&EPA
United States Office of Enforcement and EPA 300-R-00-002
Environmental Protection Compliance Assurance January 2000
Agency
The State of Federal
Facilities
An Overview of Environmental
Compliance at Federal Facilities
FY 1997-98
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Federal Facilities Enforcement Office
TABLE OF CONTENTS
Section Page
Acronyms iii
List of Exhibits v
I. Introduction 1
II. Regulated Universe 5
IE. Inspections 17
IV. Compliance Rates 23
V. Enforcement Actions 33
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Acronym
AIRS
CAA
CEI
CFA
CWA
CWS
DOD
DOE
EPCRA
FFCs
FFCA
FFEO
FIFRA
FUDS
GOCO
IDEA
HAP
JOCO
LQG
NAAQS
NCDB
NESHAPs
NOV
NPDES
NSPS
ACRONYMS
Definition
Aerometric Information Retrieval System
Clean Air Act
Compliance Evaluation Inspection
Civilian Federal Agency
Clean Water Act
Community Water System
Department of Defense
Department of Energy
Emergency Planning and Community Right-to-Know Act
Federal Facilities Coordinators
Federal Facility Compliance Act (Agreement)
Federal Facilities Enforcement Office
Federal Insecticide, Fungicide, and Rodenticide Act
Formerly Used Defense Site
Government-Owned Contractor-Operated
Integrated Database for Enforcement Analysis
Hazardous Air Pollutant
Jointly-Owned Contractor-Operated
Large Quantity Generator
National Ambient Air Quality Standards
National Compliance Database
National Emissions Standards for Hazardous Air Pollutants
Notice of Violation
National Pollutant Discharge Elimination System
New Source Performance Standards
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Acronym
NSR
NTNCWS
OECA
PCS
POGO
PWS
PWSS
RCRA
RCRIS
SDWA
SDWIS
SEPs
SIC
SNC
SQG
TNCWS
TRI
TRIS
TSCA
TSDF
Definition
New Source Review
Non-Transient Non-Community Water System
Office of Enforcement and Compliance Assurance
Permit Compliance System
Privately-Owned Government-Operated
Public Water System
Public Water System Supervision
Resource Conservation and Recovery Act
RCRA Information System
Safe Drinking Water Act
Safe Drinking Water Information System
Supplemental Environmental Projects
Standard Industrial Classification
Significant Noncompliance (Noncomplier)
Small Quantity Generator
Transient Non-Community Water System
Toxics Release Inventory
Toxics Release Inventory System
Toxic Substances Control Act
Treatment, Storage, and Disposal Facility
IV
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LIST OF EXHIBITS
Exhibit Page
Regulated Universe
1. Federal Facilities by Agency Category 5
2. Distribution of CFA Facilities by Agency 6
3. Universe of RCRA Federal Facilities by Agency Category 7
4. RCRA Federal Facilities by Handler Type 8
5. Major Federal NPDES Facilities by Agency Category 9
6. CAA Major Federal Sources by Agency Category 10
7. Universe of Federally-Owned Public Water Systems by Agency Category 12
8. Universe of Federal Facilities Reporting under TRI 13
9. TRI On-Site and Off-Site Releases at Federal Facilities 14
Inspections
10. RCRA, NPDES, and CAA Inspections by EPA and States at Federal Facilities
by Agency Category 17
11. TSCA, FIFRA, and EPCRA §313 Inspections at Federal Facilities by Agency
Category 18
12. EPA and State Inspections at Federal Facilities (FY 1993 - FY 1998) 20
Compliance Rates
13. Federal Facility Compliance Rates for Selected Indicators 24
14. Percentage of Inspected TSDFs not Cited for RCRA Class I Violations 24
15. RCRA Compliance Rates by Federal Agency Category 25
16. Percentage of Major NPDES Facilities not in SNC 26
17. NPDES Compliance Rates by Federal Agency Category 26
18. Percentage of CAA Major Sources in Compliance 27
19. CAA Compliance Rates by Federal Agency Category 28
20. SDWA Compliance Rates at Federally-Owned Systems 29
21. TSCA, FIFRA, and EPCRA §313 Compliance Rates 30
State of Federal Facilities Report V
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Enforcement Actions
22. Enforcement Actions at Federal Facilities by Statute 33
23. Enforcement Actions at Federal Facilities by Federal Agency Category 34
24. RCRA Enforcement Actions at Federal Facilities 35
25. NPDES Enforcement Actions at Federal Facilities 35
26. CAA Enforcement Actions at Federal Facilities 36
27. SDWA Enforcement Actions at Federal Facilities 37
VI State of Federal Facilities Report
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I. INTRODUCTION
EPA's Federal Facilities Enforcement Office (FFEO), within the Office of Enforcement
and Compliance Assurance (OECA), periodically assesses federal facility performance with
respect to environmental statutes and programs. The last assessment, The State of Federal
Facilities: An Overview of Environmental Compliance Status at Federal Facilities, FY 1995-96,
was published in June 1998. This State of Federal Facilities report examines federal facility
environmental performance during FY 1997 and FY 1998. Where appropriate and when data are
comparable, this report also examines pre-FY 1997 data.
Federal facilities are generally subject to the same environmental statutes and regulations
as commercial entities. EPA, in conjunction with the states, has oversight responsibility for
federal facility environmental programs. To fulfill its oversight responsibility, FFEO conducts a
broad range of activities, including:
X Compliance oversight and enforcement;
X Training and compliance assistance; and
X Review of federal agency environmental plans and programs.
Through its network of Regional Federal Facilities Coordinators (FFCs) and state contacts, FFEO
works with appropriate facility personnel to ensure that they take the necessary actions to
prevent, control, and abate environmental pollution.
Environmental Requirements
Environmental requirements potentially affecting federal facilities range from federal
statutes and their implementing regulations to state and local laws and ordinances. This report
summarizes federal facility data during FY 1997 and FY 1998 with respect to the following
seven major environmental statutes and programs:
X Resource Conservation and Recovery Act (RCRA) - RCRA Subtitle C
and its associated amendments regulate the generation, transport, storage,
treatment, and final disposal of hazardous waste.
X Clean Water Act (CWA) — Under the CWA, EPA or approved states issue
National Pollutant Discharge Elimination System (NPDES) permits that
establish effluent limits for all municipal and industrial wastewater
discharges.
X Clean Air Act (CAA) — The CAA authorizes EPA to establish emission
control standards to achieve the air quality goals set forth in the National
Ambient Air Quality Standards.
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> Safe Drinking Water Act (SD WA) - The Public Water System
Supervision (PWSS) program authorized by SDWA enables EPA to set
standards to control both man-made and naturally occurring contaminants.
In most cases, states have primary responsibility for oversight and
enforcement under SDWA.
> Toxic Substances Control Act (TSCA) - Under TSCA, EPA identifies
and controls the manufacture, process, distribution, use, and disposal of
existing and new chemical substances and mixtures.
X Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) — Under
FIFRA, EPA has the authority over the sale, distribution, and use of
pesticide products.
X Toxics Release Inventory (TRI) — Under §313 of the Emergency Planning
and Community Right-to-Know Act (EPCRA), EPA provides information
about toxic chemicals to the public through an annual report of releases of
such chemicals by industrial and other facilities.
The information contained in this report is drawn from many sources within and across
the various EPA environmental program offices. The starting point for the analysis is the
Integrated Database for Enforcement Analysis (IDEA), which is a mainframe information
management system that draws upon several other EPA databases, including:
X RCRIS — The Resource Conservation and Recovery Act Information
System is the mainframe database that tracks hazardous waste handlers
under RCRA.
X PCS — The Permit Compliance System tracks EPA Regional and state
compliance and enforcement data for the NPDES program under the
CWA.
X AIRS -- The Aerometric Information Retrieval System manages
aerometric emissions and compliance data on point sources tracked by
EPA, state, and local governments in accordance with the CAA.
X NCDB — The National Compliance Database is the national repository for
compliance and enforcement data collected by EPA under FIFRA, TSCA,
and EPCRA §313.
In addition, this report also presents data from the following "stand alone" systems:
X SDWIS — The Safe Drinking Water Information System is a national
database that tracks public water supply system compliance and
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enforcement data collected by EPA Regions and states under the PWSS
program of SDWA.
X TRIS -- The Toxics Release Inventory System tracks releases of chemicals
listed in the TRI according to chemical type, quantity, and nature of the
release.
Organization of the Report
Previous versions of the State of Federal Facilities report were organized by individual
media or programs (i.e., separate chapters devoted to RCRA, CWA, etc.). This report adopts a
multi-media approach in which the data are organized to address the following basic questions:
X What is the universe of federal facilities that are regulated/affected under
each of the environmental programs? (Section n - Regulated Universe)
X What is the level of inspection activity at federal facilities for each of the
environmental programs? (Section HI - Inspections)
X What are the current trends in compliance? (Section IV - Compliance
Rates)
X What actions are taken to address noncompliance? (Section V -
Enforcement Actions)
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II. REGULATED UNIVERSE
Although all federal facilities are potentially subject to environmental regulations, most
are not involved in activities that would trigger requirements to comply with regulations.
According to IDEA, there are approximately 14,400 federal facilities that engage in some type of
activity directly affected by environmental requirements.1 These facilities can be grouped into
six broad categories - Department of Defense (DOD), Department of Energy (DOE), Civilian
Federal Agencies (CFAs), Formerly Used Defense Sites (FUDS), federal facilities located in
foreign lands, and unidentified federal facilities (Exhibit 1).
Exhibit 1
Federal Facilities by Agency Category (FY 1998)
FUDS (9.9%) 1,428
Unidentified (6.8%)
DOE (2.8%) 406
i 981
DOD (32.0%) 4,615
Total = 14,431 federal facilities
Located in Foreign Lands (5.3%) 771
CFAs (43.2%) 6,230
DOD and DOE facilities typically include large installations (e.g., military bases, storage
depots), manufacturing/fabrication plants, and laboratories/research facilities. The universe of
CFA facilities is somewhat more diverse and includes organizations such as the Department of
the Interior, General Services Administration, Department of Justice, Tennessee Valley
Authority, Environmental Protection Agency, and many others.
Exhibit 2 shows the distribution of CFA facilities according to individual agencies.
Department of Transportation facilities comprise the largest single share (19.9 percent) of all
CFAs, followed by the Department of Interior (16.8 percent), the Postal Service (16.0 percent),
the Department of Agriculture (10.9 percent), and the Corps of Engineers (10.8%).
1 Because SDWIS is a stand alone database, the facility total derived from IDEA does not include
federally-owned public water supply systems.
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Exhibit 2
Distribution of CFA Facilities by Agency
200
400
600
800
1,000 1,200 1,400
Note: Differences in the distribution of CFA facilities relative to the FY 1995-96 State of Federal Facilities
report are primarily due to the removal of outdated facility information in the Federal Facilities Information
System.
Missions of the Federal Agencies
DOD is charged with defending the interests of the United States anywhere in the world.
As such, DOD maintains thousands of installations to provide the necessary infrastructure for the
armed services to meet this mission. Installations range in size from a few acres to thousands of
square miles; their missions range from logistics and training to manufacturing and rebuilding
aircraft and ships. Many of these installations are the equivalent of small cities, and thus they
possess all of the infrastructure (e.g., hospitals, sewage treatment plants, roads, airports)
associated with city environments. Much of the support activity associated with DOD's mission
is industrial, therefore, DOD installations face compliance issues relating to air and water
pollution and solid/hazardous waste generation.
DOE is involved in electric power generation and transmission, fuel research, petroleum
storage, and nuclear weapons research and production. Many of DOE's approximately 400
installations are dedicated to laboratory research. DOE laboratories work on a variety of issues
including solar energy, battery development, energy transmission methods, atomic energy, fossil
fuels, and nuclear weapons. Some laboratories are located on large compounds such as
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Savannah River, Los Alamos, and Oak Ridge, while others are part of university systems such as
the Fermi Lab in Chicago. Like DOD, the large-scale manufacturing and industrial nature of
many DOE activities presents DOE with a broad range of environmental compliance issues.
CFA facilities range in size and scope from single-purpose buildings to extensive multi-
purpose compounds. Activities include vehicle fleet management, construction, facility
operation, scientific and medical research, materials storage and shipment, and many others. On
an individual facility basis, many CFA facilities have few environmental concerns; however, the
diversity of CFA activities implies that, as a group, they face environmental compliance issues as
extensive as those faced by DOD and DOE facilities.
When discussing the entire community of federal facilities, it is important to recognize
that not all federal facilities are owned and/or operated by the federal government. At numerous
federal facilities and on many public lands, a private party or private parties are involved. Thus,
in addition to traditional government-owned government-operated facilities, the federal facility
community includes government-owned contractor-operated (GOCO) facilities, privately-owned
government-operated (POGO) facilities, jointly-owned and contractor-operated (JOCO)
facilities, as well as many other ownership/operating arrangements.
RCRA Universe
In 1998, there were 314,980 handlers (i.e., facilities) in the RCRA universe. The 3,637
federal RCRA facilities represent approximately 1.2 percent of this total. As shown below in
Exhibit 3, 38.2 percent of the federal facilities are DOD facilities, 3.0 percent are DOE facilities,
51.0 percent are CFA facilities, and another 7.8 percent are unidentifiable by agency category.
Exhibit 3
Universe of RCRA Federal Facilities by Agency Category (FY 1998)
CFA (51.0%) 1,854
Unidentifiable (7.8%) 284
Total = 3,637 RCRA Federal Facilities
DOE (3.0%) 110
DOD (38.2%) 1,389
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RCRA facilities can be divided into three handler types: generators, transporters, and
treatment, storage and disposal facilities (TSDFs). Generators of RCRA-regulated waste must
obtain an EPA ID number; prepare hazardous waste for transport; and comply with the
accumulation and storage, record keeping, and reporting requirements. They are also responsible
for tracking waste through a manifest system. The manifest system creates a written record of
the chain-of-custody from the time a waste leaves a generator until it reaches its final disposal
site. Transporters must obtain an EPA ID number, comply with the manifest system, and
address any hazardous waste discharges. TSDFs are subject to record keeping and reporting
requirements and technical standards covering treatment and disposal methods, as well as the
location, construction, and operation of disposal sites. Finally, both generators and TSDFs may
be subject to land disposal restrictions requiring treatment of the waste before it is land-disposed.
In addition, a small number of facilities are classified as non-notifiers. Non-notifiers are RCRA
facilities that have been identified through sources other than regular reporting and are suspected
of engaging in RCRA-regulated activities without proper authority.
As shown in Exhibit 4, large and small quantity generators (LQGs and SQGs) make up
the largest share of federal RCRA handlers (89.3 percent), followed by TSDFs and transporters
(7.7 percent and 2.3 percent respectively). The TSDF universe is used to develop the
compliance indicator for RCRA presented in Section IV.
Exhibit 4
RCRA Federal Facilities by Handler Type (FY 1998)
LQGs (19.7%) 718 Transporters (2.3%) 83
TSDFs (7.7%) 281
Non-Notifier (0.6%) 23 "" '
SQGs (69.6%) 2,532
Total = 3,637 Facilities
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CWA Universe
Under the CWA, all point source
dischargers of wastewater, including federal
facilities, must submit an application for a
NPDES permit. NPDES permits may contain
water quality-based and/or technology-based
standards for effluent discharges, compliance
schedules, and monitoring/reporting
requirements.
Major (versus minor) NPDES facilities
are defined as those that contribute a larger
share of pollutants discharged to surface
waters.
At the end of FY 1998, federal facilities comprised approximately 1.7 percent (117) of
the total universe of 6,786 major facilities regulated under the NPDES program. As shown in
Exhibit 5, of these 117 facilities, 67.5 percent were DOD, 12.0 percent were DOE, and 20.5
percent were CFA facilities. The universe of NPDES majors is used to develop the CWA
compliance indicator presented in Section IV.
Exhibit 5
Major Federal NPDES Facilities by Agency Category (FY 1998)
DOD (67.5%) 79
CFAs (20.5%) 24
DOE (12.0%) 14
Total =117 Facilities
CAA Universe
To meet EPA's National Ambient Air Quality Standards (NAAQS), states typically
require new sources of air pollution to obtain preconstruction permits. The type and level of
control required by the permit depends on the attainment status of the area, which is based upon
air quality with respect to six criteria pollutants (CO, SO2, NOX, volatile organic compounds,
particulate matter, and lead). Areas meeting the NAAQS are considered in "attainment," while
areas not meeting the NAAQS are in "nonattainment." Federal sources wishing to begin
construction in nonattainment areas must go through the construction permit review process
under the New Source Review (NSR), which allows for industrial growth (i.e., new sources) if
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stringent requirements are met, including emissions offsets, state-wide compliance for all
sources, public notification, and installation of control equipment to meet the Lowest Achievable
Emission Rate. If the federal source is to be located within an attainment area, the permit review
process falls under Prevention of Significant Deterioration requirements, which require
installation of the Best Available Control Technology, establishment of maximum allowable
emissions increases or increments, performance of impact analyses by source, and notification of
the public.
Federal sources, depending on the
nature and size of their operations, also may
be subject to technology-based New Source
Performance Standards (NSPS) for new,
modified, or reconstructed stationary sources;
health-based National Emissions Standards
for Hazardous Air Pollutants (NESHAPs) for
new and existing sources within specific
categories; and/or Title V requirements
designed to address all sources of emissions
at a facility under a single permit.
Major CAA Sources — The definition of
major source differs by program. Under the
NSPS and NSR, a source is considered
major if it emits or has the potential to emit
over 100 tons per year (tpy) of a regulated
pollutant. For Hazardous Air Pollutants
(HAPs), the limit is 10 tpy of any single
HAP or 25 tpy of two or more HAPs.
In FY 1998, of the 43,386 major sources regulated under all programs within the CAA,
478 (1.1 percent) were federal sources. As shown in Exhibit 6, 58.4 percent of these federal
sources were DOD, 7.5 percent were DOE, and 34.1 percent were CFAs. The universe of CAA
major sources is used to develop the CAA compliance indicator presented in Section IV.
Exhibit 6
CAA Major Federal Sources by Agency Category (FY 1998)
DOD (58.4%) 279
DOE (7.5%) 36
CFAs (34.1%) 163
Total = 478 Major Sources
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SDWA/PWSS Program Universe
Federally-owned public water supply systems comprised approximately 2.7 percent
(4,550) of the total universe of 168,783 systems regulated under the PWSS program. As shown
in Exhibit 7, the vast majority (85.7 percent) of these federal systems are owned by CFAs. In
particular, the U.S. Forest Service within the Department of Agriculture owns more than 70
percent of these systems.
Under the SDWA/PWSS program the definition of a public water system is "a water
system providing water for human consumption through constructed conveyances to at least 15
service connections or an average of 25 individuals daily at least 60 days per year." EPA has
interpreted the term human consumption to include drinking, bathing, showering, cooking,
dishwashing, and maintaining oral hygiene. There are three types of public water systems:
X Community water systems (CWS) serve at least 15 service connections
used by year-round residents of an area or regularly serves at least 25 year-
round residents for 60 days or more per year. The remaining two types of
systems are considered non-community water systems because they do not
provide water to more than 15 residences year-round.
X Transient Non-Community Water Systems (TNCWS) serve transient or
seasonal customers in locations such as campgrounds, motels, and
gasoline stations.
X Non-Transient Non-Community Water Systems (NTNCWS) regularly
serve at least 25 of the same non-resident people per day for at least six
months of the year. Examples of NTNCWS include schools, factories,
hospitals, and other facilities that have their own water supplies.
The universe of federally-owned public water systems is used to develop the SDWA compliance
indicator presented in Section IV.
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Exhibit 7
Universe of Federally-Owned Public Water Systems
by Agency Category (FY 1997)
CFA - Forest Service (72.7%) 3,310^
Other (1.3%) 60
DOD(12.5%)570
DOE (0.5%) 21
Other CFAs (12.9%) 589
Total = 4,550 Systems
TSCA and FIFRA Universe
TSCA and FIFRA are not permit-based compliance programs like NPDES. The number
and identity of facilities subject to TSCA or FIFRA may change substantially from year to year.
As a result, there are no readily definable TSCA or FIFRA universes. Federal facilities subject to
TSCA or FIFRA are identified and targeted for inspections through a variety of less formal
means, including: self-reporting by entities of their intent to manufacture regulated substances,
third-party requests/complaints, and EPA/state evaluation of publicly available data.
EPCRA/TRI Universe
Established under §313 of the Emergency Planning and Community Right-to-Know Act
of 1986, the TRI is a publicly available database containing specific chemical release and transfer
information from manufacturing facilities throughout the United States. The TRI is intended to
promote planning for chemical emergencies and to provide information to the public regarding
the presence and release of toxic and hazardous chemicals in their communities.
In the private sector, manufacturing facilities [i.e., facilities in Standard Industrial
Classification (SIC) codes 20-39] having ten or more full-time employees and exceeding certain
chemical use thresholds are required to report under the TRI.2 Federal facilities have been
required to report since 1994, regardless of their SIC classification. The threshold for reporting
is the manufacture and/or processing of listed chemicals in excess of 25,000 pounds per year for
each chemical, and 10,000 pounds per year for each listed chemical for other uses.
In May of 1997, EPA added seven new industry sectors that will begin reporting for 1998.
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For 19973, the most recent year for which data are available, there were 124 federal
facilities that submitted a total of 346 forms under the TRI program. As shown in Exhibit 8,
most of those reporting were DOD facilities (61.3 percent). Of the CFA facilities reporting (23.4
percent) the most common agency affiliations were NASA, Treasury Department, Department of
Agriculture, and Department of the Interior.
Exhibit 8
Universe of Federal Facilities Reporting under TRI (1997)
DOD (61.3%) 76
DOE (15.3%) 19
CFA (23.4%) 29
Total = 124 Facilities
As shown in Exhibit 9, federal facilities reported on- and off-site releases of more than
6.2 million pounds of TRI chemicals in 1997. The majority of these were comprised by releases
to air - fugitive releases (33.2 percent) and stack releases (27.9 percent). Releases to surface
water and land comprised an additional 17.9 percent and 13.2 percent respectively.
3 TRI data are reported on a calendar year basis.
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Exhibit 9
TRI On-Site and Off-Site Releases at Federal Facilities (1997)
Land (13.2%) 869,892 Underground Injection (2.6%) 173,653
Off-Site Disposal (5.1%) 336,(
- - -' — Surface Water (17.9%) 1,176,773
Fugitive Air (33.2%) 2,182,989
Total = 6,573,345 pounds
Stack Air (27.9%) 1,833,350
Due to changes in the way the quantity of releases are calculated, the data above are not
entirely comparable with that contained in previous State of Federal Facilities reports; however,
based on the 1997 TRI Public Data Release, the quantity of on- and off-site releases from
reporting federal facilities has declined by 30.5 percent since 1995, from 9,457,198 pounds to
6,573,345 pounds in 1997.
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Documentation for Exhibits in this Section
Exhibit Title
Federal Facilities by Agency Category
Distribution of CFA Facilities by Agency
Universe of RCRA Federal Facilities by
Agency Category
RCRA Federal Facilities by Handler
Type
Major Federal NPDES Facilities by
Agency Category
CAA Major Federal Sources by Agency
Category
Universe of Federally-Owned Public
Water Systems by Agency Category
Universe of Federal Facilities Reporting
under TRI
TRI On-Site and Off-Site Releases at
Federal Facilities
Information
Source
IDEA
IDEA
IDEA
IDEA
IDEA
IDEA
SDWIS &
data from
federal
agencies
TRIS
TRIS
Date of
Data Pull
2/2/99
2/2/99
2/2/99
2/2/99
3/4/99
3/1/99
10/97
6/1/99
6/1/99
Comments
-
~
~
~
~
~
Data derived from direct download
from TRIS and 1997 TRI Public Data
Release report.
Data derived from direct download
from TRIS and 1997 TRI Public Data
Release report.
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III. INSPECTIONS
EPA and states monitor activities at federal facilities to determine whether they are in
compliance with environmental laws and regulations. Compliance monitoring also enables EPA
to measure and track performance over time and to identify potential problem areas and
compliance assistance opportunities. Most environmental programs rely on some form of facility
inspection as the principal tool for determining compliance. The level of effort associated with
these inspections varies, depending on the specific requirements addressed, the size and
complexity of the facility's operations, and the type and amount of data required to assess
compliance.
EPA and states conducted 1,395 RCRA, 314 NPDES, and 942 CAA inspections at
federal facilities during FY 1997 and FY 1998. The number of inspections conducted under each
of these statutes/programs remained fairly constant during both fiscal years (Exhibit 10). The
number of SDWA/PWSS inspections is not reported in the federal SDWIS database and
therefore is not presented in this report.
Exhibit 10
RCRA, NPDES & CAA Inspections by EPA and States at Federal
Facilities by Agency Category (FY 1997 and FY 1998)
500
400
300-
200
100
RCRA'97 RCRA'98 NPDES'97 NPDES'98 CAA'97
• DOD TZ\ CFA CH DOE
CAA'98
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TSCA, FIFRA, and EPCRA §313 inspections at federal facilities were less common
(Exhibit 11). There were 26 TSCA, FIFRA, and EPCRA §313 inspections in FY 1997 and 31 in
FY 1998.
Exhibit 11
TSCA, FIFRA & EPCRA §313 Inspections by EPA and States at
Federal Facilities by Agency Category (FY 1997 and FY 1998)
10
2
TSCA '97 TSCA '98
FIFRA'97 FIFRA'98 EPCRA/TRI'97 EPCRA/TRI'98
DOD ^ CFA rH DOE
As shown in Exhibits 10 and 11, most inspections (69 percent and 69.3 percent in FY
1997 and FY 1998, respectively) occurred at DOD facilities. CFA inspections comprised 21.3
percent and 23.2 percent of the total, while DOE facilities received 9.7 percent and 7.5 percent,
respectively. The total number of inspections in FY 1997 was 1,355 and in FY 1998 it was
1,353. Exhibit 12 shows the total number of EPA and state inspections at federal facilities for
RCRA, NPDES, CAA, and TSCA/FIFRA/EPCRA §313 since FY 1993.
RCRA Inspections
To assess compliance with RCRA requirements, EPA inspectors conducted 120 and 106
inspections at federal facilities in FY 1997 and FY 1998. The totals for state-led inspections
were 576 and 593, for an overall total of 696 in FY 1997 and 699 in FY 1998 (Exhibit 12).
RCRA inspections range in intensity from comprehensive compliance evaluation
inspections (CEI) to fairly basic record reviews. CEIs remain the most common form of RCRA
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inspection, accounting for 65 and 69 percent of inspections at federal facilities during FY 1997
and FY 1998. Record reviews accounted for 12 to 14 percent of inspections. The remainder
were composed of a variety of other inspection types (e.g., corrective action oversight, case
development, compliance schedule, operations and maintenance).
CWA/NPDES Inspections
Implementation responsibility for the NPDES program lies primarily with the states. As a
consequence, more than 85 percent of NPDES inspections conducted at federal facilities during
FY 1997 and FY 1998 were led by states. In FY 1997, states performed 143 inspections versus
23 by EPA. In FY 1998, states performed 131 inspections versus 17 by EPA. Thus, the total
number of inspections in FY 1997 was 166 and in FY 1998 it was 148 (Exhibit 12).
CAA Inspections
EPA and state inspectors conducted 467 CAA inspections of major federal sources during
FY 1997 and 475 in FY 1998 (Exhibit 12). States continued to take a lead role on the majority
of CAA inspections (444 state-led inspections versus 23 by EPA in FY 1997 and 467 state-led
inspections versus eight by EPA in FY 1998).
SDWA/PWSS Inspections
The number of SDWA/PWSS inspections is not reported in the federal SDWIS database
and therefore is not presented in this report.
TSCA. FIFRA. and EPCRA §313 Inspections
The number of TSCA inspections conducted at federal facilities decreased from 16 in FY
1997 to 14 in FY 1998 (Exhibit 11). Most inspections (10 of 16 in FY 1997 and 11 of 14 in FY
1998) were led by EPA. The number of FIFRA inspections conducted at federal facilities
remained very small; one inspection occurred during FY 1997, while two occurred during FY
1998 (Exhibit 11). All FIFRA inspections were led by EPA.
In addition to the standard reporting requirements of the EPCRA §313 (TRI program),
EPA conducts a limited number of inspections at reporting federal facilities. Given the nature of
the program, inspections conducted under EPCRA §313 tend to involve record reviews, although
the process of verifying the accuracy of TRI reporting may involve some on-site field
evaluations. During FY 1997 and FY 1998, there were nine and 15 EPCRA §313 inspections
conducted at federal facilities (Exhibit 11). In accordance with Section 5-502 of Executive
Order 12856, EPA Regions acted as the lead on all EPCRA §313 inspections. The total for
TSCA, FIFRA, and EPCRA §313 inspections, shown in Exhibit 12, was 26 (six state-led) in FY
1997 and 31 (three state-led) in FY 1998.
State of Federal Facilities Report 19
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Federal Facilities Enforcement Office
Exhibit 12
EPA and State Inspections at Federal Facilities (FY 1993 - FY 1998)
1,000
800-
600
400-
200
FY 1993 FY 1994 FY 1995 FY 1996 FY 1997
FY1998
RCRA
NPDES
E3 CAA
Kl TSCA/FIFRA/EPCRA
20
State of Federal Facilities Report
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Federal Facilities Enforcement Office
Documentation for Exhibits in this Section
Exhibit Title
RCRA, NPDES & CAA Inspections by
EPA and States at Federal Facilities by
Agency Category
TSCA, FIFRA & EPCRA §313
Inspections by EPA and States at Federal
Facilities by Agency Category
EPA and State Inspections at Federal
Facilities (FY 1993 - FY 1998)
Information
Source
IDEA
IDEA
IDEA
Date of
Data Pull
Various
Various
Various
Comments
-
—
-
State of Federal Facilities Report
21
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Federal Facilities Enforcement Office
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22 State of Federal Facilities Report
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Federal Facilities Enforcement Office
IV. COMPLIANCE RATES
It is not feasible to develop a single measure of compliance for federal facilities for all
environmental programs. However, evaluating narrowly defined compliance indicators over time
can reveal how a sector of federal facilities is performing generally with respect to individual
environmental programs.
Table 1 provides the definitions of selected compliance indicators used to calculate
compliance rates. The reader should keep in mind that the compliance rates only apply to the
universe of facilities within the definitions in Table 1. For example, the RCRA indicator and
RCRA compliance rates only apply to inspected TSDFs. They should not be applied as a
measure of compliance for uninspected TSDFs, non-TSDFs (e.g., generators), or other RCRA
programs (e.g., underground storage tank program).
Table 1
Definitions of Compliance Indicators for Federal Facilities
Statute Compliance Indicator
RCRA Percent of inspected federal TSDFs not cited for Class I violations4
CWA Percent of NPDES major federal facilities not in significant
noncompliance (SNC)
CAA Percent of major federal sources in compliance
SDWA Percent of federal public water systems not in SNC
TSCA Percent of inspected federal facilities not in SNC
Exhibit 13 presents compliance rates for five statutes based on the definitions of the
indicators taken from Table 1. Pre-1997 rates were calculated in previous State of Federal
Facilities reports. In this section, the rates are calculated for the federal sector as a whole
(Exhibit 13) then calculated by federal agency category (i.e., DOD, DOE, and CFAs) for RCRA,
CWA, and CAA. Compliance rates for the entire federal sector are also compared with the non-
federal (i.e., private) sector for RCRA, CWA, and CAA.
Exhibit 13 shows that from FY 1993 to FY 1998, RCRA compliance increased, while
CWA compliance exhibits a steady decline. SDWA compliance fluctuated but remained high
(above 90 percent), as did CAA compliance (between 84 and 90 percent). After a low in FY
1994, TSCA compliance rebounded and has remained at 100 percent for the past four years.
Beginning in FY 1998, the Violation Class field in RCRIS is no longer required. The field has not been
removed from the RCRIS database and it may continue to be populated with new data. Subsequent State of Federal
Facilities reports will rely on a different RCRA compliance indicator.
State of Federal Facilities Report 23
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Federal Facilities Enforcement Office
Exhibit 13
Federal Facility Compliance Rates for Selected Indicators
Statute
RCRA
CWA
CAA
SDWA
TSCA
FY 1993
55.4%
94.2%
87.0%
99.2%
93.5%
FY 1994
61.6%
88.5%
87.9%
98.7%
87.5%
FY 1995
73.8%
76.2%
88.8%
93.0%
100%
FY 1996
75.1%
73.0%
87.4%
96.4%
100%
FY 1997
81.2%
70.4%
84.2%
97.1%
100%
FY 1998
88.2%
61.5%
88.9%
98.1%
100%
.
Note: These rates reflect compliance only for the universe of facilities defined by the indicators in Table 1 on page
23. For example, the RCRA rates apply only to inspected TSDFs. They do not apply to non-TSDFs (e.g.,
generators), uninspected TSDFs, or other RCRA programs (e.g., underground storage tanks).
RCRA Compliance Rates
In FY 1997 and FY 1998, 213 and 221 inspected federal facilities were TSDFs, which are
generally considered "major" facilities under RCRA. Of these, 40 (18.8 percent) and 26 (11.8
percent) were cited for Class I violations. Therefore, 81.2 percent and 88.2 percent were not
cited for Class I violations in FY 1997 and FY 1998. The corresponding compliance rates for the
non-federal universe of inspected TSDFs were 79.5 percent and 83.3 percent (Exhibit 14).
Exhibit 14
Percentage of Inspected TSDFs not Cited for RCRA Class I Violations
(Federal vs. Non-Federal TSDFs)
100.0% -i
90.0%
80.0% -
70.0%
60.0% -
50.0%
Legend
Federal TSDFs
Non-Federal TSDFs
I
FY 1997
FY 1998
24
State of Federal Facilities Report
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Federal Facilities Enforcement Office
Exhibit 15 presents RCRA compliance rates according to federal agency category.
Compliance rates at DOD facilities were 80.9 percent in FY 1997 and 87.5 percent in FY 1998.
These rates were very close to the overall compliance rate for federal facilities. In FY 1997 and
FY 1998, the CFA compliance rate was 100 percent. RCRA compliance rates at DOE facilities
were lower (70.6 percent and 85 percent) than the overall federal facility rate for both years.
Exhibit 15
RCRA Compliance Rates by Federal Agency Category
Agency
DOD
CFAs
DOE
Total
FY 1997
Inspected
TSDFs
183
13
17
213
TSDFs With
Class I
Violations
35
0
5
40
TSDFs
Without
Class I
Violations
148 (80.9%)
13 (100.0%)
12 (70.6%)
173 (81.2%)
FY 1998
Inspected
TSDFs
184
17
20
221
TSDFs With
Class I
Violations
23
0
3
26
TSDFs
Without
Class I
Violations
161 (87.5%)
17 (100.0%)
17 (85.0%)
195 (88.2%)
NPDES Compliance Rates
Under the CWA NPDES program, SNC is characterized by a violation of significant
magnitude and/or duration to be considered among the EPA's priorities for review and/or
response. The definition of SNC is EPA policy, which can change or evolve as the NPDES
program changes. Beginning in FY 1998, the definition of SNC was expanded to encompass
more categories of violations.
Exhibit 16 compares the percentage of major federal facilities not in SNC against the
corresponding percentage for the universe of major non-federal NPDES facilities. In FY 1997,
the percentage of major federal facilities not in SNC was 70.4 percent, roughly 10 percent lower
than for major non-federal facilities. In FY 1998, compliance rates for all major facilities
declined, though major federal facilities still experienced lower compliance rates compared to the
non-federal universe (61.5 percent versus 70.1 percent).
State of Federal Facilities Report
25
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Federal Facilities Enforcement Office
Exhibit 16
Percentage of Major NPDES Facilities not in SNC
(Federal vs. Non-Federal Majors)
100.0%
90.0% -
80.0%
70.0% -
60.0% -
50.0%
Legend
Major Federal Facilities
Major Non-Federal Facilities
FY 1997
FY 1998
The number of major federal facilities determined to be in SNC increased from 37 in FY
1997 to 45 in FY 1998. Exhibit 17 presents NPDES compliance rates by agency category for FY
1997 and FY 1998. For both years, DOD facilities were slightly below (68.2 percent in FY 1997
and 58.2 percent in FY 1998) the overall compliance rate for federal facilities. For both years,
CFA facilities had the highest compliance rates when compared to overall rates. DOE had the
lowest compliance rate relative to the CFAs and DOD, as well as the overall compliance rate.
Exhibit 17
NPDES Compliance Rates by Federal Agency Category
Agency
DOD
CFAs
DOE
Total
FY1997
Major
Facilities
85
26
14
125
SNC
27
4
6
37
Not in
SNC
58 (68.2%)
22 (84.6%)
8(57.1%)
88 (70.4%)
FY 1998
Major
Facilities
79
24
14
117
SNC
33
6
6
45
Not in
SNC
46 (58.2%)
18 (75.0%)
8(57.1%)
72(61.5%)
26
State of Federal Facilities Report
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Federal Facilities Enforcement Office
CAA Compliance Rates
Under the CAA programs, sources that have exceeded emissions standards and/or
violated procedural requirements (e.g., failed to meet a compliance schedule, or failed to follow
monitoring, recordkeeping and reporting protocols) are deemed out of compliance. As shown in
Exhibit 18, during FY 1997 and FY 1998, federal sources experienced lower compliance rates
(84.2 percent and 88.9 percent) than the rest of the regulated community. CAA compliance rates
for the same two years for major non-federal sources were 89.4 and 90.7 percent, respectively.
Exhibit 18
Percentage of CAA Major Sources in Compliance
(Federal vs Non-Federal Sources)
100.0%
90.0% -
80.0% -
70.0% -
60.0%
Legend
Major Federal Sources
Major Non-Federal Sources
FY 1997
FY 1998
As shown in Exhibit 19, DOD compliance rates were higher than both DOE and CFA
compliance rates; although the improvement in compliance rates over the two year period was
more pronounced among CFA and DOE sources.
State of Federal Facilities Report
27
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Federal Facilities Enforcement Office
Exhibit 19
CAA Compliance Rates by Federal Agency Category
Agency
DOD
CFAs
DOE
Total
FY 1997
Major
Sources
282
148
44
474
Majors Out of
Compliance
25
27
3
55
Majors In
Compliance*
251(89.0%)
114(77.0%)
34 (77.3%)
399 (84.2%)
FY 1998
Major
Sources
279
163
36
478
Majors Out of
Compliance
20
14
3
37
Majors In
Compliance*
254(91.0%)
139(85.3%)
32 (88.9%)
425 (88.9%)
* In FY 1997, there were 20 sources (six DOD, seven CFA, and seven DOE) that were of unknown
compliance status. In FY 1998, there were 16 such sources (five DOD, 10 CFA, and one DOE). These
sources were not included in the compliance rate calculation.
SDWA Compliance Rates
Under the SDWA/PWSS programs, water systems in SNC have more serious, frequent,
or persistent violations. Exhibit 20 shows the number of federally-owned public water systems
cited for violations under SDWA, as well as the number of systems classified as SNC for more
serious violations. The number of systems cited for violations decreased from 980 in FY 1997 to
853 in FY 1998. SNC systems exhibited a similar decline, from 2.9 percent in FY 1997 to 1.9
percent in FY 1998. The compliance indicator used for the SDWA is the percentage of PWSS
systems not in SNC. Therefore, as shown below, the compliance rate for federal systems overall
increased from 97.1 percent in FY 1997 to 98.1 percent in FY 1998. It was not possible to
provide a compliance rate for individual agency categories of CFAs, DOD, and DOE.
28
State of Federal Facilities Report
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Federal Facilities Enforcement Office
Exhibit 20
SDWA Compliance Rates at Federally-Owned Systems
6,000
Legend
^| Federally-Owned Systems
I | Systems with Violations [% of total with violations]
Significant Noncompliers [% of total in SNC]
[21.5%] [2.9%]
[19.0%] [1.9%]
FY 1997
(97.1% not in SNC)
FY 1998
(98.1% not in SNC)
TSCA Compliance Rates
EPA and the states did not find any inspected federal facilities to be in SNC with TSCA
during FY 1997 or FY 1998. In other words, there were no violations of TSCA at federal
facilities that triggered an enforcement response at an administrative complaint level. Therefore
the compliance indicator, defined as the percentage of inspected federal facilities not in SNC,
was 100 percent for FY 1997 and FY 1998 (Exhibit 21). In fact, TSCA compliance at federal
facilities has remained at 100 percent since FY 1995.
Exhibit 21 also presents compliance rates for inspected federal facilities under FIFRA
and EPCRA §313. For FY 1997 and FY 1998, the compliance rates for federal facilities under
both programs were 100 percent. However, the number of FIFRA inspections at federal facilities
has historically been low, and the number of EPCRA §313 inspections at federal facilities has
only recently approached the number of TSCA inspections.
State of Federal Facilities Report
29
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Federal Facilities Enforcement Office
Exhibit 21
TSCA, FIFRA & EPCRA §313 Compliance Rates
Statute
TSCA
FIFRA
EPCRA
Total
FY 1997
Inspected
Facilities
16
1
9
26
Facilities not
inSNC
16
1
9
26 (100%)
FY 1998
Inspected
Facilities
14
2
15
31
Facilities not
inSNC
14
2
15
31 (100%)
L
30
State of Federal Facilities Report
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Federal Facilities Enforcement Office
Documentation for Exhibits in this Section
Exhibit Title
Federal Facility Compliance Rates for
Selected Indicators
Percentage of Inspected TSDFs not Cited
for RCRA Class I Violations
RCRA Compliance Rates by Federal
Agency Category
Percentage of Major NPDES Facilities
not in SNC
NPDES Compliance Rates by Federal
Agency Category
Percentage of CAA Major Sources in
Compliance
CAA Compliance Rates by Federal
Agency Category
SDWA Compliance Rates at
Federally-Owned Systems
TSCA, FIFRA and EPCRA §313
Compliance Rates
Information
Source
IDEA
IDEA
IDEA
IDEA
IDEA
IDEA
IDEA
SDWIS
IDEA
Date of
Data Pull
Various
2/26/98
3/31/99
2/26/98
3/31/99
3/20/98
3/4/99
3/20/98
3/4/99
2/12/98
3/1/99
2/12/98
3/1/99
7/8/99
2/17/98
3/9/99
Comments
-
-
-
-
-
-
-
-
-
State of Federal Facilities Report
31
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3 2 State of Federal Facilities Report
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Federal Facilities Enforcement Office
V. ENFORCEMENT ACTIONS
EPA and states issued 399 and 375 enforcement actions against federal facilities in FY
1997 and FY 1998, respectively. Exhibit 22 presents these enforcement actions by
statute/environmental program. RCRA enforcement actions comprised more than 70 percent of
all enforcement actions at federal facilities, while NPDES and CAA actions accounted for
roughly equivalent shares of the remaining 25 to 30 percent. SDWA actions accounted for two
to three percent of actions. There were no enforcement actions taken at federal facilities under
TSCA, FIFRA, orEPCRA §313.
Exhibit 22
Enforcement Actions at Federal Agencies by Statute
(Formal and Informal Actions by EPA and States)
FY 1997
FY 1998
RCRA (75.9%) 303
RCRA (70.4%) 264
SDWA (2.0%) 8 V IM&I SDWA (3.2%) 12
CAA (9.5%) 38 ^^^ CAA (13.3%) 50
NPDES (12.5%) 50 NPDES (13.1%) 49
Total = 399 Enforcement Actions Total = 375 Enforcement Actions
As shown in Exhibit 23, DOD facilities received the largest share of enforcement actions
under all statutes except for SDWA. For RCRA in particular, the number of actions taken
against DOD facilities outnumbered those for the next highest agency category (CFAs) by a three
to one margin. Between FY 1997 and FY 1998, DOE's share of enforcement actions nearly
doubled - from 25 to 43 actions (6.3 percent to 11.5 percent), while DOD's declined from 283 to
241 actions (70.9 percent to 64.3 percent). Over the same period, CFAs' share increased from
22.8 percent to 24.3 percent (91 actions in FY 1997 and FY 1998).
State of Federal Facilities Report
33
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Federal Facilities Enforcement Office
Exhibit 23
Enforcement Actions at Federal Facilities by Agency Category
(Formal and Informal Actions by EPA and States)
250
200-
150
100
50
RCRA '97 RCRA '98 NPDES '97 NPDES '98 CAA '97 CAA '98 SDWA '97 SDWA '98
• DOD Y7\ CFA I I DOE
RCRA Enforcement
For RCRA, the percentage of state-led actions remained fairly constant; 242 of 303 (79.9
percent) in FY 1997 and 222 of 264 (84.1 percent) in FY 1998. As shown in Exhibit 24, for FY
1997 and FY 1998, more than 80 percent of RCRA enforcement actions taken against federal
facilities were informal (e.g., warning letters, verbal warnings). Formal actions include: civil
actions, consent decrees, federal facility compliance agreements (FFCAs), referrals to other
enforcement authorities, judicial orders, notices of noncompliance, administrative orders,
corrective action orders, and imminent hazard orders. The most commonly used formal
enforcement action is the RCRA §3008(a) administrative order; approximately 79 percent (42
out of 53) and 68 percent (27 out of 40) of formal enforcement actions taken in FY 1997 and FY
1998, respectively, were administrative orders.
Proposed RCRA penalties increased nearly fourfold from just over $400,000 in FY 1997
to almost $1.6 million in FY 1998. Despite this increase, however, final penalties actually
decreased by more than 20 percent, from roughly $161,000 to $126,000 over the same period. In
addition, final supplemental environmental project (SEP) costs under RCRA declined from
$48,000 to slightly more than $26,000.
34
State of Federal Facilities Report
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Federal Facilities Enforcement Office
Exhibit 24
RCRA Enforcement Actions at Federal Facilities
Type of Action
Informal
Formal
All Enforcement Actions
Proposed Penalties
Final SEP Cost
Final Penalties Collected (excluding SEP costs)
FY 1997 Total
250 (82.5%)
53 (17.5%)
303
$438,925
$48,000
$160,987
FY 1998 Total
224 (84.8%)
40 (15.2%)
264
$1,597,515
$26,251
$125,882
NPDES Enforcement Actions
The number of enforcement actions taken to address NPDES noncompliance at federal
facilities remained constant during FY 1997 and FY 1998; however, the types of actions
changed. As shown in Exhibit 25, the share of informal enforcement actions (e.g., phone calls,
warning letters, informal NOVs) decreased from FY 1997 to FY 1998, while the percentage of
formal actions (i.e., FFCAs, administrative orders, and formal NOVs) exhibited a modest
decrease. The percentage of other enforcement actions (e.g., unspecified pending actions and
referrals) increased from eight percent in FY 1997 to more than 40 percent in FY 1998. State-
led NPDES actions accounted for 62 percent (31 of 50) and 71.4 percent (35 of 49) for FY 1997
and FY 1998, respectively.
Exhibit 25
NPDES Enforcement Actions at Federal Facilities
Type of Enforcement Action
Informal
Formal
Other
TOTAL
Number of Actions in
FY 1997
37 (74.0%)
9 (18.0%)
4 (8.0%)
50
Number of Actions in
FY 1998
22 (44.9%)
7 (14.3%)
20 (40.8%)
49
State of Federal Facilities Report
35
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Federal Facilities Enforcement Office
CAA Enforcement
EPA and states issued 38 and 50 NOVs and orders at federal sources during FY 1997 and
FY 1998, respectively, for failure to comply with provisions of the CAA. The majority of these
actions were NOVs (Exhibit 26). States took the lead on 100 percent (38 of 38) and 96 percent
(48 of 50) of these enforcement actions. The majority of these enforcement actions were issued
against DOD sources (50 percent and 64 percent in FY 1997 and FY 1998, respectively),
although CFA sources also received a substantial share (44.7 percent and 30 percent). DOE
sources received between 5 and 6 percent of actions during both FY 1997 and FY 1998.
Exhibit 26
CAA Enforcement Actions at Federal Facilities
Type of Enforcement Action
EPA Orders
State Orders
EPA NOVs
State NOVs
TOTAL
Number of Actions in
FY 1997
-
7 (18.4%)
-
31(81.6%)
38
Number of Actions in
FY 1998
1 (2.0%)
13 (26.0%)
1 (2.0%)
35 (70.0%)
50
SDWA/PWSS Program Enforcement
Relatively few federally-owned systems received formal enforcement actions for
violations under the PWSS program, either from EPA or the states. Exhibit 27 shows that the
total number of federal systems receiving formal enforcement actions increased from eight in FY
1997 to 12 in FY 1998. States took the lead on nearly 90 percent of SDWA actions (seven of
eight) during FY 1997 and 33 percent (four of 12) during FY 1998.
36
State of Federal Facilities Report
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Federal Facilities Enforcement Office
Exhibit 27
SDWA Enforcement Actions at Federal Facilities
Type of Enforcement Action
EPA Orders
State Orders
State Bilateral Compliance Agreements
TOTAL
Number of Actions in
FY 1997
1 (12.5%)
4 (50.0%)
3 (37.5%)
8
Number of Actions in
FY 1998
8 (66.7%)
2 (16.7%)
2 (16.7%)
12
EPA formal actions include administrative orders and §1431 emergency orders, while
state formal actions include administrative orders, bilateral compliance agreements, civil
referrals, and criminal cases filed. Of the seven formal enforcement actions issued by states in
FY 1997, three were bilateral compliance agreements and four were administrative orders, while
the EPA formal enforcement action was an administrative order. In FY 1998, of the 12 formal
enforcement actions issued, eight were federal administrative orders and the remaining four were
split evenly between state bilateral compliance agreements and administrative orders. No
federally-owned systems received civil referrals or had criminal cases filed against them during
either year.
TSCA, FIFRA, and EPCRA §313 Enforcement
There were no violations at inspected federal facilities of TSCA, FIFRA, or EPCRA §313
that triggered an enforcement response at an administrative complaint level.
State of Federal Facilities Report
37
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Federal Facilities Enforcement Office
Documentation for Exhibits in this Section
Exhibit Title
Enforcement Actions at Federal Agencies
by Statute
Enforcement Actions at Federal Facilities
by Agency Category
RCRA Enforcement Actions at Federal
Facilities
NPDES Enforcement Actions at Federal
Facilities
CAA Enforcement Actions at Federal
Facilities
SDWA Enforcement Actions at Federal
Facilities
Information
Source
IDEA
IDEA
IDEA
IDEA
IDEA
SDWIS
Date of
Data Pull
Various
Various
2/17/98
3/31/99
2/13/98
3/4/99
2/20/98
2/25/99
111199
Comments
-
-
-
-
-
-
38
State of Federal Facilities Report
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