SEPA
       ISSUE #7
                             United States
                             Environmental Protection
                             Agency
                                                        Office of Enforcement and
                                                        Compliance Assurance
                                                        (2261 A)
                                              EPA#300-N-99-009
                                              Spring/Summer 1999
                             an environmental bulletin for federal facilities
EPA Settles First SDWA  Penalty  Case
Against  Redstone  Arsenal
 In the  first Safe Drinking Water Act
 (
 (SDWA) penalty case against a federal
facility, EPA settled with the Army's Red-
stone Arsenal in Huntsville, Alabama for
a cash penalty of $80,000 and $807,000 in
supplemental environmental  projects
(SEPs).  The settlement, reached  on
December  10, 1998,  resolves  an EPA
Region 4 administrative  penalty order
against the U.S. Army Aviation and Mis-
sile Command, Redstone Arsenal, for
improper management of a drinking
water system that serves the 22,000 peo-
ple at the facility.
  This is the first time EPA has imposed
a SDWA penalty against a federal agency
since SDWA was amended in 1996 to give
EPA authority to do so. The Redstone set-
tlement  is the  largest drinking water
penalty in Region 4's history.
  The drinking  water violations were
uncovered  during a  1997 multimedia
inspection at the arsenal. Redstone failed
to properly operate and maintain its stor-
age tanks and reservoirs, a water main
flushing program,  and maintain  ade-
quate disinfectant residual in the distrib-
ution system to  meet EPA's maximum
contaminant levels for total coliform. The
SEP agreed to in  the settlement will
address improvements  to Redstone's
water system, including the installation
of  a chlorine monitoring system  to
enhance water quality by allowing the
facility  to measure  chlorine residual  on
an ongoing basis. In addition, computer
software for  one of Redstone's water
treatment plants will be  upgraded and
water stagnation  problems in some of the
supply  lines will be addressed. These
efforts will help  ensure that the base's
water supply is safe, while putting less
water purification disinfectant into the
environment.
  For more  information,  contact Lisa
Uhl,  Region  4  Water  Enforcement
Branch, (404) 562-9789, or Adam Sowatz-
ka, Region 4 Office of Regional Counsel,
(404) 562-9545.
                                                                            Inside
                                                                           2   Guest Spot: Edward B. Cohen,
                                                                              DOI
                                                                           3   Update on DOI Initiative
                                                                           4   Green Facilities: Presidio of San
                                                                              Francisco, New EPA Region 7
                                                                              Building
                                                                           6   In the Field: Cherokee BIA, Tipton
                                                                              Airfield
                                                                           7   Policies & Guidance
                                                                           8   The Hammer
                                                                           10  Conference Update
                                                                           11  Resources
                                                                           12  Upcoming Events
  Director'sWord:   Craig  Hooks
 A s the Director of EPA's Federal Facil-
^•ities Enforcement Office I am con-
stantly asking myself:  where is EPA's fed-
eral facility compliance and enforcement
program now, where is it going, and
where do we want it to go? It's easy to say
that each federal agency or department
should go beyond compliance, leading the
way for both the public and private sector
to follow. But determining what strategy
to employ to achieve  that goal that
requires looking at our past mistakes and
successes, the present state of environ-
mental conditions  at federal facilities,
                                     and solutions  to future  environmental
                                     problems.
                                       My office is charged  with ensuring
                                     that federal facilities take all necessary
                                     action to prevent, control, and abate envi-
                                     ronmental pollution. I realize that this is
                                     no small task. However, I  do believe that
                                     we are producing the types of tools that
                                     other federal agencies and departments
                                     can use to  improve their  environmental
                                     decision-making and ultimately the envi-
                                     ronment in which we all live.
                                       What tools are available to assist fed-
                                     eral agencies in this admittedly difficult
                                     field? First of all, each federal agency
                                     must understand its  own environmental
                                     liabilities, be they large  or small. To
                                     accomplish this, each agency should be
                                     conducting internal audits and environ-
                                     mental  management reviews of its own
                                     programs and facilities. These should
                                     help the agency answer the question of
                                     "What have we done and how well are we
                                     doing?" By way of  example, we have
                                     developed the Generic Protocol for Con-
                                     ducting Environmental Audits of Federal
                                     Facilities  (EPA-300-B-96-012   A&B)
                                     which includes materials for conducting
                                     environmental audits that can be cus-
                                     tomized to fit each agency's requirements.
                                       We have also issued brochures, poli-
                                                          Cont/nued on page 9
                                                                                           Printed on Recycled Paper

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                                         GuestSpot
 Environmental  Compliance:  It's Good Policy and It's the  Law
 By Edward B. Cohen, Deputy Solicitor, Department of the Interior
    ^^^1^^        Oecretary Bruce
  f   ^W      WBabbitt    has
                   referred   to   the
^.•1               Department of the
                   Interior   as   the
            ^^^   Department of the
^^fl       I     Environment,  not
                   because  he   has
                           c   i
                   visions or  subsum-
ing the Environmental Protection Agency,
but because the name reflects one of our
principle  obligations as  stewards of
roughly 500 million acres of public land.
Congress  has  assigned  the  Interior
Department a variety of mandates, from
recreation to resource  development to
resource conservation. But no mandate is
more important than compliance with the
nation's environmental laws.
   As both a federal resource  manager
and law enforcement agency, environmen-
tal  compliance must be high on our  own
agenda. If it is not, we  lack the moral
authority and credibility to insist  that
users of public lands comply with our envi-
ronmental requirements.  Inherent in the
concept of stewardship is doing no harm to
the resources entrusted to our care.
   No doubt, there are few in the Depart-
ment of the Interior who would disagree
with the notion that we, as a department,
should comply with environmental laws.
But real life is rarely that simple. In these
days of burgeoning mandates, declining
budgets, fewer staff, and complex proce-
dural requirements,  environmental com-
pliance isn't  always as achievable as we
would like. Moreover, in a department
such as Interior, compliance  obligations
are  one of  many  responsibilities  an
employee or an office might have — and
not necessarily the one that gets the  pro-
motion or the additional infusion of funds.
   It is no insignificant challenge to devel-
op  programs,  systems,   and structures
that result in full environmental compli-
ance in a department as diverse as Interi-
or. We have  eight bureaus, each with a
different culture and different mandates,
and more than 65,000 employees, work-
ing in 2,000 facilities. Most of the land we
administer is widely accessible to the pub-
lic for various uses, and  we  frequently
inherit environmental messes made years
before environmental statutes were even
written. Mining wastes, unexploded ord-
nance, severe erosion from overgrazing,
and municipal landfills on public lands —
all have left a legacy of environmental
degradation to which  we must  attend.
Frequently, the perpetrator has long gone,
leaving the taxpayer holding the bag.


A New Emphasis on
Compliance
During Secretary Babbitt's tenure, there
has been a new emphasis placed on meet-
ing our environmental compliance obliga-
tions. Perhaps the most significant step
we have taken was entering into a unique
Compliance Assistance Initiative in part-
nership with EPA (see  related story on
page 3). For EPA's part, this was the first
time it  offered to provide compliance
assistance  across an entire civilian feder-
al agency. For Interior, it was an opportu-
nity to assess strengths and weaknesses
in our programs, and to make changes
where needed.
   This partnership has produced facility
level assistance, corrective action projects,
and analyses  of environmental manage-
ment systems. One of the most significant
efforts has been a joint  and thorough
review of the environmental management
systems within  the National  Park Ser-
vice, based on the Code of Environmental
Management    Principles    (CEMP).
Through this review, and by applying the
CEMP principles,  we  have  evaluated
management  commitment,  compliance
assurance, pollution prevention, enabling
systems, performance, accountability, and
measurement  and  improvement.  We
intend to undertake a similar review of
the management systems of several other
Interior bureaus as well.
   The partnership with EPA has pro-
duced other dividends. Improved contacts
between Interior and EPA field personnel
have led to better mutual understanding
and  appreciation  of  the  obligations,
resources,  and challenges of each agency.
As a result, both agencies are better able
to handle  compliance issues when they
emerge.
   One  indicator of  progress  is  the
Department's  compliance  with  EPA's
requirements for  underground  storage
tanks. On  December 22, 1998, the dead-
line for phase one compliance, all bureaus
of the Department were virtually in full
compliance with the UST rules. For an
agency that began with an inventory of
4,000 tanks, that  was a  significant
achievement.
   A second step the Department has tak-
en to improve environmental compliance
is the creation of a new branch of Federal
Facilities Compliance within the Office of
the Solicitor. The branch is responsible for
providing  compliance  and  enforcement
support across the Department  with
respect to cleanup of hazardous substance
releases.  Not  only will  this  branch
enhance the Department's ability to com-
ply with CERCLA cleanup requirements,
it will  accelerate the pace at which we
identify parties responsible for contami-
nating Department  lands  and  pursue
these parties for financial and other assis-
tance in cleanups.
   The Department of the Interior  and
EPA should be  and are environmental
soulmates. We must build  a culture of
environmental    compliance,   which
requires a sustained effort to assure man-
agement commitment,  resources, train-
ing, and accountability  at all levels of the
agency. While it cannot happen overnight,
our progress — with  the assistance of
EPA — has been impressive. And that
effort will continue.
 2 FEDFACS

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Update on  EPA-DOI Initiative:
 Review of Environmental  Management  Systems
 Conducted at National  Park Service
  EPA's first effort to
  provide compliance
assistance  across an
entire federal  agency
has  yielded  useful
progress after a year of
implementation.   In
January  1998,  EPA
and the Department of
the  Interior  (DOI)
agreed to work jointly
to enhance compliance
assistance across  DOI
Bureaus and facilities
with the overall goal of
raising the level of reg-
ulatory awareness and
compliance.
   Perhaps the most
innovative  and  far-
reaching efforts  that
has resulted from the
EPA/DOI  compliance
initiative is the analysis of environmental
management systems (EMS) within the
National Park Service (NPS), including an
analysis of support relationships between
NPS field-level facilities and NPS and
DOI headquarters environmental offices.
This analysis was conducted using the
Code  of Environmental  Management
Principles  (CEMP),  a collection of five
broad management principles and perfor-
mance objectives that provide a basis for
effective and responsible federal environ-
mental management.
   Formal and informal aspects of the
National  Park  Service's  EMS  were
reviewed at the field, regional and  head-
quarters levels. The review also addressed
portions of the parent DOI organization
which directly influence NPS environmen-
tal management activities (DOI Office of
Environmental Policy  and Compliance
and  additional DOI-level  units). The
review  covered July-December  1998, a
period during which several changes  to
the NPS EMS  were  either underway  or
planned. The assessment team conducted
75 interviews, reviewed 85 EMS-related
records, and made direct observations.

Findings
A set of recommendations was developed
for each of the five CEMP performance
objectives as suggested areas for future
improvement. The findings were designed
to encourage further NPS review of the
applicability of the CEMP in supporting
the  overall success of the NPS environ-
mental management system. Principal
findings include:

•  Management Commitment: While
   environmental stewardship and sus-
   tainability are part of the fundamental
   culture at NPS, environmental compli-
   ance also needs to be an integral part
   of both. Funding and staffing for envi-
   ronmental requirements is somewhat
   fragmented  and regulation-specific
   rather than multimedia (e.g., focused
   on hazmat/waste vs. all media). Ser-
   vice-wide funding and staffing  deci-
   sion-making processes should include
   explicit recognition of environmental
   regulatory compliance requirements.
•  Compliance Assurance and Pollu-
   tion Prevention: Compliance assur-
   ance tools, such as the audit protocol,
   are planned or  being implemented.
   Procedures  and  follow-up should be
   provided  to ensure  that  compliance
   standards in the tools are current and
   that audits include consideration of
   pollution  prevention opportunities to
   achieve  and maintain  compliance.
   Information resulting from compliance
   assurance efforts is  a valuable plan-
   ning tool  and should be recognized in
   budget planning, staffing, and pro-
   grammatic decision-making.
•  Enabling Systems:  Training  oppor-
   tunities  outside  of NPS should  be
   explored to benefit from broad regula-
   tory compliance training. Environ-
   mental compliance tracking systems
   are being implemented.  As  tracking
   protocols are being developed, opportu-
   nities to track all relevant information
   sources should be explored, including
   dissemination and feedback on areas
   of concern.
•  Performance and Accountability:
   Media-specific regional environmental
   coordinators are  designated but have
   little  direct  authority for ensuring
   environmental   compliance.   NPS
   should consider a policy to emphasize
   management responsibility and staff
   authority and responsibility for envi-
   ronmental compliance at both facility
   and support office levels.
•  Measurement  and  Improvement:
   Planned  audit  reviews  should  be
   tracked with root cause and corrective
   action response identified and shared
   across NPS. Tracking and response
   should be used in  budgetary and
   resource planning.

For more information on the project, con-
tact Will Garvey at (202) 564-2458.
                                                                                                    FEDFACS 3

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                                           Green  Facilities
Partnerships for a Zero

Waste Park

Aimee Vincent

      Presidio of San  Francisco is a
   unique national park. Covering almost
1,500 acres  at  the northern tip of San
Francisco, the Presidio is an urban park
with varied natural resources, breathtak-
ing views, and over 500 historic struc-
tures. The Presidio Trust, a non-profit
federal  corporation,  has  the  daunting
task of maintaining and enhancing the
natural and cultural resources that make
the Presidio worthy of National Park sta-
tus and able to become  financially self
sustaining by the year 2013.
   As part of our goal  to become a model
of sustainable practices, we are searching
for  ways to do our business in the  most
environmentally sound way possible. A
primary component  of this process  is
reducing waste in all areas of operations.
Diverting waste from  the landfill is one
way that we can strive toward sustain-
ability. Requiring contractors and lessees
to reduce waste is an important step. Our
major waste reduction programs include
park-wide recycling collection and educa-
tion, visitor  and special event recycling,
building materials salvage, compost and
tree debris recycling, and an environmen-
tal purchasing program.
   All of our programs require help from
local groups and other government agen-
cies. Some of our partners in reducing
waste include:
•   A local non-profit recycler
•   A local youth job-training organization
•   The State of California Department of
    Conservation
•   The San Francisco Solid Waste Man-
    agement Program
•   Local artists and craftspeople
•   A non-profit environmental advocacy
    group
•   Local volunteers.
By finding partners in  this effort we
strengthen our capabilities to get the job
done. By working with us, organizations
gain  access to  millions of visitors to
spread a  waste reduction  message to.
State and city  agencies  move closer to
state-mandated  waste diversion goals.
Local businesses and artisans benefit by
receiving materials to use as resources,
which might  otherwise have  become
waste. Working in the park can also pro-
vide a valuable training opportunity. Any
way you look at it, the environment bene-
fits from reduced waste, reduced pollu-
tion,  and  preservation  of  natural
resources.

Deconstructing Building  901
One pilot project conducted  at the  Pre-
sidio was the deconstruction of Building
901, a warehouse built by the U.S. Army
in the 1940s. Completed in the spring of
1996, this was an early example of how
hand deconstruction can be a better alter-
native than destructive demolition.  The
project involved the local waste reduction
community in finding a solution for  con-
struction/demolition waste. Partners in
the project included the National Park
Service, The San Francisco  Community
Recyclers, Beyond  Waste and the Wood
Resources Efficiency Network.
   In about six weeks, over 60,000 board
feet of lumber  were recovered  in their
structural  form.  Rather  than  being
chipped for boiler  fuel  or  ground for
mulch (common  practices in  the  demoli-
tion industry), this wood was reused in
value-added projects. The unique quali-
ties of this old growth wood made it espe-
cially valuable. Wood experts admired its
close grain, straightness, and absence of
flaws.
   A large portion  of the wood was  pur-
chased for use  in building a  custom
"green" home  in  Marin County.  The
builders found the properties of the sal-
vaged wood to be superior to that of most
new framing wood bought  new today.
Other buyers of the wood were local  arti-
sans making one-of-a-kind art pieces and
crafts people who made the wood  into
high-quality furniture and flooring. After
the success of the Presidio deconstruction
project,  many other parks and agencies
conducted pilot projects and began decon-
struction programs.
   If you are considering building demoli-
tion, follow the following hierarchy:
•   Adaptive reuse of buildings on-site
•   Removal of buildings as  whole units
    for reuse elsewhere
•   Deconstruction of buildings and value
    added reuse of building components
•   Demolition with source separation and
    a high level of reuse and recycling.

Some important lessons:
•   Have a materials  specialist examine
    the building and determine the poten-
    tial value and salvageability of materi-
    als
•   Reuse as much  material as  possible
    back on the site or elsewhere within
    your organization
•   Plan for a project that will take more
    time than a destructive demolition
•   Consider markets for materials before
    you begin the project
•   Designate a secure space for materials
    to be safely and properly stored  and
    prepared for marketing
•   Consider alternative labor sources and
    the potential to offer skills training
•   Track where the materials have gone
    and  tell your story!

For more information about deconstruc-
tion,  see  the  following  Web sites:
http://www.ciwmb.ca.gov/ConDemo/case
studies/Presidio  Trust and  http://www.
nahbrc.org/publist/huddocs.htm.

Aimee Vincent is the Sustainobility Coordi-
nator at The Presidio  Trust.  She can be
reached  at 415-561-5368  or avincentฎ
presidiotrust.gov.
 4 FEDFACS

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Region 7's New Office
Building Greening the
Heartland
In June 1999, EPA plans to formally
open its  new Region 7 office building in
downtown Kansas City, Kansas. With its
wide range of environmental features —
from energy efficient windows and light-
ing to  an advanced water management
system — the  approximately  217,500
square foot facility moves closer to build-
ing "green." Built at a projected construc-
tion cost of $32 million, the 5-story facili-
ty is designed to house roughly 900 EPA
regional  employees, with 750 scheduled
to move in initially.
  "Given the  regulatory  requirements
and the availability of green products at
the time the Solicitation for Offers was
published,  our  design team and Koll
Development did an  outstanding job in
design and construction of the  facility,"
said Marc Matthews  of EPA's Region 7.
"With the widespread availability of recy-
cled-content  and  other environmental
building products today, we hope other
facilities can go even further and build
upon our success."
   EPA regional  staff worked  with the
developer to  create an environmentally
sustainable design. Together they estab-
lished several overarching goals:
•  To create a soft visual impact.
•  To  reduce disturbance to site condi-
   tions and surroundings.
•  To accommodate natural light.
•  To emphasize EPA's overall mission of
   environmental enhancement and sus-
   tainability.

  The resulting building offers a range of
environmental features in the areas of ener-
gy efficiency,  recycling, landscaping,  and
water conservation and erosion control.
•  Energy Efficiency: In an effort to
   reduce energy consumption, the build-
ing was designed to qualify for an EPA
Energy Star  building rating.  The
building uses indirect lighting as the
primary source of light in the  open
office areas in the building. Through-
out the building, low emittance (low-e)
windows  are  recessed two  feet to
increase the  shading coefficient; T-8
fluorescent bulbs  with electronic bal-
lasts  provide energy-saving benefits.
All public  occupied spaces use  motion
sensors to detect occupants for general
lighting,  while compact  fluorescent
task  lighting is used for individual
cubicles to avoid wasteful overhead
lighting grids.
Recycling: Many of the interior fur-
nishings  contain  recycled-content
including  the carpeting, ceiling tiles,
ceramic floors, and paint. The auger
piles, footings, and foundations were
constructed with  concrete containing
1,000 tons of coal fly ash, complying
with  EPA's  Comprehensive  Procure-
ment Guidelines requirements. Recy-
clables are stored and consolidated on
each floor  in rooms next to the freight
elevators,  allowing for  a quick  and
smooth delivery to the  loading dock.
These rooms also provide storage space
for reusable office  equipment  and
materials.
          •  Landscaping:   Both
          inside and out, the build-
          ing's landscaping is truly
          "green." The outside vegeta-
          tion, including 30-40 honey
          locust trees, primarily con-
          sists of native plants, which
          require  less water  than
          imported   plants.  These
          plants also require little
          maintenance, reducing use
          and  exposure to harmful
          pesticides.  Shrub  beds
          located throughout the  site
          add visual appeal while aid-
          ing  in   erosion  control.
          Indoors,  ficus trees help
remove indoor air pollutants.
Water Conservation and  Erosion
Control:  The  building offers water
conservation  and   erosion  control
opportunities as well. Plumbing  fix-
tures in the building will include Mis-
ter Miser Urinals,  Flushometer toilet
adapters,  and low-flow shower heads
in the fitness  center which provide
water  conservation  opportunities. An
advanced water management  con-
troller  operates the  building's irriga-
tion system valves.  This allows for a
wide variety of water saving measures,
such as water budgeting and program-
mable  rain delay. Probes measure the
moisture content of the soil outside the
building to ensure that vegetation is
only watered  when necessary. In order
to improve the quality of water runoff,
the designers installed sand oil inter-
ceptors in the  parking lot drains to
screen  out water contaminants.
Air Quality:  Associated with this pro-
ject, the  City of Kansas City is con-
structing  a half-mile bike path adja-
cent to  the   new  Region  7  office
building.  This  path,  along with  the
installation of bike racks and showers
at the  facility, will give employees an
alternative means of transportation to

                    Continued on page 6
                                                                                                              FEDFACS 5

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                                           In  the   Field
Multimedia Audits of
BIA Agencies Begin with
Cherokee, NC
   Cherokee Bureau of Indian Affairs
   (BIA) Agency, located  in  Cherokee,
North Carolina, will be the first of many
BIA facilities to be  audited under  the
national multimedia  auditing program
created  under a Memorandum of Under-
standing (dated August 12,  1998) between
the EPA and BIA.  Cherokee was chosen
because of its wide range of activities.
   The  Compliance  Assistance  Project
(CAP) to be undertaken will identify com-
pliance problems at BIA facilities through
a series of multimedia audits that will be
carried out at 4-6 representative facilities.
BIA will use the information gained to
improve BIA facilities' overall  environ-
mental planning  and performance,  and
particularly as they relate to Indian trust
resources  and BIA facilities  on Indian
lands. CAPs can help to ensure that  BIA
and Indian trust resources and personnel
are protected  from potentially adverse
conditions by  identifying  compliance
issues, providing means to address them,
and recommending procedures that  can
be used at other facilities.
   In order to implement the agreement,
Craig Hooks,  Director of EPA's FFEO,
requested that each  EPA region with
BIA facilities nominate candidate facili-
ties for a  national multimedia auditing
program. The selection of Cherokee  BIA
Agency was made after consulting with
regional and BIA representatives,  and
affected tribes.
   FFEO is currently determining the scope
of the audit  and identifying  procedural
requirements for the audit with BIA Head-
quarters and the Cherokee Agency. FFEO
will use its findings and recommendations
as a guide to identify other BIA facilities for
the national multimedia auditing program.
For more  information, contact Anthony
Shelton at (404) 562-9636.
   is published by EPA's Federal Facilities
           Enforcement Office.

      Joyce Johnson, FFEO, Editor

            Gilah Langner,
     Stretton Associates, Inc., Writer

             Robin Foster,
         SciComm, Inc., Layout
  To receive FedFacs in the mail, contact:

  Federal Facilities Enforcement Office
  U. S. EPA (2261), 401M Street SW,
  Washington, DC 20460

  or Fax: 202-501-0069

  Or Internet:
  http j/www .epa.gov/oeca/fedfac/ann/index.html
GREENING THE HEARTLAND
Continued from page 5

    driving.  Parking  spaces  will   be
    reserved for  employees who carpool,
    and Region 7 will continue  to offer a
    transit subsidy program  to compen-
    sate employees for using public trans-
    portation.
With the  building almost  complete,
regional staff are turning their attention
towards a new environmental laboratory.
"We are partnering with the General Ser-
vices Administration, lab personnel, and
others to ensure that the new lab is as
green  as  possible," added  Matthews.
"We'll be able to take what we've learned
from the office building and go one step
further." Once completed, the lab will be
located across the street and within walk-
ing distance from the new office building.
   For more information  on the innova-
tive new office building or laboratory, con-
tact Marc Matthews at  (913) 551-7517.
EPA Declares Ft. Meade's
Tipton Airfield Free of
Hazardous Waste
 In a cooperative effort with the Army, the
 Maryland Department of Environment,
and the State of Maryland, EPA complet-
ed all hazardous waste cleanup work at
the Tipton Army Airfield property at Fort
George G. Meade, and issued a "Record of
Decision" saying no further action is nec-
essary.
   During the cleanup, drums of haz-
ardous waste were removed and an acid pit
was  cleaned out. In addition,  over 2,000
ordnance items were recovered and  dis-
posed of. (Ordnance items are military
weapons, including artillery  and  heavy
guns.) Further work remains to be done on
an inactive landfill at the site, situated on
property east of the Little Patuxent River.
   Fort Meade was placed on EPA's Super-
fund National Priorities List of the most
hazardous sites in the  nation last July.
Sites placed on the list are eligible for long-
term financial, technical,  and personnel
support from EPA to clean up the site. The
Tipton Airfield portion of the site is in the
process of being deleted from the list.
   Currently,  Anne Arundel County  has
leased three buildings and a portion of
the Tipton Airfield  property to use as an
airport. The Tipton Airfield property will
be transferred to Anne Arundel County by
the fall. Ft. George G. Meade has been a
U.S.  Army installation  since 1917. It is
located  in  northwestern  Anne Arundel
County, Maryland, along the Little Patux-
ent and Patuxent rivers, midway between
Baltimore and Washington, D.C.
 6 FEDFACS

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  Policies
Final EMR Policy and

Guidance Issued

The two-and-a-half year EMR pilot pro-
 I gram is over and the final "Environ-
mental Management Review Policy and
Guidance  for Federal Facilities" is avail-
able   on   EPA's    Web    site    at
http://www.epa.gov/oeca/fedfac/fflex.html.
   The final  EMR  policy and guidance
incorporates lessons learned from 25 pilot

We hope that the new
guidance will encourage
some of your facilities
to request an EPA-
conducted EMR.

EMRs conducted by EPA regional staff at
facilities belonging to the Federal Aviation
Administration,  Coast  Guard, National
Park Service, EPA, Postal Service, and the
Army Corps of Engineers. These facilities
report improved partnerships with EPA,
building a better foundation for an envi-
ronmental management program, and
identification   of   opportunities   for
improvement.
   The final policy modifies the Incidental
Violations  Response Policy to be consistent
with EPA's Audit Policy, and adds a provi-
sion that EPA generally will not  conduct
inspections at a facility  receiving an EMR
for six months afterwards.
   A National Report on the EMR  Pilot
Program will be posted  on the Web site in
May 1999.
   Given the success of the pilot program,
EMRs are slated to be an integral part of
EPA's compliance and technical assistance
toolbox for years to come. We hope that
the new guidance will encourage  some of
your facilities to request an EPA-conduct-
ed EMR. Remember: EMRs  are a volun-
tary, collaborative, inexpensive means by
which a facility can  determine the health
of its environmental management system.
Guidance Coming on
RCRA 6002 Inspections
    KEO is preparing guidance on conduct-
    ig federal facility inspections for com-
pliance with section 6002 of RCRA, as
mandated  under  a  recent  Executive
Order (see box). The final guidance docu-
ment will be available on the Envirosense
Web site in May 1999 (www.epa.gov/envi-
ronsense).
   For the  first year of implementation,
EPA inspections related  to this section
will  emphasize awareness and  compli-
ance assistance, focusing on federal facili-
ty responsibilities under RCRA 6002.
Thus, for  example,  inspections might
include distribution of a questionnaire to
the facility  and  a brief inspection of a
facility's motor vehicle maintenance shop
to determine if the facility is using and
purchasing vehicular products designated
under  the EPA buy-recycled program.
The   inspections   would   determine
whether  the  facility is  currently using
items  such  as re-refined  lubricants,
retread tires,  and engine coolant.
   In future years, based on information
learned from  inspections conducted over
the  next year, EPA will  review  its
response  to non-compliance with section
6002 to  ensure federal  facility compli-
ance. EPA has determined that violations
of RCRA section 6002 by federal agencies
do not give rise  to administrative penalty
actions or orders under  RCRA's enforce-
ment authorities.  This  conclusion does
not,  however, limit EPA's  authority to
issue a notice of violation (NOV)  for viola-
tions of RCRA section 6002 or enter into
compliance agreements  at federal facili-
ties  that are  discovered through the
inspections mandated by Executive Order
13101. It also appears that citizens may
take action  pursuant to RCRA section
7002, the citizen suit provision.
   BUY-RECYCLED EXECUTIVE ORDER  ISSUED

   On September 14,1998, President Clinton signed Executive Order 13101: "Greening the Govern-
   ment Through Waste Prevention, Recycling and Federal Acquisition." Section 403 of the Order
   directed EPA to develop guidance for inspections of federal facilities for compliance with the
   buy-recycled program established under RCRA section 6002. The guidance is to be used by EPA
   in conducting RCRA inspections or multi-media regulatory compliance inspections where RCRA
   compliance is a component of the inspection.
     Recognizing that recycling works best if there are markets for the materials collected. Con-
   gress directed the federal government to employ its purchasing powerto help create and sus-
   tain those markets by buying products manufactured with the collected materials. Section 6002
   of RCRA establishes a federal buy-recycled program and requires EPA to: (1) designate items
   that are or can be made with recovered materials and (2) prepare guidelines to assist procur-
   ing agencies in complying with affirmative procurement requirements. Once EPA has designat-
   ed items, any agency using federal monies to procure those items must purchase items com-
   posed of the highest percentage of recovered materials practicable.
     To date, the EPA Comprehensive Procurement Guidelines (CPG) program has designated 36
   products in 8 product categories. An additional 19 products will be formally listed in June 1999.
   EPA research indicates that the designated items are of high quality, are widely available, and
   cost-competitive with products made from virgin materials.
     Additional information on the CPG designated items and content  recommendations can be
   found on the World Wide Web at http://www.epa.gov/cpg/products.htm.
                                                                                                            FEDFACS 7

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                                               The   Hammer
Region 3
     Walter Reed Medical Center, DC:
     In separate violations, EPA has cit-
ed the U.S. Army for alleged violations of
(1)  federal  underground storage tank
(UST) regulations at the Army's Walter
Reed Medical Center in Washington D.C.
and the Center's Forest Glen Annex in Sil-
ver Spring, Maryland, (2) RCRA regula-
tions concerning hazardous waste storage
at Walter Reed Medical Center in Wash-
ington, DC. "Leaking underground tanks
are a major source of soil and groundwater
contamination. We have to enforce compli-
ance with UST regulations  now, or face
costly cleanups later," said EPA Regional
Administrator W Michael McCabe.
   EPA  is  seeking a  total  penalty of
$94,101  for UST violations involving five
diesel fuel tanks at Walter  Reed's main
hospital facility in D.C., and four diesel
fuel tanks  at the Forest Glen Annex.
These tanks range in capacity from 2,000
to 10,000  gallons.  District of Columbia
regulations require  UST owners to per-
manently  close  or  remove  their  tanks
within 12 months after the tanks are tak-
en out of service. EPA alleges that the five
USTs at Walter  Reed were last used
around December 1993 but were removed
between August 1995 and January 1997.
At the  Forest Glen Annex,  the  Army
allegedly failed to use corrosion-protected
steel piping in one 2,000 gallon tank and
to comply with proper leak detection pro-
cedures in two 10,000 gallon tanks.
   EPAfe September 30 complaint proposes
a $201,600 penalty for RCRA violations at
Walter Reed, although none of the violations
poses a health risk to the patients or employ-
ees at the medical center. Joint inspections
by EPA  and District officials in 1996 and
1998 found that hazardous waste containers
were improperly labeled and sealed, and the
facility did not have a permit to store haz-
ardous waste. The hazardous wastes includ-
ed  mercury,  chloroform,  acetonitrile,
trichloroacetic acid,  phenol,  methanol,
xylene, acetone, ethyl acetate, and photo fix-
er waste. EPA has ordered the Army to
immediately cease storing hazardous waste
at Walter Reed except in conformance with
requirements. The Army may request a
hearing to contest the violations and EPA's
proposed penalties.
Region 6
Region 4
101st Airborne Division (Air Assault)
and Fort  Campbell, KY/TN: EPA
Region 4 issued a RCRA complaint and
compliance order to the Army and the
Defense Logistics Agency in September
1999. The RCRA order is for violations of
the following areas: (1) OB/OD unit inter-
im status, (2) failure to have personnel
training, (3) security,  (4) inspection, (5)
permit.  Most of the violations  are the
result of improper management of the
OB/OD  unit,  including the  burning
and/or detonation  of D003 hazardous
waste in excess of the permit limit. The
proposed penalty is $540,470. The RCRA
order included a notice of opportunity for
a hearing and an invitation to request an
informal  settlement  conference.  The
Region  and Fort  Campbell have  met
informally and  are currently in settle-
ment negotiations.
   XVIII Airborne  Corps and Fort
Bragg,  NC: EPA Region  4 issued a
SDWA administrative order to the Army
in March 1999 for the following: (1) Max-
imum contaminant level exceedences for
total trihalomethanes, (2) failure to pro-
vide  timely  public  notice for maximum
contaminant level  exceedences for total
trihalomethanes, (3) failure to meet the
monitoring and reporting requirements
for total trihalomethanes, (4) failure  to
meet the public education requirements
as a result  of exceeding the 90th per-
centile action level  for lead, (5) failure to
report the failure  to  comply with the
national primary drinking water regula-
tions within 48 hours. There is no pro-
posed penalty at the present time. The
Army has requested a meeting to discuss
the order and needed actions.
Bureau of Engraving and Printing,
Fort Worth, TX: EPA filed an adminis-
trative penalty action on March 31, 1999
against the U.S. Treasury for violations of
the Clean Air Act at  the Bureau of
Engraving and  Printing (BEP), Western
Currency  Facility in Fort Worth, Texas.
This is the largest CAA penalty filed in
Region 6 against a federal facility using
recently clarified penalty authority from
the Department of Justice. (The decision
came on July 16, 1997, from DOJ's Office
of Legal Counsel that EPA has penalty
authority  under Section 113(d)  of  the
CAA against federal agencies for viola-
tions  of the  CAA.) An  EPA inspection
revealed that BEP had failed to comply
with regulations which reduce pollution
from volatile organic compounds,  sulfur
dioxide, and chromium compounds.  In
the  administrative  complaint,  EPA
charged that BEP violated regulations of
the Texas Administrative Code,  which
have been incorporated into the Texas Air
Pollution  Control  Implementation Plan,
and federal regulations concerning  two
boilers at  the plant and chromium com-
pounds. EPA seeks a $289,800 penalty for
these violations.
   In another case,  on June 12, 1998,  a
multimedia environmental  compliance
inspection was conducted  at the BEP
Fort Worth facility. From the inspection,
it was determined that nickel had been
"otherwise used"  at  above threshold
amounts for 1995 and 1996.  In addition,
the Bureau failed to maintain records for
nickel  for  the  1994 reporting year. A
show-cause letter was issued on January
12, 1999, informing the facility of its non-
compliance with  EPCRA Section 313.
Additional information was  included in
the letter  instructing the facility how to
achieve compliance. On February  24,
1999, information was received from the
facility. After reviewing the information it
was determined that BEP had met  the
terms of the show-cause letter and was
 8 FEDFACS

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now in compliance  with EPCRA 313. A
confirmation letter  acknowledging  the
Bureau's compliance  with EPCRA  313
was sent to the facility on April  6, 1999.
This issue has been  closed.
   McAlester   Army  Ammunition
Plant,  Department  of the  Army,
McAlester, OK: On December 2, 1997, a
multimedia environmental compliance
inspection   was   conducted    at   the
McAlester facility. From the inspection, it
was determined that chlorine was "other-
wise used" at above threshold amounts for
1994, 1995, and  1996. On January 12,
1999,  a show-cause  letter was issued
informing the facility of its non-compli-
ance with EPCRA Section 313. Additional
information was  included  in the letter
instructing  the facility how  to  achieve
compliance. On March 11, 1999, informa-
tion was received from the facility. After
reviewing the information  it  was deter-
mined that McAlester had met the terms
of the Show-Cause letter and was now in
compliance with EPCRA 313. A confirma-
tion letter  acknowledging  the  Bureau's
compliance with EPCRA 313 was sent to
the facility on April 6, 1999.
Region 10
Kodiak Coast Guard Station, Kodiak
Island, AK: EPA issued a complaint and
penalty on March 24,  1999 against the
U.S. Coast  Guard Integrated Support
Command located on Kodiak Island, Alas-
ka. The compliant,  seeking $74,250,
reflects alleged federal hazardous waste
violations observed by EPA inspectors at
the facility in August 1998, and violations
which  were self-disclosed by the Coast
Guard in a subsequent letter. Violations
include a failure to adequately track and
manage  containers that held hazardous
waste. In a separate, self-reported inci-
dent, the Coast Guard also illegally treat-
ed hazardous wastes by detonating excess
ordnance in a remote bunker. By disclos-
ing and correcting this violation in accor-
dance with EPA's self-reporting policy, the
Coast Guard qualified for penalty relief
and  avoided an  additional penalty  of
$74,250.
   Hanford Nuclear Reservation, WA:
EPA issued a complaint on February 11,
1999 to the Department of Energy seeking
payment of $367,078 in civil penalties for
alleged   RCRA violations  at  Hanford
Nuclear Reservation in Washington state.
The largest component of the penalty was
for improper storage of 17 drums contain-
ing solvents. The drums were stored out-
doors, some for almost three years, and
the storage area did not have a permit or
comply with storage rules. Abuilding serv-
ing as the receipt and distribution center
for the tank farms was cited for failing to
have  an  up-to-date contingency  plan.
According to EPA Region 10 officials, the
most serious problem found in the multi-
media inspection conducted last year was
Hanford's failure  to  make a  hazardous
waste determination. Although it applied
only to two one-gallon containers of waste,
officials were concerned because of Han-
ford's history of noncompliance with that
requirement.
DIRECTOR'S WORD
Continued from page 1

cies, strategies, and principles on how to
develop, conduct, and implement environ-
mental management  systems at  federal
facilities so a facility can improve its reg-
ulatory compliance,  better manage its
risks  and  liabilities, and  utilize  its
resources  most  effectively.  These tools
should help an agency answer the ques-
tion "Where are we going?" Many of our
tools and documents are available via the
Internet   on   our   Web   page   at
http://www.epa.gov/oeca/fedfac/fflex.html.
   Next, we soon will  have a  Compliance
Assistance Center for Federal  Facilities
that can assist facility managers who need
information regarding compliance with
environmental regulations. This Center's
Web site will provide a virtual tour of a
typical federal facility and explain how to
tackle various compliance issues. It will
include  a questionnaire for users to com-
plete to help update the Center to ensure
its responsiveness to user needs. The Cen-
ter, which will be located on our Web page
in the near future, will be an important
tool to help agencies figure out where they
want to be in the future.
   My goal is for all  federal agencies to
assume the mantle of true environmental
leadership. Not just compliance but lead-
ership.  That  leadership won't  just be
measured in the compliance status of its
facilities or whether an internal auditing
system has been developed. Environmen-
tal leadership will be accomplished when
the heads of each department or agency
and all of its top career and political lead-
ership view environmental management
as part of their missions — not just as
something that EPA's Federal Facilities
Enforcement Office worries about.
   And last, but certainly not least, is our
enforcement of environmental violations.
My staff  director for enforcement  once
said during a speech, "We don't want you
to like enforcement. We want the process
to be  painful." She was right. As I have
said before, enforcement actions  and
penalties deter non-compliance. We do it
because it works. Enforcement  will con-
tinue  to be  an active and vital part  of
FFEO's mission. However, embracing
environmental leadership within all fed-
eral  agencies  and departments  will
advance the concept of environmental
stewardship. Our shared  environment
will be the ultimate benefactor.
                                                                                                            FEDFACS 9

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                                              ConferenceUpdate
EPA Region 6 Hosts Second
Wetlands Regulatory
Roundtable
   EPA Region 6 hosted its second Wet-
   lands Regulatory Roundtable in Janu-
ary 1999, attracting attendance from the
US Army Corps of Engineers District and
Divisional Offices; US Fish and Wildlife
Service, Field  Offices;  National Marine
Fisheries  Service; Natural  Resources
Conservation Service; and state environ-
mental  offices which  have  a role  in
reviewing wetland permits.
   The primary objective  of the round-
table is to improve the effectiveness of
the permitting program as it relates to
Section  404 of the Clean Water Act.
Workgroups  established at the previous
year's roundtable  presented summaries
on topics such as: cumulative impacts on
wetlands,  watershed approach to pro-
jects, mitigation banking, use of hydroge-
omorphic modeling, review of completed
mitigation sites, stream restoration pro-
jects, and an enforcement strategy.
   A roundtable planned  for next year
will continue the discussions and new ini-
tiatives that will affect the wetlands pro-
gram. Information concerning the Wet-
lands Roundtable can be reviewed  on
Region  6 web page  at: http://www.
epa.gov/earthlr6/6wq/ecopro/em/per-
mits.   For  more information, contact
Wanda Boyd at (214) 665-6696.
P2 Workshop at Coast
Guard Facility
The  Coast Guard Training  Center  in
Cape May, NJ hosted a pollution preven-
tion  (P2) environmental workshop  in
March 1999, jointly sponsored by Regions
2 and 3.  The two  day  workshop was
designed primarily for civilian  federal
agencies, and  combined classroom  lec-
tures with a pollution prevention opportu-
nity assessment excercise at the automo-
tive maintenance shop of the Coast Guard
facility. Prevention opportunities identi-
fied during  the workshop  assessment
exercise were discussed in follow-up lec-
tures and with members of the facility. (A
formal  pollution prevention opportunity
assessment was conducted at the facility
in August 1997 by Region 2, which formed
the basis of some discussion as well.) The
workshop covered such topics as:
•  The Pollution Prevention Act of 1990
   and Executive Order 12856;
•  Integration  of P2 concepts into Envi-
   ronmental Management  Systems;
•  P2 and Environmental Compliance;
•  P2 plans, baselines and assessments;
   and
•  Hazardous Material Control Systems.

   The  workshop was attended  by
approximately  40  representative  from
such agencies as the U.S. Mint, Federal
Aviation Administration, National Park
Service, Bettis Atomic Power lab, and the
Smithsonian Institute.   Feedback was
positive and similar pollution preven-
tion/waste minimization  workshops will
be held for the federal facility community
in the future.
Region 8 Sponsors
Environmental Virtual
University Pilot Project
As  part  of  EPA's  national compliance
assistance for  Department of  Interior
employees,  Region 8 awarded  Front
Range  Community College (FRCC)  in
Westminster, Colorado a grant to develop
"Introduction to Environmental Science
via the Internet." The EPA grant covers
tuition for up to 30 DOI employees, who
will each earn 3 hours of college credit.
This pilot project utilizes FRCC's Web-
based distance education software and
expertise in environmental training. The
class is a core class in the environmental
curriculum at FRCC, and is designed to
introduce students to scientific and poli-
cy issues  underlying  current environ-
mental problems in  the natural world.
Issues  presented  include hazardous
waste management,  acid mine drainage
and aquatic ecosystems, urban air pollu-
tion, ozone   degradation, and pollution
prevention.
   The 12-week course started on Janu-
ary 29, 1999, and currently has 13  stu-
dents enrolled.
   Each  week's reading assignments,
Internet research   assignments, home-
work  assignments,  and/or quizzes  are
posted on the class  bulletin board. Stu-
dents contact the instructor via e-mail for
answers to questions or for any clarifica-
tions or help needed.
   Response  from participants in this
class has been positive. One  student e-
mailed the instructor "I can't tell you how
much I enjoy this  class. I am the safety
officer for our soils engineering lab, and
the  information I am picking up from
this class is right in line with some of the
work I have done or even some work I am
now doing."  Once the class is complete,
FRCC will provide each student with an
opportunity to  evaluate the course con-
tent,  instructor, and Internet delivery.
FRCC is  planning to offer this class
again in the fall, and has targeted two
additional classes, "Introduction to Envi-
ronmental Laws and Policies" and "Pol-
lution Prevention" to be  developed for
Internet  delivery.    (EPA  support for
tuition for these classes is not planned.)
For more   information,  contact John
Works (EPA) at (303) 312-6196 or Kim
Lewis (FRCC) at (303) 404-5356.
 1O FEDFACS

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                                              Resources
Who  Are  the  Federal  Facilities  Coordinators?
   Have a question about EPA and don't know whom to call? The
   Federal Facilities Coordinators, located in each EPA regional
office, will either answer your query or direct you to the right
location or person.
   Have suggestions for a workshop? Need to get together with
your state or tribal representatives on environmental issues of
mutual  concern? Need assistance to enhance a pollution preven-
tion program? FFCs plan, coordinate, or conduct inspections or
compliance assistance workshops and work cooperatively with
program staff and managers to ensure that federal facilities are
provided the tools they need to be in environmental compliance.
   FFCs have  an average  of 20 years of government service.
They are engineers,  scientists, and environmental protection
specialists.  They have work experience with EPA headquarters,
state agencies, and environmental interest groups. And they are
the primary regional points of contact for federal facilities look-
ing for EPA information and referral.
   The FFCs and FFEO welcome your suggestions and want to
work with you to strengthen our environmental partnerships!
  REGIONAL FEDERAL FACILITIES
  COORDINATORS
  Region 1:  Anne Fenn, (617) 918-1805
  Region 2:  Jeanette Dadusc, (212) 637-3492
  Regions:  Bill Arguto, (215) 814-3367
  Region 4:  Stacy Howard, (404) 562-9633 (DOE Coordinator)
           David Holroyd, (404) 562-9625 (DoD Coordinator)
           Anthony Shelton, (404) 562-9636 (CFA Coordinator)
  Region 5:  Lee Regner, (312) 353-6478
  Region 6:  Joyce Stubblefield, (214) 665-6430
  Region 7:  Diana Jackson, (913) 551-7744
  Region 8:  Dianne Thiel, (303) 312-6389
           ConnallyMears, (303) 312-6217
  Region 9:  Sara Segal, (415) 744-1569
           Larry Woods, (415) 744-1580
  Region 10: Michele Wright, (206) 553-1747
           Susan Ennes, (206) 553-6249
 On-Line Notes:
 HOW DO  YOU SPELL "ENVIRO$EN$E?"

    You may have noticed that the domain name (URL) address for
    FFEO's Enviro$en$e/FFLEX (Federal Facilities Environmental Lead-
 ership  Exchange)   Web   site  —   http://www.epa.gov/oeca/
 fedfac/fflex.html — appears   on  your  browser  screen  as
 http://es.epa.gov/oeca/fedfac/fflex.html. As you may have discovered,
 you can access Enviro$en$e/FFLEX Web pages using either address.
 So what is the significance of "www" versues "es" in the address? The
 "www" designation refers to EPA's main server; the "es" refers to the
 server currently being used by the Enviro$en$e (E$) network. Within
 the year, however, the "es" server for Enviro$en$e will become part of
 the larger EPA server system, and typing in the "es"form of the address
 will not access the site. Therefore, any time you publish or give out the
 Enviro$en$e address, you  should always use the "www" form  rather
 than the "es" designation. The main domain name address for Envi-
 ro$en$e itself can be accessed at http://www.epa.gov/envirosense.
    For more information, contact  Isabelle Lacayo, 202/564-2578 or
 lacayo.isabelle@epa.gov.
New Yellow Book

Published

^he Yellow Book:  Guide to Environmental Enforcement and
 I Compliance at Federal Facilities, commonly referred to as the
"Yellow Book," is currently being published and will be available
in hard copy and via the Internet in June 1999. The new Yellow
Book revises and supersedes the 1988 version entitled Federal
Facilities Compliance Strategy.
   The Yellow Book is designed to assist federal facilities with
achieving and  maintaining compliance with federal environ-
mental requirements  as required by Executive Order 12088,
Federal  Compliance with Pollution Control Standards, and  in
going beyond these requirements to lead the way in minimizing
environmental contamination.
   For information on ordering the Yellow Book, contact Priscilla
Harrington  of EPA's FFEO at (202) 564-2461  or fax (202)  501-
0069.
                                                                                                      FEDFACS 11

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      UpcomingEvents
August 1999
EPA Region 7 Federal Facilities
Conference
Kansas City, KS
Contact: Diana  Jackson  at (913) 551-7509  or
Jackson.diana ฉepa.gov.
August 11-12,1999
Great Lakes Regional Pollution
Prevention Roundtable Summer
Meeting
Traverse City, Ml
Contact:  Lisa  Memfield,  (217) 333-8940
merrifld@wmrc.hazard.uiuc.edu.
or
     September 20-23,1999
     1999 Chemical Emergency
     Preparedness and Prevention
     Conference
     Washington, DC
     Sponsor: EPA Region 3. Contact: Al Brown, (215) 814-
     3302, or go to http://www.epacepp.com.
November 15-18,1999
Third Annual DoD  Maintenance
Symposium and Exhibition:
Transforming Maintenance With
Technology
St. Louis, MO
Sponsor: National Defense Industrial Association,
Office of the Secretary of  Defense.  Contact: Terra
Thomas, NDIA, 2111 Wilson Blvd., Suite 400, Arling-
ton, VA, 22201-3061, tel: 703-247-2590, fax: 703-522-
1885, tthomas@ndia.org.
LIST OF ACRONYMS
CAA        Clean Air Act
CERCLA    Comprehensive Emergency
           Response, Compensation, and
           Liability Act
CFA        Civilian Federal Agency
CWA       Clean Water Act
DLA        Defense Logistics Agency
DoD        Department of Defense
DOE        Department of Energy
DOI        Department of the Interior
DOJ        Department of Justice
EMR       Environmental
           Management Review
EPA        Environmental Protection
           Agency
EPCRA     Emergency Planning and
           Community RightTo-Know
           Act of 1986
FIFRA      Federal Insecticide, Fungicide,
           and Rodenticide Act
FFEO       Federal Facilities Enforce-
           ment Office (EPA)
NPL        National Priorities List
OECA       Office of Enforcement and
           Compliance Assurance (EPA)
RCRA       Resource Conservation and
           Recovery Act
SDWA       Safe Drinking Water Act
SEP        Supplemental Environmental
           Project
TSCA       Toxic Substances Control Act
LIST        Underground Storage Tank
                                                                                                     Od '
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