&EPA
Information Transfer
State/EPA Agreement
Tracking Systems
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Information Transfer
State/EPA Agreement Tracking Systems
August 1980
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CHAPTER I
I.A. INTRODUCTION
The State-EPA Agreements (SEA) are management and communication
documents that can be used by the States, Regions and EPA Headquarters
to direct attention and resources toward resolution of priority
environmental issues. Many environmental problems do not respect
arbitrary categories and, hence, cannot be solved in a purely categorical
manner. The central aim of the SEA process is to address those environmental
problems in a comprehensive way, not limited by sometimes artificial
programmatic constraints. The process of developing solutions to particular
problems, and then monitoring the progress of those solutions is crucial to
SEA effectiveness.
I.E. PURPOSE
The purpose of this study is to examine selected existing regional
SEA tracking and evaluation systems, to explain how they work at present,
and how they may be refined and improved in the near future. This
report is designed to be a vehicle for information exchange among the
Regions, and between the Regions and Headquarters, with the aim of en-
couraging improvements in SEA tracking and evaluation at all levels within
the organization. Hopefully, each Region can draw upon the experiences
of other Regions to selectively amend its process according to its needs
and circumstances.
I.C. METHODOLOGY
The information provided in this report was collected through the use
of telephone interviews to managers in all Regions, and through visits to
five selected Regions. Regional managers and administrators concerned
with the SEA process were interviewed to obtain a detailed view of existing
SEA tracking and evaluation systems. The particular emphasis of the
interviews was to determine how tracking and evaluation is accomplished as
it relates to progress toward product or project completion, problems which
arise, resource allocation and adherence to schedules.
I.D. OVERVIEW
Chapter II presents a brief summary of the status and context of Re-
gional tracking and evaluation systems. Chapter III provides the back-
ground information on the Regions surveyed by telephone as well as those
visited. The information obtained by telephone is general in nature and
not meant to be all inclusive. Chapter IV presents a review, analysis,
and comparison of the Regional tracking and evaluation systems.
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CHAPTER II
II.A. SUMMARY OF FINDINGS
All Regions have developed, and in most cases, implemented an SEA
tracking and evaluation system. A summary of the significant features
of the systems can be seen in Figure II-l.
Each Region has built its tracking system upon the personal contacts
and reporting procedures which were in operation prior to the implementation
of the 3EAs. Eight Regions have formalized their tracking process and
make use of such supporting mechanisms as quarterly reports, summary
reports, mid-year reviews, end-of-year evaluations and SEA work plan amend-
ments. It is generally agreed by the Regions that the purpose of an SEA
tracking and evaluation system is to provide information for use by managers
at various organizational levels, particularly those in the RA's office
and on the problem-solving committees of Division Directors. Internal
program tracking at EPA and activity progress reporting within the States
are the sources of the management information.
The tracking systems are operated by the SEA coordinators with the
participation of EPA and State Project Managers, Division Directors, Branch
and Section Chiefs and other persons identified as being responsible for
an SEA activity. Making the SEA process work requires State and EPA program
managers to engage in a joint management process. This has resulted in
the identification of mutually agreed upon priorities and commitments to
be carried out; and fixes the commitments and responsibilities of both the
States and EPA. The SEA tracking and evaluation systems devised by the
Regions provide information which does enable senior managers to focus on
priority problems and issues.
The tracking systems now in effect vary in the details of how they col-
lect and distribute information, but they all seek to collect basic types of
management information with as little additional reporting effort as possible.
The most common approach being explored by the Regions is to combine SEA
tracking with the current Grants Program reporting. Although efforts in this
direction are far from complete, many useful and time-saving practices have
been developed to combine the collection and display of information from the
two reports.
The types of information collected by the Regions for the purposes of
SEA tracking and evaluation deal with: responsibility for a given activity;
the timeliness of the completion of an activity; and a short narrative of
progress which highlights problems and completed activities. A few Regions
are attempting to incorporate the collection and use of manpower and budget
information into their tracking and evaluation systems.
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The Information collected is also evaluated in different ways.
Some Regions rely on the SEA Coordinator to synthesize data and pass
on problems for resolution within the normal regional management
structure. Others have created review or oversight committees specif-
ically designed for SEA evaluation and problem resolution. All Regions
incorporate on-site reviews into their process, most concentrating on
mid-and end-of-year cycles.
In summary, SEA tracking and evaluation has commenced in the Regions.
Some Regions are more advanced than others and have, through experience,
developed processes that effectively meet their needs. The remaining
Chapters of this study describe and analyze some of these systems. A
careful review by interested Regional managers will reveal similarities
with their own situations and provide a variety of approaches to developing
tracking and evaluation processes which will enhance their managerial
capabilities and reduce unnecessary administrative effort.
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FIGURE II-1
SUMMARY OF STATE/EPA AGREEMENT TRACKING AND EVALUATION PROGRAMS
REGION CRITERIA
TRACKING SYSTEM
;«
REPORTING;
FORMAL
INFORMAL
ON-SITE VISITS
TO STATE
EVALUATION
MONITORED BY
STAGE OF
DEVELOPMENT
1
Yea
Quarterly
Mid-Year
Ongoing
As-Needed
SEA Co-
ordinator
Operating;
Subject to
Minor
Refinement
2
Yea
Mid-Year
Quarterly
Mid-Year
SEA Co-
ordinator
Operating;
Refinements
Continue
to Evolve
3
Yea
Mid-Year
Monthly
Quarterly
Mid-Year
SEA Co-
ordinator
Operating;
Refinements
Continue
to Evolve
4
Yes
Quarterly
Ongoing
Mid-Year
Sea Co-
ordinator
Operating;
Refinements
Continue
to Evolve
5
Yes
None
Mid-Year
Mid-Year
SEA Co-
ordinator
Would Like
to Start
Next Year
Conceptual;
Provisional
Operation
6
Yes
Quarterly
Quarterly
Quarterly
SEA Co-
ordinator
Attempting
to Track
Some
Commitments
Operating;
Subject to
Minor
Refinements
7
Yes
Quarterly
Ongoing
Quarterly
SEA Co-
ordinator
2 Staff
Operation
Fairly
Complete;
Improvements
Underway
8
Yes
Mid-Year
Quarterly
Reports
Ongoing
Monitoring
lid-year
SEA Co-
ordinator
1 Staff
Conceptual;
Provisional
Operation
9
Yea
Mid-Year
Quarterly
Mid-Year
Mid-Year
SEA Co-
ordinator
1 Staff
Operating
10
Yes
Quarterly
Mid-Year
Ongoing
Mid-Year and
Monthly
SEA Co-
ordinator
1 Staff
Operating;
Refinements
Continue
to Evolve
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CHAPTER III
This Chapter describes the current SEA tracking and evaluation efforts.
The first section deals with Regions I, VI, VII, VIII and X, which were
visited by the study team. This section discusses the Regions' tracking
and evaluation processes, notable characteristics of existing systems, and
improvements to the processes that the Regions will try to make during FY
1981. A list of regional staff members interviewed is presented in Appendix
A.
The second section presents a summary description of the SEA tracking
and evaluation systems in Regions II, III, IV, V and IX, the five Regions
which were not visited. This information is very general in nature and
far less detailed than in the case of Regions that were visited.
III.A. SECTION I - REGIONS VISITED BY THE STUDY TEAM
III.A.I. REGION I
PROCESS
Region I's State/EPA Agreements identify the chief environmental issues
in each State. These issues, usually 12 in number, are identified during the
development of the SEA by Division Directors, the SEA coordinator, the DRA and
State Officials. Commitments made by the States and EPA to address these is-
sues are tracked by a key senior management group called the Grants Policy Com-
mittee. This Committee is made up of the Division Directors, the SEA Coor-
dinator, and is chaired by the Regional Administrator or Deputy Regional Ad-
ministrator. The SEA tracking and evaluation system is operated by the SEA
Coordinator in Region I's Management Division.
The SEA tracking system in Region I is summarized in Figure III-l. It
is built around the concept of designating project managers for each issue
in the Region and in the States. The joint responsibility for the tracking
and managing of SEA priorities increases the level of communication between
the States and the Region and creates a greater degree of accountability.
Each project manager is charged with the responsibility of facilitating the
completion of one or more priority commitments and serving as the manager and
spokesman for tasks which related to it, and for seeing that its progress is
reported to the SEA Coordinator.
FEATURES
Region I tracks its priority issues quarterly. The
SEA Coordinator sends out a memorandum and reporting
form (sample form in Appendix B) to project managers
before the end of each quarter.
Project managers assess the status of their issues
and note accomplishments, significant problems and
any other items of concern and return the reporting
forms to the SEA Coordinator.
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FIGURE III-l
REGION I
STATE/EPA AGREEMENT TRACKING PROCESS
MANAGEMENT LEVEL
TRACKING ACTIVITY
Quarterly
Semi-Annual
Regional Administrator/
Deputy Regional
Administrator
Grants Policy Committee
Division Director
SEA Coordinator
Project Managers
Review and act on SEA
issues which are not
on track; submit formal
letter of concern to
states
Review status of major
or exceptional unre-
solved SEA problems;
report-issues to the
RA
Monitor routine Grants
Program activities
and attend to pertinent
problems noted in SEA
tracking report
Ensure reporting of
progress by project
managers; prepare SEA
progress reports for
Grants Policy Committee
Complete quarterly
progress report on SEA
issues; when significant
problems are identified
discuss solution with
Grants Policy Committee
Same as quarterly
Same as quarterly
Same as quarterly
Same as quarterly
Same as quarterly
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The SEA Coordinator analyzes the information, and
prepares a summary of notable SEA accomplishments
and problems which may warrant the attention of the
RA and the Grants Policy Committee.
The Division Directors review the SEA report with
regard to their programs, and where possible, recom-
mend actions to resolve difficulties. The Grants
Policy Committee and the RA review exceptional un-
resolved problems and make the decisions necessary
to deal with them. In some instances a major prob-
lem may require formal contact between the RA and a
senior representative of a State agency.
Division Directors are responsible for dealing with
problems noted by the SEA tracking system and also
for the monitoring of routine grant activities which
are not highlighted by the SEA. This permits the
RA to.'/devote his attention primarily to high-priority
issues which come to light through the SEA. Grant
work plans which include routine activities are not
tracked by the SEA process.
DESIRED IMPROVEMENTS
Regional staff members identified several improvements they would like
to make for tracking the FY 1981 agreements. These are:
Reinstitute more detailed mid-year and end-of-year
reviews with Senior Management in each State.
Prepare the FY 1981 SEAs in a format which will fa-
cilitate tracking (see Appendix C for a sample of
the proposed format).
Incorporate the tracking of resources (both finan-
cial and manpower) into the SEA tracking and evalua-
tion system. This is intended to give the Region
the ability to relate projected expenditures of time
and money to the level of resources the activity is
actually requiring.
III.A.2. REGION VI
PROCESS
SEA tracking and evaluation activities in Region VI are headed by the SEA
Coordinator in the RA's office. Other key actors involved in the system are:
EPA and State Staff team leaders who are responsible for a specific SEA commit-
ment; Division Directors; and the Deputy Regional Administrator and Regional
Administrator. The emphasis is on tracking State SEA priority activities,
with EPA commitments addressed primarily through internal management procedures.
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The SEA priority tracking system in use in Region VI seeks to provide
top management with qualitative management information about SEA progress.
This information is collected at the staff level and reported to management.
The reporting process isolates for attention only those matters which repre-
sent departures from the expected schedule and pattern of events. Thus, top
management efforts are focused only on unresolved problems or issues that
need their attention. A summary of the tracking and evaluation process for
Region VI is presented in Figure III-2.
FEATURES
Priority issues are identified and staff persons in
EPA and State are designated as team leaders for
each issue. They are responsible for monitoring and
tracking.
The team leaders formally track progress on a quarterly
basis, while informal reporting takes place continuously.
Semi-annual visits to the States are made by the EPA
team leaders and status reports are prepared and sub-
mitted to the SEA Coordinator.
The SEA Coordinator summarizes the material provided to
him by the task leaders and notes any exceptional prob-
lems. (See summary of SEA status report form in Appendix
D.) Highlights of significant accomplishments are also
noted at this time. This information is then listed by
State on a 1-2 page summary sheet and forwarded to the
RA and the Division Directors.
The Division Directors see that the recommended actions
are taken and that problems are resolved. Any antici-
pated problems which may affect future work progress
can also be addressed in these sessions.
It is anticipated that the RA, DRA, Division Directors,
and SEA Coordinator will meet in the future to , discuss
the problems which are highlighted in the summary sheet
and take appropriate action.
At present, budget and manpower information is not re-
ported in the SEA priority tracking system.
DESIRED IMPROVEMENTS
Region VI will attempt to improve the SEA tracking and evaluation process
for FY 1981 by concentrating on three aspects:
Incorporating budget and manpower estimates into its
tracking process.
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FIGURE III-2
REGION VI
STATE/EPA AGREEMENT TRACKING PROCESS
MANAGEMENT LEVEL
TRACKING ACTIVITY
Regional Administrator/
Deputy Regional
Administrator
Division Directors
SEA Coordinator
Team Leaders
Quarterly
Meet with team leaders on
serious problems; meet
with Division Directors
and SEA Coordinator to
review progress and prob-
lems, and identify policy
actions needed; take nec-
essary actions to resolve
problems; interface with
senior state management.
Review progress and prob-
lems with Regional Admin-
istrator, Deputy Regional
Administrator, and SEA Co-
ordinator and identify
actions needed; supervise
team leaders in implement-
ation of decisions
Attend review meetings,
summarize team leader
reports and provide them
for review meetings
Responsible for reporting
progress to SEA Coordinat-
or; formal and informal
contact with state count-
erpart; implement actions
determined by senior
management
Semi-Annual
Same as quarterly
Same as quarterly
Same as quarterly
Formal progress and problem
review meeting with state
counterpart; all quarterly
activities
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Developing an integrated, multi-media, multi-year,
problem-solving approach to SEA priorities and com-
mitments in FY 1981.
Developing commitments and activities that are more
quantitative and thereby more easily tracked.
III.A.3. REGION VII
PROCESS
Although the SEAs developed in Region VII focus on the SEA priority
issues, they include the work plans for all media programs by reference.
Region VII defines its priority issues with problem statements, a description
of the problem background, goal statements, and commitments to achieve the
goals. The commitments are explicitly written to facilitate tracking. A
list of these commitments is presented in Appendix K.
The SEA tracking and evaluation system is designed to report progress
and problems to senior management. The system is designed to combine report-
ing of SEA commitments, PPA's and program grant activities into one process.
This enhances program coordination and reduces the reporting burden. The
system is operated out of the Office of External Affairs by the SEA Coordinator
and his staff with the aid of a Policy Review Committee. The Policy Review Com-
mittee is chaired by the Regional Administrator and includes the Deputy Regional
Administrator, Division Directors, Director of External Affairs and the Regional
Counsel. The Branch Chiefs and Section Chiefs are responsible for carrying out
EPA commitments. This process is summarized in Figure III-3.
To a very great extent, Region VII has been able to institutionalize the
mechanics of an SEA priority commitment tracking system. Reception of the
system by the States and the Regional staff has been quite good.
FEATURES
Before the end of each quarter, reduced photocopies of
the SEA commitments (directly from the Agreement) are
distributed by SEA staff, to each State in Region VII
and each Division within the Regional office for track-
ing purposes. SEA staff notes the parties responsible
for each commitment (see Appendix E). In most instances
SEA staff also notes the milestones which were identified
in the work plans as being due that quarter.
The recipients respond on the reporting form with nota-
tions regarding progress in meeting SEA. commitments and
with the information required by the Planned Program
Accomplishment (PPA). The recipients also identify and
explain any problems encountered or deadlines missed and,
in some instances, note any anticipated problems which
might cause delays on future commitments. Notable ac-
complishments during the past quarters are also included
on the reporting form.
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FIGURE III-3
REGION VII
STATE/EPA AGREEMENT TRACKING PROCESS
MANAGEMENT LEVEL
TRACKING ACTIVITY
Regional Administrator/
Deputy Regional
Administrator
Policy Review Committee
Division Directors
SEA Coordinator
Branch Chiefs/Section
Chiefs
Quarterly
Review exception reports;
deputy chair Policy Re-
view Committee; oversee
implementation of de-
cisions; contact senior
state management as
needed
Review exception reports
and determine actions
needed
Participate in decision-
making; supervise actions
necessary to implement
decisions
Collect progress reports;
prepare exception report;
facilitate program inter-
action and communication
with the States
Complete quarterly pro-
gress reports; informal
regular contact with
state counterparts
Semi-Annual
Same as quarterly;
attend mid-year and
year-end review
session with states
Same as quarterly
Same as quarterly,
attend mid-year and
year-end reviews
with States
Same as quarterly;
attend mid-year and
year-end review sessions
with states
Same as quarterly
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These reporting forms are completed and returned to SEA
staff in accordance with a schedule for tracking sent
out to the Region VII States and the EPA Divisions within
the Region. This schedule lists the due dates for tracking
reports and meetings throughout the year. It is distributed
in mid-December of the previous year. (See Appendix F -
Schedule of Activities).
* The SEA staff collects the forms from the States and EPA
Divisions and prepares an exception report which lists all
unfulfilled commitments and notable problems. This report
becomes the basis for discussion and action by the Policy
Review Committee.
The Region combines SEA priority commitments, PPA's and
Grants on one form and in one report. (See Appendix G).
This aids in coordinating reporting functions and reduces
the reporting burden.
* The Region has defined and implemented an SEA amendment
process. A copy of a letter of amendment is included in
Appendix H.
* The next quarter's reporting forms show the progress from the
previous quarter. This permits respondent and reviewer to
compare progress from quarter to quarter.
* Formal evaluation meetings between EPA and the States are
held to discuss unfulfilled commitments only during mid-year
and end-of-year review sessions. At other times informal
follow-up and discussions of problems and commitments both
of the States and EPA may take place via telephone and
on-site visits.
Any changes to the SEA commitments or work plans must be
documented in a letter to the RA which discusses the desired
amendment and any foreseeable repercussions it might have on
the priority issue.
DESIRED IMPROVEMENTS
During FY 1981 the Region would like to incorporate the following
improvements to the SEA tracking and evaluation system:
* Incorporate manpower estimating and tracking into the system.
* Incorporate budget estimating and tracking into the system.
Investigate ways to further simplify the mechanics of the
reporting process.
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III.A.4. REGION VIII
PROCESS
Region VIII uses the SEA as a device to identify and manage all
State and EPA activities which fulfill priority objectives. Each Division
Director is responsible for developing one SEA in the Region. The Resources
Management Branch coordinates the SEA process for the Region. For the purpose
of tracking and evaluation, the Region focuses its attention on the most
important issues which have been identified in the SEA by the Division
Directors. All other grant activities are'tracked, but problems are usually
dealt with more routinely within the programs.
The tracking process currently in use in Region VIII is a two-tiered
.system designed to provide information to Division Directors and the RA's
office. The system, somewhat informal at this time and still in its early
stages, provides EPA staff with the opportunity to discuss the fulfillment
of SEA commitments with their State counterparts. The system is summarized
in Figure III-4.
FEATURES
* The grant work programs are incorporated into the SEAs.
The key activities in the work programs are the items
which are tracked as priority objectives for the SEA.
* Branch and Section Chiefs under each Division Director
are in charge of reporting progress toward meeting SEA
commitments on an ongoing basis. (Note: each Division
Director in Region VIII is responsible for one SEA.)
This is done by both formal and informal means, depending
on which staff must enter a narrative of progress for a
stated priority commitment. Others use informal meetings,
telephone conversations, etc., to keep informed about SEA
progress.
Branch and Section Chiefs, keep the Division Directors
informed of any existing or potential problems associated
with the fulfillment of priority commitments. Division
Directors work with Branch and Section Chiefs to deal
with the problems they have highlighted.
* Formal reporting is done quarterly and covers a review and
evaluation of EPA commitments, State commitments, and the
identification and resolution of problems. In many cases,
this involves visits to the States to work out solutions or
update work plans.
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FIGURE III-4
REGION VIII
STATE/EPA AGREEMENT TRACKING PROCESS
MANAGEMENT LEVEL
TRACKING ACTIVITY
Tier I
Regional Administrator/
Deputy Regional
Administrator
Division Directors
SEA Coordinator
Tier II
Division Directors
Branch Chiefs
Quarterly
General State review at
monthly senior staff meet-
ings; make appropriate
policy decisions and
actions
Provide brief status re-
port as necessary at
monthly senior staff
meeting
Prepare RA Tracking Log,
provide progress informa-
tion as required
Receive formal and in-
formal reports from Branch
and Section Chiefs, take
necessary actions to re-
solve problems
Prepare formal or in-
formal reports for
Division Directors; carry
out necessary actions
Semi-Annual
Indepth review with states
at mid-year review meeting
Indepth review with states
at mid-year review meeting
Assist in preparation of mid-
year briefing books
Same as quarterly
Same as quarterly
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The SEA tracking system is used to provide pertinent
information to the RA's office on high priority issues
and problems through the RA Tracking Log (See Appendix I.)
The RA Tracking Log consists of schedules and status
information for activities or commitments which EPA staff
feel are extremely important and warrant attention of the
RA and DRA. Activities other than those related to the
SEAs may be included. Specific problems and areas where
upper-level attention is needed are noted and the RA's
office reviews and suggests a course of action, usually
at a monthly senior staff meeting.
The Division Directors' and RA's comprehensive review of
State activities generally takes place at mid-year and end-
of-year meetings with the States. The Divisions prepare a
status report of accomplishments and problems, based upon
the quarterly reviews and RA Tracking Log, which becomes
a briefing book for the RA and DRA and serves as the focus
for the mid-year and end-of-year reviews.
DESIRED IMPROVEMENTS
Region VIII would like to incorporate the following improvements in
its SEA tracking system
* Develop computer software programs to facilitate the mechanics
of tracking progress.
* Write SEA commitments in a format which lends itself more
readily to tracking.
Develop a tracking system evaluation methodology so that
information from the tracking system can be synthesized and
analyzed in a timely and useful manner.
Track progress against resource commitments as well as outputs
and relate the two.
* Improve the linkage between SEA commitments and PPAs.
III.A.5. REGION X
PROCESS
Region X is attempting to use the SEA and performance agreements as means
of implementing a management concept titled, "Managing for Environmental
Results." This concept has been summarized in a paper presented at the 41st
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FIGURE III-5
REGION X
STATE/EPA AGREEMENT TRACKING PROCESS
MANAGEMENT LEVEL
Regional Administrator/
Deputy Regional
Administrator
Division Directors
Operations Office Directors
SEA Coordinator
Branch Chiefs
Quarterly
Review progress with
Division and OPS Di-
rectors and make
appropriate policy
decisions or take
necessary actions.
Review progress and
assist in policy
decision making and
action implementation.
Prepare summary
progress reports;
review progress with
RA/DRA and Division
Directors at monthly
senior management
meetings. Meet with
State counterparts
on a routine basis.
Facilitate communica-
tions; prepare and
operate computerized
tracking program;
prepare regionwide
progress report.
Prepare progress re-
port on priority
issues they are
responsible for;
attend review meet-
ings as required.
Semi-Annual
Same as quarterly; meet
with State counterparts.
Same as quarterly; meet
with State counterparts
in formal review session.
Same as quarterly; meet
with State counterparts
in formal review session.
Same as quarterly; meet
with State counterparts
in formal review session.
Same as quarterly.
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National Conference of the American Society for Public Administration in
April 1980. I/
i
In essence, Region X uses the SEA to identify priority environmental
problems, define strategies to solve those problems and fix responsibility
for the work needed to carry out the strategies. The process is seen as
a method to establish several levels of accountability in both the Region
and the States.
The Region's tracking system has been designed with this concept in
mind. A chart presenting the steps in the SEA development process and
their interrelationships is presented in Appendix J.
The organizational structure of Region X is different from that of the
other EPA Regions. Each State has an EPA Operations Office (OPS) which is
responsible for administering the grants. The Divisions in the Region X
Office work with the OPS offices to meet EPA commitments and oversee State
activities. The Resources Management Branch is responsible for coordinating
the SEA process.
FEATURES
OPS Office Directors are responsible for keeping track of
priority commitments identified in the SEA for their
respective States and routine State grant activities.
The process that is generally followed is presented in
Figure III-5.
Key priority activities are determined in meetings by
Division Directors, OPS Office Directors and the DRA.
In most instances, these commitments are monitored through
formal monthly progress reporting meetings and through
informal day-to-day contact with State counterparts.
OPS Office Directors and EPA Regional Division Directors
report quarterly, through the SEA Coordinator, concerning
the status of the SEA commitments. They give particular
emphasis to problems.
* The EPA Regional Division Directors are responsible for
tracking activities that EPA is committed to in the SEA.
Work plans are prepared and responsible individuals on the
staff are identified for a given SEA activity. Responsibility
for this activity is then translated into a personnel
performance agreement.
* Along with the quarterly reports, a review meeting is held
with OPS Directors, Division Directors, the RA and DRA and
37 Managing for Environmental Results, L.E. Coate and J.T. Fujita, U.S. EPA
Region X. Paper presented at NASPA Conference, San Francisco, CA, April, 1980.
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selected EPA program staff. A more formal and detailed
meeting is held for the mid-year review with State Agency
Directors. The outcome of these quarterly meetings is
usually a resolution of a problem through a policy decision
or a selected course of action. This can result in amend-
ments to the SEA's and the performance agreements.
DESIRED IMPROVEMENTS
During FY 1981 Region X will attempt to improve its tracking and
evaluation system as follows:
Write the commitments in a format which will allow easier
tracking and evaluation.
Write summaries of the commitments.
* Develop performance indicators which provide a better link
between SEAs, performance agreements and environmental results.
Complete computerization of the reporting.
III.B. SECTION II - REGIONS NOT VISITED BY STUDY TEAM
III.B.I REGION II
This Region centers most of its SEA tracking activities on the mid-year
review and quarterly reports circulated to managers and staff at the Regional
and State level. The SEA Coordinator conducts an on-site review with State
representatives and receives a letter of progress from Branch and Section
Chiefs regarding SEA activities. From this review the Coordinator prepares a
list of issues relating to commitments. A staff-level review is then conducted
to resolve as many problems as possible and put activities back on course.
Then, to deal with problems or issues which have not been resolved, an
executive-level review is held. The staff-level review consists of a meeting
between Branch and Section Chiefs and Division Directors. The executive-level
review is held through the RA's office and policy decisions or actions may
result in contact with State Commissioners.
III.B.2. REGION III
Project Officers (program managers drawn from various Regional divisions)
keep track of SEA commitments on a monthly basis according to their own
internal management system some involving telephone conversations with
relevant state counterparts. At the end of each quarter a status meeting
with the State representatives and Project Officers is usually held.
At the end of the second quarter a more formal mid-year evaluation is held
(also covering grant activities). A large meeting of key State staffs and
Division Directors, Branch Chiefs and Section Chiefs is held for all programs.
They deal with existing problems, justify or explain missed deadlines and
generally chart the course for the remaining six months.
-20-
-------
Important issues which were not resolved by this meeting are sent to
the RA and Secretaries of the State Departments of Natural Resources to
resolve at the policy level.
III.B.3. REGION IV
Project Officers in the State Operations Branch, Office of Program
Integration and Operations, deal with the grants in the SEAs and also monitor
the commitments. The actual SEA tracking is done in the programs (water,
air, solid waste).
Two task leaders, one at'the State level and one in the Region, are assigned
to each priority issue. They work together to coordinate the efforts of their
individual offices. They also work with the project officers in the State
Operations Branch to make them aware of any problems or issues regarding the
work to be done. Quarterly reporting is also done for the grants in the SEA
(this includes on-site visits to review grant budgets and management problems).
A reporting form is used to communicate from task leaders to Project Officers
quarterly. As a result of these reports the task leaders and project officers
can determine which issues or areas need attention. The task leaders periodically
brief the RA and other top managers on progress and major problems.
III.B.4. REGION V
I
The tracking and evaluation system for SEA commitments is still in the
early stages of evolution in Region V. Although attempts at tracking have
not been formalized, the Region has many ideas about what it would like to
do. Most notable is an intention to place the emphasis on environmental
problem-solving and linking EPA guidance to program plans.
Much of the existing effort toward tracking centers around the mid-year
evaluations. Near the end of the second quarter the Division Directors and
SEA coordinator review the products and performance on SEA commitments.
Exceptional problems are reviewed and acted upon by the State Coordinators
in the RA's office.
At the same time, the SEA coordinator reviews SEA commitment progress
through the use of an informal tracking file. He does this by occasionally
(usually quarterly) reviewing SEA activities against the list of commitments.
The system is currently very unstructured and the Region would like to make
significant improvements in it by the next year.
III.B.5. REGION IX
Region IX is instituting a tracking system which will track SEA commitments
through the grant mechanisms wherever possible. Those SEA items, not covered
by a grant program will be tracked by the appropriate SEA project officer.
Day-to-day tracking is conducted informally by direct contact and communication
between EPA Regional and State staff. More formal evaluation will take place
quarterly and at the mid-year and end-of-year evaluations. The quarterly
reviews will make use of the State Agencies Quarterly Progress Reports. These
reports will be reviewed by EPA Branch Chiefs and Project Officers along with
appropriate State personnel. Problems that can be resolved will be handled
-21-
-------
on the spot and those that cannot or any major slippage will be forwarded
to the SEA Task Force, composed of Division Directors, State Branch Chiefs,
and SEA project officers for resolution.
The mid-and end-of-year evaluations will again deal with SEA progress
and will bring together EPA Division Directors and State Agency Executive
Offices to assess SEA progress. As in quarterly reviews, unresolved problems
will be referred to the SEA Task Force for action.
-22-
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CHAPTER IV
REVIEW AND ANALYSIS
The purposes of this chapter are to identify the basic characteristics
of the SEA tracking and evaluation systems examined during the Regional
visits and to discuss those features which are considered to be most effective.
It is neither feasible nor desirable to propose that a standardized system
be implemented in all Regions. However, system components that have proven
useful in one Region may be transferable to others. Such "technology transfers"
can help improve tracking and evaluation nationwide while preserving the
Regional individuality that is so important to the solution of their specific
environmental problems. It is to facilitate these transfers that noteworthy
characteristics of the regional systems are selected and discussed in the
following pages.
IV.A. TRACKING AND EVALUATION CHARACTERISTICS IN THE REGIONS
The characteristics of SEA tracking systems in effect in the Regions
visited have been divided into two categories: (1) those which are concerned
with the process of tracking (including the organizational structure of the
tracking system), and; (2) those which deal with the content of the tracking
report and the degree of evaluation of the information the system provides.
Figure IV-1 lists these characteristics and identifies the Regions in which
they have evolved.
IV.A.I. TRACKING PROCESS AND ORGANIZATION
The group of characteristics which relate to the process of tracking
encompasses the development and definition of priority commitments, the
collection of tracking information, amendment of the SEA, and review and
contact between State and EPA personnel. The basic organizational structure
of the tracking system has proven to be quite similar in all Regions visited.
Although there are minor variations, the conceptual framework for the process
and organization of the systems is shown in Figure IV-2. Two notable
organizational differences in assignment of personnel to the functiovxs of
monitoring and evaluation have been noted. One is to assign a senior EPA
manager (usually a Division Director) and a State counterpart to be responsible
for tracking all of a State's SEA issues. In the second approach, a project
manager (or project officer) is named at both the EPA and the State to be in
charge of tracking each particular issue. Each approach is useful in the
respective originating Region and provides an internal checking mechanism to
help insure that commitments are not overlooked.
IV.A.2. REPORT CONTENT AND EVALUATION
To date, the emphasis of regional tracking efforts has been placed on the
collection of SEA progress information. Now that the SEA tracking process is
becoming refined through its implementation, Regions are shifting their
attention towards evaluating and using the information that the system provides
them. This is evident in the variety of summary reports which have been
developed for varying levels of management.
EnvironmeaSsI Protection Agency
ton, D.C,
d,j
-------
FIGURE XV-1
\
SEA TRACKING AW) EVALUATION SYSTEM CHARACTERISTICS
CHARACTERISTICS
REGION
TRACKING PROCESS AND ORGANIZATION
1. Commitments Written in
Specific Trackable Format
2. Specific Reporting Format
3. Exception Reporting
4. Combined SEA, PPA and
Grants Reporting (same form)
5. Specific Progress Reporting
Activity Schedule
6. Quarterly Reports
7. Mid-year Reports and
Meeting with States
8. Year-end Review
9. Formal SEA Amendment Procedure
10. Computer Assisted Tracking
11, Senior Management Review
Committee
12. Project Managers Responsible
for each Issue
13. Senior Level Manager
Responsibile for one State ?'s
SEA Activities
14. Tracking System can be used by
Staff to Present Issue Status
Directly to RA
I
*
X
X
X
X
*
X
X
X
VI
X
X
X
X
X
\
X
X
VII
X
X
X
X
-
X
X
X
X
x
X
X
VIII
*
x'
X
X
X
X
X
*
*
X
X
X
X
X
X
X
X
*
X
x = Currently implemented to some degree
* = Planned implementation in FY 81
-2k-.
-------
FIGURE IV-1 (Cont'd)
SEA TRACKING AND EVALUATION SYSTEM CHARACTERISTICS
CHARACTERISTICS
REGION
REPORT CONTENT AND EVALUATION
15. Progress Related to
Environmental Results
16. Specific Evaluation
Methodology
17. Progress Reporting on
Meeting Milestones
18. Progress Reporting on
Meeting Manpower and
Grant Estimates
t \
19. Integration of SEA and
Performance Agreements
20. Review of Future Planned
Activities
I
X
*
VI
X
X
X
VII
X
X
*
X
VIII
*
*
*
X
X
X
*
X
X
x = Currently implemented to some degree
* - Planned implementation in FY 81
-25-
-------
Very little effort has been expended on the tracking of manpower and
budgetary resources information. Regions I and VII are now exploring ways
to incorporate resource tracking into their systems at some future time.
Although the Regions' approaches to evaluation of progress information
received from the SEA tracking system vary, they all seek to analyze and
synthesize a mass of program information into a concise summary of items
to be brought to the attention of top management. Top management refers to
the RA's office and usually a problem-solving committee of Division Directors.
IV.B. IDEAS AND OBSERVATIONS; REGIONAL SEA TRACKING
It is clear that a considerable amount of thought and effort has been,
and continues to be, directed towards the developmment, operation, and
refinement of SEA tracking systems by the Regions. As a result, many innovative
tracking procedures have been devised, and many useful ideas and observations
made by the Regions.
The remaining section of this chapter presents significant ideas and
observations about SEA tracking and evaluation which were noted during
telephone conversations and visits with the Regions.
A universal sentiment among the Regions is that those
commitments written In concise, well defined terms with
designated products, or outcomes, and interim milestones
of achievement, are the easiest to track. Because many .
SEA commitments were vague, a number of Regions found it
necessary to re-work them with the States in order to
put them into a trackable form.
The Regions would like to prevent the tracking of milestones
from becoming a useless "bean counting" exercise. Instead,
they are attempting to Identify qualitative and quantitative
measures which link work progress to the implementation of
a strategy for achieving environmental results.
/
Regional tracking systems at present have not yet incorporated
the practice of monitoring of resources. It is generally
acknowledged b'y the system operators and developers that for
the purposes of SEA tracking, detailed budget and manpower
information is not necessary. Its tracking would be too time
consuming and cumbersome for SEA needs. Instead they would
like to use round figures or estimates of resources in order
to identify problems in their initial stages. This in intended
to give senior management a summary of what progress is being
made for what effort, where resources are being expended, and
where additional technical and financial resources are needed.
After having had at least one year's experience with tracking
SEArs, many Regions1 are now concentrating on incorporating their
tracking system design requirements into the new Agreements.
Most of the emphasis is being placed on the development of new
-26-
-------
formats and on the clarification of the language of the
agreement, so that its objectives and priorities are more
readily identifiable and trackable. An example of how
the SEA format can aid in easing the burden of tracking
(see Appendix E) has been developed by Region VII. They
have designed their SEA's in such a way that a Xerox
reduction of the commitments as they appear in the SEAs
serve as a reporting form for a quarterly narrative of
progress.
* Several Regions, and Region VI in particular, have begun
to develop and track multi-media and multi-year strategies
in order to devise workable solutions to environmental
problems. They have recognized that the SEA process,
and the tracking and evaluation systems, have given them
the flexibility to integrate program activities. This
has enabled the Regions to approach environmental problems
in a more comprehensive way, outside of the sometimes narrow
confines of program categories.
Duplication of effort in internal reporting is of great concern
to all Regions. In an effort to eliminate some of the
duplication, several Regions have begun to combine reporting
activities for the grants, and in one case even the PPAs,
into their SEA tracking and evaluation systems. The elimination
of burdensome progress requirements in the Regions and States
through the SEA tracking process has enhanced Staff acceptance
of the SEAs.
* During the course of the fiscal year adjustments are often
made to the SEA work plans and commitments in order to adapt
to unforeseen reallocations of resources or priorities.
Regions have found that if changes are not formally communicated
to the proper managers in the SEA process, serious problems
with activity scheduling, tracking and evaluation can result.
One Region's attempt to overcome this potential problem has
resulted in a formal SEA amendment process for the Region.
It consists of a letter of notification (see Appendix H) to
the SEA Coordinator which explains the change and notes any
impacts expected as a result of it. It also outlines the
reasons for the needed amendment. The SEA Coordinators incorporate
the changes into the SEA work plans, notify potentially affected
parties of the amendment, and keep the letter on file in the
Coordinator's office.
CONCLUSION
This study has described several of the SEA tracking and evaluation systems
now being used by EPA Regional Offices. It has highlighted how the Regions
have attempted to develop SEA tracking and evaluation systems which best
accommodate their own particular management structures and needs. It is hoped
-27-
-------
that through the comparison of the systems in this report Regions might be
better able to assess the strong and weak points of their own systems in
relation to other Regional systems. This assessment should encourage
sharing or borrowing ideas among Regions, and also stimulate new ideas to
improve current methods and to fill in gaps in present systems.
-28-
-------
APPENDIX
-29-
-------
APPENDIX A
CHAPTER III INTERVIEWEES
LIST OF EPA STAFF INTERVIEWED BY TELEPHONE
REGION II
Mike Bonchonsky, SEA Coordinator
Joanne Breiman, SEA Assistant Coordinator
REGION IIT
George Pence, SEA Coordinator
Paul Ambrose, Delaware Operations Director
REGION IV
Henry Hudson, SEA Coordinator
REGION V
Dave Stringhatn, SEA Coordinator
REGION IX
Catherine Kuhlman, SEA Coordinator
CHAPTER 3 INTERVIEWEES
LIST OF EPA STAFF INTERVIEWED ON VISITS
REGION I
Robert Thompson, Acting Deputy Regional Administrator
George Mollineaux, SEA Coordinator
Patricia Meaney, Director, Analytical Center
Charles Murray, Director, Water Division
Louis Gitto, Director, Management Division
A-l
-------
CHAPTER III INTERVIEWEES (CONT'D)
REGION VI
Fran Phillips, Deputy Regional Administrator
Ray Lozano, SEA Coordinator
Tony DiRosario, SEA Staff
Myron Knudson, Director, Water Division
Mac Weaver, Director, Water Supply
William Hathaway, Director, Enforcement Division
REGION VII
Don Christenson, Director of External Affairs
Gene Ramsey, SEA Coordinator
Ralph Langaemeier, SEA Assistant Coordinator
Dan Vallero, SEA Assistant Coordinator
Louise Jacobs, Director, Enforcement Division
REGION VIII
Gene Lucero, Deputy Regional Administrator
Joan Barnes, SEA Coordinator
Marcie Osterholt, Program Analyst, Resources Management Branch
Carl Worster, Chief, Computer Services Branch
Marshall Payne, Chief, Surveillance Branch
David Emery, Director, Management Division
SEA Staff: Ken Alkema, Sam Marquez, Ed Stearns, Bill Basbagill, Loretta Pickerell,
Duane Traylor
David Kircher, Air and Hazardous Material Division
Terry Anderson, Economist, Office of Analysis & Evaluation
Pat Godsil, Chief, Planning & Management Branch, Water Division
Harvey Hormberg, Chief, Office of Public Facilities Grants, Water Division
Pat Crotty, Drinking Water Branch, Water Division
A-2
-------
CHAPTER III INTERVIEWEES (CONT'D)
REGION X
L. Edwin Coate, Deputy Regional Administrator
Nora McGee, SEA Coordinator
Joanne Fujita, SEA Assistant Coordinator
Lyman Neilson, State of Washington Operations Office Director
Gary O'Neil, Director, Surveillance and Analysis Division
A-3
-------
Issue No.
APPENDIX B
QUARTERLY STATUS SHEET
1980 State/EPA Agreements
Division Director:
Project Manager:
State:
Issue:
As of 1/1/80, have all EPA milestones in the SEA been met? Yes No
As of 1/1/80, have all State milestones in the SEA been met? Yes No
Please write a brief paragraph discussing project highlights and newsworthy
items. If any milestones have not been met, is this a significant problem?
Are there any other significant problems? If so, please explain the nature
of the problem(s) and what action is being taken.
I. REGION I TRACKING REPORTING FORM
Division Director's Recommendations for follow up:
RA:
DRA:
Division Director:
Project Manager:
Other
RA/DRA Recommendations for follow up:
RA:
DRA:
Division Director:
Project Manager:
Other
Follow-up actions taken:
Return to Patricia Meaney, Analytic Center, by January 16, 1980.
B-l
-------
APPENDIX C
Vermont Issue #2: ST. ALBANS BAY RESTORATION PROJECT
Description of losucs;
Vermont continue* to place very high priority on the restoration of St. Albana Bay. The State will establish a St. Alban* Bay Reiteration Project
to be aanaged and directed by the Agency of Environmental Conaervatlon acting through the Department of Water Resources and Environmental Engineering
In cooperation with the Environmental Protection Agency. The objective of this project la to reatore the watera of St. Albana Bay to their maximum
sensible recreational and economic potential through sound water quality management praetlcea. This objective will be achieved by a three-phased
program: (1) upgrade the St. Albsns City Municipal Uaatewater Pollution Facility Including phosphorus removal; (2) conduct In-bay reatoratlon activ-
ities; and (3) implement recommended nonpolnt aource treatment propoaala. During FY 1980, the State of Vermont and EPA should agree upon a detailed
strategy for Implementation and begin implementing the strategy.
OBJECTIVE
A. Upgrade St. Albane City
municipal waate vater
treatment facility,
Including phosphorus
removal.
B. Conduct In-bay reator-
atlon activities.
C. Implement non-point
source treatment
proposals.
0
l-»
MILESTONES
DESCRIPTION
1. Step I grant application for facilities
plan for City of St. Albans submitted
to EPA.
2. State submits an updated atrategy for
the restoration of St. Albans Bay in
cooperation with EPA. Update would
include:
a. Status report of Rural Clean Water Ap-
plication for St. Albans Bay which Is
being developed In conjunction with
the Soil Conservation Service, U.S.
Department of Agriculture; and
b. Status report of Corps of Engineers
application for weed harvesting in
St. Albans Bay.
3. EPA reviews preliminary strategy and pro-
vides State with comments. EPA reviews
and approves (or recommends changes as
needed) to facilities plan application
for City of St. Albans.
4. State flnalixes strategy and submits to
EPA.
DATE
Oct. 1
Nov. 1
Dec. 1
Jan. 1
AGENCY
CHARGED
Vermont
AEC
AEC
EPA
AEC
FY 1980 RESOURCES
WORKYEARS
STAffi
0.1
Water
Division
EPA
0.2
Water Quali-
ty Section
Conatructioi
Grant a
Section
DOLLARS lUOU}
STAT£
S (*
:rA-a«t/Bourc
$ 12*
CWA 88 208,
314.205 (g)*
-
* Hypothet:
PROJECT
MANAGERS
i STATE
W. McLean
(802)
325-9987
cal: En tries
EPA
R.Manfredonii
(61-7)
223-5673
'
II. REGION I - EXAMPLE OF PRIORITY ISSUE DESCRIPTION
-------
APPENDIX D
STATE A FY 80 SEA
2nd QUARTER REPORT - MARCH 24. 1980
SAMPLE PAGE
1. Water Supply Supervision
a) Item L-17: State hired a full-time water and wastewater training
coordinator (1/31/80).
b) Item L-19: The Division of Environmental Services (DBS) has a
vacancy for an ADP person in their water supply program.
c) Item L-24: State began submitting quarterly reports to EPA.
First quarter report submitted to EPA on February 21, 1980.
d) Item L-28: During the first 6 months of FY 80, EPA responded to
Bossier City complaints about high color in the Red River. Also
responded to complaints about alleged PCB contamination of public
drinking water wells in Lake Providence, LA.
All other items are status quo and progressing in their-usual manner.
2. (UIC) Underground Injection Control Program
Department of Natural Resources identified no tasks in program plan with
definite March completion date, however, work on several program elements
is progressing. Work underway includes hydrologic investigations of
the Chicot, Evangeline, Jasper, Wilcox, Sparta and Coxfield Aquifers;
preliminary investigations regarding characterization and inventory of
injection wells. Preliminary investigative work has also been initiated
for 1) determining the aquifer recharge potential for the lignite mining
area and high density areas; 2) inventory of shallow aquifers being used
as potable water supplies for Baton Rouge - New Orleans corridor; lignite
mining area(s) and potentially hazardous areas; 3) establishment of a
data bank; and 4) initiation of well inventory.
SET*1 *****
* **««, sv,. «3
HtatMngton, D.C, 38459
D-l
-------
APPENDIX E
REGION VII
SAMPLE NARRATIVE REPORTING PAGES
NEBRASKA/EPA AGREEMENT
PRIORITY 6 - Safe Drinking Water
Issue;
The Integrity of public water supplies in Nebraska must be
maintained at a level which provides the citizens of the State
clean, safe, potable water. The Nebraska Department of
Health is vested with the, responsibility for this program
as required under Nebraska statutory authority and the
Safe Drinking Water Act.
Strategy;
The Nebraska Department of Health, through continued primacy
statutes, will provide continuing operation of the Public
Water System Surveillance Program of the Safe Drinking
Water Act. These efforts will be coordinated, where
necessary, with other Nebraska departments which share
concern and responsibility for ground water utilization
and integrity.
Nebraska Commitments:
1. The Department of Health will maintain primacy ror Safe
Drinking Water Act and carry out the enforcement activities
described in the narrative submitted with the application
for Categorical Public Water System Surveillance Program
grant funds. The Department will also participate in the
Nebraska Water Planning and Review Process as a means of
coordinating environmental and public health considerations
associated with resource management.
-------
APPENDIX E (CONT*)
ro
2. The Department of Health will prepare annual reports of
violation and enforcement actions on forms provided by EPA.
The D.O.H. definitions of violation will be used and the
reports will be in detail negotiated between the CSSE State
Liaison Group and EPA.
EPA Commitments;
1. The Regional Office will attempt to provide funds in
conjunction with the laboratory review under #8 (Laboratory)
for the purchase of an Auto-technico system and Gas
Chromatograph Mass Spectrometry Instrument for the State of
Nebraska.
2. EPA will provide an evaluation relative to upgrading all
laboratory capabilities to meet EPA quality assurance levels
as referenced in Issue #8 (Laboratory).
3. EPA will provide the forms and training to DOH staff for
the annual report.
Joint Commitments;
1. The Nebraska Department of Health and EPA will jointly
review the reporting requirements of the water supply program
in an attempt to simplify these requirements in future years.
This Review will take place by or as part of the mid-year
evaluation.
2. The Nebraska Department of Health and EPA will jointly
develop a program to provide information and advice relative
to a sound cross-connections program by February 1, 1980,
which can be promoted and administered throughout the State.
3. Corrosion control, particularly in asbestos/cement pipe,
is receiving nationwide attention. The Nebraska Department
of Health and EPA will jointly develop a program by March 1,
1980, to provide information and guidance to those water supplies
which are experiencing corrosion problems or have potential
for corrosion.
1. Auto-technicon purchased by Nebraska with
own funds. A needs assessment is underway
to determine need for G.C.M.S.
2. Planned for third quarter.
3. Completed 1/17/80.
1. Planned for April 1980. May 20, 21, 22, 1980.
2. In progress 1st quarter (planning).
Information provided January - 2nd quarter.
3. In progress. Information provided in January.
-------
APPENDIX E (CONT'D)
Contacts and Resources
DEC Contact: Cliff Summers Workyears: 14.0
FIS 541-2674
EPA Contact: Jo Ann Basel
816-374-5429
OJ
-------
APPENDIX F
REGION VII
OFFICE OF EXTERNAL AFFAIRS
First Quarter
January 18 - EPA internal program's reports on commitments due to EXTR.
January 25 - State's reports on commitments and PPAs due to EPA.
- EPA reports on commitments due to the States.
February 1 - SEPA exception report due on unfulfilled commitments.
Before February 15 - Meetings to discuss problems (only as necessary).
Second Quarter
April 18 - EPA program's reports on commitment due to EXTR.
April 25 - State's reports on commitments and PPAs due to EPA.
- EPA reports on commitments due to States.
May 2 - SEPA exception report due on unfulfilled commitments.
Before May 16 - Midyear meetings with States for review.
Third Quarter
July 18 - EPA program's reports on commitments due to EXTR.
July 25 - State's reports on commitments and PPAs due to EPA.
- EPA reports on commitments due to the States.
August 1 - SEPA exception report due on unfulfilled commitments.
Before August 15 - Meetings to discuss problems (only as necessary).
Fourth Quarter
October 17 - EPA program's reports on commitment due to EXTR.
October 24 - State's reports on commitments and PPAs due to EPA.
- EPA reports on commitments due to States.
October 31 - SEPA exception report due on unfulfilled commitments.
Before November 14 - End of year review meetings with States and programs,
If you have any questions about the schedule, please contact Gene Ramsey in
State/EPA Agreements at extension 3143.
F-l
-------
REGION VII
Objective
Provide
Groundwater
Pollution
Control
Program -
(Including
UIC)
Activity
1. 'Hold a seminar on nitrates
in Grand Island.
2. 'Fund third year of special
ASC project in Hall County
3. 'Mold Seminar in Worms on
Nitrates
4. 'Draft report on other nitrate
sources
5. 'Draft plan for UIC
6. 'Finalise nitrate report
7. 'Submit map of detection devic
siting for Nitrates
8. 'Begin operation of detection
devices for Nitrate
9. 'Prepare draft activity/assess
ment protocol
0. Conduct inspections at all
public owned water supplies under
1445(b|
1. Provide review of variances
to assure 1415 (a) schedules
are being met.
&UA)
Commitments for Priority Problem
Projected
Accomplish.
20
220
FY-
st g
1
1
1
1
1
5
50 _
^^fc,
81 Accon
2nd 0
1
5
55
^_ N.
pliahmi
3rd 0
1
5
55
X _
reviews'
;nts
4th 0
1
5
60
-»
Completion
Date
10-31-80
10-31-80
11-30-80
11-30-60
12-31-80
3- 1-81
3-30-81
6- 1-81
9-30-81
9-30-81
9-30-81
nf-Bl
Wot kyeari
(State)
1.50
1.50
1.50
1.50
.50
1.50
1.00
.50
16.50
5.50
18.50
Resources
Grant
to
State Proqram
7.5k CWA 208
130K CWA 208
7.5k CWA 208
50k CWA 106
15k SOWA
25k CWA 106
5k 60WA
0 SDWA
60k SDWA/CWA
106 k 208
4k SDHA
900k SOWA
Responsible
Aainct
NRC/NDll
NRC
NftC/NDH
NDEC
NDH
NOCC
NOH
NDH
NDH
NDH
? f
CO
D) i-3
n >
£ M
H- O
rt Q
tt> S
CD H
tJ
0 H
0 H
jj* tn
i-t
O ^3
3 0
O 2*3
t-1
o o
CTQ SZ
H- Q
0 O
(B M
O
hi ^
i-i
-------
APPENDIX H
SECOND AMENDMENT TO FY-80 NEBRASKA/EPA AGREEMENT
PRIORITY 3-C NEBRASKA DEPARTMENT OF ENVIRONMENTAL CONTROL COMMITMENT
NUMBERS la, Ib, lc, Id, le, and If are hereby revised to read as follows
(changes are underlined):
1. a) Assist the Regional EPA office to update the lists for the
Hazardous Waste Notification Program by March 30, 1980.
b) Evaluate EPA Regulations by September 30, 1980 to develop
State Hazardous Waste Management Regulations.
c) Utilize the information from the Hazardous Waste Notifica-
tion Program to update or conduct the registration of
generators, licensing oif transporters and permitting of
(interim) facilities by December 31, 1980.
d) Develop the interim authorization application to operate
the Federal Hazardous Waste Management Program and conduct
the public participation requirements by September 30, 1980.
e) Submit the authorization application and develop a memoran-
dum of agreement with the Reoional EPA office by September_
30, 1980.
f) Begin implementation of the Nebraska Hazardous Waste Manage-
ment Program by September 30, 1980 or on the schedule
presented in the approved interim authorization plan.
PRIORITY 3C ENVIRONMENTAL PROTECTION AGENCY COMMITMENT NUMBERS 1, 2, 4,
5, and 6 are hereby revised to read as follows (changes are underlined):
1. At least two visits will be provided by the Regional EPA office
on the development of the interim authorization application and
conduct of the public participation requirements by June 30, 1980.
2. Review of the necessary public participation activities on the
interim authorization application by September 30, 1980
A. Provide Hazardous Waste Notification information to NDEC for use
in their program implementation by September 30, 1980. and December
30. 1980.
5. A computer software package for integration of the EPA and NDEC
Hazardous Waste Program will be provided by September 30, 1980.
6. Develop a public education and information program to assist the
regulated community and the public to understand and support the
establishment of new hazardous waste management facilities, comply
with the new hazardous waste management facilities, comply with the
new hazardous waste regulations and report alleged problem sites by
August 30. 1980.
H-l
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APPENDIX H (CONT'D)
The undersigned have executed this Amendment to the Agreement on the day
and year specified below.
U.S.ENIRONMENTAL PROTECTION
AGENCY, REGION VII
By:
&.
Kfetnieerr Q.
Regional Administiktor
4Jjuu^
Date:
NEBRASKA DEPARTMENT OF
ENVIRONMENTAL CONTROL
By:
Dan T. Drain
Director
Date:
H-2
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APPENDIX H2
RATIONALS FOR AMENDMENTS
When the FY-80 Agreement was negotiated, both the State and EPA
anticipated an earlier publication date for the Hazardous Waste
Regulations. EPA was late in publishing several of the regulations.
These delays necessitate a change of dates in this portion of the
Agreement.
H-3
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APPENDIX I
REGION VIII
IV. STATE/EPA AGREEMENTS: RA's TRACKING LOG
1.
2.
HAZARDOUS WASTES CONTROL PROGRflM
Oeveloi) Authorization Plan and Apply for
interim Authorization*
a. Submitted to EPA by the State
b. Approved by EPA
Develop enabling legislation required
for full authorization
a. Enacted by state
CO HT ND SO UT MY
Due Status Due Status Due Status Due Status Due Status Due Status
Date Date Date Date Date Date
5/80 (2) 5/80 (2) 5/80 (2) 5/80 (2) 5/80 (2) 5/00 (2)
12/79 (2) - (4) 4/60 (2) 2/80 (2) 1979 (4) 12/79 (4)
(«) (4)
b. Approved by EPA
3. Develop procedures for issuing permits 12/80 (2) 12/80 (2) 9/80 (2) 10/80 (1) 10/80 (2)
4. Develop procedures to satisfy EPA's
inspection, monitoring, and reporting
requirements 10/80 (2) 12/80 (2) 9/80 (2) 10/80 (1) 10/80 (2)
STATUS CODE;
(I) Ahead of Schedule
(?) On Schedule
(3) Ochiiid Schedule
Completed
Discontinued or Revised
\" i
ill
* UCRA 3001 regulations will now not be out until April 1980.
This delays the promulgation of regulations approximately three
months and thus will change S/EA due dates.
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V. MANAGING EM FjyiRQTO{J.Al RESULTS
iiu\UNUfmiu<3 r
(RESOURCES) \* '
REG 1 UN X -
EMVIROHMENTAL PR
(PLANNING) ASSESSMENTS ^ G
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IORITY STRATEGIC MANAGEMENT C
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15
OW-GOIHG EVALUATIONS: PERFORMANCE // MANAGEMENT IIIFORMATION // ACCOUNTABILITY
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APPENDIX K
III. KANSAS ONGOING COMMITMENTS
(Quarterly unless otherwise indicated)
WATER
Water Quality
* Develop and submit draft FY-82 Construction Grant priority list by
May 1, 1981; and final list by July 15. 1981.
Submit quarterly updates of FY-81 Construction Grant priority list.
Submit Section 109 grant application for facility to train wastewater
treatment plant operators and maintenance personnel by March 31. 1981.
Update 5-year Water Quality Management strategy and develop FY-82 Work
Program by March 31, 1981.
Provide annual report of status of implementation of the Water Quality
Management Plan by December 31, 1980.
Submit final Clean Lakes ranking by September 30, 1981.
Revise Water Quality Standards by September 30. 1981.
* Submit by September 30, 1981, at least four Step 3 applications for land
treatment projects including at least one such application by March 31. 1981.
Prepare by March 31. 1981, and submit for EPA concurrence, design standards
for Overland Flow and Rapid Infiltration modes of land treatment.
Develop and submit for EPA concurrence by March 31, 1981, a State policy
to enforce manufacturers' warranties on wastewater processing equipment.
Water Supply
Make annual inspections of community water supply systems.
Review plans of public water supplies.
Submit reports of compliance actions for violations of Maximum
Contaminant Levels and monitoring requirements on Federal Reporting Data
System (FRDS) forms; including: 1) Analytical results of violations and
2) the MOL violated.
* Submit annual report by December 31, 1980.
K-l
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APPENDIX K (CONT'D)
Permits
Issue Best Available Technology (BAT) permits for major
primary industries by NPDES guidelines.
Issue BAT permits for major secondary industries by guidelines.
* Issue BAT permits for major primary industries by Best Engineering
Judgement (BEJ).
* Reissue permits for publicly owned treatment works (POTW's) with
secondary treatment limitations.
Reissue permits for POTW's with Section 301 (i) extensions.
Reissue permits for POTW's with administrative orders.
Issue permits for major federal facilities.
Submit pretreatment plans for municipalities.
Approve pretreatment plans for municipalities.
Submit effective permits incorporating pretreatment for municipalities.
* Implement pretreatment for municipalities.
Provide written procedures for the initial screening and substantive technical
evaluation of all compliance related information by November 11, 1980.
Provide for the maintenance of a comprehensive inventory of all sources
covered by NPDES permits including provisions for forecasting of reporting
requirements by July 1. 1981«
Provide written procedures for the determination of appropriate enforcement
responses to identified NPDES permit violations by December 31, 1980.
Prepare quarterly noncompliance reports in accordance with current NPDES
regulations by September 30, 1981.
Implement the National Municipal Policy and strategy and the Municipal
Management System by January 31, 1981.
Field Inspections
* Make sampling inspections of major dischargers.
* Make non-sampling inspections of major dischargers.
* .Make performance audit inspections of major dischargers.
* Make pretreatment inspections.
* Make biomonitoring inspections.
* Submit to EPA a copy of the final inspection report for all major dischargers.
K-2
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APPENDIX K CCONT'D)
AIR
Enforcement
Determine compliance status of Class A Sources in attainment areas,
status unknown, as of September 30, 1980.
* Inspect Class Al, NSPS & NESHAPS sources, in attainment areas once
during Fiscal Year.
Inspect Class A2 sources in attainment areas once every 2 years.
NOTES; Other ongoing commitments are included in the Priority Problems Section
and the Air Enforcement Protocol included in the SEA by reference.
SOLID WASTE
Management
Conduct on-site inspections of solid waste disposal facilities.
Participate in Urban Grants awarded to municipalities or counties in the
State; including planning, review and management.
* Conduct an evaluation of the open dump inventory by August 15, 1981; report
on those facilities declared as open dumps.
* Revise the draft solid waste management plan by June 30, 1980.
Close open dumps, upgrade open dumps, and report efforts
to prevent new open dumps.
K-3
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