230R83006
A PROFILE OF ERA ACTIVITIES'
¦	" I
Program Evaluation Division
Office of Management Systens
and Evaluation
July- 198 3

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TABLE OF CONTENTS
Introduct ion
Part I: The Agency as
Part II: Headquarters
Part III: Comparisons
a Whole
and the Regional Offices
Among EPA Programs
Table
LIST OF TABLES
List of EPA Activities
Total"BPA Workyears and Contract S By Category
Total EPA Workyears and Contract S By Activity
Division of Headquarters, Regional Workyears
Activity Workyears at Headquarters, Regions
Range of Regional Workyears
Division of Program Workyears in Headquarters
Of f ices
Division of Contract Dollars in Headquarters
Of f ices ;
% EPA Workyears'and Contract S in 3 Programs
Comparison of Headquarters/Regional % By Progra
Program Workyear Breakdown By Category
Program Workyear Breakdown By Activity
Program Contract Dollars By Activity

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A PROFILE OF EPA ACTIVITIESt
Introduct ion
The overall purpose of the study on meeting EPA's post-
delegation responsibilities is to examine the implications
for EPA of the delegation of programs to State and local	•
government. Such an examination requires useful, objective
information about trends and opinions both inside and outside -
EPA which could affect the Agency's future work. The inforrnation
needed includes data on environmental trends, an analysis of, :
current thinking in State-Federal relations, outside views
on how other organizations handle the problems of decentralized--:
management, and informed opinion on EPA's performance in
meeting its current responsibilities.
This report presents results from one of these information-
gathering efforts. It consists of a functional profile of
EPA's work, as divided among 23 different activities. The
objective of this profile is to provide a factual baseline
picture of what EPA does as an agency, organized by function
(e.g., standard-setting, research, direct administration of
programs, technical support). Further discussions of what
the Agency might or should do in the future can draw on this
vaseline in developing options for management choices, especially
)n describing what the implications of these choices might be.
Data for thi.^ report were obtained from EPA's Regional and
eadquarters offices. Offices were asked to give their best
estimates of the percentage of their current (1983) workyears and
contract dollars which are devoted to each activity. We asked
for percentages because we felt that they were appropriate to
the level of precision needed for this study, and that this
would encourage program managers to classify their offices'
activities by reflecting on the real work of their staff.
Several respondents expressed some concern that this data
would be specifically used to critique their budget submissions.
We addressed this concern by promising that this data would
not be used in connection with resource allocation decisions,
as we felt that only by making this pledge could we expect to
get valid results. We believe that while the results of this
effort are useful and accurate as an aggregate picture of EPA's ,,
work, it would not be appropriate to compare this data to detailed
budget submissions for individual offices. These budget.sub-
missions are generated by a very different system which operates
under a very different set of rules and assumptions.
tPrepared by Stan Meiburg and Gainor Eisenlohr in the Program
Evaluation Division, U.S. EPA. Special thanks are due to Pat
Meaney and Lane Krahl in EPA Region 1, who served as project
managers for all of the data reported from the Regions and
whose rigorous review of the early proposals for this project
improved it significantly.

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To collect the data reported in this profile, we used the
following process.
o A draft list of activities and definitions was developed
by the Program Evaluation Division. This list was reviewed
throughout the Agency for clarity and comprehensiveness.
o Based on this review, a revised list of activities and
definitions was developed. This revised list was sent
to all Headquarters and Regional oftices, along with
detailed instructions on how to classify each office's
work among the various activities (see Attachment 1).
o Regional offices reported their classifications bacu
to EPA Region I, which kept track of the submissions
and checked for reporting errors (e.g., percentages
which failed to add up to 100). The Program Evaluation
Division performed the sane function for Headquarters
offices. All Headquarters and Regional offices
responded to the request for information except
Region Vll's Office of Regional Counsel and Region X's
Alaska Operations Office.
o The raw data were entered into a computer at Head-
quarters, which generated the summaries presented in
this report. The totals for FTE and contract funds
reported by each office were used to weigh the
percentages reported by that office for each activity.
Several checks have been performed on the data to confirm
its quality. Reported total workyears for the Agency difter
by less than 2% from EPA's current budget estimate. Contract
funds differ by less than 4%, and the bulk of this difference
appears to stem from uncertainty about how to count carryover
funds and research grants. In addition, the percentages
assigned to different categories are relatively consistent
among Regions, suggesting that the definitions and classifications
were applied on the whole in a similar manner. Finally,
while there was no attempt no "second-guess" classifications
submitted by individual offices, the data submissions were
reviewed and checked with offices if'the reports appeared to
contain major anomalies.
For these reasons, we are confident that the data
is of sufficient quality to serve as a baseline profile
of EPA's current activities. However, to our knowledge, there
is no other sinilar profile of EPA activity. The absence of
a yardstick against which to compare the results of this
exercise suggests the need for caution in interpreting these
results. Nevertheless, they should be useful in comparing
different scenarios whicn EPA might pursue in response to
changing patterns of delegation over the next five years.

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The body of the report is divided into three parts.
The first part presents a look at how the Agency as a whole
is divided among the 7 categories and 23 activities. Part
II presents the results of some comparisons between Headquarters
and Regions and among Headquarters and Regional offices.
Part III compares three programs -- Air, Water, and Hazardous
Waste£/— each of which have substantial Headquarters and
Regional components. Since this report's intent is to be
descriptive rather than prescriptive, it presents the results
of our analyses in such a way that the reader can draw his
or her own conclusions.
A Word About the List of Activities
The appendix to this report contains a definition of each
of the 23 activities used as the basis for classifying each
offices' work. This is not the only set of activities which
could be identified, nor is it the best for all purposes, but it
enables us to make the analytical distinctions necessary for
this project. In developing the list, we applied three basic
principles: simplicity; comprehensiveness; and attention to
post-delegation support activities. We realized at the time the
list was developed that our choice of a classification scheme
would facilitate some analyses and elininate the possibility of
others. This was an unavoidable consequence of the need to
develop a list which could be used relatively quickly. Given
this need, we tried to anticipate the types of analyses which
would be most relevant to this study, and to structure the list
so that these analyses could be successfully performed.
For several of the analyses which follow, the 23 activities
have been grouped into seven major categories. Both the categories
and the activities are listed in Table 1.
2/as used in this report, the "Hazardous Waste" program includes
both the PCRA and Superfund programs.

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Table 1: List of tPA Activities
I. DIRECT PROGRAM ADMINISTRATION
A.	Permitting, Engineering, and Environmental Impact Reviews
B.	Product Review and Registration
C.	Hazardous Substance Emergency Response and Site Management
D.	Compliance and Enforcement
E.	Program Direction and Interpretation
II. TECHNICAL SUPPORT
A.	Laboratory Services
B.	Development and Distribution of Implementation Tools
C.	Direct Assistance On-Site/Person to Person
D.	Special Projects
E.	Training
III. STATE PROGRAM APPROVAL AND OVERSIGHT
A. Review of State Programs/Plans/Delegation Applications
P. Review of Individual Proposed State Actions
C. Program Review of State Actions
IV. RESEARCH
A.	Standard-Setting Support
B.	Exploratory Research
V. STANDARD-SETTING
A.	Listing Dec 1slons/Designation Activities
B.	Technical Regulations
C.	Administrative Regulations
VI. MANAGEMENT SUPPORT
A.	Policy Activities
B.	Administration and Support Services
C.	Legal Defense
VII. NATIONAL INFORMATION COT.LECTION
A.	Formal National Information Systems
B.	Special Requests for Information

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®iRT I: THE AGENCY AS A WHOLE
The data collected for this study confirm the common impression
that EPA is highly decentralized. However, they also call attention
to the size of the Headquarters component. Out of all EPA workyears,
31% are assigned to Headquarters offices, while 39% are assigned
:o the Regions. Not all Headquarters employees are located in
Washington, of course; the Office of Research and Development
(ORD) and the Office of Air, Noise and Radiation (OANR) in
^articular have large units located elsewhere which are counted
in the Headquarters totals.
The figures for contract dollars reflect the Agency's current
practices in contract administration. In general, contracts are
jssigned to allowance holders in Headquarters, which in some cases
:hen reallocates a portion of these to the Regions to satisfy
specific Regional needs. As a result, 97% of all the agency's
rontract dollars are administered from Headquarters offices,
vhile only three percent are allocated directly to the Regions.£/
/
As noted in the introduction, the 23 activities into which
:he Agency's work was divided can be grouped into seven general
rategories. Table 2 shows how the agency divides its workyears
»nd contract dollars among these seven categories.3/
Table 2; Total EPA Workyears and Contract S By Category
Workyear Contract S
% %
:.	Direct Program Administration	26	31
t. Technical Support	9	9
:.	State Program Approval and Oversight	8	0
/.	Research	12	17
/.	Standard-Setting	9	11
:.	Management Support	30	29
!.	National Information Collection	5	2
A further breakdown of the data among the 23 activities
jives a more detailed look at the overall patterns of the Agency's
ise of workyears and contract dollars. One point to remember
vhen looking at this data is that a "U%" entry does not necessarily
nean that absolutely no contract dollars or workyears are
•.pent in this area, but rather that that the totai figure
reported was less than one percent of the Agency total.
-/ Because of uncertainties in interpreting the contract dollar
percentage breakdowns reported by the Regions, all contract
collar discussions in the remainder of this report will address
Headquarters contract dollars only.
Totals in this and other tables may not add to 100% due to
rounding. For rough comparisons, 1% equals about 106 workyears
and S4.5 million in contract dollars.

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Table 3: Total EPA Workyears and Contract S By Activity4/
II
III
IV.
VI
VII

Workyear
%
Cont
DIRECT PROGRAM ADMINISTRATION


A. Permitting and Reviews
5
1
B. Product Registration
4
2
C. Hazardous Substance Response
2
22
D. Compliance and Enforcement
10
4
E. Program Direction
4
1
TECHNICAL SUPPORT


A. Laboratory Services
2
4
B. Implementation Tools
2
3
C. Direct Assistance
2
1
D. Special Projects
2
2
E. Training
1
1
STATE PROGRAM APPROVAL AND OVERSIGHT


A. Review of Plans/Applications
3
0
B. Review of Individual Actions
2
0
C. Program Reviews
3
0
RESEARCH


A. Standard-Setting Support
12
16
B. Exploratory Research
0
1
STANDARD-SETTING


A. Listing Decisions
1
1
B. Technical Regulations
7
10
C. Administrative Regulations
1
1
MANAGEMENT SUPPORT


A. Policy Activities
10
3
B. Administration/Supporr
19
2 S
C. Legal Defense
1
0
NATIONAL INFORMATION COLLECTION


A. Formal Systems
3
2
B. Special Requests
2
1
PART II: HEADQUARTERS AND THE REGIONAL OFFICES
Another way of looking at the data is to see how workyears
in the nirferent categories and activities are divided between
Headquarters and the Regions.
Tables 4 and 5 show how Headquarters workyears are divided
is conparcd to the Regional offices. Not surprisingly, both
.ables show that Headquarters and Regional offices generally do
^/Activity totals nay not exactly add up to category totals due
to rounding.

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ifferent kinds of work. Regional offices are primarily involved
n the direct administration of EPA programs as well as the
review and oversight of State programs. Headquarters' direct
program responsibilities are mainly in the pesticides and toxic
substances area; in other areas, Headquarters is primarily a
research, standard setting, and management support organization.
The concentration of management support activities in
Headquarters reflects a centralization of both administrative
support services and policy-related activities. This stands out
oven more when it is remembered that the Headquarters/Regional
i^plit in overall resources is approximately 60/40 in favor of
Headdqua rters.
Table 4; Division of Headquarters, Regional Workyears
Headquarters Regional
Workyear % Workyear %
Direct Program Administration
Technical Support
State Program Approval and Oversight
Research
Standard-Set t i ng
Management Support
National Information Collection
17
9
2
20
14
36
3
41
10
18
0
•*1
22
8
Table 5; Activity Workyears at Headquarters, Regions
Headquarters Regional
Workyear % Workyear %
DIRECT PROGRAM ADMINISTRATION
A.	Permitting and Reviews
B.	Product Registration
C.	Hazardous Substance Response
D.	Compliance and Enforcement
E.	Program Direction
1
7
1
5
3
12
0
5
18
6
TECHNICAL SUPPORT
A.	Laboratory Services
B.	Implementation Tools
C.	Direct Assistance
D.	Special Projects
E.	Training
2
3
1
1
1
2
1
4
2
2
STATE PROGRAM APPROVAL AMD OVERSIGHT
A.	Review of Plans/Applications
B.	Review of Individual Actions
C.	Program Reviews
0
1
6
4
7

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.'able 5 (continued)	HQ %	RO
IV. RESEARCH
A.	Standard-Setting Support	19	0
B.	Exploratory Research	1	0
V. STANDARD-SETTING
A.	Listing Decisions	1	0
B.	Technical Regulations	11	1
C.	Administrative Regulations	2	1
VI. MANAGEMENT SUPPORT
A.	Policy Activities	12	7
B.	Administration/Support	22	14
C.	Legal Defense	1	1
VII. NATIONAL INFORMATION COLLECTION
A.	Fornal Systems	2	4
B.	Special Requests	2	4
Another interesting item that showed up in the data is the
range of percentages which the 10 Regional offices assigned to
>ach of the seven categories. The highest and lowest workyear
jercentages reported in each category are presented in Table 6.
While th?re are differences among Regions, it is noteworthy
that the largest difference between the high and low values for
category is 15%.


Table 6: Ranqe of Reqional
Workyear %


Low %
H i qh %
Direct Program Administration
34
46
Technical Support
5
14
State Program Approval and Oversight
13
28
Standard-Setting
0
3
Managenent Support
16
27
National Information Collection
6
10

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Headquarters offices show sonewhat different patterns
of activities from one office to another. Table 7 shows
these patterns for the workyears of four headquarters offices:
Air, Noise and Radiation; Water; Solid Waste and Emergency
Response, and Pesticides and Toxic Substances. Table 8
shows the same information for contract dollars. The percentages
in each of the seven categories are a percentage of each
program's headquarters total.
Table 7: Division of Program Workyears in Headquarters Offices
(Figures are % of total office workyears)
Direct Program Administration
Technical Support
State Program Approval and Oversight
Resea rch
Standard-Setting
Management Support
National Information Collection
Table 8: Division of Contract Dollars in Headquarters Offices
(Figures are * of total office contract S)
OANR OW OSWER OPTS
Direct Program Administration
27
25
67
31
Technical Support
6
12
12
8
State Program Approval and Oversight
- 1
1
0
0
Research
*
o
2
3
4
Standard-Setting
60
39
5
38
Management Support
0
9
10
12
National Information Collection
0
10
2
^ 1
1
OANR OW OSWER OPTS
22
22
35
47
12
16
8
9
5
6
7
3
4
1
0
2
38
25
21
23
16
21
23
13
3
9
5
3

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PART III; COMPARISONS AMONG EPA PROGRAMS
Another way of looking at the data collected in this study
is to conpare patterns anong major programs of the agency—
specifically the air, water, and hazardous waste programs--
which have large Headquarters and Regional components. For the
purpose of this analysis, the "hazardous waste" program includes
activities conducted under both RCRA and Superfund authorities.
The "water" program includes both water qualitv (including
construction grants) and drinking water programs, while the
air program includes both stationary and mobile source control
act ivities
Table 9 presents the overall agency percentages of
workyears and contract dollars applied to the air, hazardous
waste, and water programs.
Table 9: % EPA Workyears and Contract S in 3 Programs
Workyear Contract S
% %
Air	10	5
Hazardous Waste	10	36
Water	16	5
Each of the three programs has a somewhat different
distribution of resources between Headquarters and Regional
offices. Table 10 shows this data for the three programs.
Table 10: Comparison of Headquarters/Regional % By Program
Headquarters Regional
	%	 %
Air	56	44
Hazardous Waste	34	66
Water	31	69
^/The Regional reports on the workyears associated with these
three programs also contain work associated with the radiation
and pesticides prograns, which have small Regional components.
Because of inconsistencies in Regional organizations, these
workyears were not all reported consistently, though radiation
workyears were most commonly reported with the air resources,
while pesticides workyears were most commonly reportec with
hazardous waste resources. The levels of workyears involved
in any event are so small that they have no appreciable
effect on the overall totals.

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Table 11 compares the workyear percentages which each of
the three programs reported for each of the seven major categories
of activity. This comparison is further broken down in Table 12,
which shows the relative percentages for each of the 23 activities.
These data represent a summary of all of the percentages reported
by both Headquarters and Regional components of each program.
There are some striking differences among the three programs.
The air program, for example, devotes a substantially larger percentage
of its resources to standard-setting (a function primarily performed
in Headquarters) than either of the other two programs. On the
other hand, the water and hazardous waste programs do substantially
more permitting and review (functions which are primarily Regional)
than does air. To contrast another area, compliance and enforcement
activities are a substantially larger percentage of air and hazardous
waste activities than is the case in the water program.
It is unclear just what these different patterns signify.
One possibility is that they reflect the need for different
approaches to solving environmental problems in the air, water,
and land. Whatever the cause, it is important to understand
that the distribution of activities among the various program
areas are quite distinctly different.
Table 11: Program Workyear Breakdown by Category^/
	WORKYEAR %
HAZARDOUS

• AIR
WASTE
WATER
Direct Program Administration
28
51
35
Technical Support
10
8
13
State Program Approval and Oversight
19
15
21
Research
3
0
1
Standard-Setting
20
8
10
Management Support
13
12
12
National Information Collection
7
6
8
^/"Research" workyears and contract dollars for each program include
program office workyears and funds only and do not include resources
devoted by ORD to air, water, and hazardous waste research.

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Table 12: Program Workyear Breakdown by Activity
WORKYEAR %
AIR
HAZARDOUS
WASTE
WATER
I. DIRECT PROGRAM ADMINISTRATION
A.	Permitting and Reviews
B.	Product Registration
C.	Hazardous Substance Response
D.	Compliance and Enforc-ment
E.	Program Direction
CI. TECHNICAL SUPPORT
A.	Laboratory Services
B.	Implementation Tools
C.	Direct Assistance
D.	Special Projects
E.	Training
CI. STATE PROGRAM APPROVAL AND OVERSIGHT
A.	Review of Plans/Applications
B.	Review of Individual Actions
C.	Program Reviews
CV. RESEARCH
A.	Standard-Setting Support
B.	Exploratory Research
V. STANDARD-SETTING
A.	Listing Decisions
B.	Technical Regulations
C.	Administrative Regulations
/I. MANAGEMENT SUPPORT
A.	Policy Activities
B.	Administration/Support
C.	Legal Defense
CI. NATIONAL INFORMATION COLLECTION
A.	Formal Systems
B.	Special Requests
4
3
0
17
4
3
3
2
1
1
8
4
7
3
0
2
17
2
5
8
1
5
2
14
1
9
17
11
1
1
S
1
1
9
2
4
0
0
6
"b
0
4
3
14
0
0
10
10
1
3
4
2
3
7
6
9
1
0
0
7
3
7
5
0
The use to which the various programs put contract dollars
can be compared using a similar analysis. About. 46% of EPA's
total contract dollars are spent in the air, hazardous waste and
water programs. Over three-fourths of this is spent in the hazardous
waste area, reflecting the activities conducted under "Superfund."
Table 13 contains a breakdown of how each program spends its
contract dollars. There are larger differences in contract dollar
percentages than in workyear percentages. For example, in addition
to the obvious difference in the hazardous waste area because of
Superfund, there are also significant differences in tne use of

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contract funds for compliance and enforcement activities, permitting
and reviews, and technical regulations.
Some caution should be used in interpreting the "hazardous
waste" percentages. Because the "Superfund" program is so large,
it makes the percentages for all other activities in the hazardous
waste program seem small even though they may be conparable in
absolute terms to similar activities in the air and water programs.
For this reason, two columns are shown for the hazardous waste
program, one which includes contract funds for emergency re ponse
actions and one excludes those funds from the base level used to
calculate the percentages.
TABLE 13: Program Contract Dollars by Activity
CONTRACT DOLLAR %
DIRECT PROGRAM ADMINISTRATION
A.	Permitting and Reviews
B.	Product Registration
C.	Hazardous Substance Response
D.	Compliance and Enforcement
E.	Program Direction
AIR
0
0
0
28
0
HAZARDOUS
WASTE 1 WASTE2
1
0
60
5
1
2
0
12
2
WATER
19
0
3
2
7
II. TECHNICAL SUPPORT
A.	Laboratory Services
B.	Implementation Tools
C.	Direct Assistance
D.	Special Projects
E.	Training
1
3
0
1
5
8
3
1
0
1
20
8
3
0
2
4
6
1
2
1
III. STATE PROGRAM APPROVAL AND OVERSIGHT
A.	Review of Plans/Applicat ions	1	0 0	0
B.	Review of Individual Actions	0	0 0	1
C.	Program Reviews	0	0 0	0
IV. RESEARCH
A.	Standard-Setting Support	7	3 8	2
B.	Exploratory Research	0	0 0	0
V. STANDARD-SETTING
A.	Listing Decisions	1	12	0
B.	Technical Regulations	50	4 10	34
C.	Administrative Regulations	2	0 0	1
VI. MANAGEMENT SUPPORT
A.	Policy Activities	0	3 7	8
B.	Administration/Support	0	8 20	0
C.	Legal Defense	0	0 0	0
VII. NATIONAL INFORMATION COLLECTION
A. Formal Systems	0	12	9
9. Special Requests	0	12	1

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