&EPA
United States
Environmental Protection
Agency
EPA 230-F-92-013
November 1992
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? 1
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 13
Summaries of Individual Clusters 14
Contaminated Media 14
Environmental Equity 15
Ground Water 16
Habitat . 17
Indoor Air 18
Lead 19
Nitrogen 20
Oil and Gas Exploration and Production 21
Petroleum Refining 22
Printing Industry 23
Pulp and Paper 24
Small Communities 25
Transportation 26
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WHAT is EPA's CLUSTER APPROACH?
EPA often has many different programs working on regu-
lations, policies, and activities that affect a single pollution
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 cluster
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-
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plementary activities.
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 EBVs 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-
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sources are focused on the most serious remaining risks,
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
* 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 thirteen clusters in operation (listed
below and described in more detail at the end of this
booklet). EPA is establishing clusters for industries affected
by new regulations developed under several statutes, for
high risk problem areas, or for other problem areas that
could benefit from a cluster approach. EPA is establishing
additional clusters as it gains experience with the cluster
approach and as new opportunities arise.
Sector-based Clusters
Oil and Gas Production and Exploration
Petroleum Refining Industry
Pulp and Paper Industry
Small Communities
Environmental Equity
Printing Industry
Transportation
Pollutant-based Clusters
Lead
Nitrogen
Resource Protection-based Clusters
Ground Water
Habitat
Contaminated Media
Indoor Air
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WHAT Do CLUSTER TEAMS Do? How DOES
THEIR WORK RELATE TO THE WORK 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 clus-
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:
> Identifying the need to change Agency priorities to better
target the most serious remaining risks;
* 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 clusters 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. Clustef 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:
Coordinated action to address a major public health risk.
The lead cluster joined with he President's Council on
Environmental Quality to launch a major public education
campaign to reduce public exposure to lead, especially
targeting lead poisoning in children.
Reduced compliance costs through better integrated
requirements. The pulp and paper cluster decreased
industry's reporting burden by conducting a single survey
to collect information in support of air, water and sludge
rules for the industry. The joint development of major air
and water rules will reduce industry compliance costs by
enabling them to make decisions in a coordinated fashion
to meet requirements of both rules.
A cross media approach which will reduce toxic
emissions. The petroleum refinery cluster will achieve this
result through an innovative approach to granting
temporary waivers to the air pollution standard for
benzene emissions. Under this approach, firms may obtain
waivers if they reduce toxic releases by an amount
significantly greater than would be required under the
new benzene standard.
Technology transfer for improved environmental
protection. Both the pulp and paper and printing industry
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clusters have been engaged in joint efforts with industry to
identify and promote the use of less polluting processes,
products, or chemicals. The nitrogen cluster has worked
with the U.S. Department of Agriculture to assist farmers
in avoiding excessive use of fertilizers. This effort has
included a workshop, newsletter, and research on simpler,
inexpensive ways farmers can determine nitrogen
concentrations in soils.
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.
Target resources on highest risks. Through analyses done
in conjunction with the lead cluster, EPA is accelerating ac-
tivities which address the highest sources of risk such as
lead paint and dust, and postponed regulation in lower
risk areas such as the disposal of lead batteries.
Improved management of cross media issues. Several of
the clusters have developed strategies and action plans to
better coordinate existing efforts and identify new
collaborative activities. The ground water cluster, for
example, has been working to ensure that the ground
water principles offered in the ground water strategy are
effectively incorporated into regulations with major
ground water impacts. About fifteen rules have
incorporated the ground water principles.
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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: The 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 sediments. The group has developed information on
the current and anticipated universe of contaminated
media sites as well as the costs and benefits of remedia-
tion, and is analyzing the impact of the current laws and
regulations on remedial actions. From this work, the
group developed objectives and principles (now in draft
form) for improving and integrating Agency clean-up
programs. These principles are helping the Agency write
major rules such as the Resource Conservation and
Recovery Act (RCRA) corrective action rule and the RCRA
"hazardous waste identification rule." Since some of the
group's recommendations could require statutory
changes, the group's work is contributing to the RCRA
reauthorization debate.
Contact: Jackie Tenusak, Office of Solid Waste and Emer-
gency Response, (202) 260-4617
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Environmental Equity
Rationale: In July, 1990, the Environmental Equity
Workgroup was commissioned to study evidence that ra-
cial minority and low income communities bore a dispro-
portionate risk of exposure to environmental pollutants.
Their findings confirmed that these groups experience
higher than average exposures to selected air pollutants,
hazardous waste facilities, contaminated fish and
agricultural pesticides. The report recommended that EPA
review and revise its permit, grant, monitoring and
enforcement procedures to address high concentrations of
risk in racial minority and low income communities.
Focus: The findings of the Environmental Equity
Workgroup led to the creation of an Environmental Equity
Cluster. This cluster works closely with the Equity Office,
and (1) Establishes Agency policies on environmental
equity issues; (2) Examines existing Agency programs to
establish baseline information, identifies gaps in pro-
grams and stimulates new and collaborative projects be-
tween programs; (3) Identifies data analysis and research
on cumulative risk in affected communities; (4) Identifies
Agency regulations and legislation with equity implica-
tions; (5) Develops long-term strategic plans and budget
items; (6) Coordinates Agency enforcement policies; and
(7) Implements and coordinates environmental equity
multimedia and multi-source risk mapping programs.
Contact: Arlene Pinknev, Office of Enforcement, (202) 260-
8895
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Ground Water
Rationale: Many of ERVs 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 Maurice LeFranc, Office of
Policy, Planning and Evaluation, (202) 260-4908
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Indoor Air
Rationale: Using EPA's resources effectively to address
indoor air quality problems presents many challenges. The
study of indoor air pollution, while relatively new, is re-
lated to Agency efforts to understand the implications of
being exposed to relatively low levels of many pollutants
for long periods of time. Also, there are specific pollutants
and sources in the indoor environment that are recognized
as having the potential to pose serious health threats.
Several Agency offices are responsible for developing poli
cies and programs to implement the statutes which give
EPA authority for a wide range of regulatory and non-
regulatory actions.
Focus: At the inception of the indoor air cluster, three
goals have been articulated: (1) to develop an Agency-
wide indoor air strategy; (2) to coordinate policy
development and program implementation actions that
offer important environmental health benefits and; (3) to
improve communication and coordination with outside
groups. In the near term, the principal tasks of the cluster
will be to prepare an Agency-wide strategy for indoor air,
to compile a list of the lAQ-related policies, guidance and
regulations affecting key constituencies, and to
establish a process to ensure that significant policy deci-
sions are reviewed by the duster management committee.
Contact: Sandra Eberle, Office of Air and Radiation, (202)
233-9722
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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 duster
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, iridustry 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 Exploration and Production
Rationale: Th£ 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
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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 Water, (202) 260-5387
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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 ef-
fectiveness 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: Steve Harper, Office of Air and Radiation, (202)
260-8953
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Printing Industry
Rationale: Nearly 80% of the over 62,000 printing
establishments in the United States employ less than 20
people. These printing businesses use a variety of solvents,
inks, adhesives, and clean-up washes that pose significant
threats to human health and the environment. Yet, small
printers often do not have the resources necessary to
comply with the complex and growing number of
environmental regulations and reporting requirements.
Nor do they have information about the comparative risks
associated with the hundred of product alternatives
available to them.
Focus: The Printing Industry Cluster has three basic
program elements. First, the Printing Cluster coordinates
regulations from different EPA Program Offices which
apply to printers. Second, it develops an integrated
permitting/reporting pilot program for the printing
industry to help small printing companies comply with all
relevant EPA regulations. Third, the cluster provides
technical assistance through the Design for the
Environment Printing Project to evaluate safer substitutes
for printing processes and to interpret that information for
small printers.
Contact: Mary Ellen Weber, Office of Pollution, Prevention
and Toxics, (202) 260-0667
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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 was held in September, 1992. The
cluster 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: Local governments and small communities are
responsible for implementing a wide range of complex
environmental regulations. The growing number of these
requirements and the depth of current budget burdens
facing local governments and small communities have
heightened the need to assist them in their environmental
protection.
Focus: In concert with local officials, state officials, public
interest groups and environmentalists, the cluster is
identifying and implementing a series of projects to
improve the implementation of environmental programs
by local governments and small communities. Such
projects could recommend procedural changes in
regulatory development, and identify needed changes in
legislation. These actions will address unmet local
environmental goals caused by limited financing;
inflexible requirements resulting from the nature of
regulations, lack of communication and coordination
among various governmental agencies and programs, and
the inability to develop priorities as to the problems to be
addressed; and the need for data and information on the
costs and benefits of regulation and on the technical,
scientific and legal aspects of regulation.
Contact: Ann Cole or Lou Kerestesy, Office of Regional
Operations and State/Local Relations, (202) 260-4719
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Transportation
Rationale: The Intermodal Surface Transportation Effi-
ciency Act (ISTEA) of 1991 makes EPA a partner with the
Department of Transportation (DoT) in U.S. transportation
policy making. Environmental protection requires good
transportation policy, and the new Act, in combination
with the Clean Air Act, broadens EPA's relationship with
DoT significantly. The new relationship and EPA's new
responsibility require the agency to closely coordinate
numerous transportation-related activities, and to estab-
lish an institutional link to DoT. Transportation policy
development also draws on numerous disciplines to meet
oft-conflicting needs.
Focus: The cluster will have three basic functions: internal
coordination, external coordination, and development and
implementation of new projects which do not fall under
the aegis of any existing office. The duster is providing a
forum in which to assemble a pollution prevention strat-
egy for the transportation sector, and will provide a focus
for EPA's participation in ISTEA implementation. A joint
EPA/Federal Highway Administration task force already
expects the duster to provide rapid inter-disciplinary
review of a study on the risks associated with recycling
tires into asphalt.
Contact: Will Schroeer, Office of Policy, Planning, and
Evaluation, (202) 260-1126
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