United States
Environmental Protection
Agency
Office of Enforcement and EPA 300-B-95-001
Compliance Assurance (2261) October 1994
Federal Agency
Environmental Management
Program Planning Guidance
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FEDERAL AGENCY
ENVIRONMENTAL MANAGEMENT
PROGRAM PLANNING GUIDANCE
October 1994
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PREFACE
This guidance document was prepared by EPA's Federal Facilities Enforcement
Office and is intended for both providers and users of information generated by the
A-106 process. The document discusses only those data elements that will be
reported to EPA. Your organization may have an environmental project/activity
tracking system that requires supplementary data elements. This document does
not contain information on any additional data elements your agency may have
included in your own in-house environmental database. It provides insight into the
rationale underlying only those data elements contained in A-106.
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TABLE OF CONTENTS
1.0 INTRODUCTION
1.1 Overview 1"!
1.2 Authorities I-2
1.3 The A-106 Process As A Management Information System 1-3
1.4 EPAReview ! - 5
1.5 The A-106 Reports 1 - 6
1.6 Schedule of Events for the A-106 Review Cycle 1-7
2.0 GUIDANCE DOCUMENT
2.1 System Description 2-1
2.2 What's New? - Changes to the Data Elements 2-2
2.3 Activities to be Reported in A-106 2-2
2.3.1 Types of Environmental Programs 2-4
2.3.2 Types of Projects 2-5
2.3.3 Size of Projects 2-5
2.3.4 Appropriations and Non-Environmental Funding Accounts 2-6
2.4 Projects and Activities Normally Excluded from the A-106 Process 2-6
2.5 Project Characterization 2-9
2.5.1 Statutory/Regulatory Authority 2-10
2.5.2 Environmental Category 2-11
2.5.3 Compliance Status 2-11
2.5.4 Project Priorities 2-16
2.5.5 Meshing Compliance Status with Project Priorities 2-18
2.5.6 Geographic Initiatives 2-19
2.5.7 Latitude/Longitude 2-20
2.6 Other Entries 2-22
2.6.1 Program Management 2-22
2.6.2 Program Definition 2-22
2.6.3 Pollution Prevention 2-23
2.6.4 Conservation of Natural and Cultural Resources 2-25
2.7 Project Characterization Summary 2-26
2.8 Types of Project Costs 2-27
2.8.1 Cost Estimating 2-29
2.9 The Budget 2-29
2.9.1 Program Phases 2-29
2.9.2 Multi-year Budget Planning 2-31
2.9.3 Estimated Project Cost 2-32
2.9.4 Guidance on Estimating Funding 2-34
2.9.5 Federal Agency Program Element 2-34
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TABLE OF CONTENTS (Continued)
2.9.6 OMB Appropriation 2-35
2.10 Additional Information 2-36
2.10.1 Reporting Requirements for Different Types of Facilities 2-36
2.10.2 Tenants 2-36
2.10.3 Operable Unit 2-36
2.10.4 Quality Assurance/Quality Control Procedures 2-37
2.10.5 New Information 2-40
3.0 INSTRUCTION KIT FOR UPDATING FEDERAL AGENCY ENVIRONMENTAL
MANAGEMENT PROGRAM PLANS
3.1 Introduction 3 -1
3.2 Instructions for Completing Agency A-106 Input Forms for
New Environmental Management Program Plans 3-2
3.3 Faciliry/Installation/Activity Information. . . . 3-3
3.4 Basic Project Information ; 3-7
3.5 Funding Information 3-10
3.6 Project Characterization 3 - 14
3.7 Project Narrative 3-18
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TABLE OF APPENDICES
APPENDIX A ENVIRONMENTAL CATEGORIES (ECATs) Al -1
(Parti)
APPENDIX A ECATs QUICK REFERENCE LIST A2 - 1
(Part 2)
APPENDIX A DEFINITIONS OF THE ECATs A3 - 1
(Part 3)
APPENDIX B DRAFT POLLUTION PREVENTION CATEGORIZATION
SYSTEM (PPCS) B - 1
APPENDIX C FACTORS TO CONSIDER WHEN PRIORITIZING A-106
PROJECTS C - 1
APPENDIX D USES FOR THE A-106 SYSTEM AT DIFFERENT
ORGANIZATIONAL LEVELS D - 1
APPENDIXE USES OF PROJECT COSTDATA E - 1
APPENDIXF AGENCY/BUREAU CODES F - 1
APPENDIX G AGENCYFUNDING ACCOUNT CODES G- 1
APPENDDC H STATE/TERRITORY AND EPA REGIONAL
ABBREVIATIONS H - 1
APPENDIX I COUNTRY CODES NATIONAL BUREAU OF STANDARDS ... I - 1
APPENDIX J ENVIRONMENTAL PROTECTION AGENCY REGIONAL
MULTI-MEDIA FEDERAL FACILITY COORDINATORS J- 1
APPENDDC K AGENCY CONTACTS FOR IDENTIFYING GSA
INSTALLATION NUMBERS CONTACT FOR FFJD
NUMBERS K - 1
APPENDK L EXECUTIVE ORDER 12088 L - 1
APPENDIXM OMB CIRCULAR A-106 M- 1
APPENDKN OMB CIRCULAR A-ll N - 1
APPENDIX O AGENCY A-106 INPUT FORM O -1
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TABLE OF TABLES
Table 2.1 A-106 Data Elements '..2-3
Table 2.2 A-106 Priority Score 2-16
Table 2.3 Factors to Consider when Setting Priorities 2-17
Table 2.4 EPA Compliance Status Codes 2-19
Table 2.5 Project Characterization Summary 2-27
Table 3.1 Codes to Document Methodology of Lat/Long Selection 3-5
Table 3.2 Identification of the Regulated Community
of Facilities with Federal Involvement 3-6
Table 3.3 Progress Codes 3-8
Table 3.4 Reason for Discontinuance Codes 3-10
Table 3.5 Types of Costs 3-11
Table 3.6 Estimated Project Cost Samples for Entering Data 3-13
Table 3.7 Compliance Classes and Priority Assessments 3-15
Table 3.8 Geographic Initiative Codes 3-17
Table 3.9 Reason for Initiation Codes 3-17
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ACRONYM
ADS
CAA
CERCLA
CMPA
COCO
CWA
ECAT
EPA
EPCRA
ESA
ESDF
ESDL
ESDP
ESRE
ESRO
ETRS
FFCA
FFID
FFIS
FIFRA
FY
GOCO
GOGO
GOPO
IAG
INOV
ISSA
NCA
NCP
NEPA
NOV
NPL
ODCS
OFFE
OMB
OTHR
OU
PDEF
LIST OF ACRONYMS
DEFINITION
Activity Data Sheet
Clean Air Act
Comprehensive Environmental Response, Compensation and Liability Act
Compliance Agreement
Contractor Owned/Contractor Operated Facility
Clean Water Act
Environmental Category
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Endangered Species Act
Established Standard and Deadline in the Future
Established Standard, Demonstrate Leadership
Established Standard and Deadline Past
Established Standard, Replacement due to Expansion
Established Standard, Replacement due to Obsolescence
EnviroText Retrieval System
Federal Facility Compliance Agreement
Federal Facility Identification Number
Federal Facilities Information System
Federal Insecticide, Fungicide, and Rodenticide Act
Fiscal Year
Government Owned/Contractor Operated Facility
Government Owned/Government Operated Facility
Government Owned/Privately Operated Facility
Interagency Agreement
Inspections or Notices of Violations
Installation Service Support Agreement
Noise Control Act
National Contingency Plan
National Environmental Policy Act
Notice of Violation
National Priorities List
Ozone Depleting Chemicals
Office of Federal Facilities Enforcement
Office of Management and Budget
Other Reasons
Operable Unit
Program Definition
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October 1994
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FEDERAL AGENCY ENVIRONMENTAL MANAGEMENT
PROGRAM PLANNING GUIDANCE
1.0 INTRODUCTION
1.1 OVERVIEW
Federal facility planning, including compliance with environmental regulations, is one of
the most important activities engaged in by a Federal agency. The development of environmental
plans, including the identification of needed projects and the estimation of the costs of those
projects, provides a mechanism through which Federal agencies can analyze both their current and
projected environmental funding requirements. In accordance with Executive Order 12088
(Appendix L) and Office of Management and Budget (OMB) Circulars A-106 (Appendix M) and
A-l 1 (Appendix N), Federal agencies are required to submit those environmental plans to the
Director of OMB through the Environmental Protection Agency (EPA).
Executive Order 12088 directs EPA to establish guidelines for Federal agencies to use in
development of their environmental plans. EPA is also assigned the responsibility of helping
Federal agencies by providing technical advice and assistance during the planning process.
Finally, EPA conducts reviews and inspections to monitor compliance with applicable
environmental requirements and to assure the adequacy of Federal agency environmental
planning.
The primary objective of OMB Circular A-106, and the supporting environmental
management information system maintained by EPA, is to ensure that Federal agencies identify all
of their environmental requirements and target resources to address them. The A-106 system
tracks these requirements from the time they are first identified until they are executed. Because
each project identified by a Federal agency is represented by a unit record, reports can be
generated using any combination of over 25 different parameters. Therefore, almost any question
regarding the planning and budgeting of an organizations^ environmental program can be
answered without additional data calls.
The A-106 process is unique in that
these funding requirements are reviewed by
another Federal agency, the Environmental
Protection Agency, before being forwarded to
OMB. EPA reviews agency submissions, and
comments on whether Federal agencies are
planning and budgeting for programs and
activities that will bring them into sustained ^^mm^^m^^^fm^^^ff^^^f^^^^a^^m
compliance with all environmental
requirements. The data is analyzed to determine gaps in Federal agency planning, identify funding
The primary objective of OMB Circular
A-106, and the supporting environmental
management information system maintained
by EPA, is to ensure that Federal agencies
identify all of their environmental require-
ments and target resources to address them.
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trends, and to forecast the size of future budget requirements. The A-106 submission is also
available as a budget support document for use by the appropriate OMB budget examiner, when
reviewing that Department's budget request. From the Federal agencies' A-106 submissions, EPA
can also provide aggregated government-wide environmental information for OMB's analysis and
preparation of the President's Budget to Congress.
This document establishes guidelines for the development of Federal agency A-106 Plans,
and provides guidance to both the providers and users of information generated by the process. It
is organized into three sections. Section 1.0 includes a general overview of the A-106 process.
Section 2.0 is the guidance portion of the document. It introduces the various components of the
system, and explains the rationale behind each of the parameters included in the database. It also
provides an explanation of process procedures, and how the system functions to turn data on
individual projects into useful information for analysis and management of environmental
programs. Section 3.0 is an instruction kit that defines all the A-106 data elements, and explains
how to fill out each data field correctly.
1.2 AUTHORITIES
The A-106 process is governed by several different authorities. These authorities include:
Executive Order 12088, OMB Circular A-106, OMB Circular A-l 1, the EPA Federal Facility
Compliance Strategy, and agency-specific Directives. Several of these authorities are discussed in
greater detail below.
Executive Order 12088
Executive Order 12088, "Federal Compliance with Pollution Control Standards", dated
October 13, 1978, makes the head of each executive agency responsible for ensuring that the
agency's facilities, programs, and activities meet applicable Federal, State, and local environmental
requirements. Agencies must take all necessary actions for the prevention, control, and abatement
of environmental pollution with respect to their facilities. The head of each Executive agency
must ensure that sufficient funds for compliance with environmental standards are requested in the
agency budget. Section 1-401 directs that each agency "shall submit to the Director of the Office
of Management and Budget, through the Administrator [of the Environmental Protection
Agency], an annual plan for the control of environmental pollution" and further requires that the
Administrator "shall establish guidelines for developing such plans." The plan should provide for
necessary improvements in, and the associated estimated costs for, "the design, construction,
management, operation, and maintenance of Federal facilities and activities."
OMB Circular A-l 06
OMB Circular A-106, "Reporting Requirements in Connection With the Prevention,
Control, and Abatement of Environmental Pollution at Existing Federal Facilities", dated
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December 31, 1974 describes the process for developing and maintaining Pollution Abatement
Plans. OMB Circular A-106 specifies that an agency should include in it's plan all project costs
necessary to comply with environmental standards. The plan should also include funds required
for studies, management, and monitoring associated with the definition and development of
corrective measures and necessary equipment to assure compliance with standards. A-106 directs
EPA to establish the process for tracking Federal agencies' environmental costs. The A-106
process is described as a methodology for identifying requirements, establishing funding priorities,
and tracking milestones so that environmental projects are completed in time to meet statutory
and regulatory requirements.
OMB Circular A-11
OMB Circular A-11, which is normally updated in July of each year, provides detailed
instructions and guidance to all Federal agencies on the preparation and submission of their annual
budget. It requires that Federal agencies consult with EPA prior to submitting budget estimates
to OMB for design and construction of pollution control and treatment projects, or remedial
environmental projects. It states that estimates for the design and construction of Federal
facilities and buildings must provide for the installation of pollution control and treatment systems
in accordance with OMB Circular A-106, Executive Order 12088, and any related instructions.
Finally, budget requests for Federal Facility pollution control and treatment projects are to be
consistent with the latest A-106 plans submitted to EPA and OMB.
1.3 THE A-106 PROCESS AS A MANAGEMENT INFORMATION SYSTEM
Although the A-106 process evolved out of the requirement in Executive Order 12088 to
report environmental needs through EPA to OMB, there are numerous other aspects to the
system. Many Federal agencies have found the A-106 data management system to be a useful
instrument for their internal program management. The A-106 database is considered by some
Federal agencies to be the most important source of information available for overall management
of their environmental programs.
The A-106 database can be described as a comprehensive multi-year listing of identifiable
environmentally-related costs. A-106 provides a mechanism for characterizing environmental
activities, establishing priorities, and identifying the resources necessary to attain and sustain
compliance with Federal, State, and local regulatory requirements. This includes future
requirements, as well as correction of those violations or problems, which already have been
identified by EPA and State regulatory authorities. The A-106 process also provides a
methodology for analysis of both current and projected funding requirements. It is necessary to
understand that, although A-106 by itself is not the budget request, it is a very significant budget
support document.
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The information compiled and reported through the A-106 process is also very useful to
EPA and to OMB. A-106 provides the data necessary to verify that Federal agencies are
adequately planing and programming for environmental compliance, and to ensure that agencies
are requesting funding for all their environmental requirements. It is also used to assess progress
in implementation of environmental programs at all levels of organizations. l
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The A-106 process is not meant to function independently from other Federal agency
management systems, but should be folly integrated and interdependent with those systems. For
example, many Federal agencies have developed formal strategies, which describe the Federal
agency's environmenta? vision, goals, and objectives for their environmental programs. Federal
agencies develop and implement specific programs and action plans, which are designed to
1 For a comprehensive list of the uses for A-106, see Appendix D.
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support, execute, and track activities necessary to carry out these environmental goals and
objectives. The projects and activities fulfilling these programs and plans should be reported in
A-106. If the A-106 database is maintained up-to-date, it can be invaluable in producing the
Federal agency's annual environmental compliance funding plan, as well as budget submissions
required by Circular A-l 1 and other environmental reports. Viewed as part of a management
system rather than as a reporting system, A-106 can be a useful instrument for the continual
update of planning and budgeting environmental information within a Federal agency.
1.4 EPA REVIEW
The primary goal of EPA's Federal Facility Compliance Program is to ensure that all
agencies reach a level of compliance with environmental requirements that equal or surpass the
rest of the regulated community. To accomplish this goal, EPA uses a three-pronged approach:
training and technical assistance, compliance and enforcement activities, and review of Federal
agency environmental plans and programs. This comprehensive approach is designed to help
Federal agencies develop appropriate compliance strategies, and request adequate funding to
carry out those strategies.
The EPA review of Federal agency A-106 plans consists of two fundamental elements:
examination of individual projects, and analysis of overall programmatic (media or multi-media)
compliance with statutory and regulatory requirements. This review identifies those situations
where a project is needed for compliance, but is not reflected in the A-106 plan. The review also
identifies projects that are in the plan, but need modification to accomplish their stated purpose.
EPA Regions generally review projects and programs at Federal facilities (installation-level),
whereas the EPA Headquarters concentrates its analysis on Departmental and Bureau level
environmental programs.
Each EPA Region has a Federal Facilities Coordinator who coordinates the review of
Federal agency plans within that Region. The primary function of EPA Regional reviewers is to
determine whether the Federal facility environmental plan is addressing all relevant compliance
issues. During a review, the plan is correlated with information in the Federal Facility Tracking
System (FFTS), and with other Regional media compliance tracking systems. If a Federal facility
has signed an Inter-agency Agreement (IAG), or a Federal Facility Compliance Agreement
(FFCA), or has been subject to an enforcement action, such as a Notice of Violation (NOV) or
Notice of Noncompliance (NON), a corrective action project may have been required to bring the
facility back into compliance. Reviewers check the compliance status of the facility being
reviewed and ensure that all such actions have been covered in the facility's A-106 submission: If
a facility requires an additional project to correct a deficiency, the Regional Federal Facility
Coordinator discusses the situation with a representative at the installation, and if necessary,
forwards a recommendation to the appropriate authority to add the project to the Federal agency
plan. EPA reviewers pay particular attention to the compliance status and the priority of each
project in the Federal agency plan. Class I projects are considered "must fund" projects. If a
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valid Class I project is included in an agency plan and no planned funding is reflected, the
installation is contacted and the problem discussed. If no progress is made toward resolution of
the problem at the local level, a recommendation that the project be amended is forwarded for
appropriate action to EPA Headquarters.
EPA Regions conduct several reviews of A-106 projects throughout the year. (The
purpose and timing of these reviews will be discussed in the following section.) However, the
most intense scrutiny of an installation's A-106 submission is made just prior to and during the
periodic compliance inspections of Federal facilities conducted by EPA media enforcement
offices.
1.5 THE A-106 REPORTS
OMB Circular A-106 prescribes that Federal agency environmental reports will be
submitted to the Director of OMB through the EPA Administrator. After review, the
Administrator will forward the Federal agencies' reports to the Director. In addition, the
Administrator will also forward an evaluation of each agency's report to OMB.
EPA Headquarters ensures that the required information is submitted by each Federal
agency in a timely manner,2 and also performs a quality control check on the data. EPA
Headquarters then conducts an analysis of each agency's environmental plan focusing on each of
the media programs and environmental categories (ECATs). Concurrently, EPA Regions begin
their review of projects and programs at the installation or facility level. Using the information
provided by the Federal agencies, the Administrator of EPA prepares several reports for OMB,
each with a different but explicit purpose.
The primary report generated by EPA evolves from the information contained in the
Federal agencies' Summer submissions due at EPA no later than (NLT) September 1st. This
report is forwarded to OMB by the first of October each year. The report contains an analysis of
significant factors associated with the environmental programs proposed by Federal agencies.
The funding level of each media program is examined in detail to assess whether funding requests
are at the appropriate level to comply with all applicable environmental statutes, regulations, and
standards. A comparison of trends in costs and other environmental data between past, current,
and future fiscal years is also presented. EPA examines five different time periods: previous fiscal
years, the current year, the budget year, the President's budget year, and future years (four or
more outyears). Because Departmental-level funding has normally been locked-in through the
end of the budget year, the EPA Headquarters concentrates it's analysis primarily on data
pertaining to the President's budget year, which is still over twelve months away. It is also
s Federal agencies submit their Plan to EPA NLT September 1st, the same date that the agencies normally submit
their budgets to OMB. This helps to ensure that the information in the A-106 report correlates as closely as possible
with the information in the agency budget submitted to OMB.
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concerned with newly promulgated or unrecognized requirements, which may be underfunded,
and other outyear unfunded requirements. Since evaluations of individual projects will not have
yet been received from the Regions, this report, which is generated almost solely by EPA
Headquarters, consists largely of statistical analysis of Federal agency environmental programs. It
is entitled the "Report to the Office of Management and Budget: Pollution Abatement and
Prevention at Federal Installations."
While EPA Headquarters conducts its analysis of environmental programs, EPA Regions
are concurrently conducting their review of the individual Federal facility's plans. During the
period from September 7th to November 1st, EPA Regions review the results of EPA and State
inspections, enforcement actions, and other compliance data, and correlate it with projects
contained in the Federal facilities' plans. EPA Regions focus their review in two areas. The first is
on the budget year, to ensure that Federal agencies direct available funds toward those facilities
that remain out of compliance at the beginning of the new fiscal year. The second is on projects
meeting certain threshold conditions, which Federal agencies have programmed for inclusion in
the President's budget. Problems are discussed directly with the facility, and a copy of any
significant information relative to the discussion is furnished to EPA Headquarters. Important
problems are communicated to the parent Federal agency and compiled in a separate report
forwarded to OMB.
The primary purpose of the Winter submission from Federal agencies (due at EPANLT
January 31st each year) is for EPA to ascertain the current status of Class I projects that Federal
agencies had programmed for completion during the previous fiscal year. EPA uses the
information to verify that those projects identified for funding during the immediate past fiscal
year were actually funded. The Winter reporting date has been established to allow Federal
agencies sufficient time to obtain and report fiscal data relative to those activities. Although EPA
is keenly interested in knowing about these projects, this information has not routinely been
provided to OMB. At this time, the unfunded requirements remaining from the previous fiscal
year should be redistributed by Federal agencies to future years. This is not done automatically by
the A-106 Database and must be accomplished by the user.
1.6 SCHEDULE OF EVENTS FOR THE A-106 REVIEW CYCLE
The A-106 Database is continually updated as information is received from Federal
agencies. The minimum number of updates is twice each year3. EPA analyzes the data submitted
by Federal agencies and provides various reports to OMB in accordance with the schedule
indicated below.
3 Federal agencies are encouraged to submit their data more frequently.
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Date
September 1 st
September 1 st
September ?fh
October 1st
November 1st
November IStli
January 31st
February 15th
^
Most Federal ageaci&s,«afenMt tkepf |otal/estife' ageaey"imdget reouesl;
- _^ •.__••.. * * •.-- ---S -5^- 5 ? S-- "V > s,« ^ * -.^^ * ,,,,r^
to OMB," ^ -^
federal
botb feelr liewasd updated A40S project data^
to
.
Regions schedule itieetjags -^itij Midlvidaal: Federal facilities so *• ^ ^ *• *"' *• s ' tfff fffff
submit apdaied A-10^
those projects teled dwlng th« pr$vi0ns ft$cal year wliich ended.
September 3Dth, "
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October 1994
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GUIDANCE DOCUMENT
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2.0 GUIDANCE DOCUMENT
The A-106 management information system is designed not only to provide EPA and
OMB with information on Federal agency environmental programs, but also for the internal use of
Federal agencies in planning and executing their environmental programs. The system provides a
standardized format with explicit data elements for reporting environmental information. This
section will describe the scope of the system, explain the rationale for the various data elements,
and provide guidance on using the system.
2.1 SYSTEM DESCRIPTION
Although sometimes called a "plan," A-106 is actually a comprehensive collection of
individual activities, projects, and programs that Federal agencies have identified and proposed for
funding in order to comply with applicable environmental standards. Each Federal agency
periodically transmits an updated compilation of environmental data to EPA, who enters the
information into the EPA A-106 Database. This system, also called the Federal Facility
Information System (FFIS), provides EPA with the capability to selectively analyze Federal
agencies' environmental projects and programs. Used with other EPA compliance and
enforcement databases, it provides a useful and important mechanism for tracking, monitoring,
and evaluating projects reported in the Federal agency A-106 Plans. It also permits EPA to assess
how well Federal agencies are forecasting and planning for new requirements, that have been
recently promulgated by regulatory authorities.
A-106 is a comprehensive collection of
individual activities, projects, and programs
that Federal agencies have identified and
proposed for funding in order to comply with
applicable environmental standards.
The FFIS contains an inventory of
all Federal environmental projects and
activities that have been reported to EPA
by Federal agencies. The FFIS database
provides information on individual
projects and programs planned to bring
the facility into compliance, to maintain mm^^^^^^^^mm^^^^^^^^^mmam^^^^
compliance with current regulations, or to
achieve compliance with future regulations. It places each project into a compliance class
depending upon the current compliance status of the facility where the project is to be
implemented. The A-106 data management system has been designed to provide the following
information:
4 The reason for initiating a project;
4 The problem the project is designed to correct;
+ The environmental impact of the project;
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4 The compliance status of the facility;
4 The priority assigned the project; and
4 The estimated cost of the project.
A-106 data elements fall into five general categories: the location of the Federal facility,
the location and description of the project, funding information, various ways of categorizing the
project, and a project narrative.
Federal agencies enter data into A-106 either by using the A-106 Input Form (Appendix
O), or through use of software developed by EPA or the Federal agency. The current A-106 data
elements are presented in Table 2.1.
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2.2 WHAT'S NEW? - CHANGES TO THE DATA ELEMENTS
The A-106 Management Information System has been completely updated from past
versions. There are several additional data elements, and at least three of the existing data
elements have been significantly changed. For example, two additional Compliance Classes have
been added to the former three Classes. The prioritization scheme (H,M,L) has been changed to a
numerical system. There are both additions and deletions to the Pollutant Categories, which have
been extensively defined and have been renamed Environmental Categories. Other new fields
address pollution prevention requirements, EPA geographic initiatives, local and
Bureau/MACOM priority rankings, and two additional account codes, etc. Some of the changes
will be effective with the issuance of this guidance document. Others will be phased in over a
longer period of time.
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2.3 ACTIVnTES TO BE REPORTED IN A-106
A-106 is a comprehensive compilation of environmental requirements regardless of
internal Federal agency organization, program management structure, or appropriation category.
An A-106 environmental "project" may be an activity, a group of activities, an aggregation of
projects, or in some cases even an entire environmental program. Projects should be reported at
the appropriate level, and in a manner, that conforms with each agency's own program
management and information needs. The intent of this new Guidance Document is to capture as
much of the Federal Government's environmental costs as is practicable. EPA recognizes that
there are major differences in the way various Federal agencies' environmental programs are
organized. Internal budgeting procedures also vary from agency to agency. Some agencies have
difficulty in reporting environmental costs on a project-specific basis. By building in a modicum
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Table 2.1
A-106 Data Elements
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Federal Facilities ID (FFID)
State Code
Agency/Bureau Code
GSA Installation Number
Ownership Type
Department/Agency Name
Bureau/MACOM Name
Installation Name
Address
City
Zip Code
EPA Region
Country
Latitude/Longitude
m ?BOJICTS^J&«MMIOI!? -•," ^ ,' •.' ~ ' "^
Project Number
Project Name and Address
Point of Contact
Contact Telephone
Multiple Installations
Building Number
Room Number
Progress Code
Milestones (5)
Reason for Discontinuance
Latitude/Longitude
Operable Unit
- , ' m FCJNfBM«MFOmMATION ---- .-^&~ - ^',
Total Cost Estimate
Year Funding Required
Federal Agency Program Element Code
Federal Agency Funding Account Code
OMB Appropriation Account Identification Code
Type of Cost
Estimated Project Cost
Estimated Cost
Programmed/Budgeted
Obligated
Funded/Unfunded
- W* JPSOJECTCJSA&ACTEfiJZATTON
-------
of flexibility in reporting, EPA hopes to encourage a more extensive level of reporting than in the
past.
Historically, the focus of most Federal agency environmental programs has been centered on
compliance issues. Most have been associated with the management of the facilities real property
program, and were concentrated on facility engineering issues. However, the requirement to
develop formal pollution prevention programs, has shifted environmental considerations and
interests into other functional areas, such as conservation of natural resources, acquisition,
logistics, operations, training, and other facility management activities. This program shift adds
an extra dimension to the environmental agenda. Projects to be reported in A-106 are therefore
not restricted to those funded by appropriations or accounts managed only by the environmental
office, but include any and all activities at the facility which are required in order to comply with
applicable environmental standards.
In addition to reporting individual projects, Federal agencies are encouraged to aggregate
similar small projects into a single "program" for inclusion in A-106. For example, several small
underground storage tank projects at a single facility are a good candidate for "bundling" into a
single UST program. This is a particularly useful technique when estimating costs in the outyears,
where specific details of projects are not yet clear. To simplify cost-estimating in outyears,
Bureaus and MACOMs may also aggregate projects at multiple installations, and enter them into
the A-106 database as a single project.
2.3.1 Types of Environmental Programs
Over the past 25 years, the Congress has continually passed environmental legislation,
increasing both the number and the breadth of environmental laws. To comply with these laws,
Federal agencies have been required to adopt environmental programs that go far beyond the
scope of the narrow programs which existed in the 1970s. To adapt to this broader agenda and to
ensure a comprehensive product, it has become necessary to widen the type of activities reported
under A-106. Fortunately, the A-106 process is sufficiently flexible, that a diverse mix of activities
can be accommodated by the system without diminishing the original intent of the Circular. For
the purpose of A-106 reporting, environmental activities are categorized into one of the following
four major program areas:4
4 Compliance ~ Activities undertaken to ensure both current and future operations
at Federal facilities meet Federal, State, local and applicable host nation
environmental requirements.
4- Cleanup ~ Actions taken to clean up contaminated sites at Federal installations.
This program includes activities that identify sites, assess risk, and clean up
hazardous wastes from previous Federal activities.
4 A fifth category "Other" is an acceptable entry if the activity does not fit into one of the four major types of programs.
2-4 October 1994
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+ Pollution Prevention -- Actions to reduce the future generation of pollutants
through source reduction. This program includes activities to reduce the quantity
of hazardous, toxic, or industrial pollutants through changes in the waste
generating, production, or industrial process at the source. However, Pollution
Prevention is not limited just to hazardous pollutants to air, water, and land, but
also includes activities to reduce the quantity of commercial and household wastes.
4 Conservation ~ Activities to promote responsible management of natural and
cultural resources. This program focuses on compliance with natural and cultural
resource laws to ensure the wise use and future integrity of valuable natural
resources, such as wetlands, endangered species habitat, and historic and cultural
sites.
2.3.2 Types of Projects
The type of environmental activities encompassed by A-106 can be categorized in many
different ways. The purpose of establishing these various categories is to assist both Federal
agency managers and EPA reviewers in understanding the rationale for the project. Placing
"labels" on projects helps place the project in perspective relative to the overall environmental
program. Originally A-106 concentrated primarily on "brick and mortar" projects, which included
major and minor construction projects, design, equipment purchases, repairs, maintenance, and
remediation. As new laws and regulations were promulgated, it became evident that inventories,
assessments, studies, surveys, audits, monitoring, testing, laboratory costs, etc. were also costly
expenses that should be included. Finally, some Federal agencies were adamant that if A-106 were
to completely reflect the actual costs of the environmental program, program management costs,
including personnel costs, travel and per diem, supplies, equipment, leases, permits, fees and other
management costs should also be reported. These additional categories of costs have now been
included as acceptable data entries. Program management costs are further discussed in section
2.6.1.
Other categories of costs to be reported in A-106 include capital costs, operating costs,
program definition costs, training costs, and the costs of research and development. Each of these
categories will be described in more detail throughout the remainder of this document. However,
the most comprehensive description of the types of projects to be reported is contained in
Appendix A, where 68 categories of environmental activities are listed and defined.
2.3.3 Size of Projects
There is no limit on the size of projects that can be reported in A-106. However, to the
extent feasible and practicable, small projects of less than $1,000 within a single ECAT should be
aggregated or "bundled" into a larger project. Centrally managed programs and/or projects which
have multi-facility impact (i.e., cross facility borders) may also be entered. These entries will
normally be made at the Bureau/MACOM or Departmental level. This procedure has been
implemented to facilitate planning, programming, and budgeting for future years, when specific
2-5
October 1994
WJW^AWWAWJtftWiftWjWMVW.^^
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details of newly required programs may not yet be available. At the time of entry, the program
may or may not yet be funded.
2.3.4 Appropriations and Non-Environmental Funding Accounts
Federal agencies should identify all of their environmental requirements without regard to
their chargeable appropriation. All environmental requirements regardless of funding account
(i.e., not just funds controlled by the environmental office) should be reported in the A-106
Database. Federal agencies must notify EPA when new account codes are added, in order for
those changes to be reflected in the computer software. Current funding account codes are found
in Appendix G. In addition to the funding account codes, which have always been reported, data
elements have been added for two additional account numbers. The first is the internal program
element code which the individual Federal agency uses to identify costs of it's various programs.
The second is the appropriate eleven-digit Federal Budget Account Identification Code (assigned
by OMB) number that applies to the project. This number is defined in Section 20 of OMB
Circular A-ll, dated July 1994. These additional account numbers have been added to cross-
walk and correlate A-106 cost data with Federal agency budgeting and obligation numbers.
2.4 PROJECTS AND ACTIVITIES NORMALLY EXCLUDED FROM THE A-106
PROCESS5
Although EPA would like to capture most of the costs associated with environmental
programs through the A-106 process, there are limits to the types of costs that Federal agencies
can or should enter into the system. These limitations are inherent in the way individual Federal
agencies organize and structure their environmental programs and their accounting systems.
Although there are specific procedures laid out clearly in a number of GAO and OMB
publications,6 each Federal agency has some discretion in determining how it will classify their
expenditures. This flexibility is understandable because of the wide variation in the way various
Federal agencies conduct their business. The difficulties associated with trying to identify all
environmental costs should be evident in the following paragraph largely taken from GAO
Publication GAO/AFMD-2,1,1, "A Glossary of Terms Used in the Federal Budget Process,"
dated January 1993.
The Federal budget functional classification system groups budgetary resources so that
expenditures can be presented according to the national needs being addressed. To the extent
feasible, functional classifications are made without regard to agency or organizational
* If a Federal agency's internal policies conflict with this guidance, it should so indicate in its semiannual transmittal
letter to EPA.
6 Both the Object Classification System and the Budget Functional Classification Systems (described in OMB
Circular A-l 1) are usefiil in classifying and defining the types of costs that may be incurred in managing for
environmental compliance.
2-6
October 1994
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distinctions. Each Federal activity is placed in a functional classification that best defines the
activity's most important purpose even though many activities serve more than one purpose. This
is necessary so that the sum of the functional categories equals the budget totals. National needs
are grouped into 17 broad areas, each of which has two or more subareas. The area of most
importance to EPA is Functional Classification Code 300, that groups expenditures dealing with
Natural Resources and Environment. Natural Resources and Environment is defined as
"developing, managing, and maintaining the nation's natural resources and environment.
Excluded are the outlays for community water supply programs, basic sewer systems, and waste
treatment plants, all of which are part of a community or regional development (rather than an
environmental enhancement) program or are part of the cost of operating a federal facility (such
as a military installation)." Natural Resources and Environment contains five subareas: water
resources, conservation and land management, recreational resources, other natural resources,
and pollution control and abatement. Pollution control and abatement is defined as "controlling
and reducing air, water, and land pollution, or enhancing the environment. Excluded are water
resource programs, water treatment plants, and similar programs that are not funded as part of an
environmental enhancement activity."
-*:
V
Clearly many environmental costs are
identified and reported somewhat differently by
each Federal agency. The fundamental issue is
whether the cost to be incurred is considered
"the cost of doing business" or an "incremental
environmental cost". Each Federal agency will
answer these questions differently and classify
the cost accordingly. Notwithstanding these
inherent institutional barriers, EPA still endorses
the concept of capturing as much of the total
cost of Federal agency environmental programs
as practicable. The following paragraphs in this
section are an attempt to clarify these issues, by
providing additional direction on the types of
projects which may reasonably be excluded from
A-106.
Incidental Environmental Requirements
Incidental environmental requirements
associated with large construction or equipment
procurement actions may be excluded from A-106. However, if the environmental portion of a
non-environmental project is significant and identifiable, it should be entered into A-106, citing
the appropriate program element and funding account codes. Conversely, significant and
identifiable non-environmental portions of environmental projects should be excluded from
A-106.
>»v
costs.
5
V%
2-7
October 1994
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Routine Recurring Maintenance or Operating Costs
Routine recurring maintenance and repairs or minor construction not required to ensure
compliance with environmental standards are not required to be reported in A-106. These costs
normally are captured in other facility engineering accounts.
Therefore, most routine recurring maintenance and operating7 costs are usually excluded
from A-106. As an example, costs to operate and maintain a scrubber on a smokestack would not
be reported. However, the additional costs of operating solid waste landfills incurred as a result
of increased regulatory requirements (i.e., ground water monitoring) under subtitle D of the
Resource Conservation and Recovery Act (RCRA) should be reported in A-106. The cost of
Hazardous waste disposal operations are considered environmental costs and should be reported
in A-106.
Operation of Utilities
In many cases, Federal agencies fund environmental requirements as a part of other major
programs rather than through their environmental accounts. The management of utilities,
including water treatment, waste-water treatment, and solid waste management activities
frequently fall into this category. The extent to which these requirements can be or should be
included within A-106 is sometimes a difficult issue to resolve. Some Federal agencies include all
of the costs of operating waste-water treatment plants, drinking water treatment facilities, and the
costs of solid waste disposal, as environmental requirements and report all operating costs in
A-106. Other agencies report only the incremental costs of achieving environmental compliance,
and consider all other operating costs of these programs as the costs of running a utility. If the
primary purpose of the proposed activity is related to the routine cost of operating a utility, it may
be, but does not have to be, reported as a project in A-106. Federal agencies should inform EPA
of the approach they plan to take on this issue.
Repair Costs
Repair costs not associated with environmental standards or enhancement of the
environment should not be included in the A-106 Database. For example, replacement of
windows at a wastewater treatment plant or replacement of pumps as part of normal maintenance
is not an environmental project. However, the replacement of pumps, as a part of upgrading the
treatment process in order to meet increasing environmental standards, is considered an
environmental cost and should be reported. The caveats expressed in the section on operation of
utilities also apply here.
7 The term "maintenance and operating" costs is used here in the generic sense, as opposed to "Operation and
Maintenance (O&M)" as a funding account code.
2-8 October 1994
j^
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Hazardous Materials Storage or Disposal Facilities
Projects for construction, repair, and/or upgrading of hazardous materials storage are the
cost of doing business and are not normally considered environmental projects. However, if they
are determined to be valid pollution prevention projects, they may be entered into the A-106
database. Construction and/or upgrading of hazardous waste storage facilities and pest control or
PCB facilities required by the Toxic Substances Control Act (TSCA) or the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA) have been included in the past and should continue to'be
included.
Certain Types of Natural and Cultural Resources Activities
Most land management programs should not be reported as environmental projects. Only
the "environmental" increment of land management and conservation programs should be
identified as an environmental requirement. For example, graveling a road is normally a standard
engineering practice, and not environmental mitigation, regardless of the incidental benefit of dust
abatement. Costs of maintaining vegetative cover and mitigating erosion is normal grounds
maintenance, and should not be considered an environmental cost, unless it is specifically being
done to protect water quality or as part of a remedial clean-up activity. Additional information on
inclusion of natural and cultural resources program requirements may be found in section 2.6.4.
Other Exclusions
In addition, the following activities should also be excluded from A-106:
4 Repair or maintenance of historic facilities;
4 Routine pest control operations;
+ Fish and wildlife management for hunting, fishing, trapping or other recreational
purposes; and
4 Routine grounds maintenance such as grass mowing and landscaping performed
for the purpose of aesthetics.
2.5 PROJECT CHARACTERIZATION
One of the great attributes of the A-106 system is the capability to analyze a large quantity
of environmental data, using various combinations and permutations of parameters reported by
the initiating organization. Organizing the A-106 database by assorted project categories
provides Federal agencies, EPA, and OMB with a significant capacity for analyzing Federal
agency environmental programs. Federal agencies characterize each of their A-106 projects
utilizing various parameters within the following five major categories:
2-9
October 1994
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4 The major statutory and regulatory authorities which govern the projects
4 Environmental category
> Compliance status
4 Facility, Bureau/MACOM and Federal agency priorities
4 Types of costs and funding accounts.
2.5.1 Statutory/Regulatory Authority8 9
The primary categorization of projects in A-106 is by statutory authority.10 Projects
should be placed into the most appropriate category corresponding to the major environmental
law or regulation driving the need for the project. It is important that agencies report the
appropriate statute for projects, because EPA and OMB analysis is largely conducted on a media-
specific basis. In addition, EPA's Regions are organized by media, and the capability to sort on
the appropriate law or regulation facilitates the review process.
One of the great attributes of the A-106
system is the capability to analyze a large
quantity of environmental data, using various
combinations and permutations of parameters
reported by the initiating organization.
Environmental issues to be
addressed at a facility sometimes overlap
statutory boundaries, and as a result, a
project could be based on more than one
environmental statute. In the past, these
projects were categorized as multi-media.
This procedure has been changed so that •Mi^B^"^™!^^™^"^"'^"^"1^"^"1™
now, Federal agencies must place these
projects in the most appropriate single media category. Where practicable, subunits of larger
projects with overlapping statutory drivers may be broken out into identifiable units and reported
within the appropriate statutory category. Only program management, auditing, and training are
reported as multi-media projects.
8 The various statutory/regulatory authorities are listed and described in Appendix A.
9 The terms "statutory/regulatory authority" and "law/reg" are used interchangeably throughout this guidance. The
term also includes Presidential Executive Orders which have time-driven environmental requirements.
10 A good resource for assistance in identifying regulatory requirements is the EnviroText Retrieval System
(ETRS), which contains all Federal and State environmental laws and regulations, Federal agencies' policy and
guidance, and many other data sets of environmental and occupational safely and health requirements. Developed
through a cooperative effort of several government agencies, Envirotext is a highly sophisticated system and can be
queried/searched using key words. For assistance in using ETRS, contact the EnviroText Support Center (ESC)
(Tel. 1- 800-NET-ETRS) for further information.
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October 1994
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2.5.2 Environmental Category u
ECAT is a term used by EPA to delineate subsets of environmental laws and regulations.
ECATs may be considered synonymous with program or sub-program areas. ECATs are used to
identify major environmental areas, a unique environmental activity, a phase of an environmental
project, or categories of pollutants to be controlled. As of this time, 68 ECATs have been defined
and cataloged. ECATs may change over time as new requirements are promulgated, and they
also may be eliminated as old programs are integrated into new initiatives.
ECAT is one of the most useful data elements in A-106 for organizing types of projects.
ECATs make up the major components of most media programs. Many Federal media program
managers use ECATs as the primary sub-elements of their programs, and establish their program
goals and objectives around them. EPA uses this data element to identify specific project types
for additional analysis, for special reports, and for detailed budget reviews. ECATs are
considered a mandatory data element which must always be filled in. If a projects does not fit
neatly into an existing ECAT, the most applicable ECAT should be selected.
2.5.3 Compliance Status
All projects and activities reported in A-106 must also be classified according to their
Compliance Status. EPA has established a system which sorts compliance status into five distinct
classes and eleven different compliance categories. Placing programs in the correct compliance
class is the first step in establishing the relative importance of a project or activity. Although
compliance status alone does not establish a project's priority, this parameter is a significant factor
in determining the necessity for and timing of the project or activity.12
As part of its review, EPA will confirm
the compliance class assigned by the Federal EPA'S most important role in the A-106
agency. EPA Regional reviewers will determine process is to validate Class I projects.
whether the scope of the project proposed by ^"••^^^^^^^^•"••^^^^^^^•^M"
the Federal facility addresses all relevant
compliance issues. During a review, the project is correlated with information in the FFTS and
with other Regional media compliance tracking systems. Reviewers check the compliance status
of the facility being reviewed and ensure that all instances of noncompliance have been covered by
some type of remedial action. EPA reviewers pay particular attention to the compliance
classification of each project in the Federal agency plan. Class I projects are considered "must
fund" projects. If a valid Class I project is included in an agency plan and no planned funding is
reflected, the installation is contacted and the problem discussed. If no progress is made toward
11 Several variations of the list of ECATs is presented in Appendix A. The first list is an alphabetical list. The
second list groups the ECATs by law and regulation. The third list provides definitions of each ECAT. ECATs were
formerly called Pollutant Categories (PCATs).
12 See Tables 2.5 and 3.7 for illustrations of the relationships between compliance classes, compliance categories,
and project priorities (explained in Section 2.5.4).
2-11
October 1994
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resolution of the problem at the local level, a recommendation that the project be amended is
forwarded for appropriate action to EPA Headquarters.
With the issuance of this guidance, two new compliance classes have been added to this
data element, bringing the total to five. This was done to accommodate the increasing scope of
the A-106 process to include the costs of managing environmental programs and the costs of
environmental activities which are required, but do not have statutory or regulatory deadlines.
The five compliance classes and eleven compliance categories are explained in the following
paragraphs.
Class 0 (Environmental Management)
Class 0 is defined as those activities necessary to cover the administrative costs, personnel
costs, and other overhead costs associated with managing environmental programs. All activities
reasonably or closely associated with specific functions or activities should be included in those
functions rather than being listed as part of general management.
+ Program Management (PGMT).13 Projects described as "program management"
are those expenses that are essential for the general management of the
environmental program. In the past it was frequently very difficult to determine
which compliance status code should be assigned to these expenses. They seldom
fit neatly into any of the three existing compliance categories. To accommodate
the diverse methods Federal agencies use to track these costs, EPA suggests
several different ways of reporting. If an agency collects program management
costs through A-106, the agency can report costs at the level the data is normally
available. If an agency does not collect program management cost data in A-106,
the agency can report the total amount allocated for program management as a
single A-106 project entry at the appropriate organizational level. Federal
agencies should thoroughly explain their methodology and rationale in the
narrative section.
ClassI (Compliance Related)
Class I projects are needed at Federal facilities that are currently out of compliance (even
if they have never been inspected by a regulatory authority), have received an enforcement action
from EPA, the State, or local authority, and/or have signed a compliance agreement or received a
consent order. Class I projects are subdivided into three compliance categories:
4 Compliance Agreement (CMPA). Projects required to support a signed
Compliance Agreement, Consent Order, Federal Facility Compliance Agreement
(FFCA), Interagency Agreement (IAG), or equivalent state enforcement action.
11 See Section 2.6.1 "Program Management" for additional information on and a more detailed discussion of
program management.
2-12
October 1994
/iAMMVW^W
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Includes pollution prevention projects required as a condition of, or resulting from,
an EPA/state enforcement action or agreement. Also includes conservation
activities required by written agreements with Federal, State, and/or local agencies.
Inspections or Notices of Violations (INOV). Projects to correct deficiencies cited
on an inspection, Notice of Violation (NOV), Notice of Non-Compliance (NON),
or an equivalent enforcement document, by a regulatory authority.
Established Standard and Deadline Past (ESDP). Other projects that should be
funded immediately because a statutory or regulatory deadline has passed. Includes
pollution prevention projects required to comply with the Pollution Prevention Act
(PPA), Emergency Planning and Community Right-to-Know Act (EPCRA), and
the deadline specific
requirements of Executive
Order 12856. Also includes
conservation projects essential
for compliance with past
statutory or regulatory
deadlines, and for procedural
requirements where violations
already exist. ESDP projects
should cite the specific
regulatory deadline violated in
the A-106 project narrative.
The date that the facility
should have been in
compliance should be entered
in the "Final Compliance
Required" field.
Class II (Future Compliance)
Class II projects are needed at
Federal facilities that are not out of
compliance at the present time, but will be in
the relatively near future if projects are not
implemented prior to some established future
deadline. Class II projects are often difficult
to plan because standards may not be firmly
established, and regulatory agencies may not
have conducted facility inspections, which
would have identified specific problems.
However, successful environmental managers
anticipate new and changing requirements,
2-13 October 1994
Oass ft projects are seeded it Federal o% -
ftfJJjVJJJi.SVAW^JJ^^^j'JJJ^J^jV^ji^jjjj^ft^j^^^/jj^^j^j^/jjjjj^.^^
-------
and plan for them accordingly. Periodic environmental audits are useful for this purpose. Class II
projects are subdivided into two compliance categories:
4 Established Standard and Deadline in the Future (ESDF). Projects to correct
situations in which conditions do not meet established standards, but the
compliance date which has been established is in the future. Includes pollution
prevention projects required to comply with the PPA, EPCRA, and the deadline
specific requirements of Executive Order 12856.
4 Pending Standard and Deadline in the Future (PSDF). Projects to correct
conditions where there is a proposed standard or agreement that is not being met,
and the compliance date, which may or may not have been established, is in the
future. Includes clean-up projects for which no agreements have been signed, but
which are in a defined program. Also includes clean-up projects at facilities with
signed agreements, but which are not on any current time-line.
Class II requirements differ from Class I in that facilities with Class II requirements are not
out of compliance at the time the A-106 is updated. However, the facility will be out of
compliance, unless funding occurs in time to complete the remediating project prior to the date
the facility becomes subject to enforcement by regulatory authorities. Therefore, a sustained
effort must be made to ensure these projects are included in Federal agency budgeting and
programming actions.
The highest priority should be given to those Class II projects that will become Class I if
not executed by the end of the budget year (the end of the fiscal year for which budget estimates
are being formulated). Facilities should further explain the legal requirement and the deadline for
each Class II project in the narrative.
Class III (Time-Sensitive)
Class HI consists of important environmental activities that are not related to immediate
compliance requirements, but are needed to address time-sensitive environmental concerns.
Although facilities with Class in projects are currently in compliance, they have great potential
for going out of compliance in the future if the proposed project or activity is not executed in a
timely manner. Class in projects should be funded to maintain the facility in compliance over the
longer term. Class ffl projects are further subdivided into three compliance categories:
4 Program Definition (PDEF). Projects needed to fully define the various
components of the environmental program (e.g., inventories, surveys, studies,
assessments, planning costs, etc.). These activities are frequently up-front costs,
and are required to determine the extent to which additional actions will have to be
taken, or programs developed. If required to meet date-specific deadlines required
by statute or regulation, these projects should be categorized as Class I or Class II.
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October 1994
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4 Established Standard, Replacement due to Obsolescence (ESRO). The facility
meets established standards, but it needs replacement (in part or whole) or repair
because of obsolescence, or it may go out of compliance in the future. This
category includes projects necessary to upgrade or modernize operational facilities.
It includes projects that use new technology to improve operations or generate
significant cost savings.
4 Established Standard, Replacement due to Expansion (ESRE). The facility meets
established standards, but the capacity needs to be increased or the facility may go
out of compliance in the future. These projects are normally generated by an
increase in size or mission of a facility.
Class III projects differ from Class I and II in that they are not related to an immediate
compliance requirement, although planning and studies may need to be initiated immediately.
Designating a project as Class III does not mean that the project is less important than a Class I or
Class II project, but simply indicates that the requirement is not currently a compliance issue with
EPA or other regulatory authorities. However, the situation may become a problem in the future,
if funding does not occur in a timely manner. As a general rule, unless reference can be made to a
date-specific requirement or deadline in a Federal, State or local law or regulation, or Executive
Order, environmental projects that are otherwise time-sensitive are considered Class III. Class III
projects differ from Class IV in that Class III activities are time-sensitive.
Class IV (Non Time-Sensitive)
Class IV projects are only indirectly related to compliance time-lines. Although Class IV
projects are not compliance-driven and not time-sensitive, they may be a significant part of a
Federal agency's comprehensive environmental program, and should be included in the A-106
database. Class IV projects are divided into the following categories:
4 Established Standard, Demonstrate Leadership (ESDL). Facility meets established
standard, but project is needed for other than compliance reasons (e.g., good
management practices determined as a result of environmental audits or based on
professional judgement). Includes projects to improve operational capability or
efficiency, usually based upon professional engineering judgement. Includes many
conservation and pollution prevention projects not required by law and many
research and development projects.
4 Other Reasons (OTHR). Projects which may be required by environmental statute
or regulation, but are unrelated to compliance regulations. Includes many
environmental projects evolving out of planning-based requirements, and other
environmental projects not identified in any of the previously described categories.
The classification of a project as Class IV is not synonymous with a low priority. Class
IV projects may be as important as their Class I/II/III counterparts. In addition, many Class IV
2-15
October 1994
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requirements, although not compliance driven, must be funded in order to maintain the continuity
of a comprehensive ongoing environmental project or program. For example, hazardous waste
minimization projects are normally classified as Class IV, but are frequently considered high
priority because they reduce future risks and costs. Each Class IV requirement must be
considered for funding on its own merit and prioritized accordingly. Section 2.5.4 "Project
Priorities" elaborates further on how a project can be classified as Class III or Class IV, but still
be considered high priority.
2.5.4 Project Priorities
Effective management of environmental programs requires that proposed projects be
continually evaluated and prioritized. Establishing the relative importance of environmental
projects is one of the most useful functions of the A-106 Process. Federal agencies must assess
each requirement and determine its relevance, based upon a number of factors that are described
below. However, all factors are not necessarily equal. The weight given any factor will depend
upon the particular situation. While projects must be funded to remedy those conditions where a
facility is out of compliance, there are other factors that should also be considered when planning
and executing a comprehensive environmental program. It is essential to identify and emphasize
those other relevant projects that should also be implemented in order to maintain the facility in
compliance over the longer term, and to achieve other goals of the environmental program.
Under previous A-106 guidance, a priority code (High, Medium, or Low) was assigned to
a project depending upon its relevance. However, with this Guidance Document, a new
numerical procedure for prioritizing A-106 requirements is being introduced. Each project will be
given a single numerical score ranging from 1.0 - 9.9. Correlation with the H, M, L system is as
follows:14
Table 2.2
A-106 Priority Score
3.-0
EPA has identified 11 factors that should be considered when prioritizing environmental
requirements. These factors are described in Table 2.3. A more comprehensive discussion of
these factors may be found at Appendix C. As indicated above, all the factors should be
considered, but the weight given any factor will depend upon the situation. In the future, this list
may be individually tailored to specific program areas. In the meantime, Federal agencies are
14 The descriptive terms (High, Medium, Low) will be used throughout this document. They will refer to the range
of numerical scores as displayed in Table 2.2.
2-16
October 1994
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encouraged to refine these guidelines, by developing and publishing their own supplementary
criteria for prioritizing their projects.15
Table 2.3
Factors to Consider when Setting Priorities
M'-W: v""^S ^v. W*JS4 V U
•. "f" 3Ci;*^"T'rd> ™ •••• "•••• \j :
,. ^ ^^JP^M^ l*>*^^ ^ ••••••••••••%« •• :
Regulatory Risk
Risk to Human Health and
the Environment
Pollution Prevention
Conservation
Mission
Federal Agency Directives
and Regulations
Program Management
Program Continuity
Investment Strategy
Professional Judgement
Public Perception
^"""-vij;^;: s ^x^^^^joiap^GKK^: -Cr ^r--.., -^ :;,;,-
Attaining and sustaining compliance with applicable laws and
regulations in the face of changing requirements.
Minimizing human health and ecologic risk.
Achieving goals of the pollution prevention program.
Maintaining a quality natural resource base and integrating the
protection of cultural resources with other programs.
Ensuring a facility's continued ability to perform its primary functions.
Meeting the Federal agency's internal directives and/or regulations.
Developing and sustaining effective management of an agency's
environmental program.
Maintaining the continuity of the Federal agency's environmental
program.
Implementing environmental projects with defined future paybacks.
Successfully planning and executing projects that will improve the
environment.
Avoiding confrontation with regulatory authorities and the public.
In addition to the prioritization scheme described above, this version of the A-106 data
management system provides two additional data fields for validating and recording project
priorities. The first is the Local Priority Code, which is used for recording the relative importance
of projects at each individual facility, installation, or activity. This is achieved by rank ordering
each project (numerically), relative to all other environmental projects currently proposed for
funding by the facility. Having placed projects in a list by their "order of merit", Federal facilities
are prepared to select those projects that are to be funded within the given budget constraints.
Implementation plans are formulated depending upon the level of funding actually expected to be
"Federal agencies are requested to provide EPA with copies of any additional or supplemental guidance they
provide their facilities relevant to prioritization of environmental projects.
2- 17
October 1994
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received. Projects above the "cut line" are considered to be "funded."16 Those below the "cut
line" are considered to be "unfunded." This methodology helps higher headquarters, regulatory
agencies, and OMB examiners understand the magnitude of the backlog of unfunded projects at
the facility, and what additional funding would achieve in terms of environmental compliance or
enhancement.
The second new priority field is the Bureau/MACOM Priority Code, which places all
projects into a hierarchy determined by the Bureau or MACOM. The purpose of this data field is
the same as above. However, EPA recognizes that many Bureaus and MACOMs have hundreds
of projects, and that it would be unreasonable to expect all projects to be placed into a numerical
order of priority. Therefore, it is left up to each Federal agency to devise its own system for
establishing and recording priorities at this level. The only stipulation is that proposed projects
are placed into some kind of relative priority, and that EPA be informed of the methodology.
2.5.5 Meshing Compliance Status with Project Priorities
As already explained, projects entered into the A-106 system are characterized by both
compliance status and project priority. Compliance status alone does not establish a project's
priority. While it is expected that all valid Class I projects will be given a priority in the High
range (7.0-9.9), other requirements must be evaluated individually and prioritized accordingly.
The classification of a project as Class IV is not synonymous with a low priority. A Class IV
project can be given a High rating by an agency, depending on the nature of the project and what
it entails. Some Class III and Class IV projects are as important to the Federal agency as their
Class I and Class II requirements. A matrix of acceptable compliance status and project priority
combinations is shown hi Table 2.4.
'* These terms are not universally accepted. For the purpose of A-106, a project that is "funded" in the outyears
means that the project is "programmed" and has a high probability of receiving funding and execution in the year
indicated, "Unfunded" means the project has not yet been programmed and may not receive funding.
2-18 October 1994
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Table 2.4
EPA Compliance Status Codes
% C&ASS r
0
I
I
I
II
II
III
III
m
IV
IV
€&B$G
PGMT
CMPA
INOV
ESDP
ESDF
PSDF
PDEF
ESRO
ESRE
ESDL
OTHR
•"•^ - ?• % -« •.•.•.•.-.•.•. ^ „..;>..„ ^IVoA™? .... ^ ^^^A&CS&J*.* '/'/'?•
°-* ^.^K&^Lmsm&M£mm&$ r, * * -»
Environmental Program Management Costs
Compliance Agreement
Inspection/Notice of Violation
Established Standard and Deadline Past
Established Standard and Deadline in the Future
Pending Standard and Deadline in the Future
Program Definition
Established Standard, Replacement due to Obsolescence
Established Standard, Replacement due to Expansion
Established Standard, Demonstrate Leadership
Other Reasons
Ffifomiry \
1.0-9.9
7.0-9.917
7.0-9.9
7.0-9.9
4.0-9.9
1.0-9.9
1.0-9-9
1.0-9.9
1.0-9.9
1.0-9.9
1.0-9.9
18
2.5.6 Geographic Initiatives
EPA has established a number of programs for the purpose of addressing the
environmental concerns within specific geographical areas, primarily important water bodies, and
estuaries. Examples include the:
4- Chesapeake Bay Program
4 Great Lakes Program
4 Gulf of Mexico Program
4- Near Coastal Waters Program
17 Although a cleanup site where an IAG has been signed is classified CMPA, or Class I, the LAG schedule
determines the compliance status and relative priority of individual projects within operable units (OUs) at that site.
If an action is not required during the budget year being considered, it may be classified as Class II and may be
given a lower priority. For further information on classifying OUs, see section 2.10.3.
18 See Table 3.8 for coding of geographic initiatives.
2-19
October 1994
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4 National Estuary Program
Narragansett Bay
Delaware Bay
San Francisco Bay
Puget Sound
Long Island Sound
4 Edwards Aquifer
+ Mexican Border Program [North American Free Trade Agreement (NAFTA)].
EPA is also implementing a "Watershed Protection Approach (WPA)" which will establish
working procedures within the EPA Headquarters and Regions, participating states, and other
agencies to focus their existing water pollution control programs to operate in a more
comprehensive and coordinated manner. The WPA concept is not new. However, it has been
applied only to a limited extent in the past (e.g. the National Estuary Program). Federal agencies
are active participants in many of these programs, and as a result, some Federal agencies will have
projects that directly support these initiatives.
Appropriate projects supporting geographic or watershed initiatives should be reported
the same as any other project, but should be identified by using the proper code in the new
Geographic Initiative field. The compliance status and prioritization of the project is dependent
upon the specific wording of commitments made in the IAG signed by both EPA and the Federal
agency. Geographic Initiative projects may be categorized under any of the Environmental
Categories, depending upon the primary purpose of the project.
2.5.7 Latitude/Longitude
Most environmental organizations have begun to configure their environmental data in
some type of spatial orientation. With the advent of Geographic Information Systems (GIS), it
has become essential to standardize the collection of individual locational data sets within the
Federal Government, so that composite maps produced from various sources can be combined to
produce a usable product. EPA participates along with other Federal agencies in the development
of uniform Federal standards.
EPA has subsequently established
an official Locational Data Policy to ensure
the collection and documentation of
accurate, consistently-formatted,
latitude/longitude coordinates as part of all
spatially-relevant data gathering activities.
Under this policy, collection and
documentation of locational information
For additional information on EPA's
approach to spatial data collection and global
positioning systems (GPS), see EPA's
"Locational Data Policy Implementation
Guidance - Guide to the Policy," March 1992,
and GIS Technical Memorandum 3, "Global
Positioning Systems Technology and its
Application in Environmental Programs."
2-20
October 1994
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will be performed for all facilities, sites, monitoring points, and observation points regulated or
tracked by EPA under Federal Environmental laws. This policy does not apply to activities that
are not locationally-based.
The essentials of the EPA Locational Data Policy are as follows:
4- Values for latitude and longitude should be complete to the second. (EPA's goal is
for all agency locational data be accurate to within 25m by the end of 1995.)
4 Data systems should be developed with a format capable of handling
latitude/longitude up to ten-thousandths of a second of specificity to accommodate
more precise measurements likely in the future.
4- The best practicable geocoding technology, currently GPS, be phased in for wide-
scale use by 12/31/95.
4 The method used to determine latitude/longitude coordinates must be documented.
Standard documentation of method is done best by representing the method as a
code and having qualifying data elements for datum and map scale.19 The degree
of accuracy must also be recorded.
kixifidk permits; aad is lively to be pleaded to oth^r media areas,,r, J
r^versm^a^ .,!*","." , \, '
^ - •• ••'•i'- ' s % •• v
19 See Section 3.3 for insiructions on how to enter the proper coding for latitude/longitude.
2-21
October 1994
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2.6 OTHER ENTRIES
2.6.1 Program Management
This revision of the A-106 Guidance Document encourages Federal agencies to include
program management costs in their environmental plans. This change requires further explanation
of how these costs should be entered into the database. In the future, program management costs
will be classified under a new Compliance Status Code (Code "0"), and will no longer be
classified into Compliance Status Codes I, II, or HI. This procedural change applies only to those
activities coded as Multi-Media (MULT) and environmental category PGMT. Program
management costs should also be prioritized using the same criteria as would be applied to any
other environmental requirement. Federal agencies with databases which permit the breaking out
of program management into separate projects can report program management in that way.
However, if a Federal agency does not have this capability, the agency can report the total amount
as a single project entry. If it is not possible for a Federal agency to separate environmentally
related program management costs from other management costs, this entry can be considered
optional. These costs will not be reviewed at the project level by EPA, but will be aggregated and
reported as a separate item of discussion in EPA's report to OMB. These entries will be the basis
for discussion with Federal installations, during periodic environmental review or program review
visits by the Regional Federal Facility Coordinator.
Federal agencies are encouraged to include
program management costs in their environ-
mentdlplans.
Program management costs are
defined as those costs required to manage
environmental programs. They include
personnel and labor costs of environmental
managers and their staffs, travel and per ••••^^^^MMBI^^^^MBU™^^™"!!^^^™
diem, office supplies, computer hardware
and software, leases, permits and fees, and other administrative costs involving resources for
personal and organizational development, and communication. Program management costs
support any or all of the five environmental program categories described in 2.3.1.
Other personnel costs, based on estimated time dedicated to the environmental program,
may be included, as well as costs for contract personnel dedicated to any media specific
compliance category. However, care must be exercised when including these costs as part of the
environmental program management category. Inclusion of costs which are more appropriately
allocated to other functions can readily diminish the significance and value of this parameter. The
salaries of utility plant operator personnel, industrial hygienists, and fire prevention/protection
personnel should not be reported in A-106.
2.6.2 Program Definition
Program definition is a term of art defining a category of information important in the
development of environmental programs. The ability of an organization to forecast requirements
and delineate programs early enough to achieve required funding in a timely manner is critical, and
2-22
October 1994
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is a primary characteristic distinguishing an effective environmental program. EPA believes that
providing Federal agencies with essential information on newly promulgated regulations is the
best technical assistance it can provide. To help accomplish this, EPA has found that it needs to
identify those situations where Federal agencies appear to be unaware of new regulatory
developments, or are slow in developing new or revising old programs to meet the new
challenges. EPA has chosen to identify a separate category of projects and activities that can
provide insight into whether Federal agencies are proceeding at an appropriate pace to ensure
they will attain and sustain compliance with the new regulations. This new category has been
labeled Program Definition, and includes a variety of types of projects which provides Federal
agencies with the information they need to have to proceed with program development.
Program definition includes inventories, assessments, surveys, studies, plans, and
environmental audits, when these are designed to assess a broad program area. It does not
include surveys or studies when focused on a single undertaking or activity.
EPA proposes to make this category a subject of special analysis during the EPA
Regional reviews of individual Federal facilities. Overall Federal agency funding in this area will
be overseen by EPA Headquarters.
2.6.3 Pollution Prevention
Recent legislation, including the PPA of 1990 and EPCRA have shifted the focus of many
Federal agency environmental programs from "end of pipe" to "front of pipe" activities. "End of
pipe" environmental activities are aimed at cleaning up or limiting waste after it is created. "Front
of pipe" activities concentrate on how to prevent and limit pollution before it is created.
Executive Order 12856, "Federal Compliance With Right-to-Know and Pollution
Prevention Requirements," and Executive Order 12873, "Federal Acquisition, Recycling and
Waste Reduction," dictate that Federal agencies establish specific pollution prevention goals,
objectives, plans, and programs.
The most important pollution prevention payoffs occur in arenas where environmental
personnel traditionally have not been big players: acquisition, logistics, operations, and research
and development. The challenge for both EPA and the Federal agencies is to determine an
acceptable methodology for identifying, reporting, and executing pollution prevention projects
and activities, which are not normally funded through traditional environmental accounts or
appropriations. The Federal Interagency A-106 Advisory Committee recommended modifying
A-106 to provide the capability for acquiring the needed information. The new data elements
which have been added and the changes to the old data elements are discussed in the following
paragraphs.
The Compliance Category Codes were rewritten to specifically address pollution
prevention issues. Pollution prevention projects required to support a signed compliance
agreement, consent order, or other EPA/state enforcement action should be identified as Class I.
2-23
October 1994
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Projects required to comply with the PPA, EPCRA, or deadline specific requirements of
Executive Order 12856 and Executive Order 12873 should be categorized as Class I or Class II
depending on the time-frame for execution of the project.
The guidance for prioritizing pollution prevention projects was modified to address the
requirements of the new Executive Orders, and to recognize the monetary savings frequently
achieved from investment in pollution prevention activities.
Three new pollution prevention fields
were also added to the A-106 format. This was
done to encourage Federal agencies to evaluate
every environmental project to determine if it
has a pollution prevention component. The
addition of these new fields will establish the
extent that pollution prevention projects are
being integrated into all Federal agency
environmental activities. In the first two fields,
agencies will indicate whether or not a project
has a pollution prevention component and, if so,
what percent of the project that component
encompasses. In the third field, the agency will
categorize the pollution prevention component
based on the codes in Appendix B.
Finally, there have been several
additions and deletions to the catalog of
ECATs that pertain to pollution prevention.
These are listed and defined in Appendix A.
Most pollution prevention requirements are
coded as POLP. However, pollution prevention
requirements which are required to meet time-
specific requirements of the PPA, EPCRA, and
the pollution prevention Executive Orders, are
coded PPEO. Pollution prevention projects
funded from non-environmental accounts are
coded POTH. Also, a separate environmental
category was added for Ozone-Depleting
Chemicals ODCS.
yMto&J?, r .,-• ---J < ,; "'<
sscmkl be ratskea m tae-
•*•» ff f f f f. f / ffj. """$ %
"'^ff,, FoBution prev-bitiba pro|ects,-wilh
' '
"-" ^ three md five years ©«i tfie Vt
2-24
October 1994
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2.6.4 Conservation of Natural and Cultural Resources
Stewardship of natural and cultural resources is essential to the long-term management of
Federal lands. Federal agencies should give equal consideration for funding of natural and
cultural resource compliance requirements under the planning and budgeting process as other
environmental requirements. Natural and cultural resources laws are primarily planning-based,
and usually do not have the specific deadline dates that are associated with other environmental
laws. Enforcement actions under these laws frequently occur only after fragile resources have
been damaged beyond recovery, and/or the Federal agency's mission has been adversely impacted
as a result of severe restrictions on the use of the installation's land.
The A-106 system provides an established framework for classifying natural and cultural
resources and establishing funding priorities to ensure these resources are protected and
conserved. The classification of natural and cultural resources is compatible with the procedures
previously described in sections 2.5.3 and 2.5.4. The following discussion reviews those
procedures and relates them specifically to natural and cultural resource projects and activities.
Class 0 requirements are the costs of managing natural and cultural resource programs,
including the costs of personnel, equipment and supplies, permits, fees, etc.
Class I includes the following activities: projects for facilities that are currently out of
compliance with conservation requirements, facilities that have been subjected to an enforcement
action, or involve a signed consent order or compliance agreement with the EPA, Fish and
Wildlife Service (FWS). Advisory Council on Historic Preservation, or a State or local
government agency. Projects are Class I if they are necessitated by laws which have set forth
specific requirements and standards that must be met, and the deadline has passed. Deadlines may
be explicitly stated by the law or implied in the following ways: 1) as a numerical date contained
within the law, 2) as a procedural milestone requirement to be accomplished prior to or
concomitant with a specific action, or 3) as a deadline synonymous with passage of the law for
cases where specific requirements are explicitly articulated and uniformly imposed on Federal
lands.
Class II includes conservation requirements at facilities which are not currently out of
compliance, but if not funded in the appropriate year, will go out of compliance before the project
can be completed. Projects which should be accomplished, but can be delayed to a subsequent
year without the facility going out of compliance, may be given a lower priority rating.
Environmental managers should review Class I and II projects closely to ensure they meet the
definitions specified above.
Class III consists of activities to prevent or reverse significant degradation of ecosystems
that are not related directly to immediate compliance concerns, but are nevertheless time-
sensitive. These activities include audits, surveys, studies, monitoring, and inventories essential to
identify requirements, define programs, and prepare plans. It includes studies and surveys to
identify and inventory fish and wildlife, cultural resources, and forest resources. It also includes
2-25
October 1994
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other projects (including design, construction, repair, etc.) necessary to sustain the current quality
of natural and cultural resources and ensure the availability of quality land for present and future
land use requirements that should be funded within the next two budget years.
Class IV includes other program initiatives, projects, and "good management practices"
which are not driven by legal requirements, and do not meet the time-sensitive criteria of Classes
I, II, and III. Includes preparation of management plans when not legally directed or committed to
by law or person of authority. Also includes investments to enhance or interpret the natural or
cultural environment.
The funding priority of conservation projects is determined largely by individual Federal
agency policy. EPA's concern is primarily with those requirements relating to the National
Environmental Policy Act (NEPA) and the Clean Water Act (CWA). EPA is currently in the
process of arranging for review of natural and cultural resource projects by the appropriate offices
within the Department of Interior.
2.7 PROJECT CHARACTERIZATION SUMMARY
As has been discussed in the previous paragraphs, environmental projects and activities are
characterized in A-106 in many different ways. While this understandably makes the task of
properly entering projects into the system more time-consuming, the capability to sort the data in
many various ways makes the A-106 a very powerful analytical tool. While some extra effort
must be spent entering the additional information, this investment saves time later by making it
unnecessary for additional data calls.
Although the rationale for the various categories should be self-evident, the reason for
several redundancies in characterizing projects may not be readily apparent. In several cases, the
categories overlap because they are not mutually exclusive. This occurs when a functional area
appears as a subcategory under two or more major categories. As an example, training is both a
"Type of Cost" and an "ECAT." Pollution prevention is both a "Law/Regulation" and an
"ECAT." Program management is a "Type of Cost" and an "ECAT," and because it is the only
sub-category under Class 0, it is to some degree a "Compliance Status." These relationships are
shown graphically in Table 2.5. This redundancy is currently necessary in order to ensure that any
combination of sorts of data will result in all projects being tabulated. If projects are
characterized correctly, there should not be any inadvertent gaps when analyzing and summarizing
the data. EPA is currently exploring better solutions to this problem through the use of improved
software.
2-26
October 1994
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Table 2.5
Project Characterization Summary
?eNM>?|^, j
s v.% * •" *"' "" '•'•'•^ '
Program
Management
Program
Definition
Training
Pollution
Prevention
--s^ ,,,,,, , "^r-^ ----- --' ---XK%^
-- "V^ ^CJ^SSlF^M^FAitAMmTlKS. ^ ,
Major
Program Area
XX
Type of Cost
XX.
XX
XX
Law/Reg/EO
XX
ECAT
XX
XX
XX
Compliance
Class
XX
XX
2.8 TYPES OF PROJECT COSTS
For the purpose of tracking the costs of environmental activities, EPA has defined eight
A-106 cost categories. The purpose of these categories is to:
Assist in identifying "brick and mortar" projects costs.
Distinguish planning activities and studies from remediation projects.
Differentiate between major and minor construction requirements.
Distinguish between capital and operating costs.
Identify research and development costs.
Capital Costs
Capital costs include new construction, procurement of major equipment, as well as both major
and minor construction at existing facilities to meet new environmental standards. Where
applicable, cost estimates of construction projects must be within the parameters (dollar
limitations) established by statute or regulation for the type of construction being programmed.
These restrictions may vary for different Federal agencies. Federal agencies should inform EPA
of these limitations.
2-27
October 1994
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Operating costs include both major and minor repair (e.g., replacement of pumps to
upgrade treatment processes), supply and material expenses, process and equipment changes,
product modification, monitoring, laboratory, and disposal costs. Repair costs not associated
with environmental standards (e.g., routine maintenance such as replacement of pumps as part of
normal maintenance) are not environmental costs and should not be included in A-106.
Mitigation/Remediation Costs
Mitigation/Remediation costs within clean-up programs are defined to include remedial
designs (REMD), remedial actions (RA), or removal actions. For other media programs, these
costs are mitigation costs which do not otherwise fit the definitions described above. The purpose
of this category is to distinguish physical activity from planning and studies.
Program Definition Costs
Program definition costs include the costs of inventories, assessments, plans, surveys,
Studies, and environmental audits. Program definition costs normally are allocated to a specific
environmental law/regulation and ECAT. These costs include preliminary assessments/site
investigations (PA/SI) and remedial investigations/feasibility studies (RI/FS) at sites either
proposed or listed on the National Priorities List (NPL). The purpose of this category is to
distinguish planning and studies from physical activities.
Program Management Costs
Program management costs are those costs required to manage environmental programs.
They include personnel and labor costs of environmental managers and their staffs, travel and per
diem, office supplies, computer hardware and software, leases, permits and fees, and other
administrative costs including resources, organization, communication, and training. Additional
discussion of program management can be found at 2.6.1.
Training Costs
Training costs include the training of both environmental and non-environmental personnel
(the appropriate internal funding codes should be cited). As a change from past practice, training
costs are no longer allocated to a specific statutory or regulatory area, but are reported under one
ECAT.
M The term "operating cost" as used here is not synonymous with the O&M appropriation account. Although
most, if not all of these costs are funded out of Federal agency O&M accounts, the O&M account in most agencies is
also used to fund many of the other environmental costs defined in this section.
2-28 October 1994
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Research and Development (R&D) Costs
Research and development costs which directly support environmental research and
development within the media-specific areas and/or pollution prevention aspects of the
environmental program.
Other Costs
Other reportable costs that cannot reasonably be classified in any of the categories defined
above.21
2.8.1 Cost Estimating
22,23
Providing reasonable estimates of costs is essential for maintaining the integrity of data in the A-
106 system. While firm engineering cost estimates are needed for actual project design, or
construction, this may be difficult to achieve when planning for projects two or more years in the
future. Using a good cost estimating procedure is a timesaving and acceptable alternative for
developing future year requirements. Federal agencies should develop algorithms and other
approximating procedures for use by their facilities in estimating project costs for programming
purposes.2425
2.9 THE BUDGET
2.9.1 Program Phases
The fiscal year is the Government's accounting period. It begins on October 1st and ends
on September 30th, and is designated by the calendar year in which it ends. For management,
planning, and budgeting purposes, the A-106 process is divided into five time segments:
21 For questions about costs related to environmental programs or projects that are not defined above, please
contact the Regional Federal Facility Coordinators listed in Appendix J.
22 For guidance on projects and costs excluded from A-106, see section 2.4.
23 Type of cost is a new category to be coded in A-106. See 3.4.
24 For additional help in estimating costs, EPA's Office of Research and Development published "A Primer for
Financial Analysis of Pollution Prevention Projects" prepared in April 1993 by the American Institute for Pollution
Prevention. Document number EPA/600/R-93/059.
25 EPA is currently in the process of developing a Cost Estimating Guide that will provide additional information.
See Appendix E for an example of how aggregated historical cost data can be useful in reviewing and evaluating
new A-106 project submissions.
2-29 October 1994
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4 Past year (PY) - The fiscal year immediately preceding the current year. The last
completed fiscal year.
4 Current year (CY) - The current fiscal year. The fiscal year immediately
preceding the budget year. The year of execution.
4 Budget Year (BY) - The next fiscal year for which estimates are submitted.
4 Budget Year+1 (BY+1) - The fiscal year following the budget year. The
President's budget year.
4 The Future Years or Outyears (BY+1 through BY+6) - The first through the sixth
fiscal year following the budget year.
The data in A-106 is used for different purposes depending upon which of the time periods
is being addressed. The Federal agency environmental manager must thoroughly understand
his/her agency's management, planning, and budgeting system and ensure that the data reported in
A-106 is integrated into that agency's budget process.
The primary purpose of A-106, for projects scheduled for implementation during the
current fiscal year, is to ensure that those projects for which monies have been budgeted actually
get funded. Once the current fiscal year begins, funding is usually a "zero-sum game," which
means that no new money is normally available. Funds for new environmental requirements that
develop during the current year must come from other uncommitted environmental funds, or from
some other non-environmental programs.
A-106 plays an important role in identifying and defining those projects that managers feel
must or should be funded. The project progress code (described in Section 3.4) is updated
throughout the year. Toward the end of the year, additional projects are readied so that if year-
end funds become available, they can also be funded. Projects that remain unfunded after the end
of the fiscal year are reexamined, reprioritized, and shifted to later years (and the A-106 updated).
For the budget year, the purpose of A-106 is primarily to reprioritize and reprogram
projects consistent with funding levels provided by OMB and/or expected to be received from
Congressional appropriations. The budget will have been built on requirements that in all
probability will be nearly two years old. In the meantime, the priority of some of these projects
may have changed. Some projects may have been completed. For various reasons, other new
high priority projects will have arisen.
For BY+1, the emphasis of A-106 is on developing information for the Federal agency's
budget submission to OMB, and formulation of the Presidents budget (to Congress). For
example, the environmental portion of the FY 1997 President's budget will be prepared during the
Fall of 1995 using information from the Federal agencies September 1st 1995 budget submissions.
Budget estimates should reflect the judgment of the agency head regarding the scope, content and
2-30
October 1994
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quality of the environmental program and activities that are being proposed to meet the agency's
environmental goals and objectives.
2.9.2 Multi-year Budget Planning
The A-106 process and other procedures used to develop the President's budget and the
Congressional budget are designed to ensure that the long-range consequences of budget
decisions are identified and reflected in the budget totals. The President's budget includes
multiyear planning estimates for 4 years beyond the budget year. Congressional budgets cover a
5-year period.
The outyears (BY+1 through BY+5) component of the A-106 process involves the
greatest amount of forecasting. Most Federal agencies have difficulty predicting outyear
environmental requirements, because the budget estimates have to be projected so far into the
future. However, Federal agency budgets begin to take shape many years in advance, and
environmental requirements must compete with agency mission requirements every step of the
way. It is important that every effort be made to identify these outyear environmental
requirements in both Federal agency programming and budget documents as well as the A-106
Report. The data in the A-106 Report is used by EPA and OMB to ensure that Federal agencies
are projecting future environmental requirements adequately, and to support and defend future
Federal agency resource requests based on realistic projections of needs.
The outyear portion of A-106 covers the five fiscal years beyond the President's Budget
Year. For example, the FY 97-01 outyear portion of a Federal Agency's A-106 Plan will be
prepared during FY 1995. The purpose of the multi-year planning estimate is to enable the
President to evaluate the long-term consequences of proposed program initiatives and to make
decisions in that context. This portion is updated every year and should be developed in
conjunction with the Federal agency's environmental strategy and action plans.26 The estimated
costs of implementing these plans should be reflected in A-106. As a minimum, each project
should have estimated costs through the construction or work completion date. If the project is
not funded and the completion date is slipped, this should be reflected in the database and
additional outyear funding reflected.
Several methods may be used to identify and program for outyear requirements:
+ Ensure all recurring costs have been identified, i.e. salaries, travel, other program
management costs, training, hazardous waste disposal, spill plan requirements,
periodic testing and/or monitoring, permits, fees, etc.
26 The failure to forecast and to program for outyear requirements is the primary reason for under-funding of
environmental programs, which frequently results in less than optimal compliance rates.
2-31 October 1994
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4 Ensure all known non-recurring projects are entered, i.e. Federal Facility
Compliance Agreements and Interagency Agreement requirements, audit findings,
self-identified projects, large major repair/upgrades, etc.
4 When scheduling projects, plan to accomplish them before the facility goes out of
compliance. Minimize the number of facilities going out of compliance by
programming projects as Class II high priority, and completing them, before
compliance deadline dates.
4 Forecast and enter projects to meet new or anticipated programs with deadlines in
the outyears. Federal agencies may enter (into the A-106 database) project
estimates for requirements (not necessarily site-specific) based on a rational and
justifiable forecast, analysis, trend, and/or extrapolation of known requirements.
For example, past projects for spill cleanups may indicate a definitive level of effort
from year to year. These surrogate projects must be replaced as actual detailed
estimates become known and are entered into the A-106 system.
2.9.3 Estimated Project Cost
Federal agencies should provide estimated costs for all projects that are needed by the
Federal agency to attain and sustain compliance with all environmental laws and regulations,
and/or achieve other goals and objectives of its environmental program. Three separate cost data
fields are provided so that the cost of projects can be tracked from the time they are initially
planned until funds are obligated or expended when the project is finally executed. By summing
up the costs of individual projects, EPA and OMB determine the total environmental requirements
of Federal agencies, the level of funding requested for any particular FY, and the magnitude of
unfunded requirements (backlog).
A-106 cost data must be coordinated with resource management personnel at
installation/facility, bureau, and departmental levels to assure projects have the proper
appropriation codes, to ascertain expected funding levels, and to ensure facility programming and
budgeting documents reflect the level of funding needed for environmental programs. In addition,
coordination will help determine the correct obligation amounts for completed projects. An
explanation of the four columns representing "Estimated Project Cost" follows.
Fiscal Year
This column should represent the earliest feasible and executable year, consistent with
statutory and regulatory requirements and Federal agency program and budget guidance,
necessary to achieve the objectives of the various Federal agency environmental strategies and
action plans. The year chosen in this column should assure the project will be completed before
the date compliance is required.
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Estimated Cost27
The "estimated cost" column represents the planning phase of the project and may contain
both funded and/or unfunded requirements. Federal agencies should enter their best estimate of
the cost of the project. This number is considered primarily a planning number and will change
with time, particularly for those projects planned for the outyears. The estimates may be adjusted
up or down, as needed, as the year of execution approaches. As the budget year nears, the
estimate of the project's cost should be much more accurate. Projects must be feasible and
executable if funds are attained in the year(s) indicated. Unfunded projects are shifted to later
years. Consistent with statutory and regulatory deadlines, environmental managers should spread
their requirements over an extended period (2 to 6 years) in order to achieve a sustainable level of
funding. Completing this column may require engineering or financial assistance in order to
obtain valid cost estimates. The sum of the entries in this column for all of an agency's projects
should represent the Federal agency's best estimate of their total environmental requirements.
Programmed/Budgeted Cost
An entry in this column means that the project has moved from the planning phase to the
programming or budgeting phase. It means that funds are expected to be available in the Federal
agency's budget to accomplish the project in the year indicated. Environmental managers should
enter their best estimate of the cost of projects for the years in which money is expected to be
received. Funding for projects in the outyears should reflect the guidance contained in the Federal
agency's budgetary and/or programming guidance. The data reflected in this column are the
primary basis for analyses that will be reported to OMB in the annual A-106 Federal Agency
Environmental Management Program Plan Report.
The cost data in the programmed/budgeted column has four different connotations
depending upon the year the cost has been entered. For the current fiscal year, it represents the
amount of funds actually available for the project. For the budget year, it is the amount actually
budgeted and expected to be received for the project. For BY+1, it is the amount of funds
actually requested for the project by the Federal agency in the President's budget request to
Congress. For BY+2 and the other outyears, it represents the amount of funds programmed for
the project and expected to be available, based upon the Federal agency's long-term planning
guidance and funding trends. Completing this column typically requires resource management
assistance.
For the data in this column to be accurate, Federal facilities or activities must prioritize
their projects for each fiscal year, including each of the outyears. Facilities should rank order their
projects in decreasing order of priority, and allocate the funds expected to be received in each
fiscal year in accordance with each project's relative importance. Since it is unlikely that all
projects will be funded, a "cut-line" is drawn under the last project likely to receive funding. The
"cut-line" differentiates those projects which are expected to be funded by the facility's budget
27 The title of this column has been renamed from "required" to "estimated cost".
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from those that are left unfunded. Entries should not be made in this column for projects unlikely
to be funded. The sum of the costs in this column for all projects should equal the total
environmental dollars expected to be available at that facility for that particular year.
Departments and bureaus should provide their facilities with sufficient programming and budget
information to allow their facilities to accomplish this computation for both the budget year and
the outyears.28 If this information is not furnished to the facility, this column should be completed
for each requirement at the bureau level. Failure to fill in this column for projects above the "cut-
line" indicates that the facility/bureau is not adequately "programming" its environmental
requirements.
Obligated
In the "Obligated" column, agencies should enter the amount of funds obligated against
each project, or actually spent on project execution. Obligations are binding agreements that will
result in outlays, immediately or in the future. Obligations reflect the amounts of orders placed,
contracts awarded, services received, and similar actions requiring payments. Budgetary
resources must be available before obligations can be incurred legally. Obligation data for
executed projects should be entered into the A-106 database as soon as it is known, but no later
than the January submission each year. The narrative section of A-106 also should be updated to
include a description of actions completed with the obligation of funds. Completing this column
requires resource management assistance.
2.9.4 Guidance on Estimating Funding
The year selected for funding should reflect a proactive but realistic estimate of the
possibility for executing the project. Preliminary assessments, design, regulatory approval,
permits and clearances, and contract awards must be considered when scheduling the project for
implementation. Facilities must plan for adequate funds for planning and design to ensure that
execution will occur before the date final compliance is required. These up-front costs may need
to be programmed in the year prior to the year the project is expected to be funded for execution.
Normally planning and design requirements will be assigned the same priority and compliance
classification as the project itself. In situations where time or fiscal constraints will prevent
execution prior to compliance dates, a Federal Facility Compliance Agreement containing a
schedule for compliance from EPA or the state regulatory agency may be warranted.
2.9.5 Federal Agency Program Element Codes
Each Federal agency develops its own data elements and codes to be cited in financial
transactions and for use in financial records. These codes are key elements in the budget and
accounting process because they provide discipline and control, and link the appropriation
58 When reporting requirements for outyears, where available cost data is less precise, it is permissible to aggregate
projects or programs within ECATs. As better data becomes available, projects should be taken out of "bundles" and
entered individually.
2-34 October 1994
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structure to the program structure. They also prescribe common data elements for use in the
Federal agency's financial, manpower, personnel, logistics, facility operations, and environmental
management information systems.
This version of A-106 provides a ten-character data field for recording the appropriate
program element account code that defines the project or activity within the Federal agency's
internal financial accounting structure. The purpose of this data element is to make A-106 a true
relational database by providing a link between the A-106 database and other Federal agency
financial data systems.
,29
2.9.6 OMB Appropriation Account Identification Codes
OMB Circular A-l 1 provides instructions on the preparation of Federal agency budget
submissions required for OMB review. Many of the materials required by OMB are in a
computerized format. The MAX budget system (MAX) is the OMB computer system used to
collect and process most of the information required for preparing the budget. Under MAX, data
entry is controlled through appropriation account titles and classifications that are assigned at the
account level. In order to cross walk the information contained in MAX with the data reported in
A-106, the OMB Appropriation Account code has been added as a new data element in the A-106
data management system.
The agency and bureau
codes may be found in
Appendix C of OMB Circular
A-l 1, which is readily available
in agency and bureau budget
offices. The appropriation or
fund account symbol (code)
that identifies the appropriate
program area is available in the
budget office. These codes are
relatively constant, but do
evolve over time. Any changes
are published periodically in
Federal agency financial
management regulations.
Federal agency environmental
managers should provide their
subordinate organizations with a list of the codes appropriate for entry in this field.
Congress provides budget authority by appropriating amounts to appropriations or fund
accounts for a specific period of availability (i.e., annual, multi-year, or no year availability. An
29
See OMB Circular A-l 1, Section 20.3 (July 1994).
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account is established in the Treasury for each successive annual appropriation for a given
purpose under the same or similar titles. However, for reporting requirements m OMB Circulars
A-ll and A-106 appropriations and other types of budget authority provided to an account with
the same or similar titles for the years covered in the budget are considered to be a single account
under a single title.
2.10 ADDITIONAL INFORMATION
2.10.1 Reporting Requirements for Different Types of Facilities
There are many different types of Federal facilities. Identifying those which are required to
identify their environmental requirements in A-106 is not necessarily a simple matter. Federal
agencies often have complex relationships with private parties. Many Federal facilities and public
lands have some level of private party involvement through operation or leasing of the facility or
lands for private use. Similarly, Federal agencies lease private sector buildings and lands for
Government use. Finally, the Armed Services have intricate responsibilities with the States vs-a-
vs their National Guard facilities. Definitions of the different types of these relationships are
presented in Table 3.2.
2.10.2 Tenants
Reporting of environmental requirements on a Federal facility is a joint responsibility of
both the tenant and the host facility. Host facilities should establish formal procedures for
assisting tenants in identifying their environmental requirements. Tenant organizations should
provide information on all their environmental requirements to the host facility environmental
manager. Host facilities should review tenants' environmental requirements on a periodic but
scheduled basis to assure requirements are being addressed.
Federal agencies should establish formal procedures for assisting tenants in reporting
A-106 requirements. Some agencies have their tenant organizations report through the host
facility environmental office. Others have tenants forward the information directly to the parent
organization. Whichever procedure is followed, the methodology should be specified in the
Installation Service Support Agreement (ISSA) or equivalent.
2.10.3 Operable Unit30
Operable unit (OU) is a data element that was added to A-106 to facilitate reporting
cleanup requirements at the Federal Facility sites listed on the National Priorities List (NPL). The
National Contingency Plan (NCP) defines operable unit as "discrete actions that comprise
incremental steps to the final remedy." An operable unit is further defined as one of the
30 See Section 3.4 "Basic Project Information" for additional information on operable units.
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following: a) a separate geographic area of treatment, b) a separate treatment technology in the
same geographic area, or c) a separate phase of response (as described in the National
Contingency Plan, 40 CFR 300).
Under CERCLA §120, EPA and Federal agencies (and others) sign lAGs, which identify
the nature of the problem, the scope of the cleanup and the milestones that must be met. The
work effort identified in the lAGs is divided into various operable units in accordance with the
definitions provided above.
Cleanup projects may be entered into A-106 in two different ways.31 Projects may be
entered individually, or aggregated with other projects in the operable unit and entered as one
project. When entered individually, they should still be identified with the pertinent operable unit
by entering the appropriate three digit operable unit number in the OU field. Since a CERCLA
site may take many years to complete, each operable unit will have many distinct milestones,
different completion dates and a separate funding profile.
At the present time there is no universal priority setting model for establishing funding
precedence among Federal agency cleanup projects. Each Federal agency has established it's
own individual priority system. EPA believes that the A-106 database provides a mechanism for
normalizing the priorities assigned by different Federal agencies, both within and'across Federal
agency lines. Requiring Federal agencies to prioritize their cleanup projects using the three
parameters (A-106 priority score, Bureau/MACOM priority, and local priority) described in
Section 2.5.4 will make it possible to construct both an individual Federal agency and an overall
Federal Government cleanup profile.
2.10.4 Quality Assurance/Quality Control (QA/QC) Procedures
Information received from Federal agencies for entry in the EPA A-106 database must be-
complete, accurate, and properly presented.32 It is the responsibility of each Federal agency to
ensure that the data provided by their facilities is accurate and that adequate QA/QC has been
performed. Depending on the number and types of errors in agency submissions, agencies will be
contacted and requested to correct them. ,
EPA is responsible for the management of the A-106 Program, including assuring that the
data received from Federal agencies is complete. EPA will conduct both summary and
substantive reviews of pertinent sections of A-106 submissions to ensure compatibility with the
goals and objectives of Executive Order 12088 and OMB Circular A-106. The reviews focus on
31 The Department of Energy (DOE) may report activities at the operable unit level or Activity Data Sheet level
(ADS#), whichever is appropriate. •
32 Some of the data elements in A-106 are critical to the review process and must be filled in. EPA has established a
hierarchy which determines the criticality of the data element and establishes the time period for correction of the various
types of errors that may be discovered. Each data element has been assigned a number in the instructions for data entry
in Section 3.2.
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important program areas and significant individual projects that appear to be inadequately
addressed in the submission.
It is helpful if Federal agencies develop Standard Operating Procedures (SOPs) for
validating their requirements and conducting QA/QC of their A-106 data. This will require
coordination among several offices within an agency to ensure accurate reporting. Federal
agencies may find it beneficial to establish an intra-agency A-106 Review Committee consisting of
environmental, legal, financial, and facilities engineering personnel to review the data prior to
submission to EPA. However, a data review should never encumber the process to the point
where a Federal agency fails to submit its A-106 data to EPA on time.
Project Titles
Project titles should depict as accurately as possible the type of work being proposed.
Most computer-generated "quicklook" reports display data without the narrative, so that the only
indication of the purpose of the project is the title. Official terms used in work classification such
as "construct" and "repair"
Proper Cost Entries
should adhere to internal Federal agency definitions of the terms.
All costs entered in the A-106 database are reported in "K" or thousands of dollars. A
hundred thousand dollar cost is recorded as $100.0 not $100,000. Individuals entering project
costs must ensure cost estimates are accurate and reasonable. Federal agencies may want to adopt
algorithms to highlight project estimates that fall outside the expected range for a particular type
of project.
Project Milestones
Project milestone dates are important for planning programs, building budgets, and
following execution progress and tracking compliance. The "Final Compliance Required" date
field should be filled in for all Class I and Class II requirements. This is the date specified in a
Presidential Executive Order, a Federal, State, or local law or regulation, a signed consent order
or compliance agreement with a regulatory authority, or any other regulatory enforcement action.
When a project has been completed, the fiscal year should be entered in the "Fiscal Year
Completed" field, and the "Progress Code" changed to "Completed."
Project Characterization
A-106 data elements fall into five general categories: location of the Federal facility,
location and description of the project, funding information, a project narrative, and various ways
of categorizing the project. Project categories include statutory and regulatory authority,
environmental category, program type, compliance status, priority evaluations, and several other
categorizations. Personnel at the facility level may not folly appreciate the importance of assuring
that all individual unit records are accurate and complete. Proper analysis of the database at
2-38
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higher headquarters levels, EPA and OMB, is dependent upon high quality information. Using
information from thousands of individual projects, EPA generates reports using combinations of
over 25 different parameters. Incomplete or inaccurate information impacts negatively on EPA's
support for funding of Federal agency environmental programs.
Project Narratives
The narrative is one of the most important parts of the submission. It should provide
both the rationale and justification for the project. Information is important to environmental
managers at all organization levels, as well as to EPA and OMB reviewers. Environmental
managers should substantiate the rationale for the compliance status and priority of each of their
projects. Information citing the reason for initiation of the project (such as a NOV, Consent
Order, FFCA, IAG, Executive Order, etc.) should be explained in the narrative description.
Any identifying number appearing on those documents should be displayed in the narrative.
Project narratives should also include a statement of the impact of not funding the project.
Inventories. Surveys, and Studies
Often an inventory, survey, or study should be considered a separate requirement from the
mitigation or remediation projects resulting from the inventory, survey, or study. This frequently
is the case with asbestos, radon, PCB, underground storage tank (UST), and hazardous waste
cleanup programs, where the time elapsed between the study and the remediation project is
substantial. In these cases, it may be appropriate to enter the requirement as two separate
projects.
Recurring Projects and Milestones
Recurring projects (monitoring, laboratory analyses, tank testing, permit renewal) should
be coded "Continuous" (Progress Code 9), and need to be entered only once. There is no need to
create new projects for each year of funding. For projects recurring annually (Progress Code 9
only), the "Final Compliance Required" date does not have to be updated continually. It is
assumed that the date is September 30th of the year in which funding has been programmed or
budgeted.
Automated Procedures
Beginning with the September 1995 update, it is expected that all Federal agency
submissions to EPA will be accomplished electronically. EPA will provide software for those
Federal agencies who have not developed their own system. In the future, it is anticipated that
the A-106 process will be on-line, and it may become possible to update the system on a
continuous basis. Until the system is completely on-line, the goal is to continue to require updates
semi-annually, with quarterly or monthly updates encouraged.
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Federal agencies should consider adopting automated procedures to determine that
information has been correctly entered into those fields that have been designated as critical. The
database should be scanned to reveal those projects whose costs deviate significantly from the
mean/median and acceptable range for that ECAT. An automated edit program can eliminate
many of the data quality problems common to information of this type.
2.10.5 New Information
Detailed instructions for entering data into A-106 are contained in Section 3.0,
"Instruction Kit for Updating Federal Agency Environmental Management Program Plans."
These instructions have been completely revised to reflect the recent changes that have been made
to the A-106 data elements.
Some of the older A-lp
1
added, iadud^p
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INSTRUCTION KIT
-------
-------
3.0 INSTRUCTION KIT FOR UPDATING
FEDERAL AGENCY ENVIRONMENTAL
MANAGEMENT PROGRAM PLANS
3.1 INTRODUCTION
Executive Order 12088 requires Federal agencies to develop and maintain plans for the
control of environmental pollution. OMB Circular A-106 directs Federal agencies to report their
environmental plans in accordance with procedures prescribed by the Administrator of EPA.
These plans are maintained by EPA on a computerized database (FFIS) that is updated regularly
by the respective agencies. These updates provide EPA with the current status of each Federal
agency's environmental program, and the activities necessary to implement it's environmental
plan. Agencies make appropriate changes to current projects, close-out completed projects, and
add additional projects which are needed to achieve the goals and objectives of their
environmental program.
Federal agencies that maintain their A-106 data on an in-house computerized database,
only need to validate this data, and submit an up-to-date computer disk to the Federal Facilities
Enforcement Office at EPA Headquarters. Those agencies that do not maintain a computerized
database must update the computer printout (hardcopy) provided by EPA, that lists all the
projects currently contained in the FFIS database. These printouts reflect the information
previously reported by an agency during the preceding update. This information should be
thoroughly reviewed and verified. Any needed changes should be made directly on the printouts.
An agency that needs to add new projects to its database, but does not submit data in a
computerized format, must submit a completed Agency A-106 Input Form (Appendix O) for
each new project to be added. (Beginning with the September 1995 update, EPA plans to
provide the capability for all agencies to update their submissions electronically.) Detailed
instructions for entering the data and completing the Agency A-106 Input Forms are contained in
Section 3.2.
It is essential that Federal agencies validate the data that they submit to EPA. There are
some data elements that are critical to making the system function effectively. For example, each
new project description must contain the correct Federal facility identification number and a
unique project number. If these numbers are missing, the project cannot be entered into the
database. EPA uses a set of algorithms to check the quality of the data submitted by each
agency. Submissions that are incomplete, have important data elements that are missing, or have
data which falls outside the range of accepted values for a parameter, will be returned to the
agency for correction.
After reviewing the environmental plans, EPA provides feedback to each agency on the
content of their submission. These discussions include suggestions for adding additional projects
to the plan, and recommendations for changes to projects that are already in the plan. During the
review process, EPA Regional Federal Facility Coordinators may contact those personnel listed
as the project point-of-contact, in order to clarify points related to a particular project. In some
3- 1
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instances, a meeting between the EPA review staff and the Federal agency reporting the project
may be necessary to complete the regional review. A discussion of the methodologies EPA
Regions employ to review the data is found in Section 1.4.
The goal of EPA's Federal Facilities Program, and the primary purpose of the A-106
system, is to ensure that all agencies reach a level of compliance with environmental regulations
and requirements that equals or surpasses the rest of the regulated community. Through
management of the A-106 system, EPA helps each agency develop a comprehensive
environmental strategy and the corresponding implementation plans necessary to reach that goal.
3.2 INSTRUCTIONS FOR COMPLETING AGENCY A-106 INPUT FORMS FOR
NEW ENVIRONMENTAL MANAGEMENT PROGRAM PLANS33
The data elements in the A-106 system fall into one of the five following categories:
4 Facility/Installation/Activity Information
+ Basic Project Information
+ Funding Information
4 Project Characterization, and
4 Project Narrative.
This section of the guidance document contains a description of each of these data element
categories. Although all entries SHOULD be completed, some of the data elements in A-106 are
critical to the review process and MUST be completed, or the project cannot be entered into the
system. In these cases, that portion of the submission pertaining to the project will be returned to
the agency for completion or correction, before any information relating to that particular project
is entered into the system. EPA has established a hierarchy, which determines the criticality of
each data element, and establishes the time-period for correction of the various types of errors
that may be discovered.
3J If a software system is not being used, all entries should be printed or typed on the A-106 Input Form, a copy of
which can be found at Appendix O.
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3.3 Facility/Installation/Activity Information.
Each data element described in this section has been assigned a number from 1-3 (shown
in parenthesis) that defines its relative impact on the ability to enter a given project into the system
if the data element is missing. The significance of these priority rankings are as follows:
1 - Project cannot be entered into system without this data. Input must be completed
or corrected immediately.
2 - Project will be entered into system. However, missing or inaccurate data is very
important, and should be completed or corrected within 45 days.
3 - Project will be entered into the system. Missing or inaccurate data should be
completed or corrected during next update.
The remainder of this section discusses the data elements in greater detail.
4 FEDERAL FACILITIES ID (FFID) MJMBER (Element Importance: 1) - This
data element is comprised of three separate elements: the State code +
Agency/Bureau code + GSA installation number.
STATE CODE - Enter the two character code for the State in which the
project is located. The list of State abbreviations can be found in Appendix
H. Enter "XX" for foreign facilities.
AGENCY/BUREAU CODE - Enter the four digit code for the Federal
organization responsible for the project. The first two digits are the agency
code. The second two digits are the bureau code. These codes are listed in
Appendix F. Not all agencies utilize the bureau codes. Those agencies that
do not utilize the bureau code should enter zeros for their bureau code.
(e.g., 1800, 6400, 6800, 9600). Please be careful in selecting the proper
code. All agencies are responsible for maintaining the list of codes in
Appendix F up-to-date. For DOD, the bureau code represents the major
command (MACOM) or other major organization.
GSA INSTALLATION NUMBER - This five digit number is available
from Facility Management Offices, Property Management Offices, or from
EPA Regional Office Federal Facilities Coordinators. The annual
Quarterly Report of Real Property Owned by or Leased to the United
States (GSA Form 1166) is submitted by each agency (usually through
Real Estate and Space Management) identifying each installation where
funds are expended for land, buildings, and other structures and facilities.
A listing of each agency's GSA Coordinator can be found in Appendix K.
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For foreign facilities without GS A numbers, enter a unique five-digit
number which identifies a facility within a particular agency.
DEPARTMENT/AGENCY NAME (Element Importance: 1) - Enter the name of
the Department or Agency responsible for the project, up to 15 characters. Where
possible use understandable abbreviations.
BUREAU/MACOM NAME (Element Importance: 1) - Enter the name of the
Bureau or MACOM responsible for the project, up to 15 characters. Where
possible use understandable abbreviations.
NAME OF FACILITY34 (Element Importance: 1) - Enter the name of the
facility/installation/activity where the project will be implemented, up to 30
characters. Where possible use understandable abbreviations.
STREET MAILING ADDRESS (Element Importance: 1) - Enter up to 30
characters for the mailing address of the facility/installation/activity where the
project is located.
<%& »«a»1$e
" ••'••••' "'"•'
'•^•^ ''•'••. WA -. %% -. V.V,-.-: --\ i "•*"-'<. > >v« f%-\ s:x'- "•
"?: r iteefe &fiii HI
CITY NAME (Element
Importance: 1) - Enter the
name of the locality where the
facility/installation/activity is
located; up to 15 characters.
ZIP CODE (Element
Importance: 2) - Enter the
complete five or nine digit (10
characters) code for mailings to
the facility/installation/activity.
Example: 20310-0600
COUNTRY (Element Impor-
tance: 1) - Enter the three
character code for the country
in which the facility is located.
Codes are listed in Appendix I.
INSTALLATION LATITUDE/LONGITUDE (Element Importance: 3) - Enter
the latitude (10 digits) and longitude (11 digits) coordinates for the installation
using the format described below. It should be the location of one of the most
visible and accessible points on the installation, normally the headquarters building.
w Do not enter the department/agency name unless it is an official part of the facility name.
3-4
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In addition, select the METHOD (procedure), DATUM, and SPATIAL
REFERENCE (appropriate scale of the source map or photo used to determine the
latitude and longitude coordinates) from Table 3.1.
Table 3.1
Codes to Document Methodology of Lat/Long Selection
SM^
A
B
C
D
E
F' '
G
H
I
J
K
L
M
N
S«5j^^V
-------
Table 3.2
Identification of the Regulated Community
of Facilities with Federal Involvement
COM
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
IS
ACfcONfMA
TERltf * ,f
COCO
COCO(E)35
GOCO
GOGO
GOPO
GOSO
JOCO
POGO
POLO
POSO
SOFO
SOSO
FUDS
Leasee
Grantee
Claimant
Patent Holder
Permittee
- •.-," ^ I--- \vu $ s 1vi\ s^W-Ss •• ¥** %\ai5i?iiaiErFj-ft?s vm "' '*
.,,:,•,>:•• a"- ?• « «•• O « 5SS" i S . " . > •• •i.f'f'X-XXf* **»«•* VTO m % , .... •• ,.
' »c s - o- ; ^^w- ifesss--1 r: ^v , „ m *** •«,.. •. ^ ^ %
-. \,' ^ •• 4 v .. - « «, ^ ¥%jy«i^SS i "sS^S^ % v. ««v™ " \..^.i...^..::^.>5.V ?*..£ »..
A non-government owned, privately operated facility that provides goods and/or
services to a Federal agency under contract.
Same as COCO, however, contractor may be furnished government equipment to
manufacture a product or provide a service.
Owned by a Federal agency, but operated in whole or part by private contractor(s).
A traditional facility where the government owns and operates all regulated activity.
A facility where the government has leased all or part of its facility to a private
operator for its operation and profit.
Federally owned/state operated.
Jointly Federally and privately owned/contractor operated.
A facility where the government leases buildings or space for its operations.
Privately owned/Federally leased and operated.
Privately owned/Federally leased/state operated.
State owned/Federally leased/state operated.
State owned/state operated.
Formerly Utilized Defense Sites. Sites may or may not be presently owned by a
Federal agency. However, the Federal agency is responsible for hazardous waste
cleanup as a result of previous operations
Parties granted use of government land by a rental or real estate agreement or title
transfer with a reversionary clause (e.g., municipal landfills, oil and gas, mining).
Parties having received a grant for permanent authorization to use government land or
given a right of way. Grants usually involve a single payment for the land or transfer
of land use rights.
Parties having properly located, recorded, and maintained mining claims under the
1 972 Mining Law on Federal lands for which a patent has not been issued.
A mining claimant who has met the statutory requirements of the 1 872 Mining Law
and has been issued a permit.
Parties granted a permit for short-term use of government land.
35 Only projects related to government owned equipment should be reported.
3-6
October 1994
-------
3.4 Basic Project Information
AGENCY PROJECT NUMBER (Element Importance: 1) - Enter the
identification number of this project (up to ten characters and/or digits). This
number must be dissimilar from any other active or inactive project number
previously used at any facility within your agency. If a second project is
generated with a number that has previously been used at that installation, it will be
automatically rejected by EPA's A-106 quality control procedures. The
combination of FFID and Agency Project Number uniquely identifies a project
within the A-106 system.
PROJECT NAME (Element Importance: 1) - Enter the descriptive name of the
project using up to 50 characters including spaces. The name should portray the
scope of the project as succinctly as possible. This name is the key project
identifier in reports to OMB and Congress. EXAMPLE: INSTALLATION OF
UST LEAK DETECTORS
PROJECT NAME CONTACT (Element Importance: 2) - Enter up to 20
characters giving the name of the individual responsible for, or knowledgeable,
about the status of the project.
PROJECT CONTACT TELEPHONE NUMBER (Element Importance: 2) -
Enter the 12 digit/character commercial telephone number where the project point-
of-contact can be reached. EXAMPLE: 202-235-7896
PROJECT STREET ADDRESS (Element Importance: 2) - Enter the address of
the actual location of the project up to 30 characters.
PROJECT CITY NAME (Element Importance: 1) - Enter the name of the locality
where the project is actually located; up to 15 characters.
ZIP CODE (Element Importance: 2) - Enter the five or nine digit zip code of the
area in which the project is actually located.
BUILDING NUMBER (Element Importance: 3) - Enter up to four characters
giving the building number assigned by the facility engineer. (Use only if
appropriate.)
ROOM NUMBER (Element Importance: 3) - Enter up to four characters giving
the room number assigned by the facility engineer. (Use only if appropriate.)
3-7
October 1994
I.VVVVWiV.V.V^JWV'.V.V^^.VA^^^^
-------
PROJECT SITE LATITUDE/LONGITUDE36 (Element Importance: 3) - Enter
the latitude and longitude coordinates for the site of the project using the same
format presented in section 3.3.
MULTIPLE INSTALLATIONS (Element Importance:!) - Mark "Y" for
programs or activities that are centrally funded and/or include projects at several
different facilities. The purpose of the data element is to encourage the listing of
projects which cannot be precisely related to specific sites at the time of the A-106
update. Do not use this data element for multiple projects at a single installation.
PROGRESS CODE (Element Importance: 1) - Enter the one digit code from
Table 3.3 that describes current project status. NOTE: Entry of the codes for
discontinued and completed will cause the project to be listed as inactive. Only
use codes 5 or 6 if a project actually has been discontinued or completed. If
code 6 is used, an entry also must be made in the "Reason for Discontinuance"
field.
Table 3.3
Progress Codes
CO»g
1
2
3
4
5
6
7
8
9
s -. "• it £ ¥*lkisssSss%sl*st '•'•'•% vf"-^-.-.-.-.-.^\ •,-.•,-.•. •. %•.•.•.
;:ii8lt^^ -
Preliminary Planning (Active Project) - PP
Design (Active) - DES
Construction (Active) - CON
Work ongoing (non-construction) (Active) - WRK
Completed (Inactive) - CMPL
Discontinued (permanently) (Inactive) - DISC
Deferred (Active) - DBF
Other (Active) (discuss in project narrative) - OTH
Continuous (Active) - CNTS
PROJECT MILESTONES (Element Importance: 3) - Projects are tracked using
the following five milestones:
34 This is currently an optional entry for individual projects. It will be used only for specific types of projects
where precise locational information is needed, and even then will be phased in over an extended period of time.
3-8
October 1994
-------
««<«<«W****WWr*VWX«WWW
-------
Table 3.4
Reason for Discontinuance Codes
CODE
01
02
03
04
05
06
07
08
+
• TEEM;"';
Combined
Criteria
Economics
Eliminated
Error
Replaced
Wrong facility
Other
; ;->v-'.,«¥w - -s^-. ^ , ^ .. *s~tyi<»v
?^" *r-^'3&^timmm{m£y™\~:™^ ^-CV
Project scope was combined with another project. Cite the project number it
was combined with in the discontinued project's narrative record. The
combined project's narrative record also should cite the discontinued project
number.
Requirement does not meet the criteria as an environmental project under the
agency's environmental program.
Project discontinued for economic reasons. For example, a project to construct
a new landfill is canceled because of the costs associated with operating and
closing it when full.
The environmental problem addressed by the project has been eliminated
(either before or after partial funding).
Mistakes were made in entering the project which cannot be corrected because
they occur in fields that cannot be modified.
Project was replaced with another active, valid environmental project with a
significantly different scope.
Project does not belong to the indicated installation (i.e., project was initially
entered under the incorrect installation or FFID number).
Other reason not identifies above.
OPERABLE UNIT COLD /ACTIVITY DATA SHEET (Element Importance: 2/.
- The operable unit element is a three digit number normally found hi the LAG, c
may be obtained from the EPA Remedial Project Manager (RPM). If the facility
is on the NPL, all cleanup projects will normally have been aggregated into a finil
number of operable units, and will have been assigned an operable unit number.
This number must be entered for all cleanup projects at facilities on the NPL. Th
field may also be completed for cleanup projects at facilities not on the NPL, if at
operable unit number has been assigned. Leave blank for all other type (non-clea
up) of projects. See Section 2.10.3 for a complete discussion of operable units.
Activity Data Sheet elements are eight digit numbers and are only used by DOE.
:^:."'f'*.*.v.tox.Kww^
3.5 Funding Informati
4 TOTAL CO!
of the total c
$3,546,200.C
.
V
>r
r
te
is
i
n-
Dn
ST ESTIMATE (Element Importance: 1) - Enter the current estimate
ost of the project in thousands of dollars. EXAMPLE:
0 is entered as 3,546.2K
3-10 October 1994
-------
YEAR FUNDING REQUIRED (Element Importance: 2) - Enter the four digits
for the fiscal year in which funding must first be received to comply with
statutory/regulatory requirements of inter-agency agreements.
FEDERAL AGENCY PROGRAM ELEMENT CODE (Element Importance: 3) -
Enter up to ten characters for the program element code used to identify the
project within the agency's financial accounting structure.
FEDERAL AGENCY FUNDING ACCOUNT CODE (Element Importance: 1) -
Enter the appropriate two digit code in Appendix G for the account that the
Agency/Bureau will use to fund the project. Federal agencies must notify EPA of
any additions or deletions to these codes.
OMB APPROPRIATION ACCOUNT IDENTIFICATION CODE (Element
Importance: 3) - Enter the 12 digit OMB account identification number that
applies to the project. (See Section 20.3 and Appendix C of OMB Circular A-l 1,
July 1994.)
FUNDED/UNFUNDED (Element Importance: 2) - Indicate whether the project is
funded or unfunded. A project is funded if in the year it is scheduled to be
accomplished, funds are expected to be available in the Federal agency's program
or budget for the project. This determination should be based on the agency's
fiscal guidance to the facility.
TYPE OF COST (Element Importance: 3) - Enter the correct code from Table
3.5. See Section 2.8 for a description of each of these types of costs.
Table 3.5
Types of Costs
w.vft •-•. ^v.% ;
01
02
03
04
05
06
07
08
;^>V^--^^o^«wr""" *"\:vV ^
Capital Costs
Operating Costs
Mitigation/Remediation Costs
Program Definition Costs
Program Management Costs
Training Costs
Research and Development Costs
Other Costs
3-11
October 1994
WAWWWJVCTAWAVW.V.V^^
-------
ESTIMATED PROJECT COST (Element Importance: 1) Federal agencies
should provide estimated costs for all projects that are needed by the Federal
agency to attain and sustain compliance with all environmental laws and
regulations, and/or achieve other goals and objectives of its environmental
program.
FY - Enter the earliest feasible and executable year, consistent with
statutory and regulatory requirements, Federal agency program/budget
guidance, the objectives of the various Federal agency environmental
strategies, and action plans. The year chosen in this column should assure
the project will be completed before the date final compliance is required.
Estimated Cost - Enter the estimated cost of needed projects required for
the agency to remain in, or return to, full compliance with all environmental
laws and regulations. Projects must be feasible and executable if funds are
attained in the year(s) indicated. This is the current working estimate of
the cost of the project by FY. These figures are used to develop budget
submissions, and therefore include future-year projections.
Programmed/Budgeted Costs - Enter the estimated cost of projects for the
years in which funds are actually expected to be received. Constrained by
an organization's budget, funds must actually be included in the
organization's official programming and budgeting procedures. For the
purpose of A-106, "budgeted" means funds have been received, are
included in next year's budget, or are expected to be included in the Federal
agency's next budget request to Congress. "Programmed" means that the
project has sufficient priority to have a high probability of funding during
future or outyears. The data reflected in this column are the primary basis
for analyses that will be reported to OMB in the annual A-106 Federal
Agency Environmental Management Program Plan Report.
Obligated - Enter amount obligated against the project or actually spent on
project execution. There should be NO entries for future fiscal years,
unless the funded account consists of no-year money.
3-12
October 1994
-------
Table 3.6
Estimated Project Cost Samples for Entering Data
The following example reflects a project required and executable in FY 95, for
which no funds are available. If the requirement is still valid, the project must be re-
scheduled.
•••-.MJ
FT
95
1,000.0
0.0
0.0
The following example reflects a project required and executable in FY 95, which
is scheduled for implementation and for which funds are included in facility budget. (No
obligation is shown until the project is actually under contract or funds spent.)
OBLIGATED ^
95
1,000.0
1,000.0
0.0
The following example reflects a project required in FY 94, for which funds were
provided and contract awarded or funds expended to execute the project.
94
1,000.0
1,000.0
1,000.0
The following example, updated in FY 95, reflects an annual recurring requirement
(e.g. training) for FY 94-97. Shows amount actually spent in FY 94, no funding in FY 95,
partial funding in FY 96, and full funding in FY 97.
94
500.0
500.0
500.0
95
800.0
0.0
0.0
96
1,000.0
500.0
N/A
97
1,300.0
1,300.0
N/A
3- 13
October 1994
-------
3.6 Project Characterization
STATUTORY AUTHORITY (Law/Regulation) (Element Importance: 1) - Enter
the four character code for the most appropriate of the 17 laws or group of laws
listed in Appendix A. Proper identification of the statute helps Federal media
program managers and budget officers administer their programs, and assures that
the project is sent to the proper EPA office for review. The multimedia code is
only to be used for environmental auditing, program management, and training
projects.
ENVIRONMENTAL CATEGORY (SCAT) (Element Importance: 1) - Enter the
four character code from the list in Appendix A. Only those ECATs pertaining to
the specific law/ regulation previously selected are valid. Both an ECAT Quick
Reference List and a more detailed list of ECAT definitions can be found at
Appendix A.
COMPLIANCE STATUS (Element Importance: 1) - Enter the four character
code that identifies the compliance status of the pollution source, operation,
function, or activity this project is designed to address. A complete descriptive list
of the compliance status codes are presented in Section 2.5.3 "Compliance Status."
Also refer to Table 3.7 as a quick reference of the possible combinations of
compliance classes and priority assessments.
COMPLIANCE CLASS (Element Importance: 1) - Enter the compliance class
(0, 1, 2, 3, 4). Class descriptions can be found in Section 2.5.3. Table 3.7 also
presents a brief overview of compliance classes and priority assessments.
"Compliance Class" must be consistent with the "Compliance Status" described
above.
3-14
October 1994
-------
yawjwi.w.wjw^^^^^^
Table 3.7
Compliance Classes and Priority Assessments
. <&&& !
0
I
I
I
n
n
n
m
m
IV
rv
rf»»
PGMT
CMPA
INOV
ESDP
ESDF
PSDF
PDEF
ESRO
ESRE
ESDL
OTHR
Ir^f?^ ^ jasffii-awfflSiifi. ; .£7 .- ;
Environmental Program Management Costs
Compliance Agreement
Projects required to support signed Compliance Agreement, Consent Order, i^'CA, iAOf, or
equivalent state enforcement action. Includes pollution prevention projects required as condition of,
or resulting from, an EPA/state enforcement action. Also includes conservation activities required by
written agreements with Federal, State, and/or local agencies.
Inspection/Notice of Violation (TSTOV)
Projects to correct deficiencies cited on an inspection, NOV, Notice of Non-Compliance (NON) or
an equivalent enforcement document, by a regulatory authority.
Established Standard/Deadline Past
Other projects required immediately because statutory or regulatory deadline passed. Includes
pollution prevention projects required to comply with the PPA, EPCRA, and deadline specific
requirements of E.0. 12856. Also includes conservation projects essential for compliance with past
statutory or regulatory deadlines, and for procedural requirements where violations already exist.
Established Standard/Deadline in Future
Projects to correct situations in which conditions do not meet established standards, but compliance
date in future. Includes pollution prevention projects required to comply with the PPA, EPCRA, and
the deadline specific requirements of E.0. 12856.
Pending Standard/Deadline in Future
Projects to correct conditions where there is a proposed standard or agreement that is not being met,
and the compliance date is in the future.
Program Definition
Projects to define the environmental program (e.g., inventories, surveys, studies, assessments).
Fstahlished Standard/Replacement due to Obsolescence
Facility meets established standards, but needs replacement because of obsolescence, or will go out
of compliance in the future. Includes projects necessary to upgrade or modernize operational
facilities. Includes projects that use new technology to generate significant cost savings.
Established Standard/Replacement due to Expansion
Facility meets established standard, but needs to increase capacity or the facility will go out of
compliance in the future.
Established Standard/Demonstrate Leadership
Facility meets established standard, but project needed for other than compliance reasons [e.g., good
management practices determined as a result of environmental audits or based on professional
judgement]. Includes improvements of operational capability or efficiency, usually based upon
professional engineering judgement and many pollution prevention projects not required by law.
Other Reasons
Projects evolving out of other planning-based requirements. Other environmental projects not
enumerated in any of the previously described categories.
\ ;
1.0-9.9
7.0-9.9
7.0-9.9"
7.0-9.9
4.0-9.9
1.0-9.9
1.0-9.9
1.0-9.9
1.0-9.9
1.0-9.9
1.0-9.9
37 Although a cleanup site where an IAG has been signed is classified CMPA (Class I), the IAG schedule determines
the priority of individual OUs at that site. If an OU is not required during the budget year being considered, it may be
characterized as Class II. For further information on classifying OUs, see section 2.10.3.
3-15
October 1994
^W.fJAWJWA*lWAVAW^^
-------
PRIORITY SCORE (Element Importance: 1) - Enter a numerical score between
1.0 and 9.9. The descriptive terms high, medium, and low are no longer entered
into the system. A more complete description of considerations to be taken into
account when prioritizing projects is provided in Section 2.5.4 "Project Priorities"
of this handbook. Please refer to Section 2.5.4 and Table 3.7 before filling out this
section.
LOCAL PRIORITY (Element Importance: 3) - Enter the three digit local priority
code. The local priority code represents the rank order of this particular project
relative to all other environmental projects in the facility/installation/activity
environmental work plan. The default value is zero.
BUREAU/MACOM PRIORITY (Element Importance: 3) - Enter the four
character BUREAU/MACOM priority assigned to the project by the bureau or
MACOM. Federal bureaus should institute their own system for determining the
relative priority of their installation's projects. (EPA has not established a uniform
definition for this parameter.) Enter any combination of up to four characters
(numbers or letters). The default value is zero.
MAJOR PROGRAM AREA (Element Importance: 2) - Enter code to indicate
which one of the following major program areas the project or activity belongs:
1 - Compliance, 2 - Pollution Prevention, 3 - Cleanup, 4 - Conservation, or
5 - Other.38
POLLUTION PREVENTION (Element Importance: 2) - All projects are
evaluated to determine whether there is a pollution prevention component to the
project. To accomplish this evaluation, three new pollution prevention fields have
been included in the new A-106 format. The new fields are as follows:
P2 Component - If there is a pollution prevention component to the
project, enter "Y" for yes or "N" for no.
Percentage of P2 Component - If yes, enter an estimate of the percent of
pollution prevention component rounded off to five, (e.g., 5, 10, 15, 20)
P2 Category - Enter the appropriate code for the type of pollution
prevention project according to Appendix B.
GEOGRAPHIC INITIATIVE (Element Importance: 3) - If the project is
identified with an EPA geographic initiative, enter the correct code from Table
3.8. Other codes may be developed in the future as needed.
18 In the future, EPA may develop separate criteria for prioritizing projects within each of the major program areas.
3-16 October 1994
-------
Table 3.8
Geographic Initiative Codes
w. -.^ -. '•'•'f^ www&AyA y^vi\% % *" '•.$&'•'•'•'•'•'•'•'•
..^:--" I^COBS---^ K
01
02
03
04
05
06
07
08
09
10
ruSr~" «i^£^:^iw^ ~^r:-^
Chesapeake Bay Program
Great Lakes Program
Gulf of Mexico Program
Narragansett Bay Program
Delaware Bay Program
San Francisco Bay Program
Puget Sound Program
Long Island Sound Program
Mexican Border Program
Edwards Aquifer
REASON FOR INITIATION (Element Importance: 3) - This two character field
is used to identify for special analysis those projects that fall within certain
program areas that receive intense scrutiny from both within and outside the
government. Enter the correct code from Table 3.9, only if appropriate
(Optional).39
Table 3.9
Reason for Initiation Codes
'< \v*3' \
^COBfc^
01
02
03
04
05
06
~"""---. v^^m.r^P''^--- "" ,-,.
,:;;^^^|f|^¥J^TlON
BASE CLOSE
ENVIRR&D
FUDSDERP
HEALTH
LAB ANALYSIS
ENVIRONMENTAL AUDIT
££^ '- ' - ,,,,, s f^jBEfife&k^f V--> «« »»v
Base realignment and closure projects
R&D Support, technology development
Formerly Used Defense Sites projects
Potential human health hazard
Required laboratory analytical costs
Environmental Audit Finding
39 If additional codes are needed, contact the Federal Facilities Enforcement Office at EPA.
3- 17
October 1994
-------
3.7 Project Narrative
DESCRIPTION (Element Importance: 2) - Enter up to 1,000 characters (printed
or typed) to describe the project or operable unit as completely as possible.
>^v^»V^V - ~~ -- CV^VO;^ , v"? */-
V ,, '*•''''' ^ ^ •1\^%-^'^^A^ ^ V% % f •••• • V. <. V.V.V. w. -,-, % ^%^%S^S-W < s S \ V •"
It 15 very imp rW:' ^X^jS^w"^™^!**^"^^^ y " -.-. •• ^ •• \^
At a ntimmum, -
•>•,•<•, •*•,•. j •. ss!i\. s w.yk ™ •••; \ \s \-;\%ss-;s% -.-. -.-. •. •.
•.s ^ss-. '•••^s^\ssss \ •»*• s % ^ '-'^ s % \ •„
0 •", \\""?; i!\5-" " ^ ^ * ~" """""' ""-
M&t&M "' "' " ;* ^ '
3- 18
October 1994
-------
^^
APPENDICES
-------
-------
ECAT
AGRM
ARCH
ASBS
AUDT
CORA
CPLN
CTAP
CVOC
DISP
EAIS
EINV
APPENDIX A (Part 1)
ENVIRONMENTAL CATEGORIES (ECATs)40
(Listed in Alphabetical Order)
ENVIRONMENTAL CATEGORIES
Agricultural Grazing/Outlease
Archeological Surveys
Asbestos
Auditing
Corrective Action (Sect 3004 U & V)
Closure Plans (Sect 6008)
Control of Toxic Air Pollutants
ENVIRONMENTAL
LAWS/REGULATION
Natural Resource Laws
(NATR)
Cultural Resources Laws
(CURL)
Clean Air Act (CAA)
Multi-Media (MULT)
Resource Conservation
and Recovery Act (RCRC,
RCRD)
RCRC, RCRD
CAA
Control of Volatile Organic Compounds CAA
Hazardous Waste Disposal Costs RCRC
Preparation of EIS/EA on Specific Projects National Environmental
Policy Act (NEPA)
Emissions Inventories
CAA
PAGE41
A3-10
A3-9
A3-2
A3-12
A3-6, 7
A3-6, 7
A3-1
A3-1
A3-6
A3-8
A3-2
40 ECAT is a term of art used by EPA to define subsets of environmental laws and regulations and/or other
environmental programs. The definitions of the ECATs may be found in Appendix A, Part 3. Italicized ECATs are new
categories since the last guidance document was published.
41 "PAGE" refers to the location of the ECAT definition in Appendix A (Part 3).
Al - 1
October 1994
-------
ECAT
ENDG
FEAS
FSTM
GENR
GWMI
HAZD
HWMP
msx
LNDM
MITM
MOBL
MSDV
MXDW
NAQP
NCON
NEHP
NPLN
ENVIRONMENTAL CATEGORIES
Endangered Species Survey
Feasibility Study
Forestry Management
Generator Requirements
Groundwater Monitoring Installation
Hazardous Waste Operations
Hazardous Waste Management Plans
Historic Preservation Surveys
Land Management
Mitigation Measures Required by Rod
Mobile Sources
Marine Sanitation Devices
Mixed Wastes
Point Source Control
Construction
National Emission Standards for Haz
Pollutants
Noise Control Planning
ENVIRONMENTAL
LAWS/REGULATION PAGE
Endangered Species Act A3-9
(ESA)
Comprehensive Environ- A3 -10
mental Response, Compen-
sation and Liability Act
(SFND)
NATR A3-10
RCRC A3-5
RCRC A3-6
RCRC A3-6
RCRC A3-6
CURL A3-9
NATR A3-10
NEPA, ESA, CURL A3-9
CAA A3-2
Clean Water Act (CWA) A3-4
A3-1
Atomic Energy Act
(ATOM)
CAA
A3-1
Noise Control Act (NCA) A3-8
CAA A3-1
NCA
A3-8
Al -2
October 1994
f.-ff.-f.-fffffffffffff^^
-------
ECAT
NPTS
ODCS
OPLM
PASI
PBDW
PCBS
PDWS
PGMT
POLP
POTH
PPEO
PRMT
PSAD
PSCS
PTRQ
RADN
r.'jttfffffffffffffffffftf*fffffffff.
ENVIRONMENTAL CATEGORIES
Non-Point Source
Ozone-Depleting Chemicals
Operating Units and Long Term Monitoring
Preliminary Assessment/Site Investigation
Lead in Drinking Water
Storage & Disposal of PCBs
Primary Drinking Water Standards
Program Management
Pollution Prevention
Pollution Prevention (Other Accounts)
Executive Order 12856 Requirements
Permits
Pesticide Storage, Application & Disposal
Point Source Control (Sect 402)
Pre-Treatment
Radon
Al-3
ENVIRONMENTAL
LAWS/REGULATION
CWA
CAA
SFND
SFND
Safe Drinking Water Act
(SDWA)
Toxic Substances Control
Act (TSCA)
SDWA
MULTI
CAA, CWA, RCRC,
RCRD, SFND, SDWA,
Federal Insecticide, Fungi-
cide and Rodenticide Act
(FFRA), Pollution
Prevention (PRVN)
PRVN
PRVN
CWA, SDWA, CAA,
RCRC, RCRD
FFRA
CWA
CWA
CAA
PAGE
A3 -4
A3-2
A3-11
A3-10
A3-5
A3-7
A3 -4
A3-12
A3-2,4
A3-5, 6
A3-7, 8
A3-11
A3-11
A3-11
A3-2, 4
A3-5-6
A3-8
A3-3
A3-3
A3-2
October 1994
'fffffffttfftttfffffffffffffffffffffffi
-------
ECAT
RADW
RCYP
REMA
REMD
RINV
RMVA
SDWS
SIPS
SPCC
SUED
SWMP
SWPS
TRAN
TRNG
TWPS
UNIC
USTS
USTU
USTR
ENVIRONMENTAL CATEGORIES
Radioactive Waste
Recycling Programs
Remedial Action
Remedial Design
Remedial Investigation
Removal Action
Secondary Drinking Water Standards
State Implementation Plan Requirements
Spill Prevention, Control & Counter-
measures Plan
Landfills (Subtitle D)
Solid Waste Management Plans
Storm Water Point Source
Transportation Requirements
Training
Toxic Water Pollutants (Sect 304)
Underground Injection Control
Underground Storage Tanks (Subtitle I)
Underground Storage Tank Upgrade
Remediation of Underground Storage
Tank Sites
ENVIRONMENTAL
LAWS/REGULATION
ATOM
RCRD
SFND
SEND
SFND
SFND
SDWA
CAA
CWA
RCRD
RCRD
CWA
RCRC
MULT
CWA
SDWA
Underground Storage
Tanks (RCRI)
RCRI
RCRI
Al-4
"w*ftWlW''Wl''WAWW^^^
PAGE
A3-1
A3-7
A3-11
A3-11
A3-10
A3-11
A3-5
A3-2
A3 -4
A3-6
A3-6
A3-3
A3-6
A3-12
A3-3
A3-5
A3-7
A3-7
A3-7
October 1994
-------
ECAT
ENVIRONMENTAL CATEGORIES
ENVIRONMENTAL
LAWS/REGULATION PAGE
USTP Underground Storage Tank Permits
and Fees
WLHP Wellhead Protection
WLND Wetlands (Sect 404)
WMIN Waste Minimization
WWTR Waste Water Treatment
RCRI
SDWA
NATR42
RCRD
CWA
A3-7
A3-5
A3-10
A3-7
A3-3
42 Wetlands have been arbitrarily listed under Natural Resource Laws, although they are legislated under Section 404
of the CWA.
Al-5
October 1994
-------
-------
APPENDIX A (Part 2)
ECATs QUICK REFERENCE LIST43
(Grouped Primarily by Environmental Law and Regulation)
ENVIRONMENTAL
LAW/REGULATION
Atomic Energy Act
(ATOM)
ENVIRONMENTAL CATEGORY
Radioactive Wastes
Mixed Wastes
CODE
RADW
PAGE
A3-1
MXDW A3-1
Clean Air Act
(CAA)
Control of Toxic Air Pollutants
Control of Volatile Organic
Compounds (VOCs)
National Ambient Air Quality Programs
(Point Source Control)
National Emission Standards for
Hazardous Air Pollutants
Emissions Inventories
State Implementation Plan
Requirements
Mobile Sources
Ozone-Depleting Chemicals (ODCs)
Asbestos
Radon
Pollution Prevention
Permits and Fees
CTAP
CVOC
NAQP
NEHP
EINV
SIPS
MOBL
ODCS
ASBS
RADN
POLP
PRMT
A3-1
A3-1
A3-1
A3-1
A3-2
A3-2
A3-2
A3-2
A3-2
A3-2
A3-2
A3-2
43 The italicized ECATs are new categories since the last guidance document was published.
A2-1
October 1994
-------
ENVIRONMENTAL
LAW/REGULATION
Clean Water Act
(CWA)
Safe Drinking
Water Act
(SDWA)
ENVIRONMENTAL CATEGORY
Wastewater Treatment
Point Source Control (Sect. 402)
Pre-Treatment Requirements
Toxic Water Pollutants (Sect 304)
Storm Water Point Source
Non-Point Source
Spill Prevention, Control,
and Countermeasure
Marine Sanitation Devices
Pollution Prevention
Permits and Fees
Primary Drinking Water Standards
Secondary Drinking Water Standards
Lead in Drinking Water
Wellhead Protection
Underground Injection Control
Pollution Prevention
Permit and Fees
A2-2
rfffftffftffffftttfffffffftttffrfftfftfftfffftfffffftftffftffftfffffffffffftfftfffftftffttfffffffffffffftfffffffffffffti
CODE
WWTR
PSCS
PTRQ
TWPS
SWPS
NPTS
SPCC
MSDV
POLP
PRMT
PDWS
SOWS
PBDW
WLHP
UNIC
POLP
PRMT
•ffffftfftfffffftffffffff*
PAGE
A3-3
A3-3
A3-3
A3-3
A3-3
A3 -4
A3 -4
A3 -4
A3-4
A3-4
A3-4
A3-5
A3-5
A3-5
A3-5
A3-5
A3-5
October 1994
ftfffftftffffffffffffffffffffftfffftfftfff:
-------
ENVIRONMENTAL
LAW/REGULATION
Resource
Conservation and
Recovery Act
(RCRC)
Solid Waste
Management
(RCRD)
ENVIRONMENTAL CATEGORY
Generator Requirements
Hazardous Waste Operations
Hazardous Waste Management Plans
Closure Plan
Corrective Action
(Sect. 3004 U and V)
Groundwater Monitoring
Installation
Hazardous Waste Disposal Costs
Transportation Requirements
Pollution Prevention
Permit Application/
Modification/Fees
Landfills (Subtitle D)
Solid Waste Management Plans
Closure Plans
Corrective Action
Recycling Program
Waste Minimization
Pollution Prevention
Permit Application/
Modification/Fees
A2-3
•%%VMWWIW^^VVVUVVWVVA^VWWSAV^AVWVWJ^^
ffffffftffffffffffffffffffffffff
CODE
GENR
HAZD
HWMP
CPLN
CORA
GWMI
DISP
TRAN
POLP
PRMT
SUED
SWMP
CPLN
CORA
RCYP
WMIN
POLP
PRMT
PAGE
A3-5
A3-6
A3 -6
A3-6
A3 -6
A3 -6
A3 -6
A3-6
A3-6
A3 -6
A3 -6
A3-6
A3-7
A3-7
A3-7
A3-7
A3-7
A3-7
October 1994
-------
ENVERONMENTAL
LAW/REGULATION
Underground
Storage Tanks
(RCRI)
Toxic Substances
Control Act
(TSCA)
Noise Control Act
(NCA)
Federal
Insecticide,
Fungicide and
Rodenticide Act (FFRA)
National
Environmental
Policy Act (NEPA)
Endangered
Species
Act (ESA)
ENVIRONMENTAL CATEGORY
Underground Storage Tanks
(General)
Underground Storage Tank Upgrade
Remediation of UST Sites
UST Permits and Fees
Storage and Disposal of
Polychlorinated Biphenyls
Noise Control Planning
Noise Control Construction
Pesticide Storage, Application,
and Disposal
Pollution Prevention
Environmental Impact Assessment
and Documentation
Mitigation Measures
Endangered Species Investigations
Mitigation Measures
A2-4
CODE
USTS
USTU
USTR
USTP
PCBS
NPLN
NCON
PSAD
POLP
EAIS
MITM
ENDG
MITM
PAGE
A3-7
A3-7
A3-7
A3-7
A3-7
A3-8
A3 -8
A3-8
A3-8
A3-8
A3-9
A3-9
A3-9
October 1994
-------
ENVIRONMENTAL
LAW/REGULATION
Cultural
Resources
Laws (CURL)
Natural Resources
Laws (NATR)
Comprehensive
Environmental Response,
Compensation and
Liability Act
(SFND)
Pollution
Prevention (PRVN)
ENVIRONMENTAL CATEGORY CODE PAGE
Archaeological Resources
Historic Preservation
Restoration Activities
Forestry Management
Agricultural/Grazing Outlease
Land Management
Wetlands (Section 404)44
Preliminary Assessment/
Site Investigation
Remedial Investigation
Feasibility Study
Remedial Design
Remedial Action
Operating Units/Long-Term
Monitoring
Removal Action
Pollution Prevention
Executive Order 12856
Requirements
ARCH
HIST
MITM
FSTM
AGRM
LNDM
WLND
PASI
RINV
FEAS
REMD
REMA
OPLM
RMVA
POLP
PPEO
A3-9
A3-9
A3-9
A3-10
A3-10
A3-10
A3-10
A3-10
A3-10
A3-11
A3-11
A3-11
A3-11
A3-11
A3-11
A3-11
44 Although technically a section of the CWA, this ECAT is more logically managed under NATR.
A2-5
•VtW
-------
ENVIRONMENTAL
LAW/REGULATION
ENVIRONMENTAL CATEGORY CODE PAGE
Pollution Prevention POLP A3-11
(Env Accounts)
Pollution Prevention POTH A3-11
(Other Accounts)
Multi-Media
(MULT)
Environmental Auditing
Program Management
Training (All)
AUDT
PGMT
TKNG
A3-12
A3-12
A3-12
A2-6
-------
sss^^^
APPENDIX A (Part 3)
DEFINITIONS OF THE ECATs45
ATOMIC ENERGY ACT (ATOM)46
RADW Radioactive Wastes - Projects related to the storage, handling, transportation, and
disposal of radioactive waste material. (Past activities are investigated under
environmental law/regulation CERCLA/Superfund.)
MXDW Mixed Wastes47 - Includes hazardous wastes mixed with low-level radiological
wastes.
CLEAN Am ACT (CAA)
CTAP Control of Toxic Air Pollutants - Projects to reduce or eliminate toxic or
hazardous air pollutants. Includes preparation of Risk Management Plans,
studies to determine best available control technology for specific
operations, and the installation of pollution control equipment.
CVOC Control of Volatile Organic Compounds (VOC) - Includes projects to reduce or
eliminate VOCs, such as installation of vapor recovery systems for petroleum
storage/dispensing facilities, and control systems to limit emissions from vapor
degreasing, paint-spraying, chemical stripping, and other similar operations.
NAQP National Ambient Air Quality Program (Point Source Control) - Includes
projects to control emissions of "criteria pollutants," such as ozone, carbon
monoxide (CO), sulfur oxides (Sox), nitrogen oxides (NOx), lead, and
airborne particulates (PM-10). Examples are projects for controlling
emissions of criteria pollutants from coal and oil-fired power plants in air
quality non-attainment areas. Includes purchase and installation of
scrubbers to reduce or prevent emissions. Also includes costs to
monitor/sample permitted sources.
NEHP National Emission Standards for Hazardous Air Pollutants - Includes projects for
the control of any of the approximately 190 hazardous air pollutants identified in
Section 112 of the CAAA-90.
45 The definitions of several of the categories, and their placement (under a particular law/reg) were sometimes
effected arbitrarily. The italicized ECATs are new categories since the last guidance document was published.
46 Also includes those sections of RCRA that pertain to hazardous chemical waste mixed with radiological waste.
47 This ECAT formerly was found under Law/Reg MULT.
A3 - 1 October 1994
-------
EIW
SIPS
MOBL
ODCS
ASBS
RADN
POLP
PRMT
Emissions Inventories - Includes projects related to the preparation of Air
Emissions Statements or Inventories, as required by the CAAA-90 or state
or local authorities. Inventories can include both Criteria and/or
Toxic/Hazardous air pollutants.
State Implementation Plan requirements
Mobile Sources - Includes planning and projects necessary to implement state-
required Employee Trip Reduction Plans (ETRPS) and Inspection and
Maintenance (I&M) Programs for fleet vehicles.
Ozone-Depleting Chemicals (ODCs) - Includes any project or initiative to
eliminate, reduce, or control emissions of ODCs. Examples include: identification
of safe alternatives for refrigerants or solvents, planning for replacement of
stationary halon fire suppression systems to include system design; replacement of
fire suppressant in a discharged halon system (stationary or portable) with an
approved alternative.
Asbestos - Includes projects related to the identification and control of
friable asbestos, such as inventories, surveys, inspections, exposure and risk
assessments, and abatement activities, including in-place management or
removal, when required to comply with CAA or AHERA regulations.
Radon - Includes projects related to the assessment and abatement of indoor
radon. [Note: Although radon is regulated under the Toxic Substances Control
Act, rather than the Clean Air Act, it is included under the category of CAA
because it is primarily an (indoor) air quality concern.]
Pollution Prevention - Includes any pollution prevention (source reduction) project
initiated to reduce, control or eliminate emissions from air pollution sources.
Includes projects to reduce the volume or amount of material burned in an
incinerator, thus reducing emissions. Examples include changing fuel type in
combustion processes to effect more complete combustion or changing paint or
coating requirements to eliminate or reduce VOC emissions. Also includes
projects to modify processes to allow or permit more complete burning of waste.
May also include the installation of devices (such as scrubbers) at the point of
emissions to capture pollutants, for voluntary reduction of emissions (not required
by law).
Permits and Fees - Includes projects related to the preparation and processing of
permits to operate air pollution sources. Includes future quarterly reporting
requirements, preparation of annual recertification reports, and fees.
A3-2
October 1994
M*W^.VAWA^^JJWWWMWUWW>W^
-------
CLEAN WATER ACT (CWA)
WWTR Wastewater Treatment - Projects for new construction of domestic or industrial
wastewater treatment plants; or repair, upgrade or rehabilitation of existing
facilities that treat domestic sewage or industrial wastewaters, including package
plants. Includes repair or upgrade of pumping stations, lift stations, standby
generators, disinfection equipment, sludge handling equipment, and repair of
leaking sewerage lines to regain or maintain compliance. Laboratory analyses for
plant operations and permit compliance, monitoring, biomonitoring, and
wastewater studies are also included here.
PSCS Point Source Control (Sect 402) - Includes projects to control all polluted
wastewater discharges (other than WWTR) that need to apply for NPDES
permits. Also includes construction, repair, and monitoring of septic tanks,
and oil-water separators associated with specific sources, such as a
washrack, whether or not they require permits.
PTRQ Pre-Treatment Requirements - Includes construction and repair of treatment
facilities in industrial areas (maintenance shops, hospitals, laundries, laboratories,
hobby shops, etc) upstream of domestic wastewater treatment systems or
discharge point to off-installation domestic sewer systems. Includes studies and
surveys to determine upstream contributors of toxic wastewater constituents.
Includes analysis necessary to identify toxic wastewater constituents. Discharges
to off-installation publicly owned treatment works (POTWs) from Federal
facilities/plants are also included. Does not include washracks or oil separators
from washracks, which are classified PSCS.
TWPS Toxic Water Pollutants (Section 304) - Includes projects to control discharges of
toxic or priority water pollutants in the CWA amendments.
SWPS Storm Water Point Source - Includes projects associated with the
control/treatment of storm water runoff from industrial activities, and from
medium sized or larger separate storm water sewer systems (systems serving over
100,000 people). Industrial activities for which storm water is regulated include
manufacturing, processing, or raw materials storage at facilities such as explosives
and chemical processing; hazardous waste treatment, storage and disposal (TSD)
facilities; and landfills that receive industrial wastes. Also included are vehicle
maintenance, equipment cleaning and airport deicing areas. Wastewater treatment
plants having a flow in excess of 1 MGD and construction activity encompassing
more than 5 acres of land area are also included. Include studies and surveys of the
above to determine compliance.
A3-3
October 1994
-------
NPTS Non-Point Source - Includes projects to control diffuse sources of
pollution to ground and surface waters not regulated as point sources.
Diffuse sources of pollution usually are attributed to rainfall or snowmelt
from urban runoff; practices related to agricultural, silvicultural,
construction, hydromodification, stream crossing, and training activities;
and land disposal practices. Includes projects to prevent sedimentation,
beach or shore erosion, and to monitor study or clean up of streams and
lakes. Also includes construction of detention ponds, wet ponds,
infiltration basins, and trenches to mitigate the impact of runoff. NOTE:
Some diffuse sources are regulated under the NPDES Program as point
source discharges (see SWPS).
SPCC Spill Prevention, Control, and Countermeasure - Includes Installation Spill
Prevention Control and Countermeasure Plans and Installation Spill Contingency
Plans to incorporate hazardous material/waste spill prevention and control
measures. Includes cost of spill response supplies and other costs of spill response
and cleanup. Includes other operational requirements associated with spill
response. (These plans should be coordinated with responding Fire Departments.)
MSDV Marine Sanitation Devices - Includes any equipment for installation on board a
vessel which is designed to receive, retain, treat, or discharge wastewater, and any
process to treat such wastewater.
POLP Pollution Prevention - Activities to eliminate or reduce the discharge of pollutants
by process modification. Also includes projects that enable reuse of water within
the industrial process, as well as for such purposes as lawn watering and vehicle
washing.
PRMT Permits and Fees - Includes projects related to the preparation and processing of
operating permits. Also includes application preparation, modification costs, and
fees.
SAFE DRINKING WATER ACT (SDWA)
PDWS Primary Drinking Water Standards - Includes projects to ensure that potable water
systems have effectively controlled the health hazard contaminants regulated by the
National Primary Drinking Water Standard. Includes monitoring and sampling;
development and upgrading of wells; and construction or maintenance of storage
tanks, reservoirs, filters, and distribution systems. Also includes construction,
repair, or upgrade of plants to comply with Surface Water Treatment. Disinfection
By-products, or Ground Water Disinfection Rules.
A3-4
October 1994
-------
SOWS
PBDW
WLHP
UNIC
POLP
PRMT
Secondary Drinking Water Standards - Includes projects to ensure that potable
water systems have effectively controlled the health hazard contaminated regulated
by Secondary Drinking Water Standards. Includes water softening, corrosivity,
desalinization, demineralization, and cathodic protection. Includes studies for
water consumptive use, leakage, and water conservation.
Lead in Drinking Water - Includes projects to control or remove lead in potable
water systems to comply with the Lead-Copper Rule. Includes corrosion studies
and replacement of lead pipes.
Wellhead Protection - Includes projects that relate to the surface or subsurface
area surrounding a well or wellfield, supplying a public water system, through
which contaminants are likely to reach such a well or wellfield. Includes
groundwater monitoring, hydrogeological studies, well testing, analytical support,
and other projects to define potential problems related to current operations.
Includes projects related to the protection of a sole source aquifer, including
recharge zones. Includes projects to plug abandoned wells. Also includes ground
water vulnerability assessments to determine if wells are influenced by chemicals
used in agricultural applications. (Past activities are investigated under
CERCLA/Superfund.)
Underground Injection Control - Includes projects for a subsurface emplacement
of any fluid through a bored, drilled, driven, or dug well (where the depth is
greater than the largest surface dimension).
Pollution Prevention - Includes the use of products or practices that modify water
treatment processes or activities that generate wastes or emissions. Includes
actions to reduce waste by establishing material reuse/recycling systems. Includes
pollution prevention projects consisting of backflow prevention or cross-
connection programs.
Permits and Fees - Includes projects related to the preparation and processing of
operating permits. Also includes application preparation, modification costs and
fees.
RESOURCE CONSERVATION AND RECOVERY ACT (RCRC)48
GENR Generator Requirements - Includes cost of compliance with generator
requirements as specified in regulations, including applicable generator fees.
48 RCRA has been sub-divided into three components, RCRC, RCRD, and RCRL
A3-5
October 1994
-------
HAZD Hazardous Waste Operations - Includes projects and costs associated with TSD
facilities outlined in Sec 3004. Also includes projects for Lead Based Paint
surveys, testing, and disposal.
HWMP Hazardous Waste Management Plans - Includes projects required to develop and
maintain compliance with regional and local solid waste management plans,
including hazardous waste management plans.
CPLN Closure Plans - Includes cost of development and implementation of closure plans
required under Section 6008.
CORA Corrective Action (Sect 3004 U and V) - Includes the cost of design and
implementation of corrective action plans.
GWMI Groundwater Monitoring Installation - Includes the cost of design and installation
of ground water monitoring facilities.
DISP Hazardous Waste Disposal Costs - Includes costs of disposal of hazardous waste
through commercial firms.
TRAN Transportation Requirements - Includes projects and costs for compliance with
standards for off-site transportation of hazardous waste. Applies to any person
who moves hazardous waste from the location where it was generated, or is
treated, stored or disposed of. This does not include the cost of the disposal itself.
POLP Pollution Prevention - Includes costs of projects designed to reduce the amount of
RCRC regulated waste produced. Examples include process changes from solvent-
based cleaners and degreasers to water-based or non-solvent cleaners and the
redesigning of material packaging for multiple uses before finally discarding.
PRMT Permit Application/Modification/Fees - Includes projects related to the preparation
and processing of operating permits. Includes fees for the permits.
SOLID WASTE MANAGEMENT (RCRD)
SUED Landfills (Subtitle D) - Includes projects to design, construct, or maintain solid
waste disposal facilities. Includes both new construction or expansion of landfills,
leachate collection systems, improvement of caps. Does not include routine
operations.
SWMP Solid Waste Management Plans - Includes projects required to develop and
maintain compliance with regional and local solid waste management plans.
A3-6
October 1994
-------
CPLN Closure Plans - Includes costs of development and implementation of closure plans
required under 40 CFR 264.110 (Subpart G).
CORA Corrective Action - Includes the cost of design and implementation of corrective
action plans.
RCYP Recycling Program - Includes projects, programs, or studies to divert materials
intended for disposal, and restore them to an economically productive use.
Includes projects such as providing facilities, containers, and/or transportation of
used materials for the purpose of reprocessing or regeneration.
WMIN Waste Minimization - Includes costs of projects designed to reduce the quantity of
RCRD solid waste. An example is the redesigning of material packaging for
multiple uses before finally discarding.
POLP Pollution Prevention
PRMT Permit Application/Modification/Fees - Includes projects related to the preparation
and processing of operating permits. Includes fees for the permits.
UNDERGROUND STORAGE TANKS (RCRI)
USTS Underground Storage Tanks (General) - Includes projects for the construction,
maintenance, closure, or removal of underground storage tanks. Includes leak
detection and testing.
USTU Underground Storage Tank Upgrade - Cost of projects to retrofit existing tanks
with upgrades required to meet regulatory compliance standards.
USTR Remediation of Underground Storage Tank Sites - All costs associated with
projects to remediate contamination due to leakage or uncontrolled release.
USTP Underground Storage Tank Permits and Fees - All fees and costs associated with
permitting underground storage tanks.
TOXIC SUBSTANCES CONTROL ACT (TSCA)
PCBS
Storage and Disposal of PCBs - Includes projects for conforming storage of PCB
items and materials, and surveys for items containing or contaminated with PCBs.
Includes projects and studies related to identification of PCBs in equipment and
the storage and disposal of such equipment.
A3-7
October 1994
-------
NOISE CONTROL ACT (NCA)
NPLN Noise Control Planning - Technical studies to assess the noise impact of ongoing
or proposed operations. Includes all phases of the Installation Compatible Use
Zone (ICUZ) process. Includes active coordination with surrounding jurisdictions
and landowners. Also includes planning for noise control prior to execution of
noise generating activities. Includes acquisition of land or interest in land with the
specific intention of reducing major problems due to environmental noise.
NCON Noise Control Construction - Includes construction and modification of buildings,
barriers, facilities, and structures with the specific intention of controlling noise.
FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FFRA)
PSAD Pesticide Storage, Application and Disposal - Includes projects for both new
construction or upgrading of conforming pesticide storage and/or mixing facilities.
Includes the cost of special disposal requirements for outdated or suspended
chemicals, and any emergency application requirements which may take special
approval from EPA, USD A, or the Fish and Wildlife Service. Includes
development, preparation or updating of Pest Management Plans. Also includes
studies, surveys, inventories and assessments, monitoring, testing, laboratory
analysis, consultations, permits and fees. May include studies on applications in
areas where threatened or endangered species are at risk due to application
techniques or chemicals in use.
POLP Pollution Prevention - Projects or actions that support efforts to reduce or prevent
pollution caused by the use of pesticides. Studies to implement physical or
mechanical control methods to reduce the use of chemicals. Includes projects that
encourage the reuse of water for such purposes as pesticide mixing.
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)
EAIS
Environmental Impact Assessment and Documentation - Includes writing, editing,
reproduction, and publication of NEPA and related documents (EA, EIS, FONSI,
ROD, NOI, NOA). Includes surveys, studies, and public involvement to support a
proposed action that is not required by another statute. To the extent practical,
activities associated with other statutes or regulations should be entered under the
defining environmental law/regulation.
A3-8
October 1994
-------
MITM Mitigation Measures - Includes committed mitigation activities or projects, which
are not required by another statute or regulation. To the extent practicable,
mitigation projects for activities associated with other statutes or regulation should
be entered under the more definitive environmental law/regulation and PCAT.
ENDANGERED SPECIES ACT (ESA)
ENDG Endangered Species Investigations - Costs of threatened and endangered species
surveys required by law, regulation, or agreement, and for NEPA documentation.
Includes costs associated with developing and revising Endangered Species
Management Plans, and costs associated with projects to monitor threatened or
endangered species or aspects of their habitats.
MITM Mitigation Measures - as required by FONSIs, RODs or court orders and the
implementation of endangered species management plans.
,49
CULTURAL RESOURCES LAWS (CURL)
ARCH Archeological Resources - Monitoring of archaeologically sensitive site areas.
Includes development, preparation or updating of archeological resources section
of the Historic Preservation Plan. Includes reconnaissance, inventory studies, and
field surveys for archeological sites.
HIST Historic Preservation - Monitoring of sensitive historical sites or structures areas.
Development, preparation or updating of Historic Preservation Plan. Includes
reconnaissance, inventory studies and field surveys for historical properties.
Includes evaluations and National Register determinations.
MITM Restoration Activities - Mitigation of adverse effects of operations on Federal
Lands. Also includes repair of damage to cultural resources from erosion, flooding
and other operations.
49 Cultural Resources Laws (CURL) include the National Historic Preservation Act (NHPA), the Archaeological
Resources Protection Act (ARPA of 1979), the Native American Grave Protection and Repatriation Act (NAGPRA) of
1990, and other Statutes.
A3-9
October 1994
-------
NATURAL RESOURCES LAWS (NATR)
50
FSTM
AGRM
LNDM
WLND
Forestry Management - Projects for maintenance and management of timber
producing areas.
Agricultural/Grazing Outlease - Administration and land management projects for
agricultural/grazing outlease areas.
Land Management - Planning Activities to identify and match land and natural
resource capabilities with mission objectives (Land Use Plan). Includes
development of the Integrated Natural Resources Management Plan. Field Data
Collection and Evaluation [Land Condition Trend Analysis (LCTA)] activities
designed to document the condition or baseline status of natural resources.
Mitigation activities required to repair impacted or otherwise degraded lands,
using re-vegetation and/or structural erosion control methods. Monitoring to
include follow-on field evaluations to document changes and trends in carrying
capacity of training lands over time. Includes long term monitoring LCTA work.
Wetlands (Section 404) - Field data collections required to locate, characterize,
and evaluate wetland conditions, and monitor trends. Includes projects to survey,
study, and document wetlands and associated buffer areas to ensure projects
comply with Section 404 of Clean Water Act and state wetlands protection
regulations. Projects to mitigate impacts and/or create new wetlands areas are also
reported here.
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND
LIABILITY ACT (SFND)
PASI
RINV
Preliminary Assessment/Site Investigation - Preliminary Assessments and Site
Inspections (PASI) are used to determine whether there is a release or potential
release and the nature of any associated threat. Includes sampling, collection and
analysis of other field data to determine if further action or investigation is
appropriate.
Remedial Investigation - Remedial Investigations determine the nature and extent
of the problem caused by a release. Includes sampling and monitoring sufficient to
characterize the site, to determine the necessity for removal and/or remedial action
and to support the evaluation of remedial alternatives.
50 Natural Resources Laws (NATR) include the Coastal Zone Management Act, Federal Noxious Weed Act of 1976,
Wild and Scenic Rivers Act of 1968, and other Statutes.
A3-10
October 1994
-------
FEAS
REMD
REMA
OPLM
RMVA
POLP
Feasibility Study - Includes projects which emphasize data analyses gathered
during a remedial investigation. Feasibility studies are used to develop and evaluate
options for remedial action including both an initial screening and detailed analysis
of alternatives. The feasibility study emphasizes data analysis and may be
performed concurrently and interactively with the remedial investigation.
Remedial Design - Are the technical analyses and procedures which follow the
selection of a remedy for a site and result in a detailed set of plans and
specification for implementation of the remedial action.
Remedial Action - Are activities consistent with permanent remedy including:
storage, confinement, perimeter protection using dikes, trenches or ditches, clay
cover, neutralization, cleanup of released hazardous substances, recycling or reuse,
diversion, destruction, segregation, dredging or excavations, repair, and
replacement of leaking containers, collection of leachate and runoff, on-site
treatment or incineration, and provision of alternative water supplies.
Operating Units/Long-Term Monitoring - Includes both operation of facilities
constructed in the remedial action phase and monitoring of facilities or sites.
Operation of facilities constructed in the remedial action phase and monitoring of
facilities or sites, as described in the Record of Decision (ROD), may have a time
limitation.
Removal Action - Actions carried out to remove released hazardous substances to
minimize or mitigate damage to public health and welfare or to the environment.
Pollution Prevention - Actions taken to reduce potential for releases to occur
during any stage of the process, but especially during removal actions.
POLLUTION PREVENTION (PRVN)
PPEO Executive Order (E.O.) 12856 Requirements - Includes activities to meet time-
specific requirements of the pollution prevention E.O. 12856.
POLP Pollution Prevention - Includes other Pollution Prevention projects which are not
classified under one of the specific environmental law/regulation. Includes
activities to meet (multi-media) requirements of the pollution prevention E.O.
12856.
POTH Pollution Prevention (Other Accounts) - Includes Pollution Prevention projects
funded from non-environmental accounts.
A3-11
October 1994
-------
MULTI-MEDIA (MULT)
AUDT Environmental Auditing - Costs related to conducting both external and internal
environmental audits of facilities. Includes protocol development, report analysis
and preparation, quality assurance, Includes contract costs. Also includes costs
associated with the development and conduct of training. Does NOT include costs
for correcting deficiencies identified by audits.
PGMT Program Management - Costs of managing the environmental program. Includes
administrative costs defined as personnel51 and benefits, supplies and equipment,
leases, travel and Per Diem, permits, fees, and contractor support services not
otherwise allocated to any media specific category. Salaries are reported separately
from other costs. Contractor support costs (for people) are also a separate
project. Program definition costs (inventories, assessments, surveys, studies, etc.)
are entered under the specific media program.
TRNG Training (all) - Costs for all environmental training. Includes costs for providing
general environmental awareness training; personnel training related to the Clean
Water Act; training of STP and IWTP operators; training for Spill Response;
training related to the Safe Drinking Water Act; water treatment operator training;
training related to threatened and endangered species; pesticide applicator
certification training; awareness, ARPA, historic building maintenance and repair,
and compliance training; natural resources management and natural resources
procedures, methodologies and concepts training; and training relating to all or
part of the Toxic Substances Control Act, including handling, identification,
storage, and disposal of PCBs.
51 Personnel costs are defined as the costs of environmental managers or coordinators and their staffs. Other
personnel costs based on estimated time dedicated to environmental programs MAY be included.
A3-12
October 1994
-------
APPENDIX B
DRAFT POLLUTION PREVENTION CATEGORIZATION SYSTEM (PPCS)52'53
CODE DESCRIPTION
AOO Projects to initiate pollution prevention strategies, plans, studies, assessments, and
to establish baselines. Includes pollution prevention inventories, assessments, and
other studies that define the Pollution Prevention Program
A01 Programs that identity environmentally degrading processes and materials
A02 Development of implementation plans
A03 Development of evaluation tools
BOO
Education, training, and awareness programs
COO
C01
C02
COS
C04
Projects that reduce the use of hazardous materials and Toxic Chemicals (Front-
of-Pipe)
Hazardous chemicals listed on EPA's 17 Industrial Toxics List
Projects that reduce the use of other toxic pollutants as defined in Section 2-207 of
Executive Order 12856
Ozone depleting chemicals (ODCS)
Other Hazardous Materials
DOO
D01
Projects that reduce the volume or toxicity of hazardous waste disposed, or toxic
chemicals/pollutants released to the environment (End-of-Pipe)
Process Modification (includes improved maintenance)
52 The description codes ending in 00 are the general categories. If a project or program does not fit into one of the
more specific categories, place it in the most appropriate general category (i.e. AOO, BOO, COO, etc.)
53 If additional breakouts are needed, please contact the Planning, Prevention, and Compliance staff of the Federal
Facilities Enforcement Office.
B- 1
October 1994
-------
CODE DESCRIPTION
D02 Reuse
DOS Recycling
D04 Pretreatment (Component)
DOS Other
EOO
E01
E02
EOS
E04
Projects that reduce the volume of nonhazardous waste disposed or released to the
environment.
Process Modification (includes improved maintenance)
Reuse
Recycling
Other
FOO
Activities (projects) related to review and revision of Military or Federal
specifications and other standardization documents (MELSPECS, MBLSTDS,
Guide Specs, etc.)
B-2
October 1994
-------
APPENDIX C
FACTORS TO CONSIDER WHEN PRIORITIZING A-106 PROJECTS
The following list of factors is provided for the use of those individuals who are
responsible for assigning the priority to their organization's A-106 projects or activities.
Individuals may use the most significant factor, several factors, or all factors in arriving at one
score for the project. The Federal agency rating the project has complete discretion in how it
applies this list.
Under previous A-106 guidance, a priority code (High, Medium, or Low) was assigned to
a project depending upon its relevance. However, with this Guidance Document, a new
numerical procedure for prioritizing A-106 requirements is being introduced. Each project will be
given a single numerical score ranging from 1.0-9.9. Correlation with the H, M, L system is as
follows:
High (H) - 7.0 - 9.9
Medium (M) - 4.0 - 6.9
Low (L)-1.0-3.9
Finally, there may be additional reasons for initiating a project which have not been
identified below.
Regulatory Risk
(H) Funding is critical to achieve compliance schedules mandated by applicable environmental
laws and regulations.
(H) Funds are required for inventories, assessments, surveys, and studies necessary to define
critical programs required by newly enacted laws and regulations.
(M) Project is required by laws/regulations, but could be postponed without the facility going
out of compliance.
(M) Project is for regulations that have been proposed, but have not yet been promulgated.
(L) Project is not currently required, but may be needed to avoid possible non-compliance in
future.
C-l
October 1994
-------
Risk to Human Health and the Environment
(H) Potential human health (cancer/noncancer) and/or ecological risk is high.
(M) Potential human health and/or ecological risk is medium.
(L) Potential human health and/or ecological risk is low.
Pollution Prevention
(H) Pollution prevention activities/projects are needed to meet time-specific requirements of
E.G. 12865, E.G. 12873, and other pollution prevention E.O.s.
(H) Pollution prevention projects that eliminate or reduce use of toxic pollutants as defined in
2-207 of E.G. 12856.
(M) Pollution prevention activities/projects are needed to meet goals and objectives that do not
have a specific deadline in E.G. 12865, E.G. 12873, and other P2 E.O.s.
Conservation
(H) Established time-sensitive standards explicitly required by environmental laws must be met
to sustain the natural resource base of the land.
(M) Legal requirements that must be met, but are not time-sensitive.
(L) Investments to the natural or cultural environment not driven by legal requirements and
not time-sensitive.
Mission
(H) Failure to act will significantly affect the facility's ability to perform its assigned or
projected mission.
(M) Failure to act may degrade a facility's ability to perform assigned or projected missions.
(L) Failure to act will not degrade the facility's ability to perform assigned or projected
missions.
C-2
October 1994
-------
Federal Agency Directives and Regulations
(H) Funds are needed to meet time-specific requirements contained in the internal directives
and/or regulations.
(M) Funds are needed to meet non-time-specific requirements contained in the internal
directives and/or regulations.
(L) Funds are needed to meet general guidance contained in internal directives and/or
regulations.
Program Management
(H) Funds are critical for developing and sustaining effective management of the
environmental program.
(M) Funds are important for developing and sustaining management of the environmental
program.
(L) Funds are desirable for developing and sustaining management of the environmental
program.
Program Continuity
(H) Deferral of funding will delay critical aspects of the Federal Agency's environmental
program.
(M) Deferral of funding will delay some important aspects of the Federal Agency's
environmental program.
(L) Deferral of funding will delay some aspects of the Federal Agency's environmental
program.
Investment Strategy
(H) Projects with monetary payback in three years or less.
(M) Projects with monetary payback between three and five years.
(L) Projects with monetary payback greater than five years.
C-3
October 1994
-------
Professional Judgment
(H) Successful execution of the project will significantly improve the environment.
(M) Successful execution of the project will greatly improve the environment.
(L) Successful execution of the project will improve the environment.
Public Perception
(H) Immediate action needed to avoid confrontation with Federal/State/local regulatory
officials or the public.
(M) Some action needed to avoid confrontation with Federal/State/local regulatory officials or
the public.
(L) Not Applicable. Not an issue.
C-4
October 1994
-------
APPENDIX D
USES FOR THE A-106 SYSTEM
AT DIFFERENT ORGANIZATIONAL LEVELS
The purpose of this appendix is to illustrate some of the uses of the A-106 management
information system at various organizational levels throughout the Federal Government.
I. FEDERAL FACILITY (INSTALLATION/ACTIVITY)
• Provides facility commanders, directors, environmental managers, and budget
offices with an important management tool in the day-to-day operations of the
environmental program.
• Provides a comprehensive inventory of all identified environmental requirements.
« Establishes relative priorities and supports the justification for funding of
environmental requirements when facility resource allocation decisions are being
made.
• Serves as the primary environmental input into other facility engineering and
resource management planning, programming, and budgeting documents.
Documents the backlog of currently unfunded projects.
• Equips the environmental manager with a legitimate reason for direct participation
in the facility planning and budgeting process.
• Provides documentation of the facility's initiatives in attempting to attain and
sustain compliance with environmental laws and regulations.
• Represents assurance to regulatory authorities that a good-faith effort is being
made to meet the milestones set forth in signed Federal Facility Compliance
Agreements (FFCAs) and other compliance and enforcement documents.
• Provides continuity to the environmental program upon the turnover of facility
environmental personnel.
D-l
October 1994
-------
H. BUREAU54
Provides the bureau with detailed information relative to the current compliance
status of each of its facilities.
Produces data necessary to determine whether bureau facilities are anticipating
new requirements and requesting sufficient funding to attain and sustain
compliance within each specific media program area.
Furnishes environmental managers and media staff officers with information
needed to effectively manage the programs for which they are responsible.
Is used to develop budget estimates for outyear requirements, and to prepare
schedules identifying funding levels in bureau program and budget documents.
Furnishes documentation of environmental funding requirements for bureau
resource allocation decisions.
Provides information for determining the relative priorities among all projects
submitted by the bureau's facilities.
Can be used to prioritize redistribution of funds at the mid-year review, to allocate
any year-end funds that become available, and to apportion cuts in funding during
times of budgetary shortfall.
Can be used to develop statistical parameters in order to compare one bureau
facility with another.
HI. FEDERAL AGENCIES
• Fulfills the requirements of Executive Order 12088, which requires Heads of
Departments to develop environmental plans for their organization.
• Provides the Federal agency with detailed information (not otherwise available)
relative to the current compliance status and funding requirements of each of its
facilities.
• Establishes relative priorities for the use of environmental funds which can be used
to maximize compliance within the organization.
M For the purpose of this appendix, the "Bureau" designates the principal subordinate organizational units of a
Federal agency, and is synonymous with MACOM, MAJCOM, Field Office, etc.
D-2
October 1994
-------
Establishes a framework for evaluating the effectiveness of the Federal agency's
environmental strategy and implementation of execution plans by its bureaus and
facilities.
Generates the data needed in order to develop appropriate departmental
environmental funding policies.
Furnishes an independent source of information for use in verifying and validating
bureau environmental budget and programming submissions.
Provides information essential to senior decision makers when making decisions on
resource allocation between competing departmental programs and requirements.
Can be used to develop outyear cost projections, and to forecast the costs of new
regulations proposed for promulgation by the Congress, EPA, and other regulatory
authorities.
Assists in development of environmental program schedules contained in budget
submissions and reports to OMB and to the Congress.
Furnishes environmental managers and media staff officers with information
needed to effectively manage the programs for which they are responsible.
Generates data needed for identifying and evaluating those areas where additional
environmental training is required.
Provides data for use in developing information for use in Congressional
testimony.
IV. ENVIRONMENTAL PROTECTION AGENCY
• Provides a systematic methodology and standardized data elements for the
collection of environmental data throughout the Federal government.
• Generates a comprehensive inventory of all identified environmental requirements
as reported by individual Federal agencies.
• Enables EPA to review and evaluate environmental plans at both the program
(aggregated data) level or individual project level.
• Permits analysis of over twenty-five (25) different parameters that determine the
priority of a project or program.
D-3
October 1994
-------
Furnishes a mechanism for EPA to validate that Federal agencies are requesting
funds for projects and other activities that will bring them into sustained
compliance with all environmental requirements.
Furnishes data in a format that facilitates correlation with other compliance and
enforcement tracking systems.
Provides the basis for review, verification, and comment on the priorities Federal
agencies have established for their environmental projects and programs.
Permits review of Federal agency progress in implementing newly promulgated
programs.
Furnishes an efficient approach for evaluating the costs of proposed projects
and/or programs through comparison of a wide range of various statistical
parameters available from analysis of other similar projects in the system.
Provides data in a format for analysis of environmental media programs in order to
determine funding trends, program discrepancies, and to determine the need for
additional program and technical assistance.
Facilitates the development of algorithms for projecting the future costs of
environmental programs through use of both historical and outyear cost data
available in the data base.
Provides EPA with information needed for implementation of other aspects of the
Federal facilities compliance program.
V. OFFICE OF MANAGEMENT AND BUDGET
• Provides OMB with summary and detailed (as needed) funding information
regarding individual Federal agency environmental programs.
• Is used as a budget support document during review and approval of Federal
agencies' environmental budget requests.
• Provides aggregated government-wide information for use and analysis by OMB
during preparation of the President's Budget to Congress.
• Provides information to support Executive branch in Congressional legislative and
oversight hearings.
D-4
October 1994
-------
APPENDIX E
USES OF PROJECT COST DATA
Aggregated historical cost data, such as those contained in the A-106 database, can be
useful for developing a number of mathematical algorithms that can be used in reviewing and
evaluating new A-106 project submissions. This cost information provides a historical
perspective on how much various projects cost, given the nature and scope of work, by regulatory
media (CAA, CWA, RCRA, Superfund, etc.).
When an environmental manager is evaluating projects for the A-106 submission, a
comparative analysis of costs on a project-by-project basis may not yield useful results. However,
when a large number of similar projects are aggregated, it can provide a useful guide for a
manager on how close proposed individual project costs track with historical averages. If a
proposed project is at the higher end of the cost range, the manager can either consider re-
packaging the project or provide a stronger justification for the higher cost.
Once the environmental manager has determined which regulatory program and project
category best describes a project, the historical cost statistics can be used to determine how the
project compares to past projects. An examination of the statistical dispersion of projects in the
database, by regulatory media and project category should provide the number of projects within
that category, the category's total cost, median, average cost, standard deviation, standard
deviation divided by mean, and the smallest and largest project for the category.
For example, an agency could maintain its information in a project-level database that
aggregates historical cost information. Such historical cost information could be used as a guide
to assess how the cost of individual projects compare to average or median costs for similar types
of past projects.
Table E-l contains cost information of 41 hypothetical projects (e.g., site survey - code
212, or tank closure/demolition - code 441). Information provided on each project type includes:
number of projects, total cost, median cost, average project cost, standard deviation, standard
deviation divided by mean, smallest project, and largest project. Projects range from $1,000 to
$870 million with an average cost of $1.1 million. However, this average can be misleading
because the standard deviation within each group is high, as reflected by an average standard
deviation divided by the mean of 4.36. Therefore, a substantial portion of values can be expected
at least 4.36 times higher or lower than the average.
Table E-2 presents a more general view of the hypothetical cost data and breaks projects
out into seven cost ranges (e.g., $1,000 - $10,000) then provides a variety of cost information.
Information provided includes: the number of projects in the cost range, the percent of projects in
this cost range compared to the total number of projects, the total number of projects in this cost
range, the percent of projects in this cost range compared to the total cost of projects, the average
E- 1
October 1994
-------
cost of a project in this cost range, the standard deviation, and the standard deviation divided by
the mean. This table can provide a variety of information. For example, projects in the $1,000 -
$1 million range constitute 88% of the total number of projects yet accounts for less than 13% of
the funds.
Another example of hypothetical cost information organized by statute is presented in
Table E-3. This table shows Superfund project category breakdowns by total cost, median,
average cost, standard deviation, standard deviation divided by the mean, and the smallest and
largest project for the category.
Although there can be a high degree of statistical variability in aggregate data of this
nature, the data can be successfully used to locate the minimum and maximum values as limits for
purposes of cost estimation. Due to this variability in cost data, perhaps one of the most
important measures to examine is the median. Given that there are clusters of projects at both the
high and low ends of the spectrum, the median cost should approximate the "typical" project
better than any other measure presented. Within these limitations, the A-106 data maintained by
an individual Federal agency can be used to provide comparative cost information that can be
used in developing planning estimates for forecasting the size of future budget requirements.
E-2
October 1994
rfttftfttrtttttftftftffffftfffffffffftfffffffrftftfffffffffffffffffJffftfffWtffl
-------
Table E-l: Project Cost Statistics by Project
(Dollar Figures in Thousands)
" &W.JM
*&JtgB*y
11
12
13
14
15
22
41
43
211
212
213
221
222
223
231
232
233
311
312
321
322
331
332
341
342
351
352
421
422
423
441
442
451
452
453
2131
2132
2133
2331
2332
2333
" tH08^
A^^BTJ^e-"
.. Nutter
of
jttat)$ee&
729
364
677
125
520
319
203
339
857
1060
236
69
142
16
51
281
164
55
441
160
408
92
473
269
136
208
420
435
1145
141
763
184
663
1190
511
277
159
105
11
17
12
" &43?
^""332
•Tofe&Cwt
163486
143586
1744013
45457
101867
334585
271144
528112
274331
484483
149566
167953
768386
144670
22864
302655
67456
34608
124663
130097
85449
72127
284690
281195
30602
141186
74761
1469134
270371
92015
195279
423534
3611089
1504446
393881
150999
8356
22603
2859
671
1426
' J683745S
smjx
M«83H"
Canst.
54
50
381
56
66
175
124
300
10
73
70
1050
1480
367
41
175
110
90
56
120
44
260
100
342
50
154
35
200
26
146
25
300
400
200
150
200
17
80
50
10
68
f
-
A««Kjge
^reject,/
-Cast
224
394
2576
364
1959
1049
1336
1558
320
457
634
2434
5441
9042
448
1077
411
629
283
813
209
784
602
1045
225
679
178
3377
236
653
256
2302
5447
1264
771
545
53
215
260
39
119
U12
', StajeSariT-,
&e\isjfeti
1531
2030
19165
1817
34883
3944
7552
5028
3193
2780
3446
3457
9713
29683
996
6382
980
1979
956
3083
626
1609
2801
1980
616
3461
526
22268
1457
3024
903
7048
39636
5953
4579
1044
81
409
600
74
138
;
;
£&n&at<3 .;"
;; 'pBvJs&w. v,
ijl&feaH ,,
6.825
5.147
7.440
4.998
17.807
3.760
5.654
3.228
9.976
6.083
5.438
1.420
1.795
3.283
2.222
5.925
2.383
3.145
3.382
3.791
2.987
2.053
4.654
1.895
2.736
5.099
2.957
6.593
6.167
4.634
3.528
3.062
7.277
4.708
4.540
1.915
1.534
1.898
2.308
1.881
1.159
43£
SawlfeSf'
Rfflj«*
1
1
1
2
1
2
1
1
1
1
1
5
5
50
2
1
1
4
1
1
1
4
1
2
1
1
1
2
1
1
1
1
1
1
1
1
1
1
20
1
5
3-
i&cl
36516
35475
476334
20048
791617
43164
84847
68862
86688
71290
48510
15000
71292
123750
5000
101964
8925
11905
10185
34140
6605
12000
50000
15700
5750
45000
6150
429771
34012
35000
12030
702500
870000
127900
73992
10150
400
2700
2150
325
500
;
9t&)0 ''••
E-3 October 1994
rfffffffff™f™™fMffffffffffffff™f*f**™**f**ttt*ff**M*frfffff**tfft*ffffffffffttttfffftffffrfffffftffffftftf^^ f
-------
Table E-2: Project Statistics by Cost Range
(Dollar Figures in Thousands)
Cost R*»gc
SI -10
S10-100
S100-500
S500- 1,000
SI, 000 -10,000
S10.000 -
588,000
588,000 -
870000
' »6f
3?*«}feCfa!
2392
5,239
3,931
1,104
1,531
216
13
*4fa&^
;\^|feftfe-v
16.6%
36.3%
27.2%
7.7%
10.6%
1.5%
0.1%
^/f$$\C^ff
147,236
233,523
980,685
807,610
4,573,114
5,286,976
4,141,308
"v^J^ J
f$UH$H
--";\-C<)*t
1 s •.-. ^ ••
0.1%
1.5%
6.1%
5.0%
28.5%
33.0%
25.8%
I,-", * wl %s
&»&*&
, >., $**^ ,
5.9
44
249
732
2,987
24,477
318,562
,,Jfc£
^ Bft^^dn "
3.0
26.9
109
149
2,099
17,226
250,129
<
-------
Table E-3: Superfund Project Statistics
(Dollar Figures in Thousands)
F*vj£^ r™^--
' &£is*£j:''j&. vv\.. *•
:^lrp|jp|!*3: ^-.g^
SFND1
SEND2
SENDS
SEND4
SENDS
SEND6
SEND?
SFND8
SEND9
SEND10
SEND11
SFND12
SEND13
SEND14
SEND15
SFHD16
SEND17
SEND18
SEND19
SEND20
i "•••^^ ••
Sll> °"1£~ ''••
^NflBssjsr-.
?fc^;
JfrtifaVljsi.,-"
11
21
46
2
5
8
139
11
69
142
16
49
3
4
3
39
27
246
30
2
s- ;" "^"-Cr - s-s
-. •••••. \V^ s ^%
% \%%%%%%''''
$2,481
$38^74
$36,210
$49
$4,182
$2,957
$93,613
$45,252
$167,953
$768386
$144,670
$172,803
$955
$12,675
$40,803
$19,129
$186,082
$2,906,419
$312,843
$2,192
M&^iaf"
">^«
<&&,
$72
$75
$290
$25
$948
$15
$110
$1,803
$1,050
$1,480
$300
$525
$175
$2,777
$17,657
$50
$902
$1,055
$375
$1,096
i •,
-Av^raf^-""
-!&j<«* -
C^-"
$226
$1,823
$787
$25
$836
$370
$673
$4,114
$2,434
$5,411
$9,042
$3,527
$318
$3,169
$13,601
$490
$6,892
$11,815
$10,428
$1,096
~ "<;~
:&aa&a-^> fff
„ "C%% '& ""A
-$&»*«$./
S^v^Kifeft
-j W^K""--
1.572
4.129
2.333
0.592
0.610
1.405
3.331
1.176
1.420
1.795
3.283
4.064
0.716
0.734
0.508
2.184
2.108
5.351
2.890
0.010
1 ;!*C
F«j^"i;i
$12
$2
$5
$10
$50
$10
$1
$199
$5
$5
$50
$15
$140
$320
$3,867
$3
$20
$4
$8
$1,085
im
$1,300
$35,475
$12,315
$39
$1,497
$1,450
$22,200
$14,481
$15,000
$71,292
$123,750
$101,964
$640
$6,802
$19,279
$6,000
$70,250
$870,000
$127,900
$1,107
E-5
October 1994
fffffffttfttffffffffffffffftfttttttfffftfffftfffttttttMfffffffffffttttfffffffffffl
-------
-------
APPENDIX F
AGENCY/BUREAU CODES
Agency/Bureau (in DOD, Agency/Major Command) code is a four-digit numeric character
combination which reflects the responsible Federal agency and Bureau of a facility. The first and
second characters of this numeric combination are assigned by the U.S. Treasury when an agency
is established. This code also assists the Office of Management and Budget (OMB) in the
identification of each individual agency for issuance of approved appropriations. The third and
fourth characters are assigned by General Services Administration (GSA), Financial Management
Information Division, after the verification of the establishment of bureau functions.
AG# BU# AGENCY NAME
BUREAU NAME
1200 1200 DEPT OF AGRICULTURE
1205 1205
1223 1223
1231 1231
1234 1234
1235 1235
1237 1237
1300 1300 DEPT OF COMMERCE
1306 1306
1313 1313
1314 1314
1315 1315
1320 1320
1400 1400 DEPT OF INTERIOR
1401 1401
1404 1404
1407 1407
1409 1409
1411 1411
1415 1415
1417 1417
1418 1418
1419 1419
1423 1423
1436 1436
1444 1444
AGRICULTURAL RESEARCH SERVICE
FOREST SERVICE
RURAL ELECTRIFICATION ADMIN
ANIMAL & PLANT HEALTH INSP SERV
SOIL CONSERVATION SERVICE
FOOD SAFETY & INSPEC SERVICE
NATL INST OF STDS & TECH
MARITIME ADMINISTRATION
NAT'L OCEANIC ATMOSPHERIC ADM
NATL BUREAU OF STANDARDS
ECONOMIC DEVELOPMENT ADMIN
OFFICE OF CONSTRUCTION MGMT
TERRITORIAL & INTL AFFAIRS
GEOLOGICAL SURVEY
BUREAU OF INDIAN AFFAIRS
BUREAU OF LAND MANAGEMENT
BUREAU OF MINES
NATIONAL PARK SERVICE
OFFICE OF SURFACE MINING
MINERALS MANAGEMENT SERVICE
BUREAU OF RECLAMATION
FISH AND WILDLIFE SERVICE
NATIONAL BIOLOGICAL SURVEY
F-l
October 1994
-------
AG# BU# AGENCY NAME
BUREAU NAME
1500 1500
1515 1515
1519 1519
DEPT OF JUSTICE
1600 1600 DEPT OF LABOR
1700 1700
1711 1711
1714 1714
1715 1715
1718 1718
1719 1719
1722 1722
1723 1723
1724 1724
1725 1725
1727 1727
1730 1730
1733 1733
1739 1739
1760 1760
1761 1761
1762 1762
1763 1763
1765 1765
1769 1769
1770 1770
1772 1772
DEPT OF NAVY
IMM & NATURALIZATION SERVICE
BUREAU OF PRISONS
CHIEF OF NAVAL OPERATIONS
CHIEF OF NAVAL RESEARCH
NAVAL INTELLIGENCE COMMAND
BUREAU OF MEDICINE
NAVAL AIR SYSTEMS COMMAND
CHIEF OF NAVY PERSONNEL
NAVAL SUPP SYSTEMS COMMAND
NAVAL SEA SYSTEMS COMMAND
NAV FAC ENGINEER COMMAND
COMMANDANT MARINE CORPS
STRAT SYSTEMS PROJECT OFFICE
MILITARY SEALIFT COMMAND
SPACE & WARFARE SYS COMM
CINC U.S. ATLANTIC FLEET
CINC U.S. NAV FORC EUROPE
CHIEF NAVAL ED AND TRAINING
NAVAL COMP & TELECOM COMM
NAVAL OCEANOGRAPfflC COMM
NAVAL SECURITY GROUP COMM
CINC U.S. PACIFIC FLEET
NAVAL RESERVE FORCE
1800 1800 UNITED STATES POSTAL SERVICE
DEPT OF STATE
1900 1900
1901 1901
1915 1915
1931 1931
1936 1936
2000 2000 DEPT OF TREASURY
OFFICE OF ADMINISTRATION
INT'L BOUND & WATER COMMISSION
US COMMISSION TO THE U.N.
OFFICE OF FOREIGN BUILDINGS
F-2
October 1994
-------
AG# BU# AGENCY NAME
BUREAU NAME
2100 2100
2101 2101
2102 2102
2104 2104
2106 2106
2108 2108
2112 2112
2116 2116
2118 2118
2122 2122
2135 2135
2136 2136
2137 2137
2138 2138
2140 2140
2145 2145
2146 2146
2147 2147
2149 2149
2199 2199
DEPARTMENT OF ARMY
INFORMATION SYSTEMS COMMAND
MILITARY DIST OF WASHINGTON
US ARMY RESERVE
OFFICE OF THE SURGEON GENERAL
CORPS OF ENGINEERS
INTELL & SECURITY COMMAND
MEDICAL COMMAND
NATIONAL GUARD
OFFICE OF SECRETARY OF THE ARMY
MILITARY TRAFFIC MGMT COMM
BALL MISS DEFENSE SYSCOM
TRAINING & DOCTRINE COMM
ARMY MATERIAL COMMAND
FORCES COMMAND
US ARMY PACIFIC
USA MILITARY ACADEMY
US ARMY EUROPE
EIGHTH US ARMY
US ARMY SOUTH
3300 3300 SMITHSONIAN INSTITUTION
3600 3600 VETERANS ADMINISTRATION
4700 4700
4715 4715
4718 4718
GENERAL SERVICES ADMIN
PUBLIC BUILDINGS SERVICE-FBF
FEDERAL PROP RESOURCES SERV
5600 5600 CENTRAL INTELLIGENCE AGENCY
5700 5700
5702 5702
5704 5704
5708 5708
5710 5710
5711 5711
5712 5712
5714 5714
5715 5715
DEPT OF AIR FORCE
HEADQUARTERS (AIR STAFF)
AIR FORCE DISTRICT OF WASH
ACCOUNTING AND FINANCE CTR
COMMUNICATIONS SERV (AFCC)
SPACE COMMAND
RESERVE COMMAND
SECURITY SERVICE
AIR TRAINING COMMAND
F-3
October 1994
-------
AG# BU#
5716 5716
5717 5717
5718 5718
5719 5719
5721 5721
5722 5722
5723 5723
5724 5724
5725 5725
5726 5726
5728 5728
5729 5729
5730 5730
5731 5731
6400 6400
6800 6800
6900 6900
6901 6901
6902 6902
6903 6903
6905 6905
6907 6907
6909 6909
6910 6910
6911 6911
6913 6913
7500 7500
7503 7503
7506 7506
7508 7508
7509 7509
7510 7510
7511 7511
7513 7513
7518 7518
AGENCY NAME BUREAU NAME
AIR UNIVERSITY
AIR FORCE LOGISTICS COMMAND
MILITARY AIRLIFT COMMAND
STRATEGIC AIR COMMAND
TACTICAL AIR COMMAND
PERSONNEL MANAGEMENT EVAL
APPELLATE REVIEW
REGIONAL CIVIL ENGINEER
PUBLICATION DISTRIBUTION CTR
OFF OF SPECIAL INVESTIGATIONS
AIR NATIONAL GUARD
AIR FORCE ACADEMY
PACIFIC AIR FORCES
U.S. AIR FORCES EUROPE
TENNESSEE VALLEY AUTHORITY
ENVIRONMENTAL PROTECTION AGENCY
DEPT OF TRANSPORTATION
OFFICE OF THE SECRETARY
RESEARCH SPEC PROG ADMIN
UNITED STATES COAST GUARD
FEDERAL AVIATION ADMIN
FEDERAL HIGHWAY ADMIN
FEDERAL RAILROAD ADMIN
MARITIME ADMINISTRATION
ST.LAWRENCE SEAWAY DEVELOPNT
ALASKA RAILROAD
DEPT OF HEALTH & HUMAN SVCS
HEALTH RESOURCES & SERV ADMIN
FOOD AND DRUG ADMIN
NATIONAL INSTITUTE OF HEALTH
CENTER FOR DISEASE CONTROL
INDIAN HEALTH SERVICE
OFFICE OF ASST SEC FOR HEALTH
ALCH, DRUG ABUSE & MENTAL HLTH
AGENCY FOR HLTH CARE POLICY
RESTRUCTURING
F - 4 October 1994
-------
AG# BU# AGENCY NAME
BUREAU NAME
8000
8002
8003
8004
8005
8006
8007
8008
8009
8010
8011
8012
8016
8019
8000
8002
8003
8004
8005
8006
8007
8008
8009
8010
8011
8012
8016
8019
NAT'L AERO & SPACE ADMIN
AMES RESEARCH CENTER
FLIGHT RESEARCH CENTER
GODDARD SPACE FLIGHT CENTER
JET PROPULSION LABORATORY
JOHNSON SPACE CENTER
KENNEDY SPACE CENTER
LANGELY RESEARCH CENTER
LEWIS RESEARCH CENTER
MARSHALL SPACE FLIGHT CENTER
MICHOUD ASSEMBLY FACILITY
NATL SPACE TECHNOLOGY LABS
WHITE SANDS TEST FACILITY
NASA DOWNEY INDUSTRIAL PLANT
8600 8600 DEPT OF HOUSING & URBAN DEVELOPMENT
8800 8800 NATL ARCHIVES & RECORDS ADMINISTRATION
8900 8900
8901 8901
8903 8903
8904 8904
8905 8905
8906 8906
8907 8907
8908 8908
8909 8909
8910 8910
8911 8911
8912 8912
8913 8913
8914 8914
8916 8916
8917 8917
8918 8918
8919 8919
8920 8920
DEPT OF ENERGY
ENERGY RESCH & DEVELOP ADMIN
STRATEGIC PETRO RES PROJ MGMT
DOE NEVADA OPERATIONS OFFICE
DOE ALBUQUERQUE OPS OFC
SAN FRANCISCO OPERATIONS OFC
SCHENECTADY NAVAL REACT OFF
IDAHO OPERATIONS OFFICE
CHICAGO OPERATIONS OFFICE
SAVANNAH RIVER OPERATIONS OFF
PITTSBURGH NAVAL REACTORS OFC
WESTERN AREA POWER ADMIN
DOE NAVAL PETRO & OIL SHALE RES
BONNEVILLE POWER ADMIN
SOUTHWESTERN POWER ADMIN
ALASKA POWER ADMINISTRATION
DOE OAK RIDGE OPERATIONS OFC
GERMANTOWN
ROCKY FLATS
9600 9600 ARMY CORPS OF ENGINEERS, CIVTL
F-5
October 1994
-------
AG# BU# AGENCY NAME
BUREAU NAME
9715 9715 DEFENSE LOGISTICS AGENCY
9799 9799 FORMERLY USED DEFENSE SITES
F-6
October 1994
-------
USDA (12)
USDOL (16)
USNAVY (17)
APPENDIX G
AGENCY FUNDING ACCOUNT CODES
Department of Agriculture
01 Region 1 25
02 Region 2 26
03 Regions 27
04 Region 4 28
05 Regions 31
06 Region 6 32
07 Region 7 33
08 Region 8 34
09 Region 9 35
10 Region 10 36
11 Dept Fund CERCLA 37
12 Dept Fund RCRA 38
13 Dept Fund CWA-PS 41
14 Dept Fund CWA-NPS 42
15 Dept Fund SDWA 43
16 Dept Fund FIFRA 44
17 Dept Fund TSCA 45
18 Dept Fund CAA 46
21 SWA Fund CERCLA 47
22 SWA Fund RCRA 48
23 SWA Fund CWA-PS Blank
24 SWA Fund CWA-NPS
Department of Labor
87..99 Year Project Funded 10
Blank Other 16
Department of the Navy
01 MILCON 06
02 O&M 07
03 RDT&E 08
04 OPN 09
05 MILCON, Navy Rsv 10
G-l
SWA Fund SDWA
SWA Fund FIFRA
SWA Fund TSCA
SWA Fund CAA
Other Funds CERCLA
Other Funds RCRA
Other Funds CWA-PS
Other Funds CWA-NPS
Other Funds SDWA
Other Funds FIFRA
Other Funds TSCA
Other Funds CAA
Combined Funds CERCLA
Combined Funds RCRA
Combined Funds CWA-PS
Combined Funds CWA-NPS
Combined Funds SDWA
Combined Funds FIFRA
Combined Funds TSCA
Combined Funds CAA
Other
DOL Funds
A-106 Funds
Family Housing
MILCON, MARCORPS
O&M, MARCORPS
Others
DERA
October 1994
-------
USARMY (21) Department of the Army
01 MCA
02 OMA-ECCP
03 RDTE - ECCP
04 PAA-PBS
05 MCAR
06 AFH (CONST)
07 MCA-ARNG
08 O&M - ARNG
09 DBOF
11 OMAR
12 AFH (O&M)
13 RPA
REIMBURSE
14 OPA
15 DERA-OMA
16 DERA-RDTE
17 DERA-MCA
18 DERA-OPA
GSA (47) General Services Administration
0 1 FBH (Federal Building Fund)
Blank Other
USAF (57) Department of the Air Force
01 MILCON
02 O&M
03 RDT&E
04 GOCO Fund
05 MILCON, Rsv Force
19
20
21
22
23
24
25
26
27
28
29
52
90
92
93
94
99
06
07
08
09
10
BCA - O&M
BCA - FH
BCA - MC
WTCV- PBS
WTCV (OCOH)
USARCS
LEGACY
DHP
WTCV - PM
ACFT
PAA- APE
OMA-
NAF
OMA, NON - ECCP
RDTE, NON-ECCP
PAA (OCOH)
NONFEDERAL US
O&M, Rsv Force
MILCON, ANG
O&M, ANG
Others
DERA
USDOT (69) Department of Transportation (United States Coast Guard)
01 AC&I (USCG)
02 OE (USCG)
03 EC&R(USCG)
G-2
04
05
Blank
tttffftfffffffffff
F&E (FAA)
OPS (FAA)
Other
October 1994
ffffffrfftfffttfffffffJffffffffffffffffftttttfftftfffrfffffffffffffffffffffffffffftffff
-------
NASA (80)
TJSDOE (89)
National Aeronautics and Space Administration
01 COF
02 ROS
03 R&D
Department of Energy
01
02
03
OE
LI
GPP
04 SFC&DC
Blank Other
04 CE
Blank Other
USACE-Civil (96) Army Corps of Engineer (Civil Works)
02 O&M 08
03 General Investigations 09
06 General Expense
MS River, Tribs.
Construction
Blank Other
USDOD-DLA (97) Department of Defense (Defense Logistics Agency)
01 MELCON
02 O&M
03 Revolving Fund
04
05
DERA
DERA
Blank Other
G-3
October 1994
-------
-------
APPENDIX H
STATE/TERRITORY AND EPA REGIONAL ABBREVIATIONS
TERRITORY OR
STATE NAME
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Canal Zone
Colorado
Connecticut
Delaware
Dist. of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas f
Kentucky
Louisiana
Maine
Mariana Islands
Maryland
Massachusetts
Michigan
Midway
Minnesota
Mississippi
Missouri
CODE
AL
AK
AS
AZ
AR
CA
CZ
CO
CT
DE
DC
FL
GA
GU
ffl
ID
IL
IN
IA
KS
KY
LA
ME
CM
MD
MA
MI
MW
MN
MS
MO
EPA
REG
04
10
09
09
06
09
09
08
01
03
03
04
04
09
09
10
05
05
07
07
04
06
01
09
03
01
05
09
05
04
07
TERRITORY OR
STATE NAME
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Trust Territory
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Foreign
Facilities
H-l
rffffffffffffffffffffffffsfffJffJffMfftftfftffftfftVftfffffftfffffffffffffff,
CODE
MT
NE
NV
NH
NJ
NM
NY
NC
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
TT
UT
VT
VI
VA
WA
WV
WI
WY
XX
EPA
REG
08
07
09
01
02
06
02
04
05
06
10
03
02
01
04
08
04
06
09
08
01
02
03
10
03
05
08
11
October 1994
tfttftfffffffffftfttffffttffffttffftfttttttirtttetftfftftffffftf,
-------
-------
APPENDIX I
COUNTRY CODES
NATIONAL
ENTITY
Aghanistan
Albania
Algeria
American Samoa
Andorra
Angola
Anguilla
Antarctica
Antigua & Barbuda
Argentina
Aruba
Australia *
Austria
Bahamas, The
Bahrain
Bangladesh
Barbados
Belgium
Belize
Benin
Bermuda
Bhutan
Bolivia
Botswana
Bouvet Island
Brazil
British Ind. Ocean
Territory
British Virgin Is.
Brunei Darussalam
Bulgaria
Burkina Faso
Burma
Burundi
Cambodia
BUREAU
CODE
ALPHA-3
AFG
ALB
DZA
ASM
AND
AGO
AIA
ATA
ATG
ARG
ABW
AUS
AUT
BHS
BHR
BGD
BRB
BEL
BLZ
BEN
BMU
BTN
BOL
BWA
BVT
BRA
IOT
VGB
BRN
BGR
BFA
BUR
BDI
KHM
I
OF STANDARDS (5/87)
ENTITY
Cameroon
Canada
Cape Verde
Cayman Islands
Central African
Republic
Chad
Chile
China
Christmas Island
Cocos (Keeling) Islands
Colombia
Commonwealth of Independent
States
Comoros
Congo
Cook Islands
Costa Rica
Cuba
Cyprus
Czechoslovakia
Denmark
Djibouti
Dominica
Dominican Republic
Ecuador
Egypt
El Salvador
Equatorial Guinea
Ethiopia
Falkland Islands
(Islas Malvinas)
Faroe Islands
Federated States of Micronesia
Fiji
j
VffMUWfWMfWffWfffJtMffffWffffffiVfttMfffttfffffff-rfffffffffffffJ'fffffffffftttftM'tt
CODE
ALPHA-3
CMR
CAN
CPV
CYM
CAP
TCD
CHL
CRN
CXR
CCK
COL
CIS
COM
COG
COK
CRI
CUB
CYP
CSK
DNK
on
DMA
DOM
ECU
EGY
SLV
GNQ
ETH
FLK
FRO
FSM
FJI
October 1994
-------
ENTITY
Finland
France
French Guiana
French Polynesia
French Southern and
Antarctic Lands
Gabon
Gambia
Germany
Ghana
Gibraltar
Greece
Greenland
Grenada
Guadeloupe
Guam
Guatemala
Guinea
Guinea-Bissau
Guyana
Haiti
Heard Island and
McDonald Islands
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
Iran
Iraq
Iraq-Saudi Arabia
Neutral Zone
Ireland
Israel
Italy
Ivory Coast
Jamaica
Japan
Jordan
CODE
ALPHA-3
FIN
FRA
GUF
PYF
ATF
GAB
GMB
DEU
GHA
GIB
GRC
GRL
GRD
GLP
GUM
GTM
GIN
GNB
GUY
HTI
HMD
HND
HKG
HUN
ISL
END
EDN
ERN
IRQ
NTZ
ERL
ISR
ITA
CIV
JAM
JPN
JOR
1-2
fffffffffffffffffffffffftffffffffffffffffffffffftfffffffffffffffffffffff.
ENTITY
Kenya
Kiribati
Korea, Democratic
People's Republic of
Korea, Republic of
Kuwait
Lao People's
Democratic Republic
Lebanon
Lesotho
Liberia
Libya
Liechtenstein
Luxembourg
Macau
Madagascar
Malawi (>
Malaysia
Maldives
Mali
Malta
Marshall Islands
Martinique
Mauritania
Mauritius
Mayotte
Mexico
Monaco
Mongolia
Montserrat
Morocco
Mozambique
Namibia
Nauru
Nepal
Netherlands
Netherlands Antilles
New Caledonia
New Zealand
Nicaragua
VWWV^VWVW.VA^^^-A^WVAVJWWfAVfffftfttfffffWttfA^WiVftft
rvttwfft
-------
ENTITY
CODE
ALPHA-3
ENTITY
CODE
ALPHA-3
Niger
Nigeria
Niue
Norfolk Island
Northern Mariana Islands
Norway
Oman
Pakistan
Palau
Panama
Papua New Guinea
Paracel Islands
Paraguay
Peru
Philippines
Pitcairn Islands
Poland
Portugal
Puerto Rico
Qatar
Reunion
Romania
Rwanda
St. Christopher and
Nevis
St. Helena
St. Lucia
St. Pierre and Miquelon
St. Vincent and the
Grenadines
San Marino
Sao Tome and Principe
Saudi Arabia
Senegal
Seychelles
Sierra Leone
Singapore
Solomon Islands
Somalia
South Africa
NER
NGA
NIU
NFK
MNP
NOR
OMN
PAK
PLW
PAN
PNG
PAR
PRY
PER
PHL
PCN
POL
PRT
PRI
QAT
REU
ROM
RWA
KNA
SHN
LCA
SPM
VCT
SMR
STP
SAU
SEN
SYC
SLE
SGP
SLB
SOM
ZAF
Spain
Spratly Islands
Sri Lanka
Sudan
Suriname
Svalbard and Jan
Mayen Islands
Swaziland
Sweden
Switzerland
Syrian Arab Repub.
Taiwan
Tanzania, United
Republic
Thailand
Togo
Tokelau
Tonga
Trinidad & Tobago
Tunisia
Turkey
Turks and Caicos
Tuvalu
Uganda
United Arab Emirates
United Kingdom
United States
United States Minor
Outlying Islands
Uruguay
Vanuatu
Vatican City
Venezuela
Vietnam
Virgin Islands of
the U.S.
Wallis and Futuna
Western Sahara
Western Somoa
Yemen (Sanaa)
1-3
ESP
SPR
LKA
SDN
SUR
SJM
SWZ
SWE
CHE
SYR
TWN
TZA
THA
TGO
TKL
TON
TTO
TUN
TUR
TCA
TUV
UGA
ARE
GBR
USA
UMI
URY
VUT
VAT
VEN
VNM
VIR
WLF
ESH
WSM
YEM
October 1994
-------
ENTITY
CODE
ALPHA-3
ENTITY
CODE
ALPHA-3
Zaire
Zambia
ZAR
ZMB
Zimbabwe
ZWE
1-4
October 1994
-------
APPENDIX J
ENVIRONMENTAL PROTECTION AGENCY
REGIONAL MULTI-MEDIA FEDERAL FACILITY COORDINATORS
Anne H. Fenn
Federal Facilities Coordinator
US EPA Region I (PAS-205)
John F. Kennedy Federal Bldg.
Boston, Massachusetts 02203
(617) 565-3927
FAX-617-565-3346
Laura Livingston
Federal Facilities Coordinator
US EPA Region II
Jacob K. Javitz Federal Bldg.
26 Federal Plaza
New York, New York 10278
(212) 264-8428
FAX-212-264-6693
Eric Ashton
Federal Facilities Coordinator
US EPA Region III
841 Chestnut Street
Philadelphia, Pennsylvania 19107
(215)597-1182
FAX-215-597-7906
Arthur Linton/Dave Holyrod
Federal Facilities Coordinator
US EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-3776
FAX-404-347-5206 or 3721
Lee Regner
Federal Facilities Coordinator
US EPA Region V
77 West Jackson Blvd.
Chicago, Illinois 60604-3590
(312)353-6478
FAX-312-3 53-5374
Brenda Black
Federal Facilities Coordinator
US EPA Region VI
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-6430
FAX-214-665-7446
Craig Bernstein
Federal Facilities Coordinator
US EPA Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
(913)551-7688
FAX-913-551-7863
Dianne Thiel
Federal Facilities Coordinator
US EPA Region VIII
One Denver Place, Suite 500
999 18th Street, 8HWM-FF
Denver, Colorado 80202-2045
(303) 294-1059
FAX-303-294-7559
Sara Segal
Federal Facilities Coordinator
US EPA Region IX
75 Hawthorne Street, E-3
San Francisco, California 94105
(415) 744-1483
FAX-415-744-1598
David Tetta
Federal Facilities Coordinator
US EPA Region X
1200 6th Avenue, WD-126
Seattle, Washington 98101
(206)553-1327
FAX-206-553-0165
J-l
October 1994
-------
-------
APPENDIX K
AGENCY CONTACTS FOR IDENTIFYING GSA INSTALLATION NUMBERS
CONTACT FOR FFID NUMBERS
NAME/AGENCY
Ms. Suzan Pinkston
Program Support Division
U.S. Postal Service
475 L'Enfant Plaza, SW
Washington, D.C. 20260-6423
Mr. James Jackson
Office Of Finance & BAG
819 Taylor Street
Ft. Worth, TX 76102
Ms. Alzora Allen
U.S. Army Corps of Engineers
Washington, D.C. 20314
ATTN: (CERE-PS)
Mr. Joe Martin
Naval Facilities
Engineering Command
Alexandria VA 22332
Mr. Murray Camp
Real Property Branch
Mailstop ASM-740
Federal Aviation Administration
800 Independence Ave., SW
Washington, D.C. 20591
Mrs. Willia Patterson
School Facilities Branch ZAP
Department of Education
Washington, D.C. 20202-6244
Mr. John Moresko
Office of the Interior
Washington, D,C. 20520
TELEPHONE
202-268-3152
817-334-2229
202-272-0529
703-325-7370
202-267-8872
202-401-1663
202-208-5704
K-l
October 1994
-------
NAME/AGENCY
Mr. Robert Mack
AFBO/PPSRE
Department of State
Washington, D.C. 20520
Mr. Bobby Daniels (responsible for new numbers)
GS A Room 6215
18th &F Streets, NW
Washington, D.C. 20405
Mr. Tom Cloutier
Public Health Service
Parklawn 17A-12
Rockville, MD. 20857
Mr. Richard Green/Phil Kogan
Department of Health & Human Services
330 Independence Ave., SW
Rm. 4700
Washington, D.C. 20201
Mr. David McKinney
Headquarters USAF/LEER
Building 16
Boiling Air Force Base
Washington, D.C. 20332-5000
Ms. Kathy Dunn
Real Property & Space Mgmt, Services
Department of Justice
Washington, D.C. 20530
Chief Financial Officer
Office of Financial Mgmt.
Panama Canal Commission
APO Miami FL 34011
Mr. James B. Wilkins
Property Administrator
National Science Foundation
1800 G Street, NW
Washington, D.C. 20550
TELEPHONE
202-647-2793
202-501-0507
301-443-2265
202-619-0426
202-767-6233
202-633-1598
202-357-7414
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NAME/AGENCY
Mr. Thomas Connor (only one kind of property)
Agency Property Management M/ASP (VOA-relay station)
301 4th Street, SW.
U.S. Information Agency
Washington, D.C. 20547
Ms. Peggy Grant, Director
Reports & Analysis Control
Staff Department, HUD
Washington, D.C. 20410
Mr. George O'Reilly
Office of Plant Service
Smithsonian Institution
Washington, D.C. 20506
Mr. William Turner, Chief
Power Accounting Branch
Tennessee Valley Authority
Chattanooga, TN 37402
Mr. Garland Green
Property Management Division
Treasury Department
Washington, D.C. 20220
Mr. Donald E. Jackson
Real Property Office
Department of Veterans Affairs (084A)
Washington, D.C. 20402
Mr. Craig Zane
Department of Energy
1000 Independence Ave, NW
Room 5B-020
Washington, D.C. 20585
Mr. Joe Mink
Director, Administrative Services
Commodity Futures
Trading Commission
Washington, D.C. 20581
K-3
TELEPHONE
202-619-6845
202-708-2721
202-357-2959
202-622-0038
202-233-5026
202-586-0247
202-254-9735
October 1994
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NAME/AGENCY
Mr. Jeff Ryan
Federal Communication Commission
Washington, D.C. 20554
Ms, Jackie Simmons
Office of Administrative Support
Federal Emergency Management Agency
Washington, D.C. 20472
Colonel Clayton L. Moran, Director
Personnel and Administration
American Battle Monuments Commission
Washington, D.C. 20314
Mr. Tony Cuticchia
Office of Facilities (Code NX)
National Aeronautics & Space Administration
Washington, D. C.
Mr. Michael Penn
Real Property & Space Management
Branch, PM-225
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20360
TELEPHONE
202-634-1524
202-646-2638
202-272-0534
202-358-1094
202-260-2022
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October 1994
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APPENDIX L
EXECUTIVE ORDER 12088
Title 3 - The President
Executive Order 12088
October 13, 1978
Federal Compliance with Pollution Control Standards
By the authority vested in me as President by the Constitution and statutes of the United
States of America, including Section 22 of the Toxic Substances Control Act (15 U.S.C. 2621),
Section 313 of the Federal Water Pollution Control Act, as amended (33 U.S.C 1323), Section
1447 of the Public Health Service Act, as amended by the Safe Drinking Water Act (42 U.S.C.
300J-6), Section 118 of the Clean Air Act, as amended (42 U.S.C 7418[b]), Section 4 of the
Noise Control Act of 1972 (42 U.S.C. 4903), Section 6001 of the Solid Waste Disposal Act, as
amended (42 U.S.C. 6961), and Section 301 of Title 3 of the United States Code, and to ensure
Federal compliance with applicable pollution control standards, it is hereby ordered as follows:
1 -1. Applicability of Pollution Control Standards.
1-101. The head of each Executive agency is responsible for ensuring that all necessary
actions are taken for the prevention, control, and abatement of environmental pollution with
respect to Federal facilities and activities under the control of the agency.
1-102. The head of each Executive agency is responsible for compliance with applicable
pollution control standards, including those established pursuant to, but not limited to, the
following:
(a) Toxic Substances Control Act (15 U.S.C 2601 et seq.).
(b) Federal Water Pollution Control Act, as amended (33 U.S.C 1251 etseq.).
(c) Public Health Service Act, as amended by the Safe Drinking Water Act (42 U.S.C.
300fetseq.').
(d) Clean Air Act, as amended (42 U.S.C. 7401 et seq.).
(e) Noise Control Act of 1972 (42 U.S.C. 401 et seq.).
(f) Solid Waste Disposal Act, as amended (42 U.S.C. 6901 et seq.).
(g) Radiation guidance pursuant to Section 274(h) of the Atomic Energy Act of 1954,
as amended (42 U.S.C. 2021(h); see also, the Radiation Protection Guidance to
Federal Agencies for Diagnostic X Rays approved by the President on January 26,
1978 and published at page 4377 of the FEDERAL REGISTER on February 1,
1978).
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October 1994
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(h) Marine Protection, Research, and Sanctuaries Act of 1972, as amended (33 U.S.C.
1401, 1402, 1411-1421, 1441-1444 and 16 U.S.C. 1431-1434).
(i) Federal Insecticide, Fungicide, and Rodenticide Act, as amended (7 U.S.C. 136 et
seq.).
1-103. "Applicable pollution control standards" means the same substantive procedural,
and other requirements that would apply to a private person.
1-2. Agency Coordination.
1-201. Each Executive agency shall cooperate with the Administrator of the
Environmental Protection Agency; hereinafter referred to as the Administrator, and State,
interstate, and local agencies in the prevention, control, and abatement of environmental pollution.
1-202. Each Executive agency shall consult with the Administrator and with State,
interstate, and local agencies concerning the best techniques and methods available for the
prevention, control, and abatement of environmental pollution.
1 -3. Technical Advice and Oversight.
1-301. The Administrator shall provide technical advice and assistance to Executive
Agencies in order to ensure their cost effective and timely compliance with applicable pollution
control standards.
1-302. The Administrator shall conduct such reviews and inspections as may be necessary
to monitor compliance with applicable pollution control standards by Federal facilities and
activities.
1 -4. Pollution Control Plan.
1-401. Each Executive agency shall submit to the Director of the Office of Management
and Budget, through the Administrator, an annual plan for the control of environmental pollution.
The plan shall provide for any necessary improvement in the design, construction, management,
operation, and maintenance of Federal facilities and activities, and shall include annual cost
estimates. The Administrator shall establish guidelines for developing such plans.
1-402. In preparing its plan, each Executive agency shall ensure that the plan provides for
compliance with all applicable pollution control standards.
1-403. The plan shall be submitted in accordance with any other instructions that the
Director of the Office of Management and Budget may issue.
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October 1994
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1-5. Funding.
1-501. The head of each Executive agency shall ensure that sufficient funds for
compliance with applicable pollution control standards are requested in the agency budget.
1-502. The head of each Executive agency shall ensure that funds appropriated and
apportioned for the prevention, control, and abatement of environmental pollution are not used
. for any other purpose unless permitted by law and specifically approved by the Office of
Management and Budget.
1-6. Compliance -with Pollution Controls.
1-601. Whenever the Administrator or the appropriate State, interstate, or local agency
notifies an Executive agency that it is in violation of an applicable pollution control standard (see
Section 1-102 of this Order), the Executive agency shall promptly consult with the notifying
agency and provide for its approval a plan to achieve and maintain compliance with applicable
pollution control standard. This plan shall include an implementation schedule for coming into
compliance as soon as practicable.
1-602. The Administrator shall make every effort to resolve conflicts regarding such
violation between Executive agencies and, on request of any party, such conflicts between an
Executive agency and a State, interstate, or a local agency. If the Administrator cannot resolve a
conflict, the Administrator shall request the Director of the Office of Management and Budget to
resolve the conflict.
1-603. The Director of the Office of Management and Budget shall consider unresolved
conflicts at the request of the Administrator. The Director shall seek the Administrator's
technological judgement and determination with regard to the applicability of statutes and
regulations.
1-604. These conflict resolution procedures are in addition to, not in lieu of, other
procedures, including sanctions, for the enforcement of applicable pollution control standards.
1-605. Except as expressly provided by a Presidential exemption under this Order,
nothing in this Order, nor any action or inaction under this Order, shall be construed to revise or
modify any applicable pollution control standard.
1-7. Limitation on Exemptions.
1-701. Exemptions from applicable pollution control standards may only be granted under
statutes cited in Section l-102(a) through l-102(f) if the President makes the required appropriate
statutory determination: that such exemption is necessary (a) in the interest of national security, or
(b) in the paramount interest of the United States.
L-3
October 1994
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1-702. The head of an Executive agency may, from time to time, recommend to the
President through the Director of the Office of Management and Budget, that an activity or
facility, or uses thereof, be exempt from an applicable pollution control standard.
1-703. The Administrator shall advise the President, through the Director of the Office of
Management and Budget, whether he agrees or disagrees with a recommendation for exemption
and his reasons therefore.
1-704. The Director of the Office of Management and Budget must advise the President
within sixty days of receipt of the Administrator's views.
1 -8. General Provisions.
1-801. The head of each Executive agency that is responsible for the construction or
operation of Federal facilities outside the United States shall ensure that such construction or
operation complies with the environmental pollution control standards of general applicability in
the host country or jurisdiction.
1-802. Executive Order No. 11752 of December 17, 1973 is revoked.
In 1987, President Reagan signed Executive Order 12580, "Superfund Implementation."
As part of the implementation, this E.O. outlined the process that Federal facilities could use to
resolve any issues prior to the selection of a remediation method at Federal hazardous waste sites;
and specifically amended E.O. 12088 to uphold the principal that the Federal government was
protected by Sovereign Immunity against private actions against the United States government
related to Superfund. (However, since the signing of E.O. 12580, the Federal Facilities
Compliance Act was passed, making Federal agencies liable under Superfund.)
Sec. 10. Federal Facilities, (a) When necessary, prior to selection of a remedial
action by the Administrator under Section 120(e)(4)(A) of the Act, Executive
agencies shall have the opportunity to present their views to the Administrator after
using the procedures under Section 1-6 of Executive Order No. 12088 of October
13, 1978, or any other mutually acceptable process. Notwithstanding subsection 1-
602 of Executive Order No. 12088, the Director of the Office of Management and
Budget shall facilitate resolution of any issues.
(b) Executive Order No. 12088 of October 13, 1978, is amended by renumbering
the current Section 1-802 as Section 1-803 and inserting the following new Section
1-802:
"1-802. Nothing in this Order shall create any right or benefit, substantive or
procedural, enforceable at law by a party against the United States, its agencies, its
officers, or any person."
L-4
October 1994
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APPENDIX M
OMB CIRCULAR A-106
December 31, 1974
CIRCULAR NO. A-106
TO THE HEADS OF EXECUTIVE DEPARTMENTS AND ESTABLISHMENTS
SUBJECT: Reporting Requirements in Connection With the Prevention, Control, and
Abatement of Environmental Pollution at Existing Federal Facilities
1. Purpose. This Circular provides procedures to be followed by Federal agencies in carrying out
the provision of section 3(a) (3) of Executive Order No. 11752 of December 17, 1973, pertaining
to the control of environmental pollution from existing Federal facilities.
2. Rescission. This Circular, supersedes and rescinds Office of Management and Budget (OMB)
Circulars No. A-78 and A-81 dated May 18, 1970.
3. Definitions.
a. The term "Federal agencies" means the departments, agencies, establish-ments, and
instrumentalities of the executive branch. !
b. The term "facilities" means the buildings, installations, structures, land, public works,
equipment, aircraft, vessels, and other vehicles and property, owned by, or constructed or
manufactured for the purpose of leasing to, the Federal Government.
c. The term "project" means an action to achieve needed corrective measures relative to
identified environmental pollution sources within a Federal facility.
d. The term "cost" means the amount of funds required for putting in place the necessary
environmental protection measures. These costs include the capital costs of structure and
equipment, irrespective of the appropriation chargeable, but riot the annual maintenance and
operating costs.
e. The term "lease-construction" means construction of a facility by a private entrepreneur
to meet requirements of a Federal agency in consideration of a commitment by the agency to lease
the facility at a specified price for a specified time period.
f. The term "Director" means the director of the Office of Management and Budget.
M-l
October 1994
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g. The term "Administrator" means the Administrator of the Environmental Protection
Agency.
4, Standards. All facilities are to conform to the requirements specified in Section 4 of the Order.
Those requirements are as follows:
a. Federal, State, interstate, and local air quality standards and emission limitations
adopted in accordance with or effective under the provisions of the Clean Air Act, as amended.
b. Federal, State, interstate, and local water quality standards and effluent limitations
respecting the discharge or runoff of pollutants adopted in accordance with or effective under the
provisions of the Federal Water Pollution Control Act, as amended.
c. Federal regulations and guidelines respecting dumping of material into ocean waters
adopted in accordance with Marine Protection, Research, and Sanctuaries Act of 1972, and the
Federal Water Pollution Control Act, as amended.
d. Guidelines for solid waste recovery, collection, storage, separation, and disposal
systems issued by the Administrator pursuant to the Solid Waste Disposal Act, as amended.
e. Federal noise emission standards for products adopted in accordance with provisions of
the Noise Control Act of 1972 and State, interstate, and local standards for control and abatement
of environmental noise.
f. Federal guidance on radiation and generally applicable environmental radiation
standards promulgated or recommended by the Administrator and adopted in accordance with the
Atomic energy Act, as amended (42 U.S.C. 2011), and rules, regulations, requirements, and
guidelines on discharges of radioactivity as prescribed by the Atomic Energy Commission.
g. Federal regulations and guidelines respecting manufacture, transportation, purchase,
use, storage, and disposal of pesticides promulgated pursuant to the provisions of the Federal
Insecticide, Fungicide, and Rodenticide Act, as amended by the Federal Environmental Pesticide
Control Act of 1972.
5. Agency Responsibilities. Pursuant to their responsibilities under the Order, Federal agencies:
a. Should cooperate with State, interstate, and local pollution control agencies and with
other Federal agencies in the evaluation of their pollution control needs.
b. May seek the assistance of the Administrator to determine the standards and the
appropriate implementation schedules applicable to particular facilities.
M-2
October 1994
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6. Pollution Control Plans.
a. Federal agencies must develop plans to assure that their facilities meet the standards
listed in paragraph 4 of this Circular.
b. Such plans are to cover existing facilities as defined in paragraph 3b of this circular.
"Lease-construction" is an example of a type of facility covered under this provision, but facilities
used under ordinary leases are not covered. Remedial measures required for buildings and
equipment owned by non-Federal lessees on Federal land are not to be reported under this
Circular unless the responsible Federal agency attests that they are constructed and operated for a
Federal purpose. In cases where lease agreements with non-Federal lessees obligate the Federal
Government to provide pollution control measures, remedial measures are to be reported under
this Circular.
c. The agency plan should include all projects involving "costs," as defined in paragraph
3d of this Circular, which are necessary to bring existing facilities into compliance with applicable
standards. Funds required for studies, management and monitoring associated with the definition
and development of corrective measures and necessary equipment to assure compliance with
standards should also be included in the plan.
d. In determining the most cost-effective remedial measures necessary for a particular
facility to meet the standards, agencies should take into account such factors as: the future use of
the facility; the best practicable technology available; the need for control system reserve
capacity; various alternative methods of control including process change; and the use of joint or
regional pollution control facilities.
e. Agency plans should include the milestones for the design, construction, and
completion of projects which, when submitted to the Director, will represent an agency
commitment to comply with applicable standards considering the Federal budgetary process and
assuming that the requested funds will be appropriated by the Congress and allocated to the
agency as planned.
f. Facilities may be exempted from applicable standards in the interest of national security
or in extraordinary cases in which it is in the paramount interest of the United States. Such
exemptions must be made in accordance with the provisions of Section 5 of the Order.
7. Reports.
a. Agency plans are to be reported in accordance with procedures prescribed by the
Administrator. Such procedures will provide for submission of pertinent details of each individual
project and a summary status report or the overall plan.
M-3
October 1994
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b. The reports will be submitted of semiannually on December 31, and June 30 to the
Director thru the Administrator. After review of the reports, the Administrator will forward the
agency's reports to the Director.
c. By September 30 of each year the Administrator will also forward to the Director an
evaluation of each agency's report.
8, Communications with the Administrator. Communications with the Administrator should be
directed to the Environmental Protection Agency, attention: Office of Federal Activities, 401 M
Street, S.W., Washington, D.C. 20460, phone 755-0790 (code 138).
9. Communications with the Director. Questions regarding the implementation of this Circular
should be addressed to the office of Management and Budget, Washington, D.C. 20503, phone
395-6827 (code 103).
M-4
October 1994
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APPENDIX N
OMB CIRCULAR A-ll
CIRCULAR NO. A-11
PREPARATION AND SUBMISSION
OF BUDGET ESTIMATES
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
JULY 1994
N-l
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N-2
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GENERAL POLICIES
12.3-12.5
commercial activity involving a cost increase exceed-
ing either 30 percent of the total capital investment
or 30 percent of annual personnel and material costs
must be justified using the results of A-76 cost com-
parisons of the total activity.
Justifications for government resources for a new
required commercial product or service, or to accom-
plish work previously provided by contract must
include:
—the contracting officer's determination that com-
mercial sources could not meet the requirement
at a reasonable price; and
—the results of the A-76 cost comparison con-
ducted after the contracting officer's determina-
tion.
As with other activities subject to A-76 review, re-
quests to purchase new aircraft, acquire aircraft
through forfeiture, or to perform new or expanded
aviation services must be accompanied by an A-76
cost comparison which demonstrates that the pur-
chase of the product or services is in the govern-
ment's best interest (see section 12.5(x)).
(q) Use of MAX electronic network—For the pur-
pose of cost distribution as specified in OMB Circular
No A-130, OMB is the user of the MAX. Accord-
ingly, agencies are not required to pay for the use of
the MAX elctronic network required by this Circular.
12.4 Required consultations
Certain proposals require coordination, as de-
scribed below, before budget estimates are submitted
to OMB.
(a) Tax expenditures.—Agencies are required to
consult with the Office of Tax Analysis, Department
of the Treasury, prior to submission of budget esti-
mates to OMB and to reflect the views of that office
in their justification materials (see section 12.3(o)
(2)).
(b) Public works in the National Capital area.--
Estimates for construction of public works in the Na-
tional Capital area will be submitted only after the
agency has consulted with the National Capital Plan-
ning Commission in the preparation of plans and
programs.
(c) Public works in the District of Columbia.--
Estimates for plans and construction of buildings and
other structures in the District of Columbia that may
affect in any important way the appearance of the
city, and other questions involving artistic consider-
ations with which the Federal Government is con-
cerned, will be submitted only after consultation with
the Commission of Fine Arts.
(d) Construction of nuclear reactors.-- Estimates
for construction of nuclear research and test reactors
will be submitted only after a letter setting forth the
recommendations of the Department of Energy has
been obtained.
(e) Communications-electronics systems.~Est-
mates for the development or procurement of major
communication-electronics systems ( including all
systems employing space satellite techniques) will be
submitted only after certification by the National
Telecommunications and Information Administration,
Department of Commerce, that the radio frequency
required for such systems is available.
(f) Federal public buildings.—Consultation with
the Federal Emergency Management Agency is
required prior to submission of budget estimates for
design and construction of federal public buildings
(see section 12.5(d)).
£g) Pollution control andi treatmeiat
Estimates, for desiga atid eoostructlorfD.f
tries- of remedial environmental projects will be^alfe
mitted only after eonsultatioa wi& the'£nyironmiinM|
Protection Agency (EPA) on OMB Circular 1510,^
plans, . '" ""
(h) Use of foreign currencies.—Where applicable,
agencies should refer to Department of Treasury and
Department of State guidelines on the use of foreign
currencies. Detailed instructions are set forth in the
Treasury Financial Manual (chapters 3200 and 9000)
and the Foreign Affairs Manual (Volume 4, Chapter
360). In addition, guidance on excess and near excess
foreign currencies is periodically issued by OMB.
Agencies should consult with the Department of
Treasury, International Trade Office, the Department
of State's Office of Financial Operations, Banking
and Foreign Currency staff, or their OMB representa-
tive on questions not addressed by these instructions.
12.5 Estimates relating to specific objects of
expenditure
(a) Hospital care.-- In developing estimates for hos-
pital costs, data based on the use of resources allo-
cated by diagnosis-related groups are the most
desirable. Such data should be compared with pay-
ment rates of other payers using similar groupings.
Care should be taken to clearly indicate whether or not
capital and depreciation costs are contained. The esti-
mates should be accompanied by a description of the
cost allocation method underlying the data.
The amount of reimbursement collected from third
parties as well as other federal agencies should be
identified when an agency provides hospital care on
Circular No.
A-l 1(1994)
N-3
17
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12.3-12.5
GENERAL POLICIES
a reimbusable basis. The estimates of reimburse-
ments and other income from charges for such care
shall be based on such per diem rates as may be
established by the agencies specifically authorized to
establish such rates for the particular class of patient
and type of care involved, unless different rates or
charges are established by or pursuant to a specific
requirement of law.
(b) Motor vehicles.—Estimates for motor vehicles
will not include funds for additional or replacement
vehicles if the agency has access to established inter-
agency fleet management system (IFMS) or to antici-
pated IFMS, except for vehicles excluded from inclu-
sion in IFMS. Proposed purchasers of motor vehicles
shall be in compliance with General Services Admin-
istration (GSA) instructions. Estimates for sedans
and station wagons shall be based on the requirements
of GSA's Federal Property Management Regulations
and Federal Standard No. 122. Estimates will not ex-
ceed price limitations in effect for the current year
plus the estimated cost of additional systems or equip-
ment justified to GSA, unless otherwise provided by
law. Provisions for replacement of motor vehicles and
related equipment will be made in accordance with
GSA replacement standards (see section 12.3(d)).
(c) Real property.-Agency estimates for the acqui-
sition of real property will be included in the agen-
cy's budget submission. Estimates for acquisition of
real property under contract will be consistent with
obligations reported in object class 32. These esti-
mates will be consistent with the policies set forth by
the Administrator of the GSA, as provided by Execu-
tive Order No. 12512.
(d) Design and construction of federal facilities.--
Estimates for federal facilities will be prepared, as
described below. .
(1) Pollution control and treatments Bsdiaates
for the design and construction of federal facilities-
and buildings wilt provide for tie iostalMpn.
of pollution; control and treatment systems, in,
accordance with OMB CketflarKo. A.-W6, Exec,
utive Order Mo. 120&S, and ansjrekted instruc*
tions. Estimates should be consistent with the
latest agency plans submitted under OMB Cir-
ri A-106
(2) Safe workplaces. --Estimates for the design and
construction of federal facilities and buildings,
capital investment, and the purchase of equip-
ment will include amounts required to ensure
that existing facilities provide safe and healthful
workplaces for federal employees consistent with
the standards promulgated under section 19 of
the Occupational Safety and Health Act of 1970,
the provisions of Executive Order No. 12196,
and the related Safety and Health Provisions for
Federal Employees of the Secretary of Labor (29
CFR, Chapter XVII, Part 1960).
(3) Structural barriers in federal buildings.-
Agencies will ensure that estimates for construc-
tion and renovation of federal facilities and build-
ings reflect full consideration of the need to elim-
inate structural barriers impeding the mobility of
individuals with disabilities, consistent with the
Architectural Barriers Act of 1968.
(4) Scientific laboratory facilities. -Submissions
mat propose additional or replacement scientific
laboratory facilities should be accompanied by
evidence that the agency has reviewed the GSA
inventory of federal laboratories. The agency
request should reflect the precise reasons for ac-
quiring new space instead of using existing lab-
oratories having sufficient space available, as re-
ported in the GSA inventory.
(e) User fees.—Agencies should ensure that esti-
mates are developed in accordance with the full cost
recovery policy for user fees set forth in OMB Cir-
cular No. A-25. Under that circular, user fees nor-
mally should recover the full cost of providing goods
or services to (he public. The exception to this rule is
when the government provides goods or services
under business-type conditions; in such cases, the user
fee should be set at the market price.
In determining full cost recovery, user fee estimates
should reflect retirement costs related to provision of
the goods or services. For the civil service retirement
system, costs should be estimated at 18.1% of base
pay; costs related to the federal employees retirement
system should be estimated as specified in section
(f) Construction in flood plains.~As required by
Executive Order Nos. 1 1988 and 1 1990, estimates for
the construction of buuildings, structures, roads, or
other facilities, whether financed directly by federal
funds or through grant, loan, or mortgage insurance
programs, should be based upon land utilization plans
that preclude the uneconomic, hazardous, or unnec-
essary use of flood plains or wetlands. Agencies will
indicate in ther requests whether the proposed activi-
ties will be located in a flood plain or wetland and, if
so, whether the activities are in accordance with the
Executive Orders.
(g) Major systems acquisitions.-- Estimates for
major systems acquisitions should be developed con-
18
N-4
Circular No.
A-l 1(1994)
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APPENDIX O
AGENCY A-106 INPUT FORM
O-.l
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O-2
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AGENCY A-106 INPUT FORM
FEDERAL AGENCY ENVIRONMENTAL MANAGEMENT PROGRAM PLANNING - PROJECT REPORT
State Agency/Bureau GSA Installation # Ownership Type
FFID
Depa
-
rtment/Apencv Name
Name nf Facility
EPA Region
'... ' ' .. -\
Country
Bureau/MACOM Name
Street Mailino Address
City Name Zip Code
Facility Latitude
f
-
L/L Method Facility Longitude
NPI
Y
es
.
.Site
»D
, ; 'II PKi^Intom&jjj ';/'- »',*', '; -.... '
Agency Proiect Number Operable Unit/ADS Number
Project Name (Brief Description)
Project Contact Name Contact Telephone
Street Address
City Name
Building # Room #
Zip Code
!-
-
-
Eroiect Latitude Proiect Longitude
Proiect Milestones (month/year)
1. Final Compliance 2. Design/Plan 3. Start 4. Completion
Reaiiired Completion
Progress Code
Reason for
Discontinuance
Yes
5
Multiple
Installations
No
FY Completed
Page 1 of 2
October 1994
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Total Cost Estimate fln S0001
Year Funding
Required
(K)
Federal Agency
Funding Type of
Account Code Cost
Vcs
'unding Expected
No
u
OMB AiwroBrWIon
1 1
Account Identification Code
1
Federal Agency Program Element Code
«nt
Estimated Project Cost
Fiscal Year
Estimated Cost (In SOOO)
. (K)
. (K)
. (K)
. (K)
• (K)
Programmed/Budgeted (in SOOO)
. (K)
. (K)
. (K)
• (K)
. (K)
Obligated (in $000)
. (K)
. (K)
. (K)
. (K)
• (K)
L»w/Rcgul»tloa'
Ef cfiitlvc Order
KMCMIVC Order C
rrri i [
Environmental
Category (ECAT)
!
Priori^
Score
.
Compliance Status
Pollution Prevention (P2)
1. P2 Component
Yes
No
2. P2 Estimate 3. P2 Category Reason for Local
(P2CAT) Initiation Priority
(5% increments)
Compliance Geographic
Class Initiative
Burcau/MACOM Major Program
Priority Area
Description (including legal requirements and pollutants to be controlled)
Date Revised
Day Mo Yr
Page 2 of 2
October 1994
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