EFA 1UO/1VVU.1
SEPA
                   United States
                   Environmental Protection
                   Agency
                    Office of
                    The Administrator
                    Washington DC 20460
June 1990
Strategic Targeted Activities for Results System
                   Third Quarter FY 1990 Report


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                                     U.S. ENVIRONMENTAL PROTECTION AGENCY

                             STRATEGIC TARGETED ACTIVITIES FOR RESULTS SYSTEM

                                            THIRD QUARTER 1990 REPORT



                                                       PREFACE
                   This quarterly report reviews Agency progress in meeting its priority program commitments.
               The report is a major component of EPA's strategic planning, budgeting and accountability system.
               Based on recommendations of the Deputy Administrator's Management Systems Task Force, the
               accountability system on which this report is based (formerly SPMS), has been renamed STARS—
               Strategic Targeted Activities for Results  System.  The change was  implemented first quarter
               FY 1990 and will be reflected in all future reports. Each quarter  the Office of Policy, Planning and
               Evaluation publishes the report using information provided by Headquarters, Regional Offices, and
               State agencies.  The Office of Compliance Analysis and Program Operations is responsible for the
               enforcement section of this report.

                   We gratefully acknowledge the assistance and cooperation of the many people through the
               Agency's management network who have make timely production  of this report possible.
                                                HEADQUARTERS LIBRARY
                                                FNVIRONMEMTAL PROTECTION AGENCY
                                                 .'^wriN.O.C. 20460

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                            TABLE OF CONTENTS
OFFICE                                                          PAGE




OFFICE OF AIR AND RADIATION	  1




OFFICE OF WATER	   21




OFFICE OF PESTICIDES AND TOXICS SUBSTANCES 	  61




OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE 	  93




OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING	127




OFFICE OF GENERAL COUNSEL	 145

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                             OFFICE OF AIR AND RADIATION

o    Highlights


o    Radiation

          Radon
          Emergency Response


o    Mobile Sources Program


o    Atmospheric and Indoor Air Pollution


o    Air Quality. Planning and Standards

          Particulates and Enforcement
          New Source Review
          Air Toxics and Enforcement of NESHAPs
          Ozone/CO SIP Remedies and VOC Enforcement
          Sulfur Dioxide and Enforcement
          Air Enforcement Combined Report
          Asbestos Demolition  and Renovation
                                          -i-

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                                    THIRD QUARTER HIGHLIGHTS
o     Forty-eight states will or have already received an EPA State Radon Grant of approximately $100,000 each.
      Montana and South Dakota are not participating claiming that the matching provisions of the grant are
      prohibitively expensive.


o     State Implementation Plan (SIP) targets are lagging behind expectations.  OAR believes that the States' failure to
      submit plans is due to the delay in passing the Clean Air Act (CAA) amendments.  States are hoping to buy
      additional time to process SIPs, and are concerned that provisions in the CAA will force them to re-promulgate
      existing SIPs.


            No final PM-10 SIPS have been published in FY 1990.  If the Clean Air Act (CAA) does not pass this
            year, the Sierra Club lawsuit could compel EPA to  prepare as many as 58 PM-10 Federal Implementation
            Plans  (FIPs) in PM-10 Group  I areas.


o     The Regions have collectively exceeded their third quarter FY 1990 target for submitting Multi-Year Development
      Plans (MYDPs) to address air toxics  by 44%.
                                                  -3-

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                                                       RADIATION

       Radon

            o     All but two states are slated to receive an EPA State Radon Grant of approximately $100,000.  Montana
                  and South Dakota are not participating in the program because they find the matching provisions of the
                  grant -- which call for a 25% match the first year, 40% the second year, and 50% the third year --
                  prohibitively expensive.   Other western states facing severe economic crises may also find the matching
                  provisions costly but have chosen to participate in the grant  program for the first year.  They may drop out
                  when the match provision rises in succeeding years.

,„»          o     Five states,  Guam, and the Cherokee tribe will participate in the FY 1991 State/EPA Survey program.  To
                  date, eleven states have not participated in the State/EPA Radon Survey program.


      Emergency Response

            o     At the request of the Chairman of the Federal Emergency Management Agency (FEMA) Regional
                  Assistance Committee, EPA Regions reviewed 24 emergency response plans against a target of 14,  The
                  program has not established a universe for the total number of reviews that EPA will ultimately have to
                  conduct.

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                STATE/EPA RADON SURVEYS COMPLETED OR UNDERWAY
                                    As of June 30, 1990
OAR 1-1.2
I	I STATE/EPA RADON SURVEY SLATED FOR FY 1991

["~7I STATE/EPA RADON SURVEY COMPLETED OR UNDERWAY
    These surveys provide a portrait of indoor radon levels state-wide.

 •^ NOT PARTICIPATING IN THE EPA STATE RADON GRANT PROGRAM
                                           -5-

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                                             MOBILE SOURCES


o      There are no third quarter targets for Mobile Sources.


o      July 31st, under court order, EPA issued a federal implementation plan (FIP) to bring the South Coast Air Basin
       in California into compliance with national air quality standards for ozone and carbon monoxide.  The mobile
       source provisions contain several innovative measures including:  ultra-clean vehicle emission standards for
       hydrocarbons and  carbon monoxide; volatility controls that vary by season, and oxygenated and reformulated fuels
       to reduce ozone and NOx emissions.  Also included are a marketable permits program for locomotives, aircraft,
       and ships.
                                   ATMOSPHERIC AND INDOOR AIR

o     There are no targets for the Office of Atmospheric and Indoor Air Pollution program.


o     In the third quarter updates to the President's Management by Objective System, OAR reports that they finalized
      the US negotiating position for stratospheric ozone protection.  OAR soon expects to complete preliminary CFC
      technical assessments for key developing countries, and to negotiate a stronger protocol consistent with the US
      position.
                                                       -b-

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                            AIR QUALITY. PLANNING AND STANDARDS
Particulate Matter

This year, OAR is tracking the development of SIPs for controlling particulates smaller than  10 microns (PM-10) in
Group I areas (those most at risk for PM-10 violations).  Group I areas are predominantly in the western Regions (81%
fall in Regions VIII, IX, and X).

      o     In PM-10 Group I areas:  Regions VIII, IX, and X  exceeded their third quarter targets for completing
            control strategy demonstrations.  All Regions with targets have met or exceeded annual expected
            performance. In addition, 13 public hearings were held in Regions I, VIII, IX,  and X.  Two PM-10 State
            Implementation  Plans were targeted to enter headquarters review from Region  IX, but none were
            submitted.

      o     In PM-10 Group II and III areas with violations:  4  SIP development plans were submitted against a  target
            of 5 (80%).  Region III, V, and  VIII met or exceeded their targets.  Region IX missed its target of 3.
            Region V completed one control strategy demonstration.

      o     No final  PM-10  SIPS have been  published in FY 1990.  States are hoping to buy additional time to process
            these SIPs and are concerned  that certain provisions in the CAA may  require them to make additional
            changes to the PM-10 SIPS they are currently working on. If the CAA doesn't pass this year, the Agency
            could be compelled to prepare as many as 58 PM-10 FIPs in Group I areas.

      o     Eight Regions exceeded their targets for reporting National Air Monitoring System PM-10 data.
                                                   -7-

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Particulate Matter  Enforcement
      o     Compliance Rates and Inspections - There are 3,917 major particulates sources in Group I and II areas, of
            which 220 (5%) are either in violation, in violation but meeting a compliance schedule, or the compliance
            status of the source is unknown.  The Regions and states accomplished 159% of their second quarter
            inspection commitment for TSP Class A SIP and NSPS sources in Group I and II areas.


      o     Significant Violators - Sixty-four TSP sources in Group I and II areas were identified as unaddressed
            significant violators at the beginning of the quarter and twelve new violators were identified during the
            quarter.  Six were returned to compliance, three were placed on schedules, and three had enforcement
            action commenced  (one was addressed within  120 days of detection, and five were addressed  within 121-270
            days after detection). Of the unaddressed violators, 19 have been in violation for more than  one year but
            less than two years, and 15 (12 in Region V) have been in violation for more than two years.

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                       PARTICULATES SIP DEVELOPMENT AND ENFORCEMENT
                                         As of June 30, 1990

            PM10 GROUP I CONTROL STRATEGY DEMONSTRATIONS
    15

    10

     5
                      n

IV
V    VI
REGIONS
100


 75


 50


 25


  0
     ADDRESSING SIGNIFICANT VIOLATORS
      (UNIVERSE: UNADDRESSED AT BOQ)
                                                   7-
                                             VII
                                                  IX
         1
                234
                 QUARTER
UNIVERSE 3.796 TSP SOURCES N GROUP I & I AREAS

OAR-80-84. 161-175
                                                       125

                                                       100

                                                        75

                                                        50

                                                        25

                                                         0
                                     CZZI IN COMPLIANCE (6)
                                     IZZl ON SCHEDULE (3)
                                     ES3 ENF. ACTION (3)
                                     •• PENDING (52)
                                                                        Q3 PERFORMANCE
                                                                        Q3 TARGET
                                                                        GROUP I UNIVERSE
                                                                INSPECTIONS (EPA & States)
                                                                 (Second Quarter FY 1990)
                                   I   II   II  IV  V  VI VII VII  IX  X
                                              REGIONS
                                          -9-

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New Source Review
            The Regions reported that 66 major New Source Review (NSR) permit packages were submitted in the
            third quarter of FY 1990.  All but two were reviewed on time. Region IX, which missed the two targets,
            reviewed 27 of the 29 NSRs submitted.
Air Toxics
            The Regions have exceeded the third quarter FY 1990 target of 34 adequate Multi-Year Development
            Plans (MYDPs) by 15 (44%). Four  Regions (II, VI, VII, X) have already met their end of year targets.


Enforcement of NESHAPS

      o     Compliance Rates - Of the 1,069 NESHAP (non-transitory) sources, 329 (31%) are either in violation, in
            violation but meeting a compliance schedule, or the compliance status of the source is unknown.

      o     Inspections - The Regions and states accomplished 117% of their second quarter inspection commitment
            for  NESHAP sources.

      o     Significant Violators - Twenty-five NESHAP sources were identified at the beginning of the quarter as
            being unaddressed significant violators and twenty-three new violators were identified during the quarter.
            Four were returned  to compliance, one were placed on schedules, and 12 had enforcement action
            commenced (12 were addressed within 60 days of detection, and 25 of the unaddressed have been  in
          '  violation more than  90 days after detection).

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                      AIR TOXICS PROGRAMS AND NESHAP ENFORCEMENT
                                        As of June 30, 1990
             ADEQUATE MULTI-YEAR DEVELOPMENT PLANS
 20

 15

 10
                                   COMPLETED TO DATE
                                   1990 Q3 TARGET
                                   UNIVERSE
                        IV
                             V    VI
                             REGIONS
VII   VIII
IX
35
30
25
20
15
10
 5
 0
        NESHAP SIGNIFICANT VIOLATORS
       (UNIVERSE:  UNADDRESSED AT BOQ)
         1
                 23
                  QUARTERS
                                                                    OAR NEW SOURCE REVIEW
                                                                        66 REVIEWS DUE
                                                             ON TIME (97%)
                                              LATE (3%)
      Universe: 1,069 Operating Non-Transitory Sources

OAR-122, 147 to 158
                                           LEGEND
                                          IN COMPLIANCE (4)
                                          ON SCHEDULE (7)
                                      (XX3 ENF. ACTION (14)
                                      ••• PENDING (0)
                                                                        INSPECTIONS
                                                                    (Second Quarter FY 1990)
                                 IV   V  VI  VII  VII IX
                                    REGIONS
                           Reporting on inspections is lagged one quarter.
                                            -11-

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Ozone/Carbon  Monoxide Remedies

      o      280  final CO/Ozone State Implementation Plan (SIPs) rules were submitted by the end of the third quarter
             FY  1990, against a target of 428 (65%).  Regions I, IV, and VIII exceeded their targets and Region VII
             met its target.  Sizeable shortfalls are evident in Regions II, III, V and IX for a number of  reasons:  many
             states  are postponing activity until the new CAA passes; several states are adopting atypical regulations
             covering transportation and  consumer (household) solvents which attract substantial public interest and
             comment; the LA and Chicago FIPs have demanded extensive staff time; and in one  case a Region has
             failed  to update the OAR computer bulletin board system.  In many  cases where submittals fall short of
             targets, regulations have gone  to public hearing.

      o      A number of complete emission inventories for Ozone and CO have  been submitted to Regions I, III,  IV,
             V, VI, VII,  VIII, and IX.  Other partial and draft emission inventories were submitted to Regions II, III,
             IV, and V.  Complete and comprehensive emissions inventories will be fundamental to an effective
             permitting program.

VOC Enforcement

      o      Compliance Rates - There are 4,974 Class A SIP and NSPS VOC sources in ozone nonattainment areas.
             OAR reports that 736 (15%) sources are either in violation, in violation but meeting a compliance
             schedule, or  the compliance  status of the source is unknown.

      o      Inspections - The Regions and states accomplished 180% of their second quarter FY  1990 inspection
             commitment for VOC Class  A SIP and NSPS sources in ozone nonattainment areas.  (NOTE:  inspection
             data for all  pollutant categories are lagged one  quarter)

      o      Significant Violators - One hundred and fifty-seven VOC sources were identified as being unaddressed
             violators at the beginning of the third quarter and forty-five nw vilators were identified during the quarter.
             Twenty-eight were returned  to compliance, 12 were placed on acceptable schedules, and 7 had enforcement
             action  commenced (22 were  addressed within 120 days of detection and  10 were  addressed within 121-270
             days after detection). Of the unaddressed violators, 34  have been in  violation for more than one year but
             less than two years, and 35 (28 in Region V) have been in violation for more than  two  years.

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    320


    240

    160

     80

      0
                        OZONE/CO SIP REMEDIES AND VOC ENFORCEMENT
                                         As of June 30, 1990
                                  OZONE/CO SIPs
                   DEFICIENT OR MISSING REGS & OTHER DEFICENCIES
                                   11 IK]
                               IV
                   V     VI
                   REGIONS
           VI
VIII
IX
200
150 -
100 -
 50 -
          VOC SIGNIFICANT VIOLATORS
        (UNIVERSE: UNADDRESSED AT BOQ)
          1
2       3
 QUARTERS
         Universe: 4.974 Class A VOC Sources

OAR-45. 108 to 119
     LEGEND

    IN COMPLIANCE (28)
    ON SCHEDULE (12)
IS2 ENF. ACTION (7)
•• PENDING (109)
   125

   100

    75

    50

    25

     0
                                                             COMPLETED TO DATE

                                                             03 TARGET

                                                             UNIVERSE
                                                 INSPECTIONS (EPA & States)
                                                  (Second Quarter FY 1990)
                II  IV   V   VI  VII  VII IX   X
                     REGIONS
            Reporting on inspections is lagged one quarter.
                                             -13-

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Sulfur Dioxide

      o     For third quarter, there are no targets for SO2.


Sulfur Dioxide Enforcement

      o     Compliance Rates - There  are 297 sulfur dioxide (SO2) sources in SO2 nonattainment areas, of which 87
            (29%) are either in violation, in violation but meeting a compliance schedule, or the compliance status of
            the source is unknown.

      o     Inspections - The Regions and states accomplished 298% of their second quarter inspection commitment
            for SO2 Class A SIP and NSPS sources in SO2 nonattainment areas.

      o     Significant Violators - Twenty-seven SO2 sources were identified at the beginning of the quarter as being
            unaddressed significant violators and five new violators were identified during the quarter.  Two were
            returned to compliance, none were placed on schedules, and none had enforcement action commenced
            (one was addressed  with 120 days of detection  and none were addressed  within 121-270 days after
            detection).  Of the unaddressed violators, eight have been in violation for more than one year but less than
            two years, and 12 (10 in Region V) have been  in violation  for more than two years.

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                    SULFUR DIOXIDE SIP DEFICIENCIES AND ENFORCEMENT
                                       As of June 30,  1990
                                         SO2 RULES NEEDED
                                    BY REGION - 155 RULES TOTAL
                              IV (3. 2%),
                                                          X(23.2%)
                               V(37.4%)

         SO2 SIGNIFICANT VIOLATORS
       (UNIVERSE:  UNADDRESSED AT BOQ)
10 -
                                                                 IX (5.8%)


                                                                 VII (2.6%)

                                                               VI (3.9%)

                                                            VI (4.5%)
                                                        125
                                                        100 —
                                                           75

                                                           50

                                                           25
                                                                     INSPECTIONS (EPA & States)
                                                                      (Second Quarter FY 1990)
         1
                   2        3
                    QUARTER
  Universe: 297 SO2 Sources in N/A Areas
OAR-83to94. 134 to 145
 LEGEND
IN COMPLIANCE (2)
ON SCHEDULE (0)
ENF. ACTION (0)
PENDING (25)
   III  IV  V  VI  VII VIII  IX  X
         REGIONS

Reporting on inspections is lagged one quarter.
                                           -15-

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Air Enforcement  Combined Report

Significant Violators

       o     There were 429 significant violators unaddressed at the beginning of the quarter and 137 new violators
             were identified during the year.  Fifty-eight were returned to compliance, 25 were placed on schedules, and
             31 had action commenced.  Of those addressed, 46 were addressed within 120 days of detection and 26
             were addressed within 121-270 days of detection.   Of the unaddressed violators, 104 have been in violation
             for more than one year but less than two years, and 76 have been in violation for  more than two years.

       o     Two hundred and ten significant violators are not  a part of the pollutant-specific reports discussed
             previously (but are included in the totals above).   Eighteen  were returned to compliance, nine were placed
             on schedules, and nine had enforcement action commenced. Of those addressed, 10 were addressed within
             120 days and 11 within 121-270 days. Forty-three  of the unaddressed violators have been in violation for
             more than  one year but less than two years, and 14 have been in violation for more than two years.

Enforcement Actions

       o     Fifty-four stationary source civil judicial  actions have been referred to DOJ through the third quarter. The
             Regions also report issuance of 186 administrative  orders (this includes lagged asbestos demolition and
             renovation  data from  the fourth  quarter of FY 1989).  The  states reported the referral of 20 civil cases and
             issuance of 450 administrative  orders through the second quarter (State data are lagged one quarter). Six
             Clean Air Act criminal cases have been referred to HQ thus far in FY 1990.

Federal Facilities

       o     The air program  identified 11  Federal facilities as  significant violators at the beginning of the quarter and
             one was returned to compliance.  Five of the unaddressed violators have been  in violation from 1-2 years,
             and two have been in violation more than two years.

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                             AIR ENFORCEMENT COMBINED REPORT
                                       As of June 30, 1990
      ADDRESSING SIGNFICANT VIOLATORS
       (UNIVERSE: UNADDRESSED AT BOQ)
                 2       3
                 QUARTERS
                                                       20
                                        ADDRESSING FEDERAL FACILITES VIOLATORS
                                            (UNIVERSE UNADDRESSED AT BOQ)
                                            LEGEND
                                                       15 -
                                          M COMPLIANCE (58).
                                                       '10 -
                         ON SCHEDULE (31)

                         ENF. ACTION(33)  5

                         PENDNG(308)

                                       0
                                                     2       4
                                                      QUARTERS
              CIVIL REFERRALS
 (CUMULATIVE - STATE DATA LAGGED 1 QUARTER)
 120
         1
OAR-195 to 199
2      3
QUARTERS
                                              ADMINISTRATIVE ORDERS
                                    (CUMULATIVE - STATE DATA LAGGED 1 QUARTER)
                                     1500
                                            LEGEND
                                                      1000
                                       I   I MADE BY STATES

                                       •• MADE BY EPA
                                                       500
2      3
QUARTERS
                                            -17-

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Asbestos Demolition and Renovation

(NOTE: Data are lagged one quarter)
o     Through  the second quarter of FY  1990, the EPA Regions report receipt of 3,114 notifications of
      asbestos demolition, and the states reported receipt of 25,038 notifications.
o     The Regions have conducted 247 asbestos demolition and renovation inspections (including 139
      contractors) through the second quarter and reported identification of 29 substantive violations.
      The states conducted 8,341 inspections (including 2,520 contractors) through the second quarter
      and reported 213 substantive violations.
o    Through the second quarter, EPA referred 33 civil actions where penalties were addressed and
     issued 48 administrative actions.  States referred 150 civil cases where penalties were addressed
     and issued 148 administrative actions.

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                          ASBESTOS DEMOLITION AND RENOVATION
                                     As of March 31. 1990
                                     (AH Data Lagged One Quarter)
    28500
            DEMOLITION AND RENOVATION ACTIVITY
     8000
     6000
     4000
     2000
OAR-185 to 198
NOTFICATKDNS MSPECTIONS  VIOLATIONS


           II STATES

           •1 EPA
500

400

300

200

100

  0
                                                       CIVIL REFERRALS
                                                     (FY 1990 CUMULATIVE)
150
120
90
60
30
n
-
-
-
-
I I




••••






                                                          2      3
                                                          QUARTERS
                                                    ADMINISTRATIVE ORDERS
                                                     (FY 1990 CUMULATIVE)
                                                                     2      3
                                                                     QUARTERS
                                           -19-

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                                 OFFICE OF WATER
o   Highlights

o   Drinking Water Programs

    -  Wellhead Protection
    -  UIC Permit Determinations
    ~  UIC Mechanical Integrity Tests
    --  UIC Well Inspections
    —  UIC Enforcement
    —  PWSS Compliance and Enforcement

o   Critical Habitats Programs

    -  Ocean Dumping EISs and Site Designations
    —  Wetlands Strategic Initiatives and Enforcement

o   Surface Water Programs

       Water Quality Assessment Activity
    --  Municipal Pollution Control Programs
    --  NPDES Permit Programs
    --  Pretreatment Programs
    ~  NPDES Significant Noncompliance
    ~  NPDES Response  to Significant  Noncompliance Exceptions
    --  NPDES Enforcement
                                     -21-

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                                  OFFICE  OF WATER

                           THIRD QUARTER HIGHLIGHTS

In Drinking Water:

o   Six states have had their wellhead protection programs approved, completing half of the annual
    target of 12.

o   Primacy states have considerably exceeded second quarter targets for UIC well inspections (by
    149%) and permit determinations (by 154%; UIC well data is lagged one quarter by Primacy
    states).

o   Only 2% of Public Water Systems are in significant noncompliance.

o   Sixty-six % of the new Microbiological/Turbidity SNCs were addressed in a timely and
    appropriate manner; 77% of the the new Chemical/Radiological SNCs have been addressed to
    date.

In Critical Habitats:

o   Regions have taken final actions on 89 out of 150 sites proposed for ocean dumping since 1985,
    including eight so far this year;

o   Regions have completed 16 of 69 wetlands strategic initiatives started in the last  five years,
    averaging two and one-quarter years to complete, and resolved 162 wetlands cases.

In Surface Water:

o   State performance in  reissuing major NPDES permits has fallen to 66% of target.  EPA
    performance has fallen from the second quarter (87%) and is now at 75% of target.

o   Net outlays for construction grants and state  revolving funds reached 97% of its target, well
    within their + or - 5% window.

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                            DRINKING WATER PROGRAMS

Drinking Water Programs include Wellhead Protection (WHP) within the Office of Groundwater
Protection, Underground Injection Control (UIC) wells and Public Water Systems Supervision
(PWSS) within the Office of Drinking Water.

o   The Wellhead Protection program provides technical assistance to states and localities.  EPA's
    work includes promoting the development of state plans for  the protection of critical
    groundwater sources of drinking water.  Each state is responsible for the development of their
    own program. To date, EPA's assistance includes guidelines for  WHP area management and
    delineation techniques, training of state/local officials on WHP data management and other
    technical issues.

o   The UIC program is delegated to a majority  of states who are responsible for:

    ~ making permit determinations for both existing and new wells;

    — verifying that mechanical integrity tests are performed to ensure that the well drilling process
      was  accomplished correctly and injected fluids are not migrating along the well bore;

    -- taking enforcement action against those wells with inappropriate injection practices.

o   The PWSS program  is delegated to all states except Wyoming, Indiana, and Washington, DC.
    The work includes:

    -- monitoring to ensure compliance with maximum contamination levels for microbiological
      contamination, trihalomethanes, turbidity, and chemicals/radioisotopes;

    — taking enforcement actions (based upon monitoring data results) against those  public water
      systems in  significant noncompliance.
                                         -23-

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                        WELLHEAD PROTECTION PROGRAMS

The 1986 amendments to the Safe Drinking Water Act (SDWA) direct states to submit proposed
Wellhead Protection (WHP) programs by June 1989 for EPA review/approval. Despite a lack of
appropriations for WHP Grants, EPA has received WHP programs/workplans from 32 States, Guam,
and Puerto Rico.  Submittals include both WHP Programs and (23) and WHP workplans (11).
Approval is based on program adherence to EPA guidelines.  Programs are statements fully
outlining State WHP implementation activities, whereas work plans may be general statements of goal
and objectives and a schedule for developing a WHP program.

WHP Activities

      o  Six State WHP programs were approved through the third quarter, completing half of the
         FY 90 target.  The States with approved plans are: Texas, Louisiana, Connecticut,
         Massachusetts, Rhode Island, and Delaware.

      o  Four States have submitted WHP workplans during FY 1990.

      o  Twenty-four other  states are currently revising programs prior to re-submission for EPA
         approval.

      o  Region I has the most approved EPA programs (three).

WHP programs are the only Ground Water Program activity currently tracked in STARS.

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                       STATE WELLHEAD PROTECTION
                             As of June 30, 1990
STATE WELLHEAD PROTECTION PROGRAMS
STATE WELLHEAD PROTECTION WORKPLANS
        I  IV  V   VI  VII  VI IX  X
             REGIONS

        RXXI APPROVED NP90
        I   I RESUBMITTED IN '90
        VTA NEW '90 SUBMISSIONS
        IBl BEING REVISED
  i   y  HI  iv   v  vi  VH  vii  ix  x
              REGIONS
                                -25-

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             UIC CLASS I, II, HI, AND V PERMIT DETERMINATIONS

To protect underground sources of drinking water (USDW), EPA requires all new underground
injection wells and some existing wells to undergo a permitting process.  This measure tracks permit
determinations for both new and existing wells.

Well                                                    Primary               Approx
Class   Purpose                                          Location              Number

I       Injection of Waste below lowest USDW             Regions IV,V,VI          500
II       Oil and Gas Production/Enhanced Oil Recovery      Regions V,VI,VII      160,000
III      Mineral Extraction                                Regions VI,VII,VIII    21,000
V       30 Types  including Agricultural Drainage,
        Sewage-related and Geothermal Reinjection          Nationwide            180,000
Made by EPA

    o  The Regions have committed to making 515 permit determinations during FY 1990.

    o  For the third quarter, the Regions completed 341 permit determinations, 89% of their target
       of 382.


Made by Primacy States (data are lagged one quarter)

    o  The primacy states have committed to making 5,228 permit determinations during FY 1990.

    o  For the second quarter, the  primacy states completed  3,900 permit determinations, 154% of
       their target of 2,526.

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                             UIC CLASS I, II, III, AND V PERMIT DETERMINATIONS
                                            (NEW AND EXISTING)
                            EPA
                     As of June 30. 1990
 PRIMACY STATES
As of March 31. 1990
DW-1
^ fW
I 600
|j 500
^ 400
1 300
I m
oc 100
-
-
-
-
f

1

Rl
RU
rai
RIV
RV
RVI
RVII
RVIII
RIX
1 RX




^
W^

,-"°
.-O'''
.••''/

• i i
1234
QUARTERS
Target
0
39
6
90
140
60
1
39
7
0
Rl
Actual
0
33 -
6 + r
104 + r
102 - r
I
I
39 +
5
0
                                                             10000

                                                              8000

                                                              6000

                                                              4000

                                                              2000


                                                 -O TARGET
                                                 -•- ACTUAL

                                             REGIONAL PERFORMANCE
                                              Those Regions showing
                                              no targets for this
                                              measure have Ittte or no
                                              responsibilities for permit
                                              determinations in the given
                                              EPA or State programs.
        2      3
     QUARTERS

   Target   Actual
Rl
RN
RW
RIV
RV
RVI
RVII
RVII
RIX
RX
54
26
6
133
113
1.374
244
73
479
24
41
24
28
183
152
2.023
447
108
893
1
-
-
+
+
+
+
+
+
+
+
                                            -27-

-------
        UIC CLASS I, II, III, IV AND  V MECHANICAL INTEGRITY TESTS

UIC mechanical integrity tests (MITs) are performed to ensure that the well casings and tubings are
sound and injected fluids do not migrate along the well bore.  All new and existing Class I and II
wells and some class HI and V wells must demonstrate mechanical integrity within the first five
years, and every five years thereafter. Class IV (hazardous waste) wells are banned.
Verified bv EPA

    o  Fo'r FY 1990, the Regions have committed to verify 2,826 MITs.

    o  For the third quarter, the Regions verified 2,254 MITs, 113% of their target of 1,997.


Verified bv Primacy States (data are lagged one quarter)

    o  The primacy states have committed to making 26,032 permit determinations during FY 1990.

    o  For the second quarter, the primacy states verified 14,354 MITs, achieving 123% of their
       target of 11,690.

-------
              UIC CLASS I, II, III, AND V MECHANICAL INTEGRITY TESTS (MITs)
                                 (NEW AND EXISTING)
                     EPA
                As of June 30. 1990
 PRIMACY STATES
As of March 31. 1990
DW-2
ouuu 	
2500 -
2000 -

1500 -

1000 - x

500 - /

ft I m 	 • —
° * 1

ra
Rl
Rl
RIV
RV
RVI
RVI
Rvyi
RIX
RX



/
x

..•''




2
Target
0
230
350
566
365
135
0
350
1
0
O
,-
/%'
/ /
.•





• i
3 4
3OUUU
30000
25000
20000

15000

10000
5000
o TARGET
-*- ACTUAL °

-
-
-

-
/

- S''^"^
S'

1
A 4 , REGIONAL PERFORMANCE
Actual Target
0 - Rl 0
311 + Those Regions showing py Q
450 + no targets for this p|y 15
569 + measure have ittte or no R)V 116
349 _ responstoity for MTTs RV 44Q
215 + in the given EPA or State RV| 732g
0 - proflrams RVI V535
350 + RVII 429
7 + RIX 1.802
3 + RX 20


,-"°
0''
>O
/• -"'
,.0''




234
Actual
0
0
20 +
254 +
642 +
8.994 +
1,628 +
643 +
2.115 +
58 +
                                   -29-

-------
                                UIC WELL INSPECTIONS

A UIC complete well inspection should include an assessment of: the wellhead, pressure and flow
meters, pipeline connections, and any other equipment associated with the injection system; an
inspection is completed only when a report has been filed with the regulatory authority.

Verified Bv EPA

    o  For FY 1990, the Regions have committed to verify 10,996 inspections.

    o  For the third quarter, the Regions completed 7,924 inspections, achieving 99.8% of their
       target of 7,935.


Verified By Primacy States  fdata lagged one quarter)

    o  For FY 1990, the primacy states have committed to verify 61,038 inspections.

    o  For the second quarter, the primacy states completed 43,448 inspections achieving 149% of
       their  target of 29,168.

-------
    12000
     9000 h
     6000 h
     3000 h
                        EPA
                  As of June 30. 1990
                                    UIC WELL INSPECTIONS
                                      (NEW AND EXISTING)
       100000
                                                  80000
                                                  60000
                                                  40000
                                                  20000
                      PRIMACY STATES
                     As of March 31. 1990
                                                                1      2       3
                                                                    QUARTERS
DW-2
 O  TARGET

-•- ACTUAL
                                       -31-

-------
             UNDERGROUND INJECTION  CONTROL ENFORCEMENT

Significant Noncompliance

    o   Based on field inspections, MITs and self-reporting 2,610 wells have been newly identified this
        year as being in SNC (1,485 by the states and 1,125 by EPA). At this time last year, 3,168
        wells were identified as being in SNC (1,681  by  the states and 1,487 by EPA).

        -  1,973 (76%) of the wells  in SNC are in Region V.

Addressing Significant Noncompliance

    o   ODW reports that there were 547  wells on the exceptions list at the beginning of the quarter.
        (Exceptions list includes wells in SNC for two or more quarters.)  Of  those 547 wells, 54
        returned to compliance and  202 have received an enforcement action  (including 151 this
        quarter).  The remaining 291 plus  220 wells coming on to the exceptions list during the
        quarter, constitute a new pending balance of 511 wells to be addressed.


Enforcement Actions

    o   Through the third quarter, EPA proposed  111 administrative orders and issued 68 final
        orders. EPA also referred four civil judicial  cases to DOJ.

    o   Through the second quarter, the states  issued 662 final orders and referred two civil actions
        and three criminal actions to the State  Attorneys General.

    (NOTE:  Some State data are lagged one quarter)

-------
                         UNDERGROUND INJECTION CONTROL
            RESPONSE TO SIGNIFICANT NONCOMPLIANCE EXCEPTIONS REPORT
                                  As of June 30, 1990
           550 —
           300 —
                     SNC'S ON     RETURNED TO
                   EXCEPTION LIST   COMPLIANCE
                 ON DECEMBER 1.1989
               PENDING
ENFORCEMENT
  ACTION
DW-6
                                                    M SNC FOR TWO QUARTERS
                                                    N SNC FOR MORE THAN TWO QUARTERS
                                    -33-

-------
                          PUBLIC WATER SUPPLY SYSTEMS

Compliance

    o   Of 58,659 Community Water Systems (CWSs), OW reports that 568 are in SNC for violations
        of microbiological, turbidity, total trihalomenthane MCLs and/or M&R and 354 are in SNC
        for violations of chemical and/or radiological MCLs and/or M&R.

    o   OW also reports that of the 25,936 nontransient noncommunity water systems (NTNCWS),
        260 were in priority violation of microbiological, turbidity, total trihalomenthane MCLs and 24
        were in priority violation of chemical and/or radiological MCLs.

Addressing PWSS SNC Exceptions  Reporting

    o   For the second quarter  FY 1990, 107 CWSs were listed as "new SNCs" for violations of
        microbiological,  turbidity, total trihalomethane MCLs and/or M&R.  Of these, 54 returned to
        compliance  and 17 had  an  enforcement action against them ("new SNCs"  for violations  of
        chemical  and/or radiological MCLs and/or M&R  are  reported only once during the year in
        first quarter and are not included in the above "new SNC1 numbers).

    o   At the beginning of the second quarter, there were 57.* CWSs, in SNC, already pending on
        the exceptions list.  During the quarter, 84 systems returned to compliance and 50 were
        addressed by an enforcement action.  The other 439 CWSs previously on the list remain to
        be addressed.

Enforcement Activity

    o   Through  the second quarter, the Regions have issued 54 final administrative orders including
        six complaints for penalty.  They also referred two civil cases to DOJ.  Through the second
        quarter,  the states have issued 588 administrative compliance orders.  The states also referred
        104 civil cases and filed 62 civil cases and three criminal cases.

(*NOTE:  Data  are lagged one  quarter)
                                        -34-

-------
                MICRO/TURBIDITY
                  PUBLIC WATER SYSTEMS
                     RESPONSE TO SNC
                    EXCEPTIONS REPORT
                     As of June 30, 1990

                                250
                                                200 -
         SNC*  RETURN TO
               PENDING
                                             CO
                                                150 -
                                                100 -
                                                50 -
DW/E-3
COMPL.   ACTIONS

 I    I IN SNC FOR TWO QUARTERS
 U7A IN SNC FOR MORE THAN TWO QUARTERS
       CHEMICAL/RAD
SNC* RETURN TO  ENF.   PENDING
      COMPL.  ACTIONS
                                                         * EXCEPTIONS AT START OF QUARTER
                                      -35-

-------

-------
                           CRITICAL HABITAT PROGRAMS

Critical habitats include the nation's oceans, near coastal waters (i.e. tidal waters and ocean areas
affected by land-based pollution), estuaries, and wetlands. For FY 1990, three Critical Habitat
programs are tracked in STARS:

o   The Ocean Dumping program regulates the  disposal of all types of material that may adversely
    affect the marine environment.

o   The Chesapeake Bay program coordinates efforts by federal, state, and local governments to
    improve the water quality and restore the living resources of the Chesapeake Bay (reported
    second and fourth quarters).

o   The Wetlands program

        uses strategic initiatives, a broad range of geographically focused efforts, to identify and
        protect valuable and  threatened wetlands with the assistance of federal, state, and  local
        agencies; and

    ~   enforces §404 of the  Clean Water Act, which authorizes EPA to assess the environmental
        impact of all discharges of dredged or fill material into U. S. waters, to review or veto the
        sites for Corps of Engineers permits  for such discharges into wetlands, and to bring civil and
        criminal enforcement actions against  illegal dischargers.

While not tracked in STARS, EPA has several other  Critical Habitat programs, including the Great
Lakes and National  Estuary programs  (both of which will be tracked in FY 1991), and the Near
Coastal Waters, and Ocean Discharge  programs.
                                         -37-

-------
                                    OCEAN  DUMPING

EPA is responsible for designating ocean dumping sites to be  used by the Corps of Engineers for
the disposal of material dredged to maintain navigation.  (Ocean dumping of sewage sludge is
banned under the Ocean Dumping Ban  Act of 1988.)  The designation process includes developing
an Environmental Impact Statement (EIS) as part of taking a final action on the site.  After
designation, these sites are  monitored  to ensure that no adverse impacts  occur to the marine
environmeqt.  Ocean dumping dredged material disposal sites  are located in a band about three
miles offshore.

    o   Seven Regions (28  states and  territories) have  territorial ocean waters used for ocean
        dumping.  About 150 sites were proposed for ocean dumping five years ago. So far, final
        actions have been taken for 89 sites (59% of the total proposed).

Final Environmental Impact Statement Issuance

The  EIS examines the effects ocean dumping would  have on the local marine environment.
Subsequently,  a determination is made whether ocean dumping is the recommended disposal option.

    o   Four Regions committed to issuing 12 final EISs for or^nn dumping sites in FY 1990.
        Through  the third quarter, Regions II, VI, and X completed  a total of eight final EISs,
        against a national target of eight.

Final Actions

Final actions tracked include proposed dredged material sites approved or disapproved  for
designation. These include  previously  designated dredged material sites cancelled or allowed to
expire.

    o   For FY  1990, three Regions committed to completing  12 site designations.  To  date,
        Regions II, VI, IX (not targeted), and X  made a total of eight site designations, against  a
        national target of six.

-------
                                           OCEAN DUMPING
                                         As of June 30, 1990
       COASTAL STATES WITH OCEAN DUMPING ZONE
   br iLuu I
                          (43) TOTAL SITES DESIGNATED *
                               * Data not complete
                         NATIONAL
WQ-1
PROPOSED  FNAL  DESIG- NTERM* LAPSED* TERMN-
  SITES   ACTIONS MATED*              ATED*
                                                         5

                                                         4

                                                         3

                                                         2

                                                         1

                                                         0
                                                4

                                                3

                                                2

                                                1


                                                0
                                                             FINAL EIS ISSUED
                                                            NAUONAL
                                                                  I   II   IV  V  VI  V»  VIII  IX  X
                                                                           REGIONS
                                                                                    TARGET
                                                                                    ACTUAL
                                                              FINAL ACTIONS
                                                                      NATIONAL
                                                                                           I
I   H  II   IV  V  VI  VK  VII  IX  X
            REGIONS
                                              -39-
                                                                                                        *,.

-------
                                                         WETLANDS

V'
                Wetlands Strategic Initiatives

                In recent years, EPA has been working to develop a more comprehensive and anticipatory approach
                to wetlands protection that complements the §404 dredge and fill program. Strategic initiatives are
                long-term, geographical^ focused protection efforts developed and carried out in conjunction with
                federal, state and local agencies.

                    o   The Regions committed to starting 13 strategic initiatives during FY 1990.  So far this  year,
                        15 wetland strategic initiatives have been started, against a  third quarter target of nine.
                        These  include:

                            Five advance identifications or special area management plans;
                        --   Four public education and agricultural community public outreach projects;
                            Three area-wide targeting/protection projects;
                            One wetlands mitigation bank for Superfund sites;
                            One wetlands restoration project; and
                            One area-wide enforcement initiative.

                    o   Beginning in FY 1986, 69 wetlands projects have  been started: 42 advanced identifications,
                        and 27 other strategic initiatives.  To date, 16 have been completed, including 10 advanced
                        identifications.  These have taken an average of two  and one-quarter years to complete.


                Wetlands §404 (Dredge and  FilH Enforcement Actions

                    o   To date, EPA issued 85 wetlands administrative orders including 10 for  penalties. Also,
                        EPA has referred 10 civil cases and five criminal  cases to DOJ, and resolved 162 cases.
                                                          -40-

-------
                                            WETLANDS
                                       As of June 30,  1990
          CUMULATIVE STRATEGIC INITIATIVES                     CUMULATIVE STRATEGIC INITIATIVES
    16
    12
     8
               75
                                                      50
                                                      25
         I   I

   LEGEND
5553 STARTED

•I COMPLETED
                   IV  V  VI  VI VIM IX  X
                     REGIONS
                   86

ADMWISTRATIVE ORDERS
     COMPLETED
                            150
                            100
                             50
WQ-2. WQ/E-1
      2       3
      QUARTERS
87
                                                                          o
88
89
   90
   (Q3)
 LEGEND
STARTED

COMPLETED
            LEGEND
   I    I AOs WITHOUT PENALTES
   •i AOs WITH PENALTES
                                                                                                    *
                                                                                                   < '*
                                            -41-

-------
•1
₯
                                                          -42-

-------
                           SURFACE WATER PROGRAMS
Water quality assessment, municipal pollution control grants, NPDES permit reissuance and
pretreatment programs are all designed to protect or improve the quality of our surface water.

      o     Water quality standards, planning and assessment programs provide oversight to
            States in their efforts.  These efforts include adoption of numeric criteria for
            toxic pollutants, evaluation of waterbodies to determine the need for an
            Individual Control Strategy, and establishment of Best Management Practices
            for controlling nonpoint source pollutants.

      o     Municipal pollution control programs are shifting their emphasis from
            construction grants to state revolving fund capitalization grants. Grant outlays
            and administrative completions for construction grant projects are tracked in this
            report, as is progress in awarding capitalization grants.

      o     NPDES permit activity reported in STARS includes permitting of major
            facilities, repermitting and permit modification with water quality based
            controls, and repermitting with Individual Control  Strategies. This year, permits
            to sludge producing facilities and permits for facilities discharging to near
            coastal waters are issued and tracked.  EPA and delegated states also report
            pretreatment auditing and inspection activity.
                                       -43-

-------
                    WATER QUALITY ASSESSMENT ACTIVITIES

Water quality standards, planning and assessment performance reporting in STARS is limited
in the third quarter to 304(1) listings.

304(1) Assessments

Section 304(1) of the Clean Water Act requires lists of waters where water quality cannot be
attained or maintained after compliance with technology based controls, pretreatment, and new
source performance standards.  The EPA deadline for final EPA approval was June 4, 1990.
      o     Through this quarter, of 56 states and territories targeted for Regional approval,
            44 states' lists were given final approval, for an overall performance of 79%.
            Regions V, IX and X failed to meet their targets. It is expected that all the states
            in Region V will have approved lists by the end of the fiscal year.

      o     Third quarter performance (17 states' lists approved) mirrors that of the second
            quarter (18 states' lists approved).

Numeric Criteria for Toxics

EPA must approve state adopted aquatic life and human health numeric criteria in order to
comply with Section 303(c)(2)(b) of the Clean Water Act, which is designed to address and
control toxic pollutants in surface waters. Progress in state adoptions are tracked in STARS
during the second and fourth quarters. As of June 31, 1990, only  ten states are in full
compliance.

-------
            WATER QUALITY ASSESSMENTS
                  As of June 30, 1990
                 STATUS OF 304(1) APPROVALS
FINAL REGIONAL APPROVAL COMPLETED
                                                  U.S. TERRITORIES
GUAM         t^J
VIRGIN ISLANDS  I  I
AMER. SAMOA   CD
N. MARIANNA    f""l
D.C.          CH
PUERTO RICO    I  I
                      -45-

-------
             MUNICIPAL POLLUTION CONTROL PROGRAMS

EPA continues to move toward increasing state flexibility in financing wastewater
treatment facilities and other water related projects.  Through the third quarter, 84% of
total outlays were for construction grants, and 16% were for state revolving funds.
Net Outlays: Construction Grants and State Revolving Fund

The Agency performance through the third quarter is comfortably within the target
window, at 97%. Five Regions are within  their target windows and only Region IX is
below 80% of the target.

State Revolving Fund Awards

To date, 43 states have established SRFs. Twenty states have received state revolving
fund awards through this year. The target through the third quarter was 36, so the
performance rate is now 55%. We did not award any first round grants this quarter.
Although these monies may be used for a variety of water projects, the current trend is
to finance wastewater treatment activities.

Construction Grants Administrative Completions

Administrative completions represent the stage in a project just prior to the final audit.
Third quarter performance is 84% of target, down from 91% in the second quarter;
this is a typical, however.  Regions I, HI and V were below 70% of target, and four
Regions met or exceeded targets. Region V continues to perform far below target.
                                       -4ft-

-------
                                MUNICIPAL POLLUTION CONTROL
                                      As of June 30, 1990
  120

  110
H
| 100


ft  «°
£  80

E  70
   60

   50
                 NET OUTLAYS
         FOR CONSTRUCTION GRANTS AND
            STATE REVOLVING FUNDS
                                      jlZUor-
5%
            II  IK  IV V VI VB VIII IX X NATIONAL
                                 PROGRAM
                         SRF AWARDS
                   FROM FY 1988 TO FY 1990
           NO AWARDS
           ONE GRANT AWARD
           TWO OR MORE GRANT AWARDS
WQ-8,9,10
             120
         g
                                      ADMINISTRATIVE COMPLETIONS
                                                                            578
         TARGET THIS QUARTER
         COMPLETED THIS QUARTER
                                       600
                                                                                    300
                                III    IV     V    VI
            UNIVERSE   80   109   165  153   226   108
                          X   3rd QUARTER

                         24     TOTAL
                                          -47-

-------
                         NPDES PERMIT PROGRAMS
Major Permits Reissued by EPA and Delegated States

States are responsible for the lion's share of permit reissuance, about 77% of the total.
State performance has fallen from 69% of target in the second quarter to 66% this
quarter. States in Region I reissued 22% of its target, and Region V States continue to
reissue less than 50%.  In Region X, State performance improved but is still below  60%
of target. This is attributable to continued poor performance in Oregon.  The forecast for
State performance through the end of the year is not encouraging.

The EPA reissuance rate is also falling this year.  In the third quarter, 166 permits were
reissued against a target of 220, or 75% of the target.  Region VI is the only Region to
meet or exceed its goal, having performed to 122% of target. In Regions I and IV,
performance is less than 60% of target. In Regions II, IX and X, performance is less than
30% of target. Some progress is expected  in the fourth quarter.

Evidentiary Hearings

States performance in resolving hearing requests for majors has improved from the
second quarter. In the third quarter, states resolved 29 requests against a  target of 33.
States in Regions I and III have not resolved any requests to date, although their end of
year targets are respectively 10. EPA performance is well above target, resolving 14
requests against a target of 7. Region VI resolved six requests this quarter, already
exceeding the end of year target of five.

-------
                   MAJOR PERMITS
                   REISSUED BY EPA
                                 NPDES PERMIT PROGRAM
                                   As of June 30, 1990
\£V
CO
i= 100

£ 80
u.
0 60
tc.
m 40
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^^
2 20




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MAJOR PERMITS REISSUED/MODIFIED
"12° FY 1990
100


,_
'-L' 7(%

X ' NATL. <


0 50
MAJOR PERMITS 2
REISSUED BY STATES
300
CO 250
H
i 200
LU
Q_
fe 160
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^ 50



—

_

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23
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80
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-•- STATES

iiii













1234
QUARTER
- 450


(23 TARGET
Iliiiljiij PERFORMANCE
X NATL .
NP-1
                       REGIONS
                                     -49-

-------
                       NPDES PERMIT PROGRAMS

Major and Minor Permits with Toxic Limits

STARS tracks the number of permits reissued or modified to limit priority toxic
pollutants from point sources.  EPA issued/modified 178 and the States
issued/modified 617 permits with water quality based limits by the third quarter.
EPA and the States issued 79 permits as Individual Control Strategies. There are no
targets for these activities, but the accomplishments here come at the expense of
major permit reissuance.  Generally, toxic limits permits are very  time consuming.
Performance by Region is illustrated on the next page.

Sludge Permits

These permits  implement EPA's interim permitting strategy for sludge use and
disposal pursuant to section 405(d)(4) of the Water Quality Act of 1987. Through
this quarter, 208  priority sludge facilities were permitted by EPA and states, well
over the target of 176. Regions II, III, IV, V, VI and VII exceeded targets.


Near Coastal Waters Permits

This quarter, EPA and the States issued 752 major and minor permits to facilities
discharging into  marine and estuarine waters.  These permits are designed to control
the discharge of harmful pollutants, including bioaccumulative and persistent
toxicants. There are no targets for this measure.
                                        -50-

-------
                                      NPDES PERMIT PROGRAM

                                         As of June 30, 1990
    CO
          100
          80
          60
          40
          20
—   17
                              TOXIC LIMITS PERMITS: EPA AND DELEGATED STATES
                           88
                                  12
                                       9
                                               65
                                                    69
                                                 18
                                                      6
                                                     LL
                                             n
                                                                   20
                                                                         49
                                                                              73
                                        IV
                                V      VI

                                 REGIONS
VI    VHI     IX
                                                                                23
NP-2
                             EPA REISSUED/MODFED WITH WATER QUALITY BASED LIMITS
                             STATE REISSUED/MODIFIED WITH WATER QUALfTY BASED LMTS
              STATE REISSUED AS INDIVIDUAL CONTROL STRATEGY
                                           -51-

-------

-------
                     PRETREATMENT  PROGRAMS

Pretreatment programs assure that POTWs implement and enforce controls needed
to protect human health and the environment from conventional and toxic pollutants
and hazardous wastes.  There are 1,428 POTWs with pretreatment programs. EPA
is responsible for 621 and delegated states for 810. To assure compliance in the
program, an audit or inspection is performed  every year.

Audits

Audit performance through the third quarter is well above expectations, with
EPA performing 89 against a target of 66,  and states completing 175 against a
target of 137.

Inspections

Inspections performance is also above target.  EPA  inspected 191 pretreatment
programs against a target of 180 and the States inspected 430 against a target of 414.
                                    -53-

-------
NPDES Inspections

    o   For coverage of major NPDES facilities, the Regions and States conducted 4,555 inspections
        against a third  quarter target of 4,445 for 102% of the aggregate national target. Four
        Regions (II, III, VI and VII) exceeded their target.  This year's annual inspection target is
        6,783 facilities.
NPDES Significant Noncompliance

    o   Of the 7,182 total major NPDES facilities, 817 (11%) were in SNC during the third quarter
        (up from 617 last quarter).  Regions IV, V and VI account for 88% of the increase (176 of
        200).

    o   Overall,  91% of major industrials are not in Significant  Noncompliance (SNC), compared to
        94% for the previous quarter. For major industrials, 3,051 of 3,244 facilities (94%) have
        achieved Final Effluent Limits (PEL).  Of 3,051 facilities on PEL, 278 (9%) are in SNC. Of
        193 facilities on Construction or Interim Effluent Limits (CS/IEL), 30 (16%) are in SNC.

    o   Overall,  86% of major municipals are not in SNC, compared to 90%  for the previous quarter
        .  For major municipals, 3,372 (89%) of 3,789 facilities  have now achieved PEL.  (For
        comparison in the fourth quarter of FY 1986, only 68% of major municipals had achieved
        PEL.) Of 3,372  facilities on PEL, 384 or 11% are in SNC.  Of 417 facilities on CS/IEL 140
        (34%) are in SNC.

    o   Overall,  90% of major federal facilities are  not in SNC  and represents no change from the
        previous quarter.  For major federal facilities, 137 (92%) of 149 facilities have achieved  PEL.
        Of 137 facilities on PEL, 13 (9%) are in SNC.  Of the  12 facilities on CS/IEL,  two (17%) are
        in SNC.
                                         -54-

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                       NPDES INSPECTIONS AND MAJORS COVERAGE
                                    As of June 30, 1990
 I   I TARGET (3Q)

 1H ACTUAL (3Q)


WQ/E-12
    18

    15

 O 12

 #  Q
     6

     3

     0


WQ/E-4.5
                               V   VI
                               REGIONS
                                        IX
                                                     NATIONAL
                                                      TOTAL
                           NPDES SIGNIFICANT NONCOMPLIANCE
                   INDUSTRIAL
                                                     MUNICIPAL
                                  O
                                  CO
I  I
IV
V VI VI VII IX
 REGIONS
NATIONAL
    24

    20

    16

    12
a«
     8

     4

     0

SNC CS/EL

SMC PEL
V VI  VI VH IX
 REGIONS
NATIONAL
                                        -55-

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Response to Significant Noncompliance Exceptions Report

    o   The percentage of major industrial, municipal and federal facilities in SNC for two or more
        consecutive quarters without being addressed or returned to compliance is at 2%.  There are
        39 facilities (15 industrial, 23  municipal and one Federal) that have been in SNC for a year
        or more without being addressed (compared to an average of 57 over the last 10 quarters).

        For major industrials,  of 42 facilities from last  quarter's exceptions list, 11 have returned to
        compliance (RTC) and 13 have enforcement actions initiated. The remaining 18 plus 30 new
        significant noncompliers on the exceptions report constitute the pending balance of 48.  One
        and a half percent of  the 3,244 major industrial  facilities are  pending on the exceptions
        report.

    --   For major municipals, of 102  facilities from last quarter's exceptions  list, 29  have returned to
        compliance and 26 have had enforcement actions initiated.  The remaining 47 plus 58 new
        significant noncompliers on the exceptions report constitute the pending balance of 105.
        About three percent of 3,789 major    municipal facilities are pending on the exceptions
        report.

    o   Of the five Federal facilities from the last quarter's exceptions list, two returned to
        compliance and two had enforcement actions initiated.  The remaining significant noncomplier
        plus six new significant noncompliers constitute the pending balance  of seven facilities.

-------
  16
  12 -
   8
                        RESPONSE TO SIGNIFICANT NONCOMPLIANCE
                                   EXCEPTIONS REPORT
                                    As of June 30, 1990
                MAJOR INDUSTRIALS                             MAJOR MUNICIPALS
                                                                          NATIONAL
        I   I  IB  IV  V  VI  VI V»  IX  X

                    REGIONS
I   I  I  IV   V  VI  VI  VM IX  X
            REGIONS
WQ/E-6.7
                                    I  I  RETURNED TO COMPLIANCE
                                    Y77\  ENFORCEMENT ACTION
                                    •I  UNADDRESSED
                                        -57-

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NPDES Enforcement Activity

    o   Through the third quarter, EPA issued 972 administrative orders compared to 1,071 through
        the third quarter of last year.  The total includes 86 orders for failure to implement a
        pretreatment program and 118 proposed penalty orders.  The states reported they have
        issued 689 orders through the third quarter (compared to 992 reported for the same period
        last year).  The total includes 67 penalty orders.

    o   This year,  the Regions  have  referred 21 NPDES civil cases to DOJ compared to 45 last year,
        plus one Pre-Referral Negotiations Case and ten consent decree enforcement cases.  The
        states  have referred 175 civil cases this year compared  to 291 and 426 over the same period
        the last two  years.

    o   The Regions have referred 24  Clean Water Act criminal cases (up from six at this time last
        year) and the states have filed have 43 criminal cases in state courts (122 last year).

    o   During FY 1990, EPA  has had 239 cases in the active civil docket (civil referrals to DOJ).
        As of  the end of the quarter, the  status of the 239 cases was: 85 cases were at DOJ, 101
        cases were filed by DOJ, 36  cases were concluded, and 17 cases are currently returned to the
        Region.  The states report an active civil docket  of 801 cases (including 495 in Region  V).

-------
                               NPDES ENFORCEMENT ACTIVITY
                                        CUMULATIVE
                                     As of June 30, 1990
              ADMINISTRATIVE ORDERS
                  IV  V   VI  VI  VII  IX  X

                     REGIONS
                                            50
                                            40
                                            30
                                            20 -
                                            10 -
CIVIL REFERRALS TO DOJ
   IV   V  VI   VI  VII  IX  X

      REGIONS
                                         /ZJ
                                            EPA
                                            STATES
WQ/E-8.9
                                        -59-

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-60-

-------
and Toxics

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              OFFICE OF PESTICIDES AND TOXIC SUBSTANCES
o  Highlights

o  Pesticides Program
       Establishment of Requirements in Data Call-ins
       Pesticide Special Reviews
       Pesticide Registration Applications
       Emergency Exemptions for Pesticides
       Pesticide Tolerance Petitions
       Regional Measures
       FIFRA Enforcement
o  Toxics Program
       New Chemical Reviews
       ASHAA Close-Outs
       EPCRA Outreach Initiatives
       Asbestos Accreditation Programs
       TSCA Enforcement
       EPCRA Enforcement
                                     -61-

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               OFFICE OF PESTICIDES AND TOXIC SUBSTANCES

                           THIRD QUARTER HIGHLIGHTS


o   OPTS requested a target change from 106 to 52 Data-Call-ins (DCIs) for List A chemicals
    for the remainder of the  fiscal year. To date, no list A chemical DCIs have been issued.
    OMB  approval has severely delayed the reregistration process for these high profile
    chemicals.

o   Three new Regional  measures:  Regions report  progress on state involvement  in the areas
    of worker protection, groundwater (pesticides), and endangered species. These measures will
    not be targeted due to delays in issuing final rules.

o   OPTS exceeded many of their Headquarter cumulative targets.  Targets were exceeded for:

    ~ New Active Ingredients (completed 9 against a target of 7)

       Old Chemicals (completed 1,272 against  a target of 1,050)

    --  Amendments (completed 2,844 against a target of 1,900)

       Tolerance Petitions (52 final decisions  made against a target of 40).
                                       -63-

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-------
                       OFFICE OF PESTICIDES PROGRAMS

            ESTABLISHMENT OF COMPREHENSIVE DATA REQUIREMENTS
                   IN DATA CALL-INS (REGISTRATION STANDARDS)
                                                                           «

In FY 1990, OPTS planned to establish 106 comprehensive data requirements in data call-ins.

   o   OPP did not address any List A chemicals in the third quarter, therefore, missing its third
       quarter target of twenty. Complete OMB approval has been obtained for six pesticide
       chemicals.

   o   OPP now expects to issue no more than 52 of the projected data call-ins.  This
       assumes more rapid OMB clearance, but would still leave the program far behind
       schedule in its review of List A chemicals.  Reregistration action lags several years
       from the point of data-call-in.
                                      -65-

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yy-

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                        PESTICIDES SPECIAL REVIEWS
A "Special Review" is a review of an active ingredient for which data indicate a potential for
unreasonable adverse effects to public health or the environment.

o   OPTS has completed four special review during the third quarter against a target of three.

REVIEW                TYPE OF DECISION    DECISION RESULTS
NRDC Petition
Response (revocation
of 11 food additive
tolerances subject to the
Delaney Clause)

Mercury
EBDCs
R-ll
Response to             Proposing revocation of
Revoking 409 Tolerances 4 of the 11. Denied petition
                        to revoke trifluralin food additive
                        tolerances for spearmint & peppermint oil
                        under "de minimis" exception.
Negotiated
Settlement
Proposed Tolerance
Revocation
Voluntary
Cancellation
Eliminated use of mercury compounds in
indoor latex paints (approximately 25 to
30% of interior use latex paints currently
contain mercury). Required warning labels
on all outdoor paints containing mercury.
Estimated 13 million people each year may
be exposed to mercury through painting;
about 3.3  million are under the age of 18.

Reduce/revoke tolerances for mancozeb,
maneb, and metiram in or on 56 RACs
covered by 45 pesticide registration.
(FR 55:20416)

205 products cancelled containing R-ll.
Adverse effect data [6(a)(2)J cited ovarian
atrophy and developmental effects.
                                       -67-

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                                   PESTICIDE REGISTRATION APPLICATIONS

               o   OPTS exceeded cumulative targets for the following categories during third quarter:

                   o   New Active Ingredients - 9 new chemicals were registered against a target of 7.

                   o   New Uses - 67 final decisions were made against a target of 40.

                   o   Amended Registrations - 2,844 final decisions have been made against a target of 1,900.

                   o   Old Chemicals  - 1,272 final decisions have been made against a target of 1050  this quarter.


               o   The pesticide registration application backlog decreased from 3,314 at the end of second quarter
                   to 3,003 third quarter.

                   There was a decrease for:

                           Old Chemicals              from   1,008    to   779
                           Amended Registrations      from   2,193    to  2,104
                           New Active Ingredients      from      4   to      2

                   There was an increase for:

                           New Uses                  from    109    to   118
V'

-------
                          PESTICIDE REGISTRATION APPLICATIONS
                                NUMBER OF FINAL DECISIONS
                                       (CUMULATIVE)
                                    As of June 30, 1990
      CO
      22
      O
      LU
      O
             ACTIVE INGREDIENT  NEW USES
                                               3000
                                               2500 -
                                               2000 -
1500 -
                                               1000 -
                                                500
P-4
                                          LEGEND

                                            TARGET

                                            ACTUAL
         AMENDED       OLD
       REGISTRATION   CHEMICALS
                                       -69-

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                   EMERGENCY EXEMPTIONS FOR PESTICIDES


An emergency exemption is granted by a Federal or State agency if EPA determines that emergency
conditions exist (e.g., pest outbreak is identified and no effective pesticide is registered for a
particular use).

o   OPTS made 231 final decisions, against a third quarter cumulative target of 260.

o   During the third quarter OPTS made 115 final decisions, against a target of 140.  Of these,
    85 exemptions were issued (forty-four granted to USDA) and 30 were denied.
                        PESTICIDE TOLERANCE PETITIONS

A tolerance petition decision applies to all requests for tolerance levels and exemptions from
requirement of a tolerance level for pesticide residues in or on raw agricultural commodities,
processed foods and minor uses.

o   OPTS made final decisions on 52 tolerance petitions, exceeding their third quarter cumulative
    target of 40.

o   During third quarter, OPTS made final decisions on 17 tolerance petitions, exceeding their
    target of 15.

-------
                        EMERGENCY EXEMPTIONS GRANTED
                              AS OF JUNE 30, 1990
                                        \   IOWA.
                                  NEBRASKA  \
                                         I  ' ..	/     i  IN
                                         \	   /ILLINOIS

                                          I
                                                                     PUERTO RICO

                                                                        3
EEG-1
                                    -71-

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                         PESTICIDE REGIONAL INITIATIVES

The Office of Pesticide Programs has initiated three new regional measures to address concerns
resulting from pesticide application.  Final publication of the Worker Protection Rule, the
Groundwater Management Strategy, and the Endangered Species Protection Program are pending.
Regions were  provided the option to report progress made third quarter in developing cooperation
with the States on these initiatives or report progress in the fourth quarter only.  Some of the
Regions have  progress to report.

Worker Protection

    The Regional Offices are to report initially on the number of States that have accepted
    worker protection cooperative agreement funds and identify the State agency responsible for
    outreach, education, and enforcement. These funds are to be used to establish an
    infrastructure to conduct outreach, education and enforcement  activities identified in the new
    rule.

Groundwater Protection

    The Regional Offices are to report initially on the number of States that have accepted
    cooperative agreement funds and on the number of States that have started to establish the
    infrastructure to map vulnerable areas,  monitor groundwater, coordinate a State  program,
    and prepare to implement a State Management Plan.

Endangered Species

    The Regional Offices are to report initially on the number of States with Cooperative
    Enforcement agreements that have accepted base endangered species funding, the number
    of these States  that are working on the establishment of an infrastructure  to respond public
    inquiries and coordinate the evaluation  of state habitat/range maps, the number of States
    working on state pesticide  management plans, and those States which are  currently engaged
    in  Federal endangered species pilot plans.

-------
                               PESTICIDE REGIONAL INITIATIVES

                         BASE FUNDING TO STATES & INDIAN TRIBES

                                     As of June 30, 1990
CO
ft
p
         CO


         <
         CO
         u_
         o
         DC
               30
               25
               20
      15
      10
                       WORKER PROTECTION    GROUNDWATER
                                             ENDANGERED SPECES
PRI-2
                            STATES
                                  INDIAN TREES
                                      -73-

-------
FIFRA Compliance Monitoring Inspections and Compliance Levels
(*NOTE:  State data are lagged one quarter.)

    o   In the second quarter of 1990, the States completed 12,630 FIFRA use and restricted  use
        pesticide dealer inspections, completing 194% of their state grant targets.  The States
        reported taking 3,909 enforcement actions in the second quarter representing a violation rate
        of 31%.for "use" inspections.  In the second quarter of 1989, the States completed 9,738
        inspections, with 3,395 enforcement actions taken and a violation rate of 31%.

    o   In the third quarter of FY 1990, Regions VII and VIII, with non-delegated programs,
        completed a total of 239 use and restricted use dealer inspections, achieving 99% of their
        targets.

Addressing FIFRA Significant Noncompliance

    o   Through the third quarter, the Regions referred 71 significant use violations to the States for
        investigation and enforcement action.  Skty-four were referred at the end  of the third quarter
        of FY 1989.

    o   The Regions  also identified 52 significant violator cases for EPA action.

FIFRA Enforcement Action

    o   The Regions  issued 190  administrative  complaints through the third quarter of FY 1990,
        compared to  227 a year ago.  Through the third quarter of FY 1990, three FIFRA civil cases
        were referred to DOJ and one FIFRA criminal case was referred.
                                         -74-

-------
      80
      60
      40
      20
                              FIFRA COMPLIANCE AND ENFORCEMENT
                                        As of March 31, 1990
                 •USE" INSPECTION LEVELS
               (DATA LAGGED ONE QUARTER)
             I   I
         •   IV  V  VI VI VI  IX  X
              REGIONS
        REFERRALS TO STATES
P/E-1.3.4
     1234
             QUARTERS
(32)  CH ADDRESSED WITHN TMEFRAME
(20)  K3 PENDNG WITHN TIMEFRAME
(19)  IZ2 ADDRESSED .BEYOND TMEFRAME
 (0)  • NOT ADDRESSED BEYOND TIMEFRAME
                                                        COMPLIANCE STATUS
                                              ~ - 125+

                                              - - TARGET

                                                 12,630 USE
                                                 NSPECTIONS
                                                 CONDUCTED
      (31%) • VIOLATION WITH ACTION TAKEN
      (69%) O NO ACTION WARRANTED OR
              COMPLIANCE DETERMNATION
              PENDNG.

EPA CASES AND REFERRALS FROM STATES
                                                 O
                                                          VIOLATION   PENDNQ    CASES    CASES
                                                          DETECTED ENFORCEMENT ADDRESSED  CLOSED
                                                                    ACTION
                                                           (52)       (11)      (41)     (11)
                                              -75-

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                          OFFICE OF TOXIC SUBSTANCES

                          TSCA NEW CHEMICAL REVIEWS

Manufacturers and importers of new chemical must give EPA notice a 90-day advance notification
or their intent to import or manufacture a new chemical.  OTS reviews all new chemicals, imposing
controls as necessary to reduce risk.

o   Valid New Chemical Notices Received - 1,037 new chemical notices have been received this
    quarter.

    --  Of the 1,037 notices received,  748 are Premanufacture Notices (PMNs).  289 were valid
       exemption notices (i.e., polymer exemptions, low volume exemptions, and test market
       exemption applications).

o   Control Actions - 37 control actions (action taken on new chemicals which  pose a threat to
    public health or the environment)  have been taken this quarter.  Five were PMNs which were
    withdrawn in face of regulatory action, 26 were PMNs with consent orders  issued, which includes
    one biotechnology PMN, four were exemptions which were denied, and 2 were modifications to
    biotechnology PMNs.

o   Notices of Commencement (NOG) - 251  NOCs have been received this quarter.
. '-

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                                   ASHAA CLOSE-OUT SITE EVALUATION

               The Asbestos School Hazard Abatement Act of 1984 (ASHAA) provides grants and loans to school
               districts for asbestos abatement.

               o  The Regional Offices are to conduct close-out site evaluation inspections of all outstanding
                  ASHAA awarded projects (i.e., all projects awarded ASHAA loan and grant money during
                  FY 86, 87, 88 or 89) by confirming that abatement assistance was actually disbursed to
                  designated school projects and that abatement work was accomplished.
                                    SITE-EVALUATIONS  COMPLETED

                  REGION         Ql        Q2       Q3
                  I
                   II
                   III

v'                 IV
;                  v
                   VI
                   VII
                   VIII
                   IX
                   X
32
4
5
16
12
5
22
13
1
0
32
6
8
22
21
5
36
32
5
2
111
6
10
24
7
21
37
37
12
2
                  TOTAL           110       169       267
                                                    -78-

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            EPCRA - NUMBER OF OUTREACH PRESENTATIONS
                              AND WORKSHOPS
     MADE TO GOVERNMENT AGENCIES AND THE GENERAL PUBLIC

The Regional Offices are to make presentations (e.g., speeches, discussions) to inform the audience
of any aspect of the Section 313 program, such as availability of the Toxic Release Inventory (TRI)
and how to access and use TRI.

o  During third quarter, the Regions made 78 presentations and conducted 34 workshops. The
   Regional breakdown is as follows:
                   PRESENTATIONS    WORKSHOPS
   REGIONS
   I
   II
   III
   IV
   V
   VI
   VII
   VIII
   IX
   X

   TOTAL
18
 6
 1
 0
 7
 0
38
 5
 0
 3

78
14
14
 0
 0
 1
 1
 1
 2
 0
 1

34
                                   _ 70 _

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   EPCRA - NUMBER OF TECHNICAL PRESENTATIONS AND OUTREACH

                 WORKSHOPS CONDUCTED FOR INDUSTRY

The Regions are to report quarterly on the number of technical presentations and outreach
workshops they conduct for the regulated community to inform the audience about Section 313 of
the Emergency Planning/Community Right to Know Act (EPCRA).

o  During third quarter, the Regional Offices made 73 presentations and conducted 74 workshops.
   The breakdown by Region is as follows:
                   PRESENTATIONS    WORKSHOPS
   REGIONS
   I
   II
   III
   IV
   V
   VI
   VII
   VIII
   IX
   X

   TOTAL
 8
 9
 2
 0
 7
 0
35
 5
 1
 6

73
14
 8
12
 0
 6
19
 4
 5
 4
 6

74
                                   -80-

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 I
00

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                            PUBLIC ACCESS TO SECTION 313
                        TOXIC RELEASE INVENTORY (TRI) DATA

 OTS reports quarterly on how data collected under Section 313 of the Emergency Planning and
 Community Right-to-Know Act (as referred to as Title III of the Superfund Amendments) are
 disseminated to the general public.

 EPA has selected the National  Library of Medicine's TOXNET automated database system as the
 method for online access to TRI data.  In  addition, EPA has decided to produce and market the
 TRI data via computer tapes, compact disks (CD-ROM), microfiche, and computer diskettes. The
 data are also provided to the public at the Title III Reporting  Center.
                      1st Quarter   2nd Quarter    3rd Quarter
                                                           l
 Number of Computer     1,374
    search hours
            1,174
               1,470
 TRI products sold
     Magnetic tapes
     PC Diskettes
     Microfiche
     Compact disks
     National Report

 Reporting Center
     Phone Request
     Walk-In  Request
   62
  128
12,0832
    0
  139
    8
 23
 77
 30
924
 414
404
  9
  5
 20
 10
 20
200
503
 10
Estimated  totals

Represents Fiche distributed.   Totals in  Q2, Q3,  and Q4 will  represent
 Fiche sold.
                                        -82-

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                              DISSEMINATION OF SECTION 313
           TOXIC RELEASE DATA (TRI) INVENTORY DATA TO THE GENERAL PUBLIC
                                    As of June 30, 1990
 14000

 12000

 10000

  8000

  6000

  4000

  2000

    0
FIRST QUARTER
SECOND QUARTER
THIRD QUARTER
                      B
  A—NUMBER OF COMPUTER SEARCH HOURS USED
  B--NUMBER OF TRI PRODUCTS SOLD/DISTRBUTED
    (MAGNETIC TAPES. PC DISKETTES, AND MICROFICHE)
  C—NUMBER OF INFORMATION REQUESTS REPORTED AT THE
    TITLE III REPORTING CENTER (PHONE AND WALK-INS)
TRI PRODUCTS SOLD
   CUMULATIVE
TRI-1
                                       MAGNETIC TAPES
                                       PC DISKETTES
                                       MICROFICHE
                                       COMPACT DISKS
                                       TRI NATIONAL REPORT
                                        -83-

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                    ASBESTOS ACCREDITATION PROGRAM

The Regions are to report on the number of course audits performed for full approval of asbestos
training courses which had previously been granted contingent approval and the number of refresher
courses that have been audited in a quarter.  Regional representatives must determine that the
course meets the criteria set forth in the EPA Model Accreditation Plan.

o  During third quarter Regions conducted the following audits:
   REGION
   I
   II
   III
   IV
   V
   VI
   VII
   VIII
   IX
   X

   TOTAL
                      AUDITS FOR
                    CONTINGENTLY
                       APPROVED
                         COURSES
  7
 42
 10
 13
  5
 17
  7
 17
  0
  4

122
                   AUDITS FOR
                   REFRESHER
                   COURSES
 2
11
11
23
 2
12
13
 6
 5
12

97
                                     -84-

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 I
in
oo
 i

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      APPROVED STATE OR TERRITORY ASBESTOS ACCREDITATION

                                   PROGRAMS

The Regions are to report on the status of State programs for each of the disciplines (i.e.,worker,
contractor/supervisor, inspector/management, and project designer).

o  During third quarter, the States conducted 59 asbestos training courses as follows:
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Worker
2
4
2
0
3
1
3
6
23
2
Contractor/
Supervisor
2
6
2
0
1
1
3
0
21
2
Inspector/
Management
2
6
1
0
1
0
2
0
29
3
Project
Designer
2
3
1
0
0
0
2
0
1
1
TOTAL          46        38             44               10
                                     -86-

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                                 EPA APPROVED
                   STATE ASBESTOS ACCREDITATION PROGRAMS
                                As of June 30, 1990
                         EZ3 PARTIALLY APPROVED PROGRAMS
                         YZA FULLY APPROVED PROGRAMS
AAP-1
                                  -87-

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TSCA Inspections and Compliance Levels

    o   The Regions and Headquarters completed 97% of their third quarter target for TSCA
        compliance inspections.  They conducted 1,230 inspections versus a target of 1,268.  States
        with inspection grants conducted 1,514 inspections, or 96% of the States' third quarter target.
        Of the total 2,744 inspections completed during the third  quarter, 968 (35%) were in
        compliance, 1,314 (48%) were pending a compliance determination, and 462 (17%) were i-n
        violation.  The number of initial EPA Regional  and  state  grant inspections conducted for
        PCB disposal facilities was 53,  or 113% of the third  quarter target. Initial  inspections
        conducted for broker/storage facilities total 91,  or 114% of the  third quarter target (only
        initial inspections are targeted).

Response to TSCA Significant Noncompliance

    o   At the beginning of the year, the Regions had 732 SNC cases on the fixed base.  Of this
        total, 532 are pending issuance of enforcement action and 200 are opened  (issued but not
        closed). At the end of the third quarter, 105 SNC and 226 Non-SNC pending cases were
        issued and  122 SNC cases were closed. Through the third quarter of FY  1990, the Regions
        identified 38 new significant violators based on  FY 1990 inspections. Seventeen cases were
        issued within 180 days of inspection.

    o   For Federal facilities, 38 TSCA SNC cases were identified at the BOY.  Of the total, 22 were
        open (issued but not closed) and 16 are pending enforcement actions.  At  the end of the
        third quarter, 12 SNC and no Non-SNC pending cases were issued and  17  SNC Cases were
        closed. The Regions did not identify any new significant violators through  the third quarter
        based on FY  1990 inspections.

TSCA Enforcement Activity

    o   Through the third quarter, the Regions issued 339 administrative complaints compare to 346
        a year  ago. Four TSCA civil cases were referred to DOJ and three criminal cases were
        referred.

-------
                            TSCA COMPLIANCE AND ENFORCEMENT
                                       As of June 30, 1990
        TSCA FEDERAL AND STATE INSPECTIONS
                                     PCB NSPECTIONS
i£a
TARGET 100
&< 75
^_
O pc gQ
lu t*
3 25
n





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                  IV  V VI VI VII IX  X HQ
                               I   I   i  IV  V  VI VI VI IX  X
                   750
                   600

                   450
                     REGIONS
                          TSCA SK3NFICANT VIOLATORS FIXED BASE
                                  (PRE FY 1990 CASES)
                                         REGIONS
                                        • PCB DISPOSAL FACUTY

                                        22 PCB BROKER/STORAGE FACUTY
T/E-1.3.6
 BOY    OPEN  PENDING PENDNQ PENDING  CASES
TOTAL               SNC  NON-SNC CLOSED
                  CASES  CASES
                  ISSUED  ISSUED
                                            -89-

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EPCRA Inspections and Compliance Levels

    o  At the end of the third quarter of FY 1990, the Regions completed 566 EPCRA inspections
       or 112% of their target.  Of the total 566 completed inspections this quarter, 202 (36%) were
       in compliance, 239 (42%) were pending a compliance determination, and 125 (22%) were in
       violation.

Response  to EPCRA Significant Noncompliance

    o  At the beginning of the year, the Regions had 231 significant noncomplier cases on the fixed
       base. This total includes 82 open cases  (issued but not closed) and 149 pending issuance of
       enforcement action.  At the end of the third quarter, 89 SNC and 6 Non-SNC cases were
       issued.  Forty-seven SNC cases were  closed.

    o  Through the third quarter, the Regions identified 99 new significant violators based on FY
       1990 inspections.  Twenty cases were issued within 180 days of inspection.

EPCRA Enforcement Activity

    o  Through the third quarter of FY 1990, the Regions issued 136 administrative complaints.  No
       civil referrals have been issued this fiscal year.

-------
     125
     100
  5
  5   75
     50
     25
      0
                             EPCRA COMPLIANCE AND ENFORCEMENT
                                        As of June 30, 1990
               EPCRA FEDERAL INSPECTIONS
                     IV  V  VI  VI  VII  IX   X
                        REGIONS
  250

  225

  200

to 175

O 150

*125

  100

   75

   50

   25

    0
          SIGNIFICANT VIOLATORS FIXED BASED
                (PRE FY 1990 CASES)
        TOTAL OPEN PENDNG PENDNG PENDING CASES
         BOY              SNC  NON-SNC CLOSED
                         CASES  CASES
                         ISSUED  ISSUED
E/E-1-3
                                            -91-

-------

-------
emergency Response

-------

-------
         OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
o  Highlights

o  Superfund
   --  Remedial and Removal Program
   ~  Enforcement

o  Chemical Emergency Preparedness and Prevention
   —  Preparedness and Prevention
   ~  Enforcement

o  RCRA
   --  Land Disposal
   ~  Incinerators
   --  Storage and Treatment
   ~  Corrective Action
   --  Regional Initiatives
   ~  Enforcement

o  Office of Underground Storage Tanks
   --  State Program Approvals
   --  Leaking Underground Storage Tanks
                                  -93-

-------

-------
           OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE

                           THIRD QUARTER HIGHLIGHTS

Superfund
--   The Regions exceeded their targets for Site Investigations and Completion of Remediation.

--   The Regions missed their targets for  RODs, completing 41 (35% of target), and for Remedial
    Design and Remedial Action starts.

—   The Regions exceeded their targets for RD/RA Unilateral Administrative Orders, but fell short
    of their targets for §107 referrals.  OSWER reported over $27 million in cost recovery, a three-
    fold increase over second quarter.  There were 23 interagency agreements signed at NPL federal
    facilities.
CEPP
--   Regions continue to substantially exceeded their targets for technical assistance and emergency
    simulations.  Most Title III violators continue to return to compliance without formal
    enforcement actions.

RCRA
--   The Regions continue to exceed the targets for all permitting and closure measures.

~   The Regions completed 120 RCRA final permit determinations through third quarter. A total
    of 185 RCRA facility closure plans were approved through third quarter.

UST
~   LUST cleanups initiated, releases under control, and cleanups completed are increasing, and
    continue to be paid for by the responsible parties (over 95% in all stages).

-------
                            THE  SUPERFUND PROGRAM

                                       OVERVIEW

o   The Superfund Program addresses the government's response to:

       Hazardous substance releases or substantial threat of release into the environment, and;
       Pollutant or contaminant releases of substantial threat of release which may present an
       imminent or substantial  danger to the public health or welfare.

o   The Superfund Program encompasses several major areas of activity:  Remedial actions,
    Removal actions, Enforcement, and Chemical Emergency Preparedness and Prevention (CEPP).
    The programmatic activity status,  as it is tracked in STARS, will be discussed in this report by
    each  of these areas.


                                REMEDIAL PROGRAM

o   The remedial program can be divided into three activity stages:  Pre-Remedial Investigation,
    Remedial Alternatives Evaluation, and Remedial Action Implementation, shown on the adjoining
    chart. These three stages track a Superfund site from discovery through cleanup.  The activities
    comprising the Remedial process are detailed under each stage.  Most of these activities are
    tracked in STARS.

o   Each of these stages will be  presented in more detail  in the  following pages.

o   As each is presented, information from the handbook, "CERCLA Orientation: Superfund;  What
    it is, How it works" will be used to describe and define activities.
                                        -96-

-------
**
          The  Superfund Remedial Program  in Perspective
     Pfe-Remedial
     Investigation
Site Discovery

:: Notification  :
    1
  Prefiminary
 Assessment
         National
         Priority
         Listing
                             Remedial
                           Alternatives
                            Evaluation
** Removal activities can be initiated at any stage in the remedial program.

II Activity is tracked in STARS
   Remedial
    Action
Implementation
                                                                   Remecial
                                                                     I
                                                                   Remedial
                                                                    Action
                                                                     i
                                                                  Operation and
                                                                  Maintenance
                                                                     i
                                                                  Post-Closure
                                                                   Monitoring
                              -97-

-------
                         REMEDIAL PROGRAM OVERVIEW
o   Using STARS data from the third quarter of FY 1990, the adjoining chart shows a national
    performance summary toward the major stages in the Superfund Remedial Program "pipeline."

o   While the comparison between progress at certain stages in the pipeline is not appropriate, this
    diagram does indicate areas where progress is slow.  These slow stages may ultimately cause a
    backlog as more sites move through the earlier stages of the pipeline.

o   Through third quarter each remedial stage shows varying progress.  Most stages of the remedial
    process have been substantially below target  through several consecutive quarters.  From second
    to third quarter, performance through the pipeline remained  roughly constant, except for the
    large number of remediations completed, 11  of which were in Region IV.
                                       -QR_

-------
                              SUPERFUND REMEDIAL PROGRAM
                             NATIONAL PERFORMANCE PROFILE
                                     As of June 30, 1990
DC
<
o
£
Q_
   200

   180

   160
   140   —
120

100

 80

 60

 40

 20

  0
            SI
          COMP
                    REMOVAL
                   ACTION AND
                     RI/FS
                    START*
 REMEDES
AT NPL SITES
  (RODs)
FIRST
 RD
 FIRST
  RA
STARTS
                                        REMEDIAL ACTIVITY
                      PERFORMANCE / TARGET = PERCENT OF 3rd QUARTER TARGET
                       *COMBINED IN FY 1990 TO INDICATE GENERAL ACTIVITY AT SITES
COMPLETION
  OF ALL
REMEDIATION
                                                                             CURRENT QUARTER

                                                                          ^ LAST QUARTER
                                                                          • - - ONE YEAR AGO
                                         -99-

-------
Program Progress as
 of June 30. 1990
   Site Discovery
        or
    Notification:

    32.923 sites
       T
    Preliminary
    Assessment:

    30.303 sites
       Site
     Inspection:

    12.221 sites
       MRS
     Scoring:
    2,257 sites
      National
      Priority
      Listing:

     1.218 sites
                                     SUPERFUND PRE-REMEDIAL INVESTIGATIONS
Site Inspections


o   A  site inspection (SI) characterizes the problem at a potential Superfund site to determine
    what, if any, further action is necessary. A site inspection occurs after the initial site
    discovery and notification to EPA, and after being screened by a Preliminary Assessment.


o   In  third quarter, the  Regions completed 1,471 Sis, exceeding the target of 1,093.


o   As of June 30,  1990, the Regions have conducted 30,303 Preliminary Assessments,
    representing 92% of those facilities discovered  and reported to EPA. The Regions have
    conducted 12,221, 40% of all sites that have had a PA. The investigations of 14,450 sites
    have shown that no further action is required.


o   To date, 2,257 sites have been scored  by the Hazard Ranking System, 328 of which have
    been scored in  FY 1990.  There are 1,218 sites currently on the NPL or are proposed for
    the NPL.  Federal facilities account for 6% of  the NPL sites to  date.
                                                          -1UO-

-------
                               PRE-REMEDIAL SUPERFUND
                                   As of June 30, 1990
                            SITE INSPECTIONS
S/F-1.2
I   IV   V   VI   VII  VII  IX   X

      REGIONS

TARGET FOR 3rd QUARTER
 ACTUAL 3rd QUARTER
 ACTUAL 2nd QUARTER
 ACTUAL 1st QUARTER
                                                                 2000
                                                                      NATIONAL
                                                                 1000
                                                                     FY89 FY90
                                                                     Q1-Q4 Q1-Q3
                                                                  	NATIONAL TARGET
                                     -101-

-------
Program Progress as
  of June 30, 1990
     Remedial
    Investigation
       and
     Feasibility
      Study:
    1.112 sites
       1
    Record of
     Decision:
     491 sites
                  REMEDIAL ALTERNATIVES EVALUATION

Site Activity Starts

o   Although the Remedial Investigation and the Feasibility Study (RI/FS) have different
    purposes, the former being to define the extent of the problem and the latter being to
    develop and evaluate remedial alternatives, they are often performed concurrently.

o   The Superfund Removal Program involves short-term  actions taken to prevent or mitigate
    significant risk to human health, welfare, or to the environment.  Situations which warrant
    an immediate removal action may include: drinking water contamination, human health
    and animal food chain exposure,  fire/explosion threat, or other acute situations.

o   STARS tracks a combination of RI/FS and removal starts at NPL sites, even though
    removal actions are not exclusive to NPL sites. The Regions addressed 69 sites in  third
    quarter, against  a target of 93.

o   In  Superfund to date, 2,360 sites  have had removal or remedial activities started, and of
    these, 984, or 42%, included PRP (potentially responsible party) financing. Sixty-eight
    sites were federal facilities.
                    Records Of Decision  (RODs)

                    o   The Record of Decision document provides the basis for the remedial decision and
                        describes the selected remedy.

                    o   In third quarter,  41 RODs were signed at NPL sites, for 35% of the target of 117.  All of
                        these sites were the result of fund-lead RI/FS.

                    o   Remedies have been selected at 491 NPL sites (19 of which were No Action  Alternatives)
                        through June 30, 1990.
                                                       -IU2-

-------
                  SUPERFUND REMEDIAL ALTERNATIVE DEVELOPMENT
                                  As of June 30,  1990
       NPL SITES WITH REMOVAL ACTION
              OR RI/FS START
25
20
15
10
          \  K
  I   I   I
J   ^
        x\
/o
            '«
                  I   '--
      i   y
IV  V  VI  VII  VIII IX  X
                 REGIONS
                              REMEDIES SELECTED AT NPL SITES (RODs)
                          30


                          25


                          20


                          15


                          10


                           5


                           0
                                              Ll
                                            	I
                                              IvXI
                                   I   U
 S/C-2
              	TARGET FOR 3rd QUARTER
              ^^^\l THIRD QUARTER
              VTA SECOND QUARTER
              I   | FIRST QUARTER

                             S/C-3
                                                          \\
                                            '/
                                                       1—(^
                                                             l-'~\
f\X1
[yq
                                                  IV  V  VI  VII VIII  IX  X
                                                    REGIONS
                                                                    NATIONAL
                                                                      RODs
                                                                    200

                                                                    150

                                                                    100

                                                                    50

                                                                     0
                                                                                  FY89 FY90
                                                                                  Q1-Q4  Q1-Q3
                                                                                	NATIONAL TARGET

-------
                                       REMEDIAL ACTION IMPLEMENTATION
Program Progress as
  of June 30,1990    Remedial Design Activity
     Remedal
      Design:
     420 sites
       I
     Remedial
      Action:
     282 sites
   Operation and
    Maintenance
    Post-Closure
     Monitoring
     Completion
   of Remediation
    or Removal:
      53 sites
o   The remedial design is the detailed plan for conducting the remedial action.  STARS
    tracks funding or PRP contract awards for remedial design activity starts.

o   The Regions initiated remedial design activity at 60 NPL sites, missing their third quarter
    target of 106. As of June 30, 1990, remedial design activity had been initiated at 420 NPL
    sites.
Remedial Action Activity

o   The Regions initiated 34 remedial action starts in third quarter, of the target of 45. Of
    these, 22 were PRP-financed and 12 were fund-financed.  As of June 30, 1990, there were
    282 NPL sites with remedies implemented or in progress.  Of these 282, 146 or 52% were
    fund-financed.

o   Remedial Implementation was completed at 14 sites in third quarter, of seven sites
    targeted for completion.  As of June 30,  1990, 53 NPL sites had been cleaned up.  One
    year ago, 41  sites had been  cleaned up.

o   Post-closure monitoring provides the remedy verification needed to delete a site from the
    NPL.  There was one site deleted from the NPL in third quarter, and 29 sites have been
    deleted from the NPL to date.

-------
                     REMEDIAL IMPLEMENTATION AT NPL SITES
                                 As of June 30, 1990
          REMEDIAL DESIGN STARTS
                                       REMEDIAL ACTION STARTS
ou
25
20
15

10
5



" r* 'i
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i i i
- ' -\ i i
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          I   III  \V  V  V\  VII  VIII  IX  X
                  REGIONS
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'// i\V 	
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INN
                                    I   II
IV  V  VI  VII  VIII IX  X
  REGIONS
                           COMPLETION OF REMEDIATION
12


 9


 6


 3


                                                                   TARGET FOR 3rd QUARTER
                                                                   ACTUAL 3rd QUARTER

                                                                   ACTUAL 2nd QUARTER

                                                                   ACTUAL 1st QUARTER
S/C-4, 5, 6
      I   II   III  \M  V  VI VII VIII  \X  X
                REGIONS
                                      -105-

-------
Supert'und Enforcement

    o   Enforcement cases under CERCLA may he brought under Section 106 (ordering cleanup to
        be performed by PRPs), Section 107 (cost recovery from PRPs where EPA has performed
        the cleanup by use of the Fund), or a combination of both, such as where EPA has spent
        money on the site which it wants to recoup under Section 107, but also wants to require the
        PRPs to perform remaining work under Section 106.

    o   During the first three quarters of FY  1990, there were 29 Section 107 cost recovery site
        referrals to OE or DOJ for pre-remedial action (against a target of 35).  There were three
        Section 107 cost recovery site referrals for remedial action (against a target of 16), bringing
        the total number of cost recovery site referrals (greater than or equal to $200,000) to 32
        against a target of 51.

    o   In the OE Docket, the total number of CERCLA Section 107 cost recovery referrals to DOJ,
        including those less than $200,000 and/or those involving proof of claim bankruptcy issues,
        was 43 for the first three quarters. The  total number of CERCLA referrals was 82 compared
        to 74 for the same period last year.

    o   The Regions had 38 Section 106 referrals for RD/RA with settlement (against a target of 54)
        and 26 sites were issued unilateral administrative orders for RD/RA (against a target of 21).
        There were no Section 106 referrals without settlement (against a target of two).  In FY
        1989, there were a total of 22 Section 106 cases referred during the first three quarters.

    o   The Regions issued 78 Section 106 removal orders (20 NPL/58 Non-NPL) during the first
        three quarters compared to 67 (22 NPL/45  Non-NPL) in the first three quarters of FY 1989.

    o   There were 23 Interagency Agreements  signed (against a target of 42) at NPL or proposed
        NPL federal  facilities for RI, FS, RD, RA or RD/RA. Regions IV and X had seven
        agreements each.

-------
             SECTION 107
       COST RECOVERY REFERRALS
             (CUMULATIVE)
                          SUPERFUND ENFORCEMENT
                              As of June 30, 1990
IO
15
12

9

6
3
n

-
-

-
— — -v
— ^^ _ I


° I II II






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//
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//
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'/A HTTl Y// 17^/1771
\/ V\ VI VU IX X
REGIONS
                                         18
                                         15
                                         12
                                          9
                                          6
                                          3
                                          0
                    12
                    10
                     8
                     6
                     4
                                   SECTION 106
                                  CIVIL REFERRALS
                                   (CUMULATIVE)
    \\
    I
I-J
                                 SECTION 106
                               REMOVAL ORDERS
                                 (CUMULATIVE)
                                 IV  V  VI  VI  Vi  IX  X
                                   REGIONS
                                     	CUMULATIVE TARGET
                                        CUMULATIVE ACTUAL
S/E-1(a)
            IV  V  VI  VI  VII  IX  X
              REGIONS
                                 -107-

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         CHEMICAL EMERGENCY  PREPAREDNESS AND PREVENTION
Preparedness Program

The CEPP program goals are to reduce chemical accidents by promoting community awareness of
chemical hazards, and to assist states, localities, and private sector organizations to prevent and
respond to chemical accidents.  CEPP is authorized under Title HI of SARA.

o   Simulations are table-top or full-field exercises conducted to evaluate a contingency plan.  In
    third quarter, the Regions assisted with or participated in 99 test exercises, against a target
    of 42.

o   Technical assistance is the provision of expertise by EPA to improve preparedness and
    prevention capabilities and programs. The Regions provided  technical assistance in 484
    instances, exceeding a third  quarter target of 308.
Prevention Program

The CEPP Accidental Release Information Program (ARIP) focuses management attention on
facilities with repeated or "serious" chemical releases, and provides EPA with detailed information
on the causes and the activities undertaken to prevent subsequent releases.  Chemical safety audits
are on-site inspections of the handling and process operations at facilities.  ARIP activities combine
the authorities of CERCLA, SARA,  RCRA, the Clean Air Act, and the Clean  Water Act.

o   During third quarter, Regions sent 293 ARIP questionnaires to facilities with releases. EPA will
    share  the ARIP information with national, state, and local organizations.

o   Thirty on-site chemical safety audits were conducted by the  Regions, of the third quarter target
    of 29.
                                       108-

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  CHEMICAL EMERGENCY PREPAREDNESS AND PREVENTION
                           ENFORCEMENT
                        As of June 30,  1990
                           ADMINISTRATIVE ORDERS
    6
    2


    0
                            IV     V    VI
                                REGION
VI   VII
IX
                              NATIONAL
                               TOTALS
                            30

                            20

                            10

                             0
                              THIRD QUARTER
                              FIRST QUARTER
The enforcement program seeks to identify violators of SARA (§302, 303, 304, 311, and 312), issue
enforcement actions if necessary such as administrative or state orders, and return violators to
compliance.

Investigation activities of potential violations (chemical releases  or administrative) varies greatly
between the Regions and includes on-site inspections, use of CERCLA §104 and ARIP letters, and
cooperation with state and local enforcement counterparts. Activities reported may include state
activity.

Of 1,030 investigations of potential violations in third quarter, 882 were in Region IV.  Of the 1,030
potential violations, 48 violations were identified (13 were identified in Region V).  There were 650
violators (592 in Region VII) returned to compliance without formal enforcement actions, and seven
(four in Region III) returned with formal actions.

In third quarter, the Regions issued 24 administrative orders in  response to violations identified under
CERCLA and EPCRA.   Proposed  penalties resulting from these actions  total over  $2 million.
                                -109-

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                                          THE RCRA PROGRAM
                                      LAND DISPOSAL FACILITIES

As of June 30, 1990 the land disposal facility (LDF) universe numbered 1,510.  Of these facilities, 162 LDFs were on the
permit track, 988 were on the closure track,  114 were on both tracks, and 246 LDFs were not classifiable.

Permitting Track
                     *
      o  As of June 30, 1990, 93% or 256 of the 276 facilities on the permitting track (including those facilities on both
         tracks) have been determined.  Twenty LDFs have yet to be determined.

      o  There are no targeted LDF measures for facilities on the permit track. There were ten draft RCRA permits
         issued and ten final RCRA permit determinations through third quarter.

Closure Track

      o  Of the 1,102 land disposal facilities on the closure track as of June 30, 1990, (including those
         facilities on both tracks) 823 have  approved closure plans.

      o  The Regions approved 53 land disposal facility closure plans through the third quarter, the third quarter target
         for this measure was 37.

      o  The Regions have issued 17 LDF post-closure permits through third quarter.
                                                  -110-

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     120
     100
      80 -
      60 -
      40 -
      20  -
                                      LAND DISPOSAL FACILITIES
                                          As of June 30, 1990
                FINAL PERMIT DETERMINATIONS
                     (PROGRAM TO DATE)
I   II   III  IV   V  VI   VII  VHI  IX  X

             REGIONS

 NUMBER WITHOUT FINAL DETERMINATIONS

 NUMBER OF PERMITS DENIED

 NUMBER OF PERMITS ISSUED
                                                    CLOSURE PLANS APPROVED
                                        20
                                                     15 -
                                        10  -
                                                      5 -
                                                            I   II   III   IV   V   VI  VII  VIII  IX  X

                                                                         REGIONS

                                                            [ZZ! NUMBER OF CLOSURE PLANS APPROVED

                                                            	TARGET FOR 3rd QUARTER
R/C-1(D&E)
                                         R/C-1(F)
                                            -111-

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                                               INCINERATORS

As of June 30, 1990, the incinerator universe, which includes both stand alone incinerators and incinerators at disposal
facilities, numbered 342. Of these facilities, 195 incinerators were on the permit track, 89 were on the closure track, 10
were on both tracks, and 58 were not classified as being on either track.

Permitting Track

      o  Of the 205 facilities on the permitting track (including those facilities on both tracks), 79% or 162  have been
         determined as of June 30, 1990. This leaves 43 facilities to be determined .

      o  The Regions have made 38 final permit determinations through the third quarter. This performance exceeds
         the third quarter target of 25.  Of the 38 determinations, 33 resulted in issued permits and five have been
         denied.

      o  In addition, seven draft permits and one notice of intent to deny have been issued through third quarter.

Closure Track

      o  Of the 99 incinerators on the closure track as of June 30, 1990 (including those facilities on both tracks), 57
         have approved closure plans.

      o  Through the third quarter, the Regions have approved 16 incinerator closure plans, exceeding the target of
         nine.

      o  The Regions issued nine notices of incinerator closure plan availability through third quarter.  There were no
         incinerator post-closure permits issued during third quarter.
                                                      -IT?-

-------
     20
     15
     10
                              INCINERATOR DATA TRACKED IN STARS
                                         As of June 30, 1990
                                                                                       *
                                                                                       i.
              FINAL PERMIT DETERMINATIONS
                                    NATIONAL
                                      3rdQ
                                      1990

I   H
                     IV  V   VI  VII  VII  IX  X

                       REGIONS
                  NUMBER OF PERMITS DENIED
              ES3 NUMBER OF PERMITS ISSUED
              ---- TARGET FOR 3rd QUARTER
R/C-1(D&E)
                                       10
                                                   8
                                                  CLOSURE PLANS APPROVED
                                                                       NATOMAL
                                                                   20

                                                                   15

                                                                   10

                                                                    5

                                                                    0
                                                                         3rdQ
                                                                         1990
                                             I    II   III  IV  V   VI  VII  VII  IX   X

                                                          REGIONS


                                             Y7A NUMBER OF CLOSURE PLANS APPROVED
                                             	 TARGET FOR 3rd QUARTER
                                       R/C-1(F)
                                            -113-

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                                 STORAGE AND TREATMENT FACILITIES

As of June 30, 1990, the storage and treatment (S/T) facility universe, which includes only facilities without disposal or
incineration processes, numbered 2,802.  This universe was comprised of 1,641 S/T facilities on the permit track, 493
facilities on the closure track and 958 facilities that have not submitted a permit application or closure plan. Regions and
States are  working toward the November 8, 1992 storage and treatment facility permit determination statutory deadline.

Permitting Track

      o   As of June 30, 1990, 673  S/T facilities or 39% of the permit track facilities had received final permit
          determinations.

      o   The Regions made 72 final storage and treatment facility permit determinations, through the third quarter,
          exceeding the target of 62.  Of these 72 determinations, 65  resulted in issued permits and seven permits were
          denied.

      o   The Regions also issued 67 draft permits and seven notices  of intent to deny a permit.

Closure Track

      o   Of the 493 storage and treatment facilities  on the closure track, as of June 30, 1990, 343 have approved
          closure plans.

      o   The Regions approved  116 storage and treatment facility closure plans and issued 73 notices of closure plan
          availability through the third quarter.  There were no post-closure permits  issued during third quarter.

-------
   30
   25 -
   20 -
   15 -
   10 -
    5 -
    0
                              STORAGE AND TREATMENT FACILITIES
                                        As of June 30, 1990
             FINAL PERMIT DETERMINATIONS
R/C-1(D&E)
         I    I   II  IV   V  VI  VII  VI  IX   X

                      REGIONS

           EZl NUMBER OF PERMITS DENED
           E23 NUMBER OF PERMITS ISSUED

           	TARGET FOR 3rd QUARTER
  60
  50
  40
  30
  20
  10
             CLOSURE PLANS APPROVED
                                                                                  NATIONAL
                                                                              150
                                                                              100
                                                                               50
                                                                                    3rdQ
                                                                                     1990
            II   III  IV  V  VI  VII  VHI IX  X

                     REGIONS

            NUMBER OF CLOSURE PLANS APPROVED
R/C-1(F)
                                           -115-

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                              CORRECTIVE ACTION ACTIVITY

o  Corrective action activities may be conducted at a facility during interim status, permitting, and closure stages.
   The corrective action process is shown in the graphic below.  Year-to-date program information, as of June
   30, 1990, is shown for several of these steps.

o  Many of the corrective action measures have changed for FY 1990. The RFI imposed measure is the
   only corrective action measure to be targeted in STARS.  The following measures have been added:
   RFI workplan approved or notice of deficiency (NOD) issued, interim measures required of
   owner/operator and corrective action oversight inspections at beginning-of-year corrective action
   facilities.

o  The Regions completed 127 RFA's and imposed 113 RFIs (exceeding the target of 66) through the third
   quarter of FY 1990. They have completed 1,993 RFAs and imposed 678 RFIs through the corrective action
   program year-to-date . The Regions  completed work on  90 RFI workplans through third quarter and 57 RFIs
   year-to-date.

o  Three corrective action remedies have been selected and three corrective action designs have been approved
   through third quarter. The Regions have completed 24 remedy selections and approved  18 corrective measures
   designs year-to-date.  The Regions have reported 15 interim measures required of owner operators in the third
   quarter. They have required 64 interim measures and completed eight year-to-date.

o  Proposed regulations for the procedural and technical requirements for corrective action  at solid waste
   management units have been released by OMB.

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                          CORRECTIVE ACTION PROGRAM STATUS
   500
   400
   300
   200
   100
                                     As of June 30, 1990
                RFA's COMPLETED
               (PROGRAM TO DATE)
          I  II  ID  IV  V  VI  VP  VUI  IX  X
                    REGIONS
                  RFI's IMPOSED
          THROUGH THIRD QUARTER FY 1990
                             RFrS IMPOSED
                             TARGET
               II  IV  V  VI  VI  VIN  IX  X
                    REGIONS
175
150
125
100
 75
 50
 25
  0
20

15

10

 5

 0
              RFI's IMPOSED
           (PROGRAM TO DATE)
PERMITS
ORDERS
            II  IV  V  VI VI VIII  IX  X
                REGIONS
             RFI's COMPLETED
            (PROGRAM TO DATE)
SOURCE:  CARS
      II  III  IV  V VI VII VIII IX  X
                 REGIONS
                                          -117-

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RCRA Enforcement

    o   Inspections - Both EPA and the states performed well on third quarter inspections targets for
        land disposal facilities (839 against a target of 730 (115%)); for treatment, storage and
        disposal facilities (1,292 against 975 (133%)) and for federal, state and local treatment,
        storage and disposal facilities (299 against 225 (133%)).  Of those generators generating over
        1,000kg of waste and subject to land disposal restrictions, 3,387 have received a land ban
        inspection.  Twenty high priority violations were reported based on these inspections.

    o   Addressing Significant Noncompliance (Snapshot) - The RCRA program reported 801
        treatment, storage and disposal facilities (TSDFs) in significant noncompliance (SNC) at the
        end of the third quarter.  Of these, 645 (81%)  had been addressed by a formal enforcement
        action, but had not returned to physical compliance.

    o   Of the 801 TSDFs in SNC at the end of the third quarter, 133 (17%) did not have a formal
        enforcement action taken within 135 days of inspection.

    o   Federal Facilities (Snapshot) - At the end of the quarter, there were 67 federal facility
        TSDFs in SNC.  Of these, 44 (66%) had been  addressed by a formal enforcement action, but
        had not returned to physical compliance.

    o   Of the 67  federal facility TSDFs in SNC at the end of the  third quarter, 23  (34%) did  not
        have a formal enforcement action taken within  135 days of the inspection.  There was one
        federal facility (EPA lead) with final EPA regional action completed within 120 days of the
        initial  action.

    o   Judicial and Administrative Enforcement Activity - During the first three quarters, EPA
        referred ten RCRA civil and 17 criminal cases  to the  U.S.  Department of Justice.  The states
        filed 30 civil and/or criminal cases  against Subtitle C handlers. EPA issued 217 formal
        administrative actions compared to 287 for the  same  period last year.  The states issued 891
        administrative actions compared to 753 during the first three quarters of last year.
                                        _1 1 Q

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  1000
   800
   600
   400
   200
     0
                            RCRA ENFORCEMENT
                             As of June 30, 1990
ADDRESSING TSDFs IN SNC - SNAPSHOT
                                           175
                                           150
 729
775
        801
   1000
   800
   600
   400
   200
     0

R/E-1(b),2
    604
            618
    IN SNC
EZZ3 ADDRESSED
645
             1234
                     QUARTERS

            FORMAL ADMINISTRATIVE ACTIONS
 l/W
                        KX><1 EPA
                        \77X STATES
            2        3
            QUARTERS
                                                                   TSDF INSPECTIONS
                                  35
                                  30
                                  25
                                  20
                                  15
                                  10
                                   5
                                   0
                                                  I   I
                                                  IV  V  VI  VI  VI  IX
                                                    REGIONS
                                                    CIVL AND CRMNAL REFERRALS
                                                    E22 EPA
                                                    (Z23 STATES
                                                   2       3
                                                    QUARTERS
                                             -119-

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                                RCRA REGIONAL INITIATIVES

The FY 1990 RCRA Implementation Plan maintains the policy of providing an option for regional
flexibility.  Regions were invited to trade-off 10-15% of their RCRA program resources to address
environmentally significant priorities, which differ from the national priorities.  Four Regions have
submitted initiatives under this flexibility plan: I, HI, VI, and X.  Some of the initiatives have affected the
STARS commitments for the Regions. The  following is a brief summary of the flexibility activities in each
Region.

   o  Region I initiatives include:  the acceleration of corrective action activities in New England;
      RCRA data and files management, continuation of clean closure review process at Connecticut
      sites; and expanding the scope of inspections at storage and treatment facilities to improve the
      permitting process (a top priority is the 1992 permitting deadline). The Region will reduce
      activity in inspector training, State oversight, and closure plan reviews.

   o  Region III initiatives include: the identification of hazardous waste facilities that have not
      notified EPA of their activities and the return to compliance of these non-notifiers through
      formal enforcement actions and follow-up inspections. The Region will reduce activity in
      environmentally insignificant compliance inspections and evaluations.

   o  Region VI initiatives include: the identification, inspection, and return to compliance of non-
      notifiers.  The Region will reduce inspections at insignificant land disposal facilities.

   o  Region X initiatives include:  increased post-closure permitting;  emphasis on corrective
      action; responding to permitting and compliance priorities at "mega-sites"; Oregon and
      Washington generator surveys and enforcement; continuing work on environmental indicators.
      The Region will reduce activity in low priority inspections and at insignificant storage and
      treatment facility permits.
                                               -121-

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                      OFFICE OF UNDERGROUND STORAGE TANKS

                                         OVERVIEW

o  The OUST mission is to protect human health and the environment by preserving surface and ground
   water quality against contamination from USTs, and to prevent human exposure to carcinogenic or
   explosive vapors. OUST activity is authorized under Subtitle I of RCRA.

o  The primary responsibility of  OUST is the regulation of petroleum tanks and certain other chemical
   tanks. Nationally there are nearly two million USTs at approximately 700,000 facilities, ranging
   from small businesses to major oil corporations.

o  The OUST program has two main facets: State Program Approvals and the LUST (Leaking
   Underground Storage Tanks) Trust Fund for corrective action.

      --  The State Program Approval process seeks to assist all states in establishing their own
         UST legislation and programs; direct federal oversight is impossible due to the large
         number of USTs nationwide. The principal criteria for state program approval is that
         the state's program be no less stringent than the federally mandated program.

      --  The LUST Trust Fund program provides funds to states for corrective action activities
         through cooperative agreements.
                                            -123-

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STATE PROGRAM APPROVALS

      o  State Program Approval, or "franchising," contains two stages.  First, the state establishes the
         necessary legislative authorities. Second, the state submits an application to the Regional OUST for
         approval.

            --  Through third quarter, three states (two in Region IV and one in Region VI) have
               submitted applications for program approval, exceeding the target of two.

      o  Until state programs are approved, OUST works to set up agreements with states to implement the
         federal UST program.  EPA published the Technical Standards Rule and the Financial Responsibility
         Rules in third quarter of FY 1989.

         —  One state program and three applications have been approved to date.  Fifty-one states have
            agreements to implement the federal program prior to state program approval.

      o  UST regulations  mandate owner/operator financial responsibility for their USTs in the event of leaks
         or spills.  Oust will phase-in F.R. requirements to allow disadvateged O/Os to obtain liabilitiy
         insurance.  OUST is enforcing demonstration of financial responsibility according to  facility size.
         UST facilities must show financial responsibility by:

                October  26, 1989    if they have 100-999 USTs;
                April 26, 1991      if they have 13-99 USTs;
                October  26, 1991     if they have 1-12 USTs, net worth less than
                                    20$ million, or are local governments.

      o  After state programs are approved, the role of OUST  will be to continue to improve state programs
         and maintain requirements  no less stringent than federal requirements and administer the LUST
         Trust Fund.
                                                   -174-

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LUST TRUST FUND

      o  LUST Trust Fund monies are provided to states through cooperative agreements which are
         renegotiated annually.  A state is required to have certain legislative authorities in place, such as
         enforcement or cost recovery provisions, before it can obligate LUST Trust Fund monies.

      o  An objective of OUST is to have the responsible parties lead cleanup efforts at LUST  corrective
         action sites. OUST estimates that thousands of LUSTs will be discovered annually.

      o  The rate of LUST cleanup activity nationwide continued to increase in third quarter.

            --  There were 8,998 LUST cleanups initiated in third quarter (21% of the 44,432 to date).
               Of these, 8359 (93%) were responsible party-led, 282 (3%) were state led with LUST
               Trust Fund monies, and 357 (4%) were state-led without LUST Trust Fund monies.

            -  There were 7,777 LUST releases under control in third quarter (25% of the 31,336 to
               date). Of these, 7,196 (93%) were responsible party-led, 252 (3%) were state led with
               LUST Trust Fund monies, and 329 (4%) were state-led without LUST Trust Fund
               monies.

            -  There were 5,279 site cleanups completed in third quarter (36% of the  15,228 to date).
               Of these, 5,021 (95% were responsible party-led, 32 (1%) were state led with LUST
               Trust Fund monies, and 226 (4%) were state-led without Trust Fund monies.
                                                   -125-

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   Enforcement aud
Compliance Monitoring

-------

-------
                         OFFICE OF ENFORCEMENT
o  Civil Enforcement




o  Criminal Enforcement




o  Federal Facility
                                -127-

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CIVIL ENFORCEMENT
Proposed Consent Decree Review Time

    o  OE reviewed and forwarded 92 consent decrees to DOJ through the third quarter of FY
       1990 compared to 91 last year.

    o  The average review time for the quarter was 23 days, meeting the  35 day average target.
       The review times ranged from one to 118 days.
Civil Referral Activity

    o   The Regions referred 173 new cases directly to DOJ and eight to HQs through the third
       quarter for a total of 181; compared to 183 a year ago.

    o   There have been 49 new pre-referral negotiation cases opened through the third quarter.
       Of these, 33 are CERCLA cases.

    o   There have been 15 consent decree enforcement cases initiated through the third quarter (a
       year ago there were eight cases initiated.)
                                       -129-

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Follow-Through On Active  Civil Case Docket

    o  OE reports that there are 870 active Pre-FY 1990 civil cases (i.e. cases referred to DOJ
       before 10/1/89, but not concluded before 10/1/89). As of the end of the third quarter, the
       867 cases had the following status:

       -- 179 (20%) were pending at the DOJ.

       - 51  (6%) were returned to the Region.

       ~ 14  (2%) had been concluded before filing.

       - 513 (59%) were filed  in Court.

       -- 110 (13%) had been concluded after filing.

       Of the 867 cases, 247 (28%) of these have been ongoing for more than two years since
       being filed.

    o  There were 189 civil cases referred to DOJ through the third quarter (FY 1990 cases)
       compared to 184  a year ago.  As of the close of the quarter:

       -- 154 (81%) were pending at the DOJ.

       - 0 were  returned to the Region.

       - 3 (2%) was concluded before filing.

       -- 25  (13%) were filed in Court.

       ~ 7 (4%) was concluded after filing.

    o  The total  number of active cases (including fixed and  dynamic) was 922.


                                        -130-

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                      FOLLOW-THROUGH ON ACTIVE CIVIL CASE DOCKET
                                       As of June 30, 1990
                 CIVIL CASE DOCKET                                  NEW FY 1990
                                                                REFERRALS TO DOJ
    900
200
                                                   150
                                                   100
                                                    50
                    2       3
                     QUARTERS
                  LEGEND
                CASES PENDING AT DOJ
                CASES RETURNED TO THE REGION
                CASES CONCLUDED BEFORE FUNG
                CASES FILED IN COURT
                CASES CONCLUDED AFTER FLNG
                  CASES:

                              Ax
            NUMBER OF REFERRALS - 189
E/C-4.5
                                        -131-

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Consent Decree Tracking

    o  At the end of the third quarter, the Regions reported  that there are 594 active consent
       decrees compared to 564 a year ago.

    o  Consent decree compliance for the quarter was 77%, a decrease from the  first quarter rate
       of 80%.

    o  Of 136 consent decrees reported in violation:

       — 79 (58%) had a contempt action, a decree modification referred, or a stipulated penalty
       collected.

       ~ 43 (32%) had formal enforcement  action planned but not commenced.

       -- 14 (10%) had no formal enforcement action planned or deemed necessary.
                                       -132-

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                                 EPA CONSENT DECREE TRACKING
                                         As of June 30, 1990
                                                                                     NATIONAL
                                                                              600
                                                                                   1234
                                                                                     QUARTERS
                           [Z3 N COMPLIANCE WITH THE TERMS OF THE DECREE

                           RX3 N VIOLATION WITH FORMAL ENFORCEMENT ACTION INITIATED

                           •I M VIOLATION WITH FORMAL ENFORCEMENT ACTION PLANNED BUT UNCOMMENCED

                           I   I IN VIOLATION WITH NO FORMAL ENFORCEMENT ACTION PLANNED AT THIS TIME
E/C-1
                                            -133-

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CRIMINAL ENFORCEMENT
Criminal  Referral Activity

    o  There were 94 new criminal investigations opened through the third quarter of FY 1990
       compared to 89 a year ago.  Twenty investigations were closed prior to referral to the
       Office of Criminal Enforcement.  There were 215 open investigations at the end of the
       quarter compared to 172 a year ago.

    o  The Regions referred 52 new cases to HQs and 47 cases were referred from OE to DOJ.
       A  year ago the Regions referred 47 cases to HQs, and 44 cases were referred from OE to
       DOJ.
                                       -135-

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Follow-Through On Active Criminal Case Docket

    o  There were 106 active Pre-FY 1990 criminal cases (referred before 10/1/89), compared to 97
       a year ago. As of the close of the third quarter.

       --  12 (11%) were under review by DOJ.

       —  32 (30%) were under grand jury investigation.

       --  27 (24%) had charges filed.

       --  22 (21%) had been closed following prosecution.

       --  13 (12%) had been closed without prosecution.

    o  There were 47  new criminal cases referred to DOJ through the third quarter compared to
       44 a year ago.  As of the close of the quarter:

       -  11 (23%) were under review by DOJ.

       —  29 (62%) were under grand jury investigation.

       —  4  (9%) had charges filed.

       --  1  (2%) was closed following prosecution.

       -  2  (4%) was closed without prosecution.

    o  The  total number of active cases was 115 compared to 104 last year.
                                        -"Rfi-

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   o
120


100


 80


 60

 40


 20

  0
                   FOLLOW-THROUGH ON ACTIVE CRIMINAL CASE DOCKET
                                      As of June 30,  1990
                PRE-FY 1990 REFERRALS
                      2      3
                      QUARTERS
                                                  60
                                                  48
                                                  36
                                                  24
                                                  12
                                                         STATUS OF NEW
                                                        FY 1990 REFERRALS
                                                    1234
                                                            QUARTERS

                                                  NUMBER OF NEW REFERRALS - 47
                                                LEGEND
E/C-7.8
                             IX X  UNDER REVEW AT DOJ
                             I   I  UNDER GRAND JURY INVESTIGATION
                             II  WITH CHARGES FLED
                             (•'•:.. I  CLOSED FOLLOWING PROSECUTION
                             •I  CLOSED BY DOJ WITHOUT PROSECUTION
                                          -137-

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                            FEDERAL FACILITY COMPLIANCE

Federal Facility Violation Rates (Note: data are lagged one quarter)

    o   During the second quarter of FY 1990, 213 inspections of federal facilities were conducted.
        Eighty violations were detected in these inspections  for a 38% violation rate.  A year ago
        the second quarter rate for violations was 21%.*

        For the Air media, two violations were detected in 32 inspections for a 6% rate.

    --   For NPDES, one violation was detected in 32 inspections for a 3% rate.

        For SDWA, no violations  were detected and three inspections were conducted.

        For RCRA, 64 violations were detected in 109 inspections for a 59% rate.

    ~   For TSCA, 11 violations were  detected in 32  inspections for  a 34% rate.

        For Multi-Media, two violations were detected and four inspections were conducted.

    o   In the second quarter, 48  enforcement actions were  taken  against previous violations
        (compared to 46 a year a  go.)

    *Note:  Regions I and HI data were not submitted in  time for this report.
                                        -138-

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                        FEDERAL FACILITIES VIOLATION RATE
                               BASED ON INSPECTIONS
                                As of March 31, 1990
        DC
100
 90
 80
 • 70
 60
 50
 40
 30
 20
 10
  0
E/C-1/4E
                      AIR     NPDES     DW     RCRA    TSCA
                      (32)     (33)     (3)     (109)    (32)
                                  NUMBER OF INSPECTIONS
                                       % NOT IN VIOLATION
                                       % IN VIOLATION
                                               OVERALL
                                                (213)
                                        -139-

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Response To Significant Federal Facility Noncompliance
    o   OAR identified 11 federal facilities as significant violators as unaddressed at the beginning
        of the quarter.  One was returned to compliance and the remaining ten are pending.

    o   OW identified five federal facilities on the exceptions list that were carried over from the
        previous quarter.  Two were returned to compliance and two had enforcements action
        initiated.  The remaining SNC constitutes the pending balance of one facility.

    o   Thirty-eight TSCA federal  facility SNC cases were identified at  the BOY.  Of the total,  22
        were open (issued but not closed) and 16 are pending enforcement actions.  At the end of
        the third quarter,  12 SNC cases were issued and 17 SNC cases  were  closed.

    o   OSWER compliance snapshot at the end of the third quarter shows 67 federally owned or
        operated TSDFs in SNC.  Of these facilities, 44 have been addressed with formal
        enforcement actions, but are not yet in compliance.

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                 RESPONSE TO SIGNIFICANT FEDERAL FACILITY NONCOMPLIANCE
                                        As of June 30,  1990
                     AIR FIXED BASE
             BOY    1
                    3     4
       60


       45


       30


       15


        0
                     I  I ADDRESSED
                     •I PENDING

          TSCA SIGNFICANT VIOLATORS FIXED BASE
                  (PRE FY 1990 CASES)
E/C-SNC1
 BOY   OPEN PENDING PENDNG PENDNG CASES
TOTAL            SNC NON-SNC CLOSED
               CASES CASES
               ISSUED ISSUED
                                               WATER EXCEPTIONS REPORT
                                                   16


                                                   12


                                                    8
   SNC  ENFORCEMENT RETURNED TO PENDNG
         ACTION   COMPLIANCE
CZI SNC 2 CONSECUTIVE QUARTERS
•• SNC FOR MORE THAN 2 QUARTERS


   RCRA COMPLIANCE SNAPSHOT
    1       2       3.      4

EZ SNC/ADDRESSED/END OF QUARTER

• SNC/UNADDRESSED/END OF QUARTER
                                           -141-

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-142-

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Number of New Criminal Referrals to EPA-OCEC
             (3rd Quarter FY90)


Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VIII
Region IX
Region X
NEIC
Total

RCRA
2
0
2
3
1
0
0
3
0
2
4
17
CLEAN
AIR
1
0
1
3
0
0
0
0
0
1
0
6
CLEAN
WATER
2
2
5
6
2
2
0
1
1
3
0
24

FIFRA
0
0
0
0
1
0
0
0
0
0
0
1

TSCA
0
0
0
0
1
0
2
0
0
0
0
3

CERCLA
0
0
0
0
0
0
0
0
0
1
0
1

Total
5
2
8
12
5
2
2
4
1
7
4
52
                    -143-

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-144-

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Office of General Counsel
       -145-

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Red Border Review Deadlines

    o  OGC received 90 Red Border documents for review through the third quarter of FY 1990.
       Thirty-one documents were received for review during the third quarter.

    o  OGC Completed:

       — 23  (74%)  reviews within three weeks, compared to a target of 80%.

       — 3 (10%) reviews within four weeks,  compared to a target of 100%.  The cumulative total
       of completed reviews for the quarter was 26 (84%).

       — 5 (16%) reviews were not completed within the four week review target.


State Delegation Agreement Review Deadline

    o  OGC received no applications for review during the third quarter.  Three applications were
       reviewed during the first and second quarters and concurrence was received within the 15
       day target.

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   25
   20
CO
UJ
>  15
ui
cc.
LJ_
O
(5  10
              OGC CUMULATIVE REVIEW OF RED BORDER PACKAGES
                              As of June 30, 1990
                                                             PROGRAM SUMMARY
           OAR     OARM    OSWER
                        PROGRAMS
                                   OPTS
                                                        90
CO

>
cc.
u.
O
cc.
                                                        60
                                                        30
                                                                 2    3
                                                                QUARTERS
G/C-2
                          LEGEND
                     COMPLETED WITHIN 3 WEEKS

                     COMPLETED WITHIN 4 WEEKS

                     INCOMPLETE AFTER 4 WEEKS
                                   -14 /

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00

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f.
   «   I

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-------