - 459 -
FY 1979.  For purposes of this Guidance, assume
that the present functions performed by the Staff
Offices will continue in FY 1980 and 1981. Discussion
of alternatives for these offices will be reserved
until completion of the study.

     The activities covered by this portion of
the Guidance are carried out by the following
offices:

     o  Civil Rights

     o  Inspector General

     o  Legislation

     o  Public Awareness

     o  Federal Activities

     o  Regional and Intergovernmental Operations

     o  International Activities

     o  Immediate Office (Administrator-Deputy)

         - Administrative Law Judge

         - Science Advisory Board

         - Land Use Coordination

     Because of the close relationship between
these offices and the Administrator and Deputy,
many of the activities of these offices are
flexible and are readily adjusted to meet
changing priorities.

     In addition to the priorities set out explicitly
in the following paragraphs, we will continue
to give high priority attention to urban policy
efforts. The Immediate Office of the Administrator/
Deputy Administrator will continue to provide
leadership for the Urban Work Group. The Regional
and program offices should continue to provide
staff support and initiatives. Program offices
should continue to identify regulations and legis-
lative and budget initiatives with potentially

-------
                         -  460  -
signficant urban impacts and to conduct urban
and community impact analyses on those initiatives,
preferably as an integral part of other required
impact analyses.

     Office of Civil Rights — The Office of
Civil Rights (OCR)  oversees the implementation
of affirmative action plans and will work closely
with Personnel Management Division on programs
to increase the number of women and minorities
in under-represented occupational groups. OCR
investigates and oversees processing discrimination
complaints in Headquarters, Regional offices,
and laboratories and has assumed jurisdiction over
all processing in five Regional Offices.  OCR
manages programs designed to assist small,
disadvantaged, and minority-owned businesses
in providing indirect procurement services to
EPA; directs, monitors, and reviews implementation
of Minority Business Enterprise policy under
the construction grant-in-aid program; monitors
other nondiscrimination compliance programs
involving Agency assistance; and provides
liaison with external civil rights groups.

     In FY 1981, responsibility for processing
discrimination complaints should be shifted back
to the five Regional Offices for which OCR assumed
jurisdiction. Initial implementation of the
new MBE program will be resource intensive; an
increase of 0.7 FTE workyears in FY 1980 at
Headquarters will enable this office to provide
the support and oversight required to implement
this Presidential initiative.

     Inspector General — The Office of the
Inspector General, which will be created in
FY 1979 by combining the Office of Audit with the
investigations resources of the Security and
Inspection Division, will be undergoing a complete
evaluation of its functions and resources in
FY 1979 and 1980. It will be responsible for
implementing, for EPA, the Inspector General
Act of 1978, P.L. 95-452.

     The Office will undergo a thorough evaluation
of its goals and priorities after the Inspector                ^

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                      - 461  -
General is appointed.  The priority emphasis will
continue to be the Construction Grants program.
'we will complete the initial implementation of
changes to the Audit Management System (Audit
Resolution Board and computer tracking of audit
findings) in late FY 1979 and early 1960.  The
Office of Audit should continue its successful
emphasis on the use of contract auditors to
supplement the EPA Audit personnel.

     Office of Legislation —  The Agency will
continue to need a central capacity through which
to initiate and coordinate communications and
interaction with Congress. The functions provided
include daily liaison with key Congressional
members, committees, and staff to gather information,
convey and advocate agency positions, and brief
members on items of interest; preparation of
testimony and briefing materials for Congressional
hearings; development and negotiation of legisla-
tive changes; review and comment on introduced
legislation; and direct services such as response
to personal and telephoned Congressional inquiries
and Congressional mail and notification of grant
awards. In addition OL distributes Congressional
documents, provides summaries of pertinent
Congressional Record and Federal Register entries,
and compileshearings schedulesand reports for
use throughout the Agency.

     Legislative priorities  include passage of the
Integrated Environmental Assistance Act, legislation
to establish a comprehensive Hazardous Waste
Emergency and Liability Fund, and reauthorization
of all existing programs, including the Clean Water
Act.  OL expects Congressional oversight of the
Clean Air Act following the  Report of the Air Quality
Commission and revision of the SIPs.  Continued
strong Congressional interest in the effects of
EPA regulations on inflation and as a constraint
on energy development will necessitate an increase
in office liaison activities, preparation of
hearings, and efforts to head off undesirable
legislation.  Case work and  liaison with Regional
Administrators and their Congressional and out-
reach staffs will have to expand to deal with
concerns of members of Congress and their con-
stituents as the State-EPA Agreements are effected

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                       - 462 -
and new programs are implemented pursuant to the
recent revisions to the CAA, CWA, and FIFRA.

     Office of Public Awareness — The Immediate
Office of the Administrator and the Office of
Public Awareness are jointly developing an Agency-wide
public participation policy during FY 1979 and
are providing guidance to the programs and Regions
for the development of their public participation
plans and priorities.  They will also provide
direction for implementation training, development
of evaluation criteria and incentives to strengthen
public participation in all programs.

     The Office of Public Awareness priorities,
in order of importance are to --

     o  Develop public information materials
        in support of EPA program operations.
        Public information/participation plans,
        with their elements prioritized, are
        prepared by OPA in coordination with
        the programs and are revised annually.

     o  Perform outreach activities to increase
        constituent understanding of the EPA
        mission and programs, and EPA apprecia-
        tion for the concerns of its diverse
        constituencies.

     o  Promote public awareness of EPA activities
        through electronic and print media.

     o  Provide resources to, and serve as coordinator
        between OPA headquarters, OPA Regional staffs
        and State Public Information Officers in support
        of program information and participation
        activities.

     Greater commitment to these goals by program
offices will be required in FY 1980/81 to offset
the FY 1980 reduction in central resources.

     Office of Federal Activities —  The Office of
Federal Activities has four major goals and priorities
(in rank order):

-------
                      - 463 -
     o  Oversee the development (including relevant
        research) and presentation (including
        negotiations with the senior officials in
        other agencies) of the EPA position on all
        proposed major Federal actions likely to
        have significant impacts on the human
        environment.

     o  Provide information, and recommendations to
        the Administrator and Deputy Administrator
        through staff papers and briefings concerning —

        - EPA's compliance with NLPA (including
          development of appropriate guidance
          documents and regulations) and related
          statutes, executive orders, and policy
          statements (e.g., wetlands, endangered
          species and prime farmlands);

        - the environmental impact of the programs
          and activities of other Federal agencies.

     o  As National Program Manager, exercise quality
        control over and develop programs to improve the
        performance of the EIS Review and EIS Preparation
        Programs and staff in EPA's program and Regional
        offices.

     o  Participate on EPA working groups and interagency
        task forces on matters relating to OFA management
        programs.

     Office of  Regional and Intergovernmental Operations —
The office provides a Headquarters secretariat for the
Regions and coordinates and assures Regional participation
and representation in the Agency's policy and regulation
development and evaluation processes.  The office also
serves as Agency liaison with national organizations
representing general purpose State and local governments
such as the National Governors' Association and the U.S.
Conference of Mayors.  The ORIO staff maintains
continuing contact with these organizations to ensure
their understanding of, gain their support for, and
provide interpretation of their views on EPA objectives
and policies.  ORIO is expected to concentrate on these
objectives:

     o  Strengthening the communications linking the
        Administrator, Deputy Administrator, staff and

-------
                      - 464 -
        program offices with EPA's ten Regional
        Administrators and their staffs;

     o  Continuing to assist in improving the effective-
        ness of the participation and representation of
        the .Regional Administrators in EPA's policy
        and management processes;

     o  Supporting the Administrator's/Deputy Adminis-
        trator's efforts to strengthen the Federal/State/
        local partnership with particular emphasis
        on State/EPA agreement activities in the
        Regional Offices and passage and implemen-
        tation of an Integrated Environmental
        Assistance Act.

     Office of International Activities — The Agency
has these specific international objectives for
1980-81 (in priority order):

     o  Provide leadership, especially to the
        industrialized countries, in establishing
        effective environmental control of toxic
        substances and hazardous and radioactive
        waste and work toward harmonization
        of regulatory actions in these and other
        environmental areas;

     o   Extend our efforts with Canada and Mexico
         to solve the most pressing pollution
         problems threatening both sides of the
         borders;

     o   Expand and improve the exchange of
         state-of-the-art technology with German^,
         Japan, and other countries most advanced
         in environmental protection;

     o   Enlarge and improve EPA's cooperation with
         developing countries to enable them to
         address their environmental problems more
         effectively, working directly with a few
         selected foreign countries and through the UN;

     o   Continue to support productive programs
         with the USSR, NATO's Committee on the
         Challenges of Modern Society, and various

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                       - 465 -
         Countries through the Scientific Activities
         Overseas program;

     o   Develop environmental cooperation with
         the People's Republic of China;

     o   Continue to press for adequate
         environmental standards in all marine
         negotiations, including Law of the
         Sea, the Ocean Dumping Convention and
         the Intergovernmental Maritime
         Consultative Organization;

     o   Continue to coordinate the Agency's
         participation in the environmental aspects
         of the Nuclear Nonproliferation Act.

     The Office of International Activities coordi-
nates the achievement of these Agency objectives and
represents the Agency in a variety of international
forums. A reduction in resources in FY 1980 will put
a larger burden of coordination on the program
offices and will decrease the amount of support
available in international efforts.

     Immediate Office of the Administrator and
Deputy — In addition to personal staff assistance,
the immediate office contains the offices of
the Science Advisor and the Administrative Law
Judge. Increased resources in the Science Advisor's
Office will make possible better coordination and
preparation of information for the Administrator's
regulatory decisions.  The mission of the Office
of Land Use Coordination is to ensure that the Agency's
programs contribute to planning integration and sound
land use planning.  In particular, the office will
work to ensure that adverse effects of growth and
land use in urban areas and environmentally sensitive
areas are minimized through program assistance and by
continuing to help provide staff support to the
EPA Urban "Work Group.

     The Administrative Law Judges should expect an
increased workload as a result of the civil penalties
requirements under the Toxic Substances Control
Act, Section 120 of the Clean Air Act and the Solid
Waste Disposal Act.  In addition, amendment of the

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                      - 466 -
FIFRA rules of practice will require cases to go
to the ALJ at an earlier stage, resulting in additional
cases.  An increase in resources for FY 1980/61 ir.ay
be necessary to handle these increased requirements.

Regional Policy Direction

     This Decision Unit brings together the key                     *•
elements in the Regional office which enable the
exercise of internal leadership to achieve program
unity and more effective use of resources, and the
exercise of external leadership to achieve a fuller
understanding of the Agency's goals and purposes and
a fuller degree of Federal-State-local cooperation.

     Specifically, energies will need to be focused
on:

     o   Providing integrative leadership and cross-
         media insight and understanding of Regional
         and national programs.

     o   Working with State and local officials to                 ™
         achieve more effective, coordinated and
         integrated efforts to solve environmental
         problems and decrease or eliminate environmental
         pollution. Implementing effective State/EPA
         agreements.

     o   Maintaining contact with local Congressional
         staffs to be responsive to their concerns
         and to achieve a fuller understanding of
         the Agency's goals.

     o   Providing information to the press and other
         media implementing programs to assist the
         public to better understand the purposes
         and goals of the EPA, and ensuring that
         public concerns are identified and under-
         stood with the Regional Offices.

     o   Improving public participation in Agency
         decision-making.

     o   Emphasizing EEC programs to ensure more
         effective participation.

     o   Refining and upgrading analytical capacity                4
         to achieve more effective participation in

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                      - 467 -
         ZBB, regulatory development and reform and
         other management strengthening processes.

     o   Identifying and implementing changes needed
         to achieve more effective use of resources.

     o   Ensuring implementation of the Civil Service
         Reform Act.

     o   Ensuring implementation of the Integrated
         Environmental Assistance Act upon its
         passage .

Program Management

     The primary objective of program management
is to provide management and support to the
programs, to enable them to better accomplish their
objectives.  The program management element of each
Assistant Administrator's office plays a key role
in the integration of Agency programs, Regional
coordination, and the accomplishment of key planning,
budgeting and other management processes.  It is
essential that these offices develop and maintain
a strong capacity to fulfill these roles.

     The main priorities for the Office of Toxic
Substances during B* 1980 and FY 19bl are to:
     o   Achieve institutional maturation with
         a stable organization and technically
         and managerially Qualified staff;

     o   Operate a detailed planning and evaluation
         system for toxic substances and pesticide
         programs ;

     o   Develop, in cooperation with the R&D
         community, a high priority research program;

     o   Examine the need for major legislative
         changes to the Toxic Substances Control
         Act in 1981, and develop and support
         such changes, if appropriate.

     In addition to its continuing management role,
the Office of Enforcement will give priority
attention to the following activities:

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                      - 468 -
     o   Coordinating the Office of Enforcement's
         compliance efforts with respect to Federal                 ';
         facilities, including the development of
         policies, guidance, and procedures to ensure
         full compliance;                                           A

     o   Reviewing EPA litigation prior to transmittal
         to the Department of Justice;

     o   Expanding the coordination and planning role
         to include implementation of a multi-media
         docket and status-tracking system, legal
         strategy development and development of a
         national training program tor legal/
         enforcement personnel;

     o   Developing multi-media industry enforcement
         strategies for various industries;

     o   Reviewing methods, strategies and techniques              *
         and Federal/State/local roles in ensuring
         continuous compliance;

     o   Improving and extending cooperative enforcement
         with other Federal agencies;

     o   Developing, in cooperation with the Regions,
         effective workload models for distributing
         resources in both Regions and Headquarters.

     The highest priorities tor the Office of Air, Noise
and Radiation will be:

     o   Strengthening capability to coordinate
         Headquarters and Regional planning;

     o   Extending program capacity to manage the
         implementation of new personnel requirements.

     The major priorities for the Office of Planning and
Management will be:

     o   Developing and implementing a variety of
         management reforms to enable both the
         Office of Planning and Management and                     4
         the Agency to do a better job;                            ™

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              - 469 -
Significantly improving cooperative
relationships with the Regions, especially
with the Management Divisions;

Developing, in cooperation with the Regions,
a good set of management media workload models
for resource allocation purposes;

Implementing centralized budgeting and
management information and tracking systems
within the Office of Planning and Management;
Completing the staffing of the office with
         m


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                        - 470 -
for the scope of GWWM responsibilities.  The staff
generates new policy initiatives and program
implementation strategies.  It performs a coor-
dinating and synthesizing role among OWWM's several
programs and between OWVv'M, the other program offices
of the Agency and with the Regions.  Major areas
of staff concentration in OWWM are:

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                       - 469 -,
     o   Significantly improving cooperative
         relationships with the Regions, especially
         with the Management Divisions;

     o   Developing, in cooperation with the Regions,
         a good set of management media workload models
         for resource allocation purposes;

     o   Implementing centralized budgeting and
         management information and tracking systems
         within the Office of Planning and Management;

     o   Completing the staffing of the office with
         highly competent, qualified people capable
         of undertaking a wide variety of management
         tasks.

     Beyond its continuing responsibilities for
managing the program, the main focus for the Office
of Research and Development will be:

     o  Expanding the research committee system
        to encompass nearly all of the R&D
        program;

     o  Improving the responsiveness of the
        Research Program to the needs of the
        Enforcement Program and the Regions;

     o  Refining the system used to award and
        monitor grants and cooperative agreements;

     o  Improving the ability of management to
        handle new programs and changes in
        organizational structure;

     o  Strengthening the management, collection
        and dissemination of technical information
        and scientific data.

     The Assistant Administrator's Office for Water and
Waste Management will continue to  strengthen its
capabilities to provide staff support to the Assistant
Administrator in his day-to-day responsibilities  to
implement and administer  the water and waste manage-
ment statutes.   Additionally, the  staff performs a
function of program analysis planning and development

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                        - 470 -
for the scope of OWWM responsibilities.  The staff
generates new policy initiatives and program
implementation strategies.  It performs a coor-
dinating and synthesizing role among OWWM's several
programs and between OWWM, the other program offices
of the Agency and with the Regions.  Major areas
of staff concentration in OWWM are:

     o  Program planning, budget and financial
        management;

     o  Coordination and review of standards and
        regulation development;

     o  Review and t'espond to Agency management
        initiatives} and

     o  Policy an-d strategy development an^
        assessment.

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