&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9272.0-01
TITLE: Implementation of CERCLA Strategy at Federal
Facilities
APPROVAL DATE: April 2, 1984
EFFECTIVE DATE: Aprii 2, 1984
ORIGINATING OFFICE: office of External Affairs
SPINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
E DIRECTIVE DIRECTIVE D
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03/19/87 United States Environmental Protection Agency
Washington, D.C. 20460
EPA OSWER Directive Initiation Request
1. Directive Number
9272.0-01
2. Originator Information
Name of Contact Person
COOPER
MalCode
Office
OEA
Telephone Number
N/A
3. Title
IMPLEMENTATION OF CERCLA STRATEGY AT FEDERAL FACILITIES
4. Summary of Directive (Include brief statement of purpose)
Memorandum dated from Josephine Cooper, AA for
External Affairs, to Lee Thomas, AA Oswer, on
implementation phase of Federal Facility CERCLA
Strategy. (4/84, 1 p)
5. Keywords
SUPERFUND, CERCLA, REMEDIAL PROGRAM, FEDERAL FACILITIES
6a. Does this Directive Supercede Previous Dlrecttve(8)?( [ yes | Xj NO What directive (number, title)
b. Does it Supplement Previous Directives^)?
yaa
No What directive (number, title)
7. Draft Level
A-SlgnedbyAA/DAA I I B - Signed by Office Director
C • For Review & Comment
In Development
This Request Meets OSWER Directives System Format
8. Signature of Lead Office Directives Coordinator
Date
9. Name and THle of Approving Official
COOPER
Data
04/02/84
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OSWER Directive 9272.0-1
APR 2 1984 OFFICE OF
EXTERNAL AFFAIPS
MEMORANDUM
SUBJECT: Implementation of CERCLA Strategy at Federal Facilities
FROM: Josephine S. Cooper, Assistant Administrate^
for External Affairs (> \
TO: Lee Thomas, Assistant Administrator
for Solid Waste and Emergency Response
Now that we have completed the Federal Facility CERCLA Strategy for
Al Aim, I suggest we move quickly into the implementation phase.
Reviewing the overall status of Federal facilities compliance, I am
particularly concerned that some Federal agencies have not initiated a
well-defined program for identifying and assessing abandoned hazardous
waste sites at their facilities. While 112 potential sites have been
identified at non-DOD facilities, efforts to identify additional sites,
or assess those which have been identified, are proceeding very slowly.
On the last update of the A-106 report, only 5 such projects have been
reported. Where agencies are not making progress, it is largely because
of a perception that they don't have a problem, or that their Environmental
Policy Office has been unable to gain support from top management to
initiate the needed studies to document the situation. Finally, the
absence of time-phased requirements in CERCLA are a barrier to
aggressive action unless there is top management support for the program.
I suggest that we need to meet with OMB to establish time-phased
goals for the Federal sector which could then be communicated to the
heads of Federal agencies, with assurance that OMB will support agency
budgets for the identification and assessment studies that need to be
initiated quickly. We need to personally visit some of the key policy
level officials in selected agencies. Our objective would be to
obtain full commitment for this effort from top management in these
agencies so that their staffs can initiate actions knowing that they
will be supported. If your schedule does not permit personal visits
to Federal agencies, I suggest that we discuss other ways of quickly
bringing this matter to the attention of agency heads.
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I also would like to suggest two other actions that we can take
within EPA to help define the extent of the problem. First, we need
to notify the Federal community that if they do identify additional
sites, these should be reported to our Regions so that they can be
placed on the ERRIS list. Some agencies have identified sites but
have not reported them because they believed the 103(c) requirement
to be a one-time action. Secondly, I suggest we direct our Regions
to make a quick assessment of those non-DOD sites on the ERRIS list
which have not already been investigated. Although these sites may
not have appeared to have had a high priority, I believe it is
essential to make a quick determination of the extent of the non-DOD
CERCLA problems so that we address the issue appropriately with
agency heads.
Finally, I suggest that we rapidly develop an action plan to
implement the remaining elements of the strategy. The point of
contact in my office will be Lee Herwig (382-5908) in the Office
of Federal Activities.
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