v»EPA
United States EPA 230-F-92-010
Environmental Protection July 1992
Agency
Policy, Planning, And Evaluation (PM-219)
EPA's Clusters
A New Approach For
Environmental
Management
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CONTENTS
What is EPA's Cluster Approach? I
What Are the Advantages of a Cluster Approach? 3
Project Goals 5
How Many Clusters Does the Agency Have? What
Are They? 6
What Do Cluster Teams Do? How Does Their Work
Relate to the Work of Agency Programs? 7
How Are Clusters Managed? 9
Do Cluster Teams Interact With the Public? 10
What Benefits Have Clusters Provided to Date? 11
For More Information , 11
Summaries of Individual Clusters 13
Contaminated Media 13
Ground Water 14
Habitat 15
Lead 16
Nitrogen 16
Oil and Gas Extraction and Production 18
Petroleum Refining , 19
Pulp and Paper 20
Small Communities 21
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WHAT is EPA's CLUSTER APPROACH?
EPA often has many different programs working on reg-
ulations, policies, and activities that affect a single pollu-
tion source, a particular pollutant, or a unique ecosystem.
For example, in the fall of 1990, EPA faced the prospect of
developing seven major regulations and guidance docu-
ments dealing with the pulp and paper industry. This
industry, which includes more than 600 domestic pulp,
paper, and paperboard manufacturing facilities, is among
the largest industry categories in terms of the quantity of
toxic chemicals it releases. The industry's releases to air,
water, and the land are covered by different statutes and,
therefore, the job of developing the regulations fell to the
several program offices responsible for implementing the
various statutory provisions.
To better integrate the Agency's work in this and other
problem areas, EPA has formed "clusters," teams of staff
and managers from the relevant EPA offices, which ap-
proach problems holistically, rather than from a more
traditional program-by-program perspective. Each clus-
ter focuses on a specific economic sector (e.g., pulp and
paper), pollutant (e.g., lead), environmental resource
(e.g., ground water), or other logical grouping of Agency
activities. Each team seeks to ensure that within its area,
regulations and non-regulatory activities work together.
Moving beyond the planning and coordination functions
typical of task forces, these teams guide the activities of
individual programs and implement cross-cutting sup-
plementary activities.
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In short, the cluster approach seeks to improve EPA's ef-
ficiency and effectiveness by bringing together the appro-
priate regulatory and non-regulatory resources and tools,
and solving problems holistically.
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WHAT ARE THE ADVANTAGES OF A CLUSTER
APPROACH?
The traditional approach to environmental protection is
oriented by environmental media and so tends to be frag-
mented. At least three separate laws — the Clean Air Act,
the Clean Water Act, and the Resource Conservation and
Recovery Act — govern the air emissions, water emissions
and solid/hazardous waste from a typical industrial facil-
ity. The lines drawn by statutes, rather than by whole in-
dustries or ecosystems, have shaped environmental insti-
tutions and expertise both within and outside of the
Agency.
While existing environmental programs have led to im-
pressive gains in environmental quality, the current legal
and institutional framework has obvious limitations. Its
media-specific and pollutant-specific structure creates the
potential for narrowly focused regulations simply to shift
pollution from one environmental medium to another, and
can lead to duplicative activities across offices. Most im-
portant, a media-specific approach impedes EPA's ability
to identify and apply innovative, comprehensive strategies
(such as pollution prevention approaches) to environmen-
tal problems and to set priorities among multiple actions
addressing the same problem.
Clusters can help overcome these inherent limitations.
Based on a comprehensive assessment of a problem area,
cluster teams can assure that EPA's programs and re-
sources are focused on the most serious remaining risks,
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are well coordinated, and efficient. Drawing on the exper-
tise and resources of many EPA offices, teams can design
and implement innovative policies. Interdisciplinary teams
can also evaluate the full range of regulatory and non-
regulatory options and tools in their areas. In the long run,
clusters can break down institutional barriers by broaden-
ing staffs' familiarity with EPA programs and environmen-
tal issues outside their area of expertise.
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PROJECT GOALS
The project's immediate goal is to demonstrate the policy
and management benefits associated with a comprehen-
sive, problem-solving approach to Agency work. The ac-
tivities of specific clusters discussed later in this publica-
tion reflect this goal.
The long term goals are to:
<» promote integrated approaches to regulatory and policy
development, and
»t» build the institutional capacity and commitment needed
to execute these approaches where appropriate.
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How MANY CLUSTERS DOES THE AGENCY HAVE?
WHAT ARE THEY?
EPA now has nine clusters in operation (listed below and
described in more detail at the end of this booklet). EPA is
establishing dusters for industries affected by new regula-
tions developed under several statutes, for high risk prob-
lem areas, or for other problem areas that could benefit
from a cluster approach. EPA is establishing additional
dusters as it gains experience with the cluster approach
and as new opportunities arise. (EPA is currently develop-
ing new clusters for indoor air, environmental equity, the
printing industry, and transportation.)
Sector-based Clusters
Oil and gas production and exploration
Petroleum Refining Industry
Pulp and Paper Industry
Small Communities
Pollutant-based Clusters
Lead
Nitrogen
Resource Protection-based Clusters
Ground water
Habitat
Contaminated media
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WHAT Do CLUSTER TEAMS DO? How DOES
THEIR WORK RELATE TO THE V\ORK OF AGENCY
PROGRAMS?
Cluster teams enhance the work of individual EPA pro-
grams by developing the information needed to consider
individual regulations in a broader context, and by im-
plementing supplementary projects. Cluster teams assess
the human health and ecological risks associated with the
problem area, review of the problem's economic character-
istics, and inventory of current and planned Agency activ-
ities related to the area. Based on this information, decision
makers can evaluate individual actions in the context of
the Agency's overall efforts to address a particular envi-
ronmental problems.
The special projects cluster teams pursue vary. Each dus-
ter team identifies and explores opportunities to improve
policy and streamline management. Cluster teams, work-
ing with the programs, can accomplish these goals in a
variety of ways, including:
•J» Identifying the need to change Agency priorities to better
target the most serious remaining risks;
»I* Enhancing efforts to address high risks through near-term
actions, such as multi-media enforcement efforts, out-
reach activities, and technical assistance;
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Increasing the cost-effectiveness of particular rulemakings
through the use of innovative, multi-media approaches
such as pollution prevention and economic incentive
approaches;
Improving management efficiency by reducing duplication
of effort within the Agency, eliminating redundant
regulatory requirements, and jointly collecting data,
and
• Improving communication with outside groups by enhanc-
ing information on Agency activities available to inter-
ested groups and providing a forum for comprehensive
discussions of particular problem areas.
Examining broad strategic questions and setting the
Agency's overall agenda for the problem area.
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HOW ARE CLUSTERS MANAGED?
Responsibility for managing dusters and developing clus-
ter strategies is shared throughout the Agency. Cluster
teams have staff and managers from several Agency of-
fices, but lead'responsibility is typically assigned to a se-
nior manager in one of the four national program offices.
The Deputy Administrator regularly reviews the agendas
for each cluster team and is involved in important policy
decisions. The Office of Policy, Planning, and Evaluation
provides general management support for the project.
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Do CLUSTER TEAMS INTERACT WITH THE PUBLIC?
Clusters can enhance EPA's communication with industry,
environmental groups, and other organizations by provid-
ing a forum for comprehensive discussions of technical
and policy issues associated with particular sectors, envi-
ronmental resources, or pollutants. Cluster teams are en-
couraged to work with outside groups to assemble data
and examine potential management and policy improve-
ments, as well as to keep interested parties informed about
EPA activities. Cluster teams are using a variety of ap-
proaches, including meetings, focus groups, conferences,
and newsletters, to involve the public in their activities.
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WHAT BENEFITS HAVE CLUSTERS PROVIDED TO
DATE?
The Agency is already seeing a variety of benefits from the
cluster approach. For example:
More efficient data collection. The pulp and paper clus-
ter collected in a single survey much of the data needed for
the surface water effluent guideline revision, the air toxins
standard for chloroform, rules governing disposal of pulp
and paper mill sludges, and other rules and guidance. This
decreased industry's reporting burden and the Agency's
data collection and management costs.
Better use of existing data. The oil and gas cluster is pool-
ing and analyzing data that EPA's Regional Offices have
individually collected and will make this analysis available
to the Regions for use in issuing general permits and in
regulating drilling muds.
Focus on highest risks. Through analyses done in con-
junction with the lead cluster, EPA is accelerating activities
which address the highest sources of risk such as lead sol-
der and plumbing fixtures.
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Easier integrated planning in the private sector. A
petroleum refining company developed and proposed to
EPA a cluster approach to controlling benzene emissions
from waste water. EPA has incorporated the general ap-
proach in guidance for granting temporary waivers to the
hazardous air pollutant standard for wastewater benzene
emissions.
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FOR MORE INFORMATION
The Office of Policy, Planning and Evaluation will report
semi-annually on the status and progress of clusters. Ques-
tions about the initiative can be directed to Joe Retzer at
(202) 260-2472. Contacts for individual clusters are pro-
vided below.
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SUMMARIES OF INDIVIDUAL CLUSTERS
Contaminated Media
Rationale: Hie number of potential cleanup sites facing
the nation is enormous and growing. Remediation respon-
sibility is shared among several EPA offices, other federal
agencies, and states. Inconsistency among their approach-
es and the high cost of remediation create a need for an
integrated contaminated media strategy.
Focus: The cluster examines strategic issues and options
for achieving more consistent, higher quality, cost-effective
clean-ups of contaminated soil, ground water, and sedi-
ments. The group has developed information on the cur-
rent and anticipated universe of contaminated media sites
as well as the costs and benefits of remediation, and is ana-
lyzing the impact of the current laws and regulations on
remedial actions. From this work, the group developed ob-
jectives and principles (now in draft form) for improving
and integrating Agency clean-up programs. These princi-
ples are helping the Agency write major rules such as the
Resource Conservation and Recovery Act (RCRA) correc-
tive action rule and the RCRA "hazardous waste identifi-
cation rule." Since some of the group's recommendations
could require statutory changes, the group's work is con-
tributing to the RCRA reauthorization debate.
Contact: Jackie Tenusak, Office of Solid Waste and Emer-
gency Response, (202) 260-4617
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Ground Water
Rationale: Many of EPA's statutes, including drinking
water, pesticides, and hazardous waste programs, seek to
protect ground water. In May, 1991, EPA published a
Ground Water Task Force Report that identified principles
for consolidating the diverse ground water policies estab-
lished under individual statutes. The report identified the
ground water cluster as its implementing mechanism.
Focus: The cluster is responsible for ensuring that the
Agency's Ground Water Principles are considered in the
development of Agency regulations, guidance, and poli-
cies. The cluster has trained Agency staff responsible for
developing key groundwater regulations to ensure, for
example, that these rules provide states with flexibility
where feasible.
Contact: Chuck Job, Office of Ground Water and Drinking
Water, (202) 260-7084
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Habitat
Rationale: The EPA Science Advisory Board, in its Sep-
tember 1990 report Reducing Risk, identified habitat alter-
ation and loss as a high-priority problem. EPA shares
responsibility for habitat protection with other federal and
state agencies. Fulfilling this responsibility requires EPA to
clearly define its role in habitat issues and identify oppor-
tunities to better incorporate habitat consideration into its
programs.
Focus: The cluster will review and synthesize information
on habitat loss, identify critical issues, and evaluate EPA
efforts. The cluster will develop near term steps and a
longer term strategy for the Agency to improve habitat
protection, including ways in which EPA could better
work with other agencies to most effectively address habi-
tat issues. The first product was an overview of EPA's leg-
islative authority to protect habitat, followed by topic pa-
pers identifying the resource base and sources of stress,
determining trends in habitat loss (including socio-eco-
nomic considerations), describing the ecological and eco-
nomic values of habitat, and applications to programs and
policies.
Contact: Bruce Newton, Office of Wetlands, Oceans, and
Watersheds, (202) 260-7076, or Tim Barry, Office of Policy,
Planning and Evaluation, (202) 260-5867.
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Lead
Rationale: Lead is a ubiquitous pollutant associated with
a variety of human health and ecological effects. A sub-
stantial number of U.S. citizens, particularly children, con-
tinue to be exposed to lead at unacceptable levels.
Focus: This cluster is responsible for implementing the
Lead Strategy, which identified major sources of lead ex-
posure and set goals for lead risk reduction. The cluster
coordinates the wide range of activity underway to im-
plement the Strategy and is further analyzing sources of
risk to refine Agency priorities. Some priorities have
already been adjusted (e.g. lead solder and plumbing fix-
tures have become high priority). The cluster is also devel-
oping an Agency strategy for managing lead in urban
soils, an important source of lead exposure, and is devel-
oping a cross-media public education program.
Contact: Doreen Cantor, Office of Prevention and Toxic
Substances, (202) 260-1777
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Nitrogen
Rationale: Nitrogen compounds are common drinking
water contaminants and are the major cause of estuarine
system eutrophication. These compounds are generated by
a wide range of sources, including fertilizers, manure, sep-
tic systems, waste-water treatment plants, industry and
automobiles. Several EPA programs and other government
agencies have authority over nitrogen sources.
Focus: The cluster team has drafted an action plan that
identifies gaps in federal government programs affecting
ground and surface water nitrogen and includes a series of
cost-effective recommendations for EPA and U.S. Depart-
ment of Agriculture programs. As a follow-up to the draft
plan, EPA and USDA have formed a work group to ex-
plore areas for cooperation. Through this process, USDA
has agreed to sponsor a technical conference on nitrogen
soil testing to give farmers a tool that would allow them to
reduce nitrogen use to economically efficient levels.
Contact: Roberta Parry, Office of Policy, Planning and
Evaluation, (202) 260-2876
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Oil and Gas Extraction and Production
Rationale: The exploration and production of oil and gas
generates wastes which are subject to regulation under the
Resource Conservation and Recovery Act, the Clean Water
Act, and the Clean Air Act. In the next few years, the
Agency will promulgate several regulations that will affect
the management of this waste.
Focus: This cluster is coordinating the collection of multi-
media environmental effects and risk information for use
in rulemaking. The cluster assisted in resolving a potential
conflict between Clean Air Act requirements for oil and
gas platforms in California and pending Clean Water Act
regulations. The cluster will also facilitate coordination of
information collection, schedules, and requirements asso-
ciated with related studies and regulations.
Contact: Mahesh Podar, Office of Policy, Planning, and
Evaluation, (202) 260-4772
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Petroleum Refining
Rationale: Refineries are a major focus of EPA's environ-
mental protection efforts. Not only are petroleum refining
and production processes regulated, but the refinery prod-
ucts themselves are subject to EPA actions. This cluster
tracks the extensive, complex set of regulations that will
affect the refining industry over the next decade, and looks
for ways to reduce burdens and improve the effectiveness
of regulations.
Focus: The cluster is currently drafting guidance for
granting temporary compliance waivers to the hazardous
air pollutant standard for benzene emissions from waste
water. The team is developing multi-media criteria for
waiver approvals modeled on a "cluster" approach pro-
posed by an oil company. The options would achieve a
level of environmental protection equivalent to that re-
quired by the current rule while providing the flexibility
companies need to construct comprehensive systems that
better manage water and solid waste while reducing air
emissions.
Contact: K.C. Hustuedt, Office of Air and Radiation, (919)
541-5395
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Pulp and Paper
Rationale: The large, diverse, and economically signifi-
cant pulp and paper industry is one of the nation's largest
sources of industrial pollution, releasing 370 million
pounds of Toxic Release Inventory chemicals in 1988. The
cluster will coordinate development of several regulations
affecting the industry over the next decade to ensure they
efficiently and effectively address risks.
Focus: The cluster assembled a single data base which it
uses to support rulemakings under several statutes. The
cluster is closely coordinating the development of two
regulations — the effluent guideline revision and the haz-
ardous air pollutant standard (NESHAP) — because com-
mon ^technologies may exist that can fulfill the objectives of
both regulations. To further the understanding of pollu-
tion prevention alternatives for the industry, the cluster is
organizing an international conference on identifying and
removing barriers to pollution prevention in the pulp and
paper industry that will be held in the summer of 1992.
The duster is developing a newsletter to advise interested
parties of its activities.
Contact: Mark Luttner, Office of Water, (202) 260-9454
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Small Communities
Rationale: Small communities often have the responsibil-
ity to implement a wide range of complex environmental
regulations. The growing number of these requirements
and the depth of current budget burdens facing small local
governments have created a heightened need to assist
communities in their environmental protection efforts.
Focus: The cluster is exploring ways to increase communi-
ties' capacity to implement environmental programs and
to ensure that regulations and programs are consistent
with the special needs of small communities. The cluster is
developing options in four areas: small government fund-
ing (including public-private partnerships); enforcement;
regulatory development; and technology assistance. The
group is also finalizing a comprehensive "plain language"
list of regulations affecting local governments, and has
been active in EPA's revision of its Regulatory Flexibility
Guidelines.
Contact: Ann Cole, Office of State and Local Relations,
(202) 260-4719
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