United States       Region 5          December 1983
EPA //
This document records the significant accomplishments of the Region V
Waste Management Division during Fiscal Year 1983 and presents the
major objectives established for the Division in Fiscal  Year 1984.
This report is dedicated to all the Waste Management Division staff
whose efforts in Fiscal Year 1983 resulted in this impressive record
of achievement and whose continued diligence will bring  another
successful year in protecting the environment and the public health.
                                             David Stringham
                                             Deputy Director

United States Environmental Protection Agency
                  Region  V
         Waste Management Division
              Fiscal  Year 1983
               Annual  Report
               December, 1983
          Chicago,  Illinois 60604

                            Table  of Contents

  I.   Introduction                                                       1

 II.   Review of Programs                                                 2

      -   RCRA                                                           2
      -   TSCA                                                           9
      -   FIFRA                                                         15
      -   CERCLA                                                        17
      -   Multi-media Initiatives                                        22

III.   People and Spaces                                                24

      -   Staff                                                         24
      -   Space                                                         24
      -   Affirmative Action                                            25

 IV.   1984 Goals and Priorities                                         26

      -   RCRA                                                          27
      -   TSCA                                                          28
      -   FIFRA                                                         29
      -   CERCLA                                                        29
      -   Multi-media                                                   30
      -   Management, Personnel, Administrative                         31

  V.   Conclusion                                                       32

I.   Introduction

    The year 1983, the first full  fiscal  year for the Region  V  Waste
    Management Division,  proved to be a highly successful  period  of
    accomplishment despite an extraordinary sequence  of sometimes
    disruptive challenges.  The rapidly evolving  nature of the  RCRA and
    CERCLA programs and the emerging strains on the TSCA and  FIFRA programs
    combined with the intense national  attention  focused on EPA's
    implementation of these laws,  provided a severe test of the Division's
    ability to effectively implement these programs in the Region.  The
    Division's involvement with Congressional  staff investigating various
    allegations ranged from personal interviews and testimony,  to extensive
    file evaluations relative to our past dioxin  activities,  as well  as
    the CERCLA and RCRA programs.   Throughout the year, however,  regard-
    less of intensive news media scrutiny, GAO investigations,  and IG
    audits, all of which  consumed  a great deal of our time, the Waste
    Management Division kept a steady path toward environmental protection.
    The negative impacts  of the Agency's  national  problems, which severely
    affected the Division's ability to  move forward with positive environ-
    mental  solutions, included deep citizen mistrust, pervasive emotional
    reaction to hazardous waste and toxic materials issues, as  well as
    Congressional involvement in nearly every action  we undertook.  In
    addition during the year, the  Division had to confront the  gritty
    practical  realities of an organizational  move from one building to
    another, serious space constraints, and hiring restrictions.   Despite

     various  obstacles,  which  ranged  from  the  impacts of  significant shifts
     in  national  policy  direction  to  the persistent presence  of a  range of
     administrative  impediments, the  Waste Management Division established
     an  impressive record  of accomplishment  in FY  1983.

     The accomplishments of the Waste Management Division during the year
     included not only activities  and positive results anticipated in our
     basic  work  plans, but also included other significant efforts such as
     managing the Region's dioxin  initiative,  directing the work of the
     Great  Lakes  Water Quality Board's Toxic Substances Committee,  and
     providing health effects  technical guidance.  These  activities entailed
     a work load  extending well beyond our initial estimates.  To  meet our
     planned  output  commitments for the year while accommodating unplanned
     demands  required the  Division's  managers  at all levels to make decisions
     on  a continuing basis toward  effectively  balancing various competing
     interests,  changing priorities,  and handling  crises. It also required an
     extra  degree of effort from our  staff at  all  levels  throughout the
     year.   The  following  report of the Division's operations and  activities
     in  FY  1983  is a testament to  the many Waste Management Division staff
     who, through dedication to the Agency's ideals, and  a lot of  consistent
     hard work,  achieved so much under very  difficult conditions.

II.  Review of Programs
     The Region's Resource Conservation and  Recovery Act  program,  for which

the Waste Management Branch (WMB) is responsible,  is designed to regulate
hazardous waste management throughout the six-state area.   The primary
areas of activity in the RCRA program include state authorization,
permitting hazardous waste treatment, storage,  and disposal  facilities,
and enforcement of RCRA's regulatory requirements.  The Division
worked closely with the Office of Regional  Counsel in each of these
major phases of the program.  Significant accomplishments  were realized
in these areas of the program during the year.
                       State Authorization
State authorization is one of Region V's highest priorities.  If any
of the states authorized for Phase I is unable  to  meet the January  26,
1985, deadline, the Federal hazardous waste program for Phase I
activities will be reinstituted in that state.   Region V is  considering
various procedures or measures to be implemented to ensure a smooth
transition should this become necessary.  However, all states in
Region V are actively working toward receiving  final authorization,
and we are optimistic they will be able to  meet the January 26, 1985,

Four states in the Region have Phase I interim  authorization under
RCRA.  Ohio, the last state in the Region to receive interim
authorization, received a lot of attention  in the  authorization
process during the year since it submitted  its  Phase I application
January  7, 1983.  The state received Phase I authorization  on July 15,
1983.  The states of Illinois, Indiana, and Wisconsin received Phase I
interim authorization in FY 1982.

Since the next delegation step for each of our states, including
Michigan and Minnesota, is final  authorization of the entire RCRA
program, the program's major efforts were directed toward assuring
the greatest success of the states in the authorization process.  To
accomplish this, schedules with specific milestones were developed
with each state.  With none of the four interim authorized states
able to submit an application for Phase II interim authorization or
for final authorization by the July 26, 1983, regulatory deadline,
these states requested extensions past this date for submitting
applications for final authorization.  The Division prepared the
Regional Administrator's approvals of these requests, based on an
evaluation of the following criteria:  (1) reasons given by each
State for requesting an extension; (2) progress made to date toward
receiving final authorization; and (3) schedule for meeting the
January 26, 1985, final authorization deadline.  Notice of approval
was published in the July 27, 1983, Federal Register.

During FY 1983 the Region was the first to have all states receive
complete pre-application statutory reviews for final authorization.
By the end of the year, Michigan, Minnesota and Illinois had passed
statutory amendments needed for final authorization.  Indiana, Ohio
and Wisconsin each has hazardous waste legislation which differs from
RCRA in several areas.  These latter three states will have to rely
on their Attorney General Statement to explain how existing state
authority is fully equivalent to Federal law, or pass statutory

modifications sufficient to meeting this test for program equivalency.
Regulatory changes were adopted by Illinois, with all other states
drafting or scheduling adoption of regulations in FY 1984.  The
Division's efforts in developing state programs extended beyond just
legislative and regulatory reviews.  The Division provided testimony
in Indiana to help increase state resource capacity needed to qualify
for authorization.  We also worked with each state to pursue meeting
its grant conditions which clearly  show its capacity to effectively
initiate enforcement and issue permits.  Cooperative grant agreements
were negotiated with the objective of improving State capabilities,
while improving environmental and public health protection.  These
agreements not only provided specific objectives and outputs for
inspecting, enforcing, and permitting hazardous waste handlers, but
also provided support for improving state regulatory authority to
implement necessary controls.  ADP systems and QA/QC programs were
enhanced or developed using these funds and specific contractor
support was made available in each case to further the effectiveness
of these efforts.  All state outputs for inspections, enforcement,
and permitting exceeded past years' efforts, as enhancement of a
balanced state/Federal program continued under RCRA.  To improve
state program capability more rapidly, we improved the quality of
quarterly audits as well as the mid-year and end-of-year reports.
These various efforts should assure the earliest possible final
program authorization for each of our six states.

The RCRA permitting program was directed toward permitting new facilities
or existing facilities which were selected by Region V and the States
due to their environmental  significance (size, proximity to large
populations, compliance history, or other unique characteristics).
During the year, 182 storage/treaters, 24 incinerators, and 52 land
disposal Part B applications were requested by the Region.

The Division also received  25 voluntary Part B permit applications,
of which 16 were for new storage or treatment facilities, 5 incinerators,
and 4 proposed land disposal facilities.  In preparation for the 166
permit applications received during the year, Division personnel
conducted or directed formal training of state and Regional staff,  as  well
as holding individual discussions with applicants to assist in developing
permit applications of acceptable quality.  To date, we have completed
135 reviews of these applications, with the states providing the
major support for the effort.  Seventy-six of these applications are
completed.  In FY 1983, we  held 28 public hearings and issued 18 RCRA
permits.  The hearings were expanded where significant public concern
was noted to allow questions and answers in addition to the regulatorily
required "receipt of comment" format.  These efforts increased public
understanding of the permits, and the public's ability to comment
more effectively.

The 18 RCRA permits issued by Region V in FY 1983 accounted for 23
percent of the 80 RCRA permits issued by the Agency and authorized
states altogether.  Of the 43 permits issued directly by USEPA during
the year the Region's total accounted for 42 percent.  In addition,
three of the six incinerator permits issued nationally were issued
by Region V.  This will significantly increase the capacity in the
Region to safely destroy hazardous waste.

The states in Region V played an important role in the permitting
process even though the Region itself retained authority to make
final permit decisions.  The states provided considerable assistance
to the Region in carrying out RCRA permitting activities.  Grants
were awarded to the states in part to support this activity.   States
conducted completeness checks and technical reviews, and assisted
in the drafting of permits.  State involvement with the Region in
carrying out Federal permitting responsibilities provides for a
stronger, more experienced state program when it is finally authorized.

In summary, permitting activities over the past year were primarily
limited to storage and treatment facilities, though several
incineration-facility permit applications were processed.  Land
disposal facilities were also brought into the permitting program as
a result of the effective date of the land disposal regulations—January
26, 1983.  However, these types of facilities will be addressed in


greater depth over the next several  years, since the Region is  just
now beginning to receive permit applications for those facilities.


The RCRA enforcement program continued to expand in FY 1983,  with
the states exceeding their commitment of 2261 inspections and the
Region completing 100 inspections.  Clearly, the RCRA enforcement
program in the Region relies heavily on state participation.   These
combined state  and Federal inspections led to the issuance of more
than 1,000 warning letters from the states, and 110 warning letters
from the Region.  Many of these warning letters were issued for
violations which could have elicited the issuance of administrative
orders according to Agency guidance.  Due to the high noncompliance
rates, (groundwater monitoring 70%, financial assurance 60%,  and
other requirements from inspections 50%) the Region had to select
less resource-intensive enforcement responses, such as warning letters,
to deal with the many violators.  It is noteworthy, however,  that  warning
letters were highly successful in returning violators to compliance.
Warning letters resulted in a 70-80% effective rate in returning
violators to compliance.  In FY 1984, we will use more administrative
enforcement actions consistent with national guidance, since higher
staffing levels will be available for this more resource-intensive

During the year, higher levels of enforcement response were also
undertaken in the RCRA program.  The Region issued 19 Class I
administrative orders, many of which assessed penalties, and 54
Class II orders.  More than 600 facilities returned to compliance
during the year as a result of the Region's and states' use of
various enforcement actions.  In addition, the RCRA program initiated
24 criminal investigations, of which four should be brought to grand
juries in FY 1984.  The enforcement resources available in FY  1983
were inadequate to meet demands.  The increase in FY 1984 will allow
us to initiate additional  higher level actions more quickly.

State enforcement efforts were more carefully reviewed in FY 1983.
Notices of Violation were issued to Wisconsin regarding two
facilities against which Wisconsin had not initiated appropriate
enforcement.  In both cases, Wisconsin initiated actions within the
30 days allowed by our NOV's.  Besides reviewing state enforcement
efforts, we agreed with Illinois to issue Federal orders with  penalties
in cases where existing state regulations made penalties difficult.
We intend to initiate this process in Ohio, and have already issued
orders prepared by Michigan.
The Region's Toxic Substances Control Act program, for which the
Toxic Materials Branch (TMB) is primarily responsible, is designed to
secure compliance with regulations aimed at eliminating unreasonable
public health or environmental risks from the manufacture, use, or

disposal of toxic chemicals.   The major areas of activity in the
Region include an active inspections and enforcement program operated
out of 1MB, as well as an active PCB disposal and destruction approval
program, for which the Waste  Management Branch is the lead office.   The
Division worked in close coordination with the Office of Regional
Counsel  to implement a very productive TSCA program in the Region.


A total  of 405 inspections under TSCA were conducted in Region V
during FY 1983.  This total accounts for 18.2% of the 2,224 TSCA
inspections conducted nationally during the year.  These inspections
addressed a variety of regulatory requirements under the law.  From
this active inspectional effort came the most aggressive TSCA enforce-
ment effort of any Region.  During the year, the Division conducted 58
inspections designed to ensure that chemical manufacturers complied
with TSCA's premanufacturing notification (PMN) requirements.  These
inspections, which comprised over 46% of this type of inspection
under the national program, covered approximately 30% of all
companies in the United States that submitted PMNs in FY 1983.
Under Section 6 of TSCA are regulations aimed at the problems of
asbestos in schools.  During the year, the Division not only completed
83 school compliance inspections, a total well above our commitment

of 64, but also 3,000 information mailings were made to advise school
districts of their responsibilities.   The high degree of effectiveness
of our efforts, which were undertaken in close cooperation with the
State school agencies, is reflected in a 97 percent reporting rate
(22,715 schools out of a 23,300 total) for asbestos inspections.  Our
follow-up compliance inspections were aimed at schools where non-
compliance with the asbestos rule was known or suspected.  The Region's
total of 83 school inspections in 30  local school  districts comprised
over 40% of the Agency's national total  of 207 inspections.

Since the Section 6 PCB regulations went into effect in July 1979,
Region V has inspected about 950 facilities to ensure that the regulations
on use, storage, disposal, marking and recordkeeping are followed.
Nearly one-third of this total (302)  of PCB inspections occurred in
FY 1983.  We directed much of our PCB inspectional  effort toward key
geographic areas (Detroit, Green Bay, and northern Ohio) in support
of the Great Lakes areas of concern.   Only 50% of  the facilities
inspected in this part of the program were found to be in compliance.
Cooperative grant agreements with the states of Ohio and Michigan
to conduct PCB inspections under Federal authority, which cannot
be delegated to states under TSCA, significantly augmented the
efforts of the staff in the Region.  The 199 inspections completed
under these grants lead to the issuance of 37 notices of non-
compliance and 79 civil administrative complaints.

The Region's TSCA enforcement program in FY 1983 exceeded all
output commitments in terms of inspections completed and
enforcement actions taken.   Our enforcement actions accounted
for an impressive 41% of the national total of civil administrative
complaints.  In summary, 120 civil  administrative actions were
initiated, including the 79 actions associated with the Ohio and
Michigan cooperative inspectional efforts, 67 notices of non-
compliance were issued, one civil referral was made to the
Department of Justice, and one criminal indictment was entered
as a result of the Region's efforts.  The director of the Compliance
Monitoring Staff in the Office of Pesticides and Toxic Substances
commented in an October 1983 memorandum that "Region V stands
out among the ten regions for the strong TSCA enforcement
program last year."

                          State Programs
In addition to the extensive TSCA enforcement activities, PCB
spill response efforts, and a variety of health effects technical
assistance, the Region's TSCA staff continued to manage several
cooperative agreements under Section 28.  These projects conducted
through state health departments, as well as state environmental
agencies, have been aimed at a number of purposes.  In Wisconsin,
the state's Department of Health and Social Services completed a
study of the health effects associated with formaldehyde exposure
in mobile homes.  The  Illinois Department of Public Health's project,

which continues in FY 1984, was designed to establish an integrated
system for detecting, recording and investigating morbidity and
mortality from exposure to toxic substances in the environment.
Finally, in Michigan, the state's Department of Natural Resources
developed a system using a Section 28 grant for recording and tracking
the reports of facilities listed on Michigan's Critical Materials
Register.  At the end of FY 1983, Michigan, under another Section 28
grant, continued work on establishing interagency risk assessment
process involving the state's Departments of Natural Resources,
Agriculture, and Public Health.  It is readily apparent from this
summary that state toxic substances program development has received
significant support under TSCA.  In addition, the cooperative
enforcement agreements with Michigan and Ohio, mentioned earlier,
have achieved a high degree of success in forging a practical state/
Federal partnership to augment the non-delegable Federal TSCA enforce-
ment program.

                       PCB Disposal Program
The Toxic Substances Control Act requires that anyone who wishes to
dispose of or destroy PCBs must obtain the prior approval of the
Regional Administrator.  Also, prior to initiating research and
development activities associated with PCB "destruction, approval
must be obtained from the Regional  Administrator.  The Region, lead
by the Waste Management Branch, reviews each request for approval to


assure that a demonstration of the requestor's ability to comply with
the TSCA regulations has been provided.  When it is determined that
the requestor can comply, an approval is drafted that establishes
certain operating conditions.  The Office of Regional Counsel  reviews
each commerical approval for legal sufficiency and enforceability
prior to issuance.  If the requestor cannot or does not make a
satisfactory demonstration of his ability to comply, then approval
will not be granted.  TSCA does not require public participation in
the approval process; however, as a matter of policy, the Region does
conduct a public participation program for commercial incineration
and land disposal facilities.

The Region's PCB disposal/destruction approval program during FY 1983
resulted in 19 research and development approvals, 7 commercial
destruction facility approvals, and one industrial boiler use approval,
for a total of 27 approvals.  The most significant of our PCB destruction
approvals occurred at the very end of the fiscal year.

On September 26, 1983, Region V granted SCA Chemical Services, Inc.,
approval to commercially destroy PCB-contaminated materials at its Chicago
incinerator.  This is the third commercial incinerator approved in the
United States, and the first incinerator in the midwest.  There has
been a critical shortage of commercial destruction facilities for
high-concentration PCB materials.  This problem is compounded by the

regulatory requirement that all stored PCB's must be disposed of by
January 1, 1984.  The approval of the SCA incinerator by Region V
will provide additional disposal capacity to assist midwestern companies
in complying with the PCB disposal regulations.

The Region's pesticides program, for which the Toxic Materials Branch
is responsible, is designed to manage a broad state/Federal regulatory
enforcement program under the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA).  In this effort, the Division's staff work
closely with the Office of Regional Counsel.

The 1972 amendments to the Federal Insecticide, Fungicide and Rodenticide
Act (FIFRA) completely revised pesticide regulation, changing the
1947 FIFRA from essentially a labeling law to one providing full
control over manufacture, distribution, and use of pesticides.
Significant new enforcement roles for the Regional Office included
(1) registration and surveillance of the some 3200 pesticide
producing establishments located in the region; (20% of national
total) (2) surveillance and monitoring of the use of pesticides
by professional pest control operators, aerial applicators,
homeowners, industry officials, and farmers; (3) issuance of
immediate Stop Sale, Use, or Removal Orders when any pesticide
was found in violation of the 1972 FIFRA; and (4) issuance of
enforcement actions assessing monetary civil penalties for major
FIFRA violations.  Since 1972, Regional Pesticides Section
personnel have conducted over 2,100 site inspections, collected


over 6,400 pesticide samples, and performed over 600 use
investigations.  These activities have resulted in approximately
420 civil penalty actions, 65 criminal actions, 1400 warning letters,
and 310 stop sale orders.  The incidence of major violations has
materially decreased since 1972.

During FY 1983, Federal inspections and enforcement under FIFRA
increased significantly over the  year prior and exceeded our workplan
commitments.  The Regional staff  completed over 350 inspections,
while the states under cooperative agreement performed 1,637 use
inspections, 216 producer establishment inspections, and 1,345 market-
place inspections.  Of the 350 inspections conducted by the Regional
program staff, 167 were at producing establishments, 54 were market-
place inspections, 111 were targeted at planned pesticide use, 5 were
misuse inspections following specific state requests, and 15 were
aimed at pesticides imports and exports.  As part of the overall
information collection and compliance effort, the pesticides staff
reviewed 200 import documents, collected 236 samples for chemical
analyses and registered 3,200 producers, entering registration
information into the FATES computer data base.

From these inspectional and information collection activities, the
Region's FIFRA enforcement activities increased dramatically in FY
1983.  The Region issued 307 notices to establishments for failure to

report production, 48 notices of intent to cancel  establishment
registrations, and 50 Section 9 (c)(3) warning letters. In addition,
the Region issued 21 critical stop-sale orders to  protect the public
from unsafe or mislabeled pesticides, as well  as seven recall  letters.
Most impressively, however, the Division initiated 106 civil
administrative complaints, which constituted 48 percent of the national
total of such actions.
                          State Programs
The FIFRA program marked a milestone this year with the granting of a
cooperative enforcement agreement to the Ohio Department of Agriculture.
This brings all six states into the Federal funding program and will
provide a strong basis upon which Ohio can increase its enforcement
efforts.  State enforcement and certification grants have improved
investigations of pesticide misuse, an area where  Federal emphasis
will continue in FY 1984.

During the year, the Division's staff have undertaken a more careful
program of grant negotiations with thorough mid-year and end-of-year
follow-up reports to improve state program effectiveness.  Also,
toward achieving two objectives in our Environmental Management
Report, we also moved directly with our states to  address groundwater
contamination by the pesticide Aldicarb in central Wisconsin,  as well
as undertaking a review of the environmental hazards of bulk herbicide

The Superfund program under the Comprehensive Environmental
Response, Compensation and Liability Act is designed to provide
public-financed response capability at hazardous waste spills

or unregulated hazardous wastes sites, as well as authorities to
induce privately-financed corrective actions.  In Region V, the
overall Superfund program responsibility is divided between the Waste
Management Division and the Environmental Service Division (ESD)
essentially with ESD handling immediate response (there are some
exceptions at NPL sites) and the WMD conducting the remedial
action and overall program support functions.  Throughout this
effort the Division has necessarily worked closely with the states
and the Office of Regional Counsel, as well as the ESD and the Public
Affairs Office.
                     Remedial Action Program
In FY 1983, the Region continued to work closely with our states
to assess potential hazardous waste sites and nominate appropriate
candidates to the National Priority List.  This effort resulted
in the addition of 45 more sites to the list, the largest increase
of any region.  Also, Wisconsin began active participation in
the program, placing 20 sites on the proposed list.

Significant progress was made on the 99 sites on the original NPL
during the year.  Nine state-lead cooperative agreements were awarded,
with funds approved for 17 Federal lead projects.  A significant
measure of success in our efforts is the fact that joint decisions
made with our States will result in Federal funding of 13 State lead
cleanups and 18 Federal lead cleanups.  Of the remaining sites,
States have taken the enforcement lead in 22 cases, while federal
lead has been initiated at 20 sites.  Nine of our sites are being


pursued through joint Federal and state enforcement efforts.  In

addition to this, five sites are being handled as "dual track" sites

with enforcement actions (negotiations) being pursued while remedial

actions are held in abeyance.  Twelve (12) sites on the NPL have not

been actively addressed due to lower priority and severe resource


Groundwork laid by the Region in 1981 and 1982, coupled with increasing

state participation, resulted in fund obligations for remedial

investigation/feasibility studies at sites in five states (none in

Wisconsin).  These studies will  determine the nature and extent of

problems at the sites, evaluate alternative corrective actions and

recommend the most cost-effective remedial action that ensures public

health and the environment are protected.

Funds totaling $10.1 million were committed for remedial work at 28

sites in FY 1983.  Remedial investigation/feasibility studies valued

at $8 million were initiated for response related activities at 21

sites.  In addition, $705 thousand were committed for studies in

support of litigation at 7 sites.  The Region also gained funding for

initial remedial measures at three sites.  This activity covered the

cost of the field actions ranging from fence construction to drum and

soil removal to provision of alternate water supplies.  Much of the

field related response activity resulted from the scrutiny of National

Priority List (NPL) sites and the identification of removal  activities.

During FY 1983 such activities valued at $6.6 million were conducted
by Region V at 19 NPL sites.   In addition,  the Division conducted two
of the few planned removals in the country-the cleanup of Midco I in
Indiana and the cleanup of the Cleveland radiation sites.  Division
staff also commenced work at  Calumet Containers in Indiana.  In the
immediate removal category, it was necessary during the year for the
On-Scene Coordinators from the WMD to perform seven immediate removal
actions at NPL sites, such as Berlin and Farro and the Verona well
field in Michigan, to mitigate emergency conditions.

Finally, toward the end of FY 1983, the program staff in the Remedial
Response Branch developed and submitted to Headquarters a Regional
Remedial Action Plan (RAP).  This plan, which will be discussed in
more detail later, forms an important basis for managing the program
in FY 1984.
In no other Agency program is the interplay between enforcement
activities and the more traditional technical program activities as
intricate or continuous as in the Superfund program.  The enforcement
potential is a permanent consideration at any site where technical
activity is proceeding.  Hence, while our remedial program efforts
concentrated on remedial investigations and feasibility studies
during the year, we also moved forward with enforcement efforts to
address some of the most significant site problems in the Region.
Among these are Chem-Dyne in Ohio, Seymour and Enviro-Chem

in Indiana, A&F Materials in Illinois, FMC and the Oakdale sites in
Minnesota, and a variety of sites in Michigan.

The Division participated in initiating or resolving a significant
number of enforcement actions under the Superfund program during FY
1983.  Seven consent decrees were completed, and one was lodged but
not entered (Enviro-Chem).  Some 114 agreed administrative orders
were issued for significant cleanups, 13 civil referrals (12 for
cost-recovery and one for cleanup) were made, and three civil actions
were filed.  In addition, the Superfund program negotiated a RCRA
Section 3013 consent order resolving the Diamond Shamrock case in the
Ashtabula, Ohio area.  Negotiated cleanup settlements emerging from
the Superfund program during the year were valued at $57.5 million.
The national total was $87.6 million.
                          State Programs
While the CERCLA program does not provide official program delegation
we have worked diligently to move lead responsiblity to the states
wherever reasonable.  Consequently, states have taken the enforcement
lead on 22 of the NPL sites and we are sharing the lead on nine
others.  One hundred percent Federal funding of remedial investigation
and feasibility studies has made Federal lead much more appealing
then in the past, but we did agree to nine new cooperative agreements
for State lead fund-financed cleanups in the remedial program in FY
1983.  The cooperative agreement with Ohio for the planned removal at
the Cleveland radiation sites marks the first State lead planned
removal in the country.

A key Superfund accomplishment in FY 1983 was the award of $1.8
million through RCRA Section 3012 to all Region V states for the
update of existing state and federal site data bases and the
conduct of preliminary assessments.  Region V has 2,908 sites in
the Emergency and Remedial Response Information System.  During the
year, 570 preliminary assessments and 175 site inspections were
conducted.  Prior to the availability of 3012 funds, the Region
working in conjunction with the states provided input into the
promulgation of the original NPL and the first update of the
NPL.  As a result of these efforts, Region V states total 141
final or proposed sites on the update list.  This is the largest
Regional total in the country.

Multi-Media Initiatives
                 Regional/National Dioxin Program
In mid-year the Waste Management Division assumed the lead in re-
organizing the Region's dioxin activities and setting a new ambitious
course of action for the Region.  Through the new Regional Dioxin
Task Force, which was chaired by the WMD and supported by the active
participation of six other staff members from the Division, the Region
commenced a multi-media study of dioxins in Michigan, concentrating
on the Dow Midland area where earlier, more limited studies revealed
dioxins in the environment. Our efforts, initiated in direct response
to a request from the State of Michigan in March, resulted in the
broadly coordinated development of a general study plan and detailed
soil sampling plan for Midland, Michigan.  This flurry of activity
which involved virtually all offices in the Region, especially the

Environmental Services Division and Water Division as well  as our
Division, had to be very carefully coordinated not only within the
Region but also between the Region, Headquarters,  the State,  and many
individuals outside the governmental agencies.  The Division  was
deeply involved in this undertaking, which evolved into a coordinating
role during the Agency's preparation of a response to a precedent
setting citizens'  petition from Michigan, extensive technical
participation in preparing a detailed information  request to  Dow,
active involvement in developing a Regional  dioxin workplan,  and
coordinating the Region's active participation in  the formulating of
the Agency's national dioxin strategy.  Late in the year, the Division
was asked by Headquarters to participate on the national Dioxin
Management Task Force.
                   Great Lakes Toxic Substances
During the year the Waste Management Division played a significant
role in the Agency's activities related to the toxic substances concerns
of the Great Lakes Water Quality Agreement.   The Division provided
the chairman of the Toxic Substances Committee, a  diverse group of
Canadian and United States scientists and technicians established
under the Great Lakes Water Quality Board, of which the Regional
Administrator is co-chairman.   With leadership provided by the
Region V members of the Toxic  Substances Committee, a program to
update the list of toxic chemicals in the Great Lakes basin was
initiated and a special work group was established to define  a dynamic
system for listing toxic chemicals in the basin on the basis  of their
physical, chemical, and toxicological characteristics, their  environ-

      mental  presence,  and  their production characteristics.  The Division
      also directed the design  of this  emerging  listing  system, which should
      provide a useful  toxic  chemical  information  base for the various
      environmental  and health  agencies  in  the basin.

III.   People  and Spaces
      Beginning in October  1982, the Division, then  only eight months old,
      employed 100 "permanent full-time  individuals"  (PFT) and 18 "other-
      than-permanent full-time  individuals" (OPFT).   Working  side-by-side the
      Divisional staff  were 11  contractor staff  in the WMB and RRB, as well.
      as two  individuals in the 1MB hired under  arrangement with the American
      Association of Retired  Persons  (AARP).  By the  end of the year, the
      Division had expanded to  168 staff, both PFT and OPFT.  This expansion
      which occurred primarily  in the  RCRA  and Superfund programs is expected
      to continue in FY 1984.  In addition, four more individuals through the
      AARP will be joining  the  TMB in  FY 1984 to augment the  Region's asbestos-
      in-schools compliance program.
      During  FY 1983, the Waste Management  Division  moved from the 16th  floor
      of the  Trans-Union Building back to the Kluczynski Building.  Late in
      January 1983, we  were able to complete the move on successive week-ends,
      with the Toxic Materials  Branch  shifting to  the llth floor of the
      Kluczynski Building and the balance of the Division on  the 13th.   With

additional growth in the size of the Division in FY 1984.  Efforts
continue to secure space in the "230 Building" to avoid the inevitable
productivity and morale problems attendant excessive crowding of work
                          Affirmative Action
During FY 1983, the Waste Management Division continued its efforts
toward achieving EEO goals while simultaneously meeting the pressing
functional needs of the organization.  Our affirmative action and
program objectives were successfully corollated in our personnel actions,
such as hiring and promotions, training, and special assignments.  The
Division was successful in filling 16 job vacancies with minority
individuals and females from several racial groups.  In addition, we were
able to temporarily promote three female clericals to secretarial
positions, as well as return a highly-qualified minority staff member,
down-graded during the Agency's reduction-in-force, to a supervisory
position in the Waste Management Branch (WMB).  The WMB also continued
its support of the CETA Youth Development Program, by providing jobs
for three female minority students, one of whom has since become a
regular, part-time employee of the branch.

The Division paid special attention to EEO objectives in other actions
as well.  We were able to convert from OPFT to PFT four females out of
a Divisional conversion allowance of seven during the year.  Special
assignments to high-priority Regional and national task forces and
coordinating positions were made to at least seven staff members
coming from minority population groups.  It can be said without


     qualification that  the Division,  in particular  the  Waste  Management
     Branch,  made a notable record  of achievement with respect to  affirmative
     action objectives in FY 1983.

     For 1984,  the Division intends to redouble  its  efforts  to attain
     expanded EEO objectives.   We intend to extend additional  hiring,
     training,  and promotional  opportunities to  affirmative  action target
     groups.   Toward the goal  of achieving expanded  EEO  objectives in  FY
     1984,  the  Division  plans  to define  and institute  its  own  affirmative
     action plan by January 1984.

IV.   1984 Goals and Priorities

     In FY  1984 the Waste Management Division will continue  its various
     activities in a variety of environmental and public health areas.
     The wide range of Divisional activities requires  that clear goals  are
     set and priorities  established.  The following  list of  goals  and
     priorities identifies specific areas of desired attention and achieve-
     ment for the Waste Management  Division.  While  these high-priority
     activity areas should receive  emphasis in our decision-making,  deploy-
     ment of resources,  and effort, the Division recognizes  that the
     successful accomplishment of many other specific  activities will  be
     necessary for us to achieve our priority objectives as  well as  attain
     the many performance commitments in the Administrator's Management
     Accountability System (AMAS) and our workplans  overall.


    1.  State authorization - The Division must work closely with the
states to ensure that the specific milestones on the FY 1984 path toward
final  authorization are accomplished. This accomplishment will  be critical
to the final  authorization of our six-states as early in FY 1985 as

    2.  Permitting - The Division must make 105 permit determinations in
FY 1984.  Of these final permit determinations, we expect most  of them
will result in the actual issuance of final RCRA permits.  For  those
facilities unable to meet the technical requirements necessary  to receive
a permit for which application was required, we will terminate  their
interim status.

    3.  Enforcement -  The Division must conduct an aggressive  enforcement
program aimed specifically at achieving compliance with RCRA requirements,
especially those pertaining to groundwater and financial responsibility.
To accomplish this, the Division is expected to use all appropriate
enforcement techniques, including greater employment of higher  order
enforcement actions.  The Division should make concerted efforts to
establish enforcement procedures, including procedures with the states,
to ensure expeditious enforcement in response to instances of non-compliance.



    4.  PCB compliance and enforcement - The Division should continue its
extensive compliance and enforcement activities aimed at facilities especially
those in high-priority geographical  areas of environmental  concern, that are
regulated under Section 6 of TSCA.   During 1984, emphasis will  be placed
on completing 154 high-quality inspections and preparing appropriate
enforcement actions.  Mechanisms for coordinating PCB inspectional and
enforcement activities with other related Regional  regulatory activities
should be further delineated and used.

    5.  PCB disposal - The Division  should continue to give due emphasis
to approvals of PCB disposal and destruction.  This is especially important
relative to the January 1984 requirement that all stored PCB's must be
properly disposed of or destroyed.   In addition, the Division should
emphasize compliance with the PCB disposal approvals already issued by
the Regional Administrator.

    6.  Asbestos in schools - In FY  1984 the Division should at least
double its FY 1983 level of activity in the "school asbestos" compliance
and enforcement program.  Emphasis will continue to be placed on substantive
non-compliance with the asbestos requirements under Section 6 of TSCA.
Additional efforts will be undertaken to broaden compliance activities
with the state school authorities as well as publicizing noteworthy cases
of Federal enforcement action.


    7.  State/Federal pesticides enforcement - The Division should identify
areas in state/Federal pesticides enforcement needing improvement, such as
compliance tracking.  Specific mechanisms for making pesticides enforcement
more effective and more comprehensive should be developed during the
year.  The Division should consult with state agriculture and environmental

    8.  Pesticides Use and Misuse -  In its pesticides enforcement program,
the Division should place greater emphasis on taking actions in cases of
pesticides misuse.  In addition, the Division, together with the states
and other Agency offices, should identify areas where pesticides use
according to label instructions may be contributing to environmental

    9.  Ohio Pesticides Program - During FY 1984 the Division must place
additional emphasis on assisting the State of Ohio in developing its
cooperative pesticides enforcement program.  Careful attention should be
paid to helping the State make any adjustments necessary to enable it to
operate a mature cooperative pesticides enforcement program.
    10.  Remedial Accomplishments - The Division should be directing its
efforts toward full achievement of the outputs specified in the Headquarters
approved Remedial Accomplishments Plan (RAP).  The RAP, for which the

Division must develop and maintain a detailed schedule,  calls for the
completion of 13 Remedial Investigation/Feasibility Studies,  8 Remedial
Designs, 4 Remedial Actions, 2 Initial  Remedial  Measures,  1,010 Preliminary
Assessments and 247 Site Investigations.   Close  coordination  of these
activities with the states will  continue.

    11.  Superfund Enforcement - The Division, in cooperation with the
states, should continue its efforts to identify  and plan candidate sites
for various enforcement activities.  These activities include responsible
party searches, negotiations with responsible parties,  administrative and
judicial enforcement actions, and cost recovery  actions.  An  important
management goal for Superfund in the Region will be the full  integration
of the planning and implementation of remedial action and enforcement
activities during FY 1984.


    12.  Toxics Coordination - The Division will co-chair (with the Planning
and Management Division) the Region's reorganized toxics coordination
effort.  This major initiative under the general direction of the Deputy
Regional Administrator will establish an initial agenda of toxics goals
and work priorities to be addressed in the FY 1985 Regional  planning
process.  Subsequently, during this year, the toxics coordinating effort
will define a process for defining and implementing a toxics  strategy in
the Region on a continuing basis.


    13.  Dioxin Strategy - The Division will  continue to provide overall
leadership to the Region's dioxin initiative, including serving on  the
Headquarters Dioxin Management Task Force and coordinating the preparation
and implementation of the Region's multi-program dioxin work plan.

                  Management, Personnel, Administration

    14.  General Management - During FY 1984  the Division will  give added
emphasis to establishing and maintaining planning,  management,  tracking
and evaluation procedures.  Particular attention will  be paid on a  continuing
basis to scheduled accomplishment of work plan and  AMAS commitments;
timely, high-quality response to congressional and  other controlled
inquiries; briefings; and routine reporting to the  ORA and Headquarters.

    15.  Affirmative Action - The Division will  be  placing added emphasis
on developing and implementing a progressive  EEO accomplishments plan.
The growth of the Division this year will  provide a good opportunity to
make significant progress in the area of affirmative action.

    16.  Internal Controls - The Division will be undertaking a concerted
effort to establish strong internal controls  in the areas of greatest
vulnerability:  (a) adequate information management system which is
well-organized, well-maintained, and secure;  and (b) RCRA permitting
administrative records.


        17.   Space - The Division will  work with the Planning and Management
    Division as well as the Office of the Regional  Administrator to secure
    critically needed space to accommodate the significant expansion of the
    Division.  Our objective is the secure space on two successive floors  in
    the Kluczynski Federal  Building as early in FY  1984 as possible.

V.  Conclusion

    FY 1984 will provide many new challenges to the Waste Management Division
    and to each of its members.  Based on the accomplishments of FY 1983,  it
    is clear that the Division has built a strong foundation for achieving our
    ambitious objectives established for FY 1984.