United States
Environmental Protection
Office of
Management Systems
and Evaluation PM-222
Washington DC 20460
Proceedings of the
Workshop on Managing for
Environmental  Results

May 25-27,1982

Proceedings of the
Workshop on Managing for
Environmental Results

May 25-27,1982

 1  Introduction
 3  Summary of  Regional Presentations
 3  Environmental Results in Overall Regional Management
 4    "Environmental Status Reports as the Basis for Nego-
      tiations with States" — Region 2
 6    "Joint Environmental Planning with Each State" —
      Region 8
 7  Environmental Results Management  in Regional Air
 7    "Reviewing the Appropriateness of Monitoring Sites and
      Non-Attainment Designations" — Region 7
 8    "The Emission Inventory as the Key to Managing Air
      Quality" — Region 9
 9    "Integrated Data Assessment for Problem Scoping and
      Targeting" — Region 5
10  Environmental Results Management  in Regional Water
10    "Comparing Ambient Data with State Standards for
      Initial Problem Screening" — Region 8
10    "Using Ambient, Discharge, and Flow Data for Pre-
      liminary Determination of Priorities: The Water Manage-
      ment System" — Region 6
11    "Use of Biological Information for Water Quality
      Management" — Region 4
12    "Using Compliance Data to Target State Activities and
      Evaluate Effectiveness" — Region 6
13  Environmental Results Management  in Regional Hazard-
    ous Waste Programs
14    "Data and Information for Setting Priorities and Target-
      ing Resources in RCRA and Superfund" — Region 9
15  Summary of  Headquarters Presentations
15  Office of Water
17  Office of Air, Noise, and Radiation
18  Office of Toxic Substances
19  Office of Solid Waste and Emergency Response
21  Summary of Presentations on the Use of Biological and
    Public Health Data
21  Biological Data
22  Public Health  Data
25  Summary of  Presentations on Multimedia Approaches
    to Environmental Assessment
25  PIP Geographic Approach
26  NEIC Multimedia Assessment

27 Panel Discussion on EPA and State Roles in Managing    57 Summary of Workshop Accomplishments and Next
   for Environmental Results                                 Steps
35 Panel Discussion on Planning, Resource Allocation,       61 Closing Remarks
   Accountability, and Evaluation
45 Summary of Workgroup Discussions and                   Appendices
   Recommendations                                    62   |  Agenda
46 Water Quality                                         64  „  Ljst of participants
48 Air Quality                                           66  m  Recommended Accountability/Evaluation Measures
49 RCRA/Superfund                                      67  ,v  Ljst of Questjons Considered by Workgroups
51 Drinking Water                                        68  v  pre-Workshop Briefing Package
53 Panel Discussions on Workgroup Findings

On May 25, 26, and 27, 1982, the Environmental
Results Branch (ERB) of the Management Systems
Division, Office of Management Systems and
Evaluation (OMSE) sponsored a workshop for
Headquarters and Regional managers at EPA on
"Managing for Environmental Results." This material
summarizes the proceedings of the Workshop. It
includes summaries of the technical presentations
made by EPA Regional and Headquarters offices,
transcripts of the panel discussions at the Workshop,
summaries of workgroup discussions and
recommendations, and identifies some next steps
that ERB will undertake to further the Agency's
efforts to manage for environmental results. The
Agenda, a  list of Workshop participants, and the
briefing materials that were distributed before the
Workshop are included in the Appendix.
Workshop  Summary

The Environmental Results Workshop was held to
define managing for environmental results, to
introduce some innovative approaches now in use, to
identify issues and concerns for further work, and to
develop a consensus on EPA's next steps. During the
three days of the workshop, approximately one
hundred fifty people participated in the discussions.
  Managing for environmental results was defined by
EPA Deputy Administrator Dr. John Hernandez in the
opening  session to mean that Agency managers will
use environmental quality data  to set goals for each
program and then manage their programs to  achieve
those goals. Managers will evaluate progress made
toward the goals and be able to report on that
progress. The workshop participants agreed that this
was not  a new concept; that all managers must set
priorities among the many environmental problems
that need to be solved, decide how to best use the
available resources, and evaluate whether we are
being successful in moving toward our statutorily
defined goals. There was a consensus, however, that
there are some constraints to this approach and that
efforts may have to be taken, some quite significant
departures from how the Agency has operated in the
past, to institutionalize this results-oriented approach
and allow managers the flexibility to respond to site-
specific problems, while holding them accountable
for the success of their efforts.

  The first day and a half of the workshop presented
examples of programs or activities now under way or
being developed to improve use of existing data on
environmental status and trends and to use those
data to resolve geographic specific environmental
problems. Several Regions reported on activities to
identify and rank problems, to seek cooperation with
state and local governments, to improve data
collection, and to plan for evaluation of program
results. In addition, two potentially useful types of
data, health and biological data, were discussed as
additional sources of information on changes in
environmental quality. Representatives of each
Headquarters program office also discussed national
efforts to identify policy direction to resolve
environmental problems.
  The afternoon of the second day was spent in
workgroup  discussions which focused on how to
better manage the EPA Water Quality, Air Quality,
Drinking Water, and RCRA/Superfund programs
using information on environmental status and
trends. These workgroups looked at available
indicators of environmental status and changes in
environmental quality over time and suggested
indicators which are not routinely used, but could
demonstrate changes in environmental quality for
use by program managers as well as the public.
  The final session consisted of a presentation  of
some recent demonstration projects on multi-media
assessment: the Program Integration Project's
geographic approach and the multi-media compliance
auditing concept of the National Enforcement
Investigation Center.
 Next Steps

 Lew Crampton, Director of the Office of Management
 Systems and Evaluation, summarized the findings of
 the workshop and, based on the recommendations
 made during the Workshop, proposed the next steps
 that the Agency should pursue in its efforts to
 manage for environmental results. He highlighted
 eight areas:

 Strategic Planning.
 A need for better strategic planning  was identified.
 OMSE will work with each  AA to develop a short
 strategic plan on a one to three year perspective that
 will, medium by medium, focus on how we are going
 to achieve environmental results. OMSE will then
 develop an agency-wide strategic plan to integrate
 the plans prepared by the AAs and to add an
 intermedia perspective.
Environmental Status Reports.
As a next step in defining goals and setting action
priorities, OMSE will work with each Region to
develop State by State Environmental Status Reports.
The reports will be set up to assure flexibility in each
Region's approach. OMSE will combine the reports to
produce a State of the Environment Report.

Resource Allocation.
A critical concern of the workshop participants was
that the resource allocation process be improved so
that it supports management for environmental
results. OMSE will work with the Comptroller's
Office to seek improvements  in the budget and
resource allocation cycles. Specific concerns were:
achieving greater flexibility in the workload models;
increasing the ability to reprogram without penalty;
better planning for monitoring networks; and the data
needs to evaluate environmental status and results
of EPA activities.

• Accountability.
The current "bean counting" approach in the
accountability system should be replaced, where
possible, with qualitative  rather than quantitative
measures. OMSE will look for measures which
document changes in environmental quality as a
result of Agency activities; for example in the
enforcement area we can move from measures such
as the  number of administrative or compliance orders
toward measures of compliance rates.

• Evaluation.
Pilot projects, for example in the area of quality
assurance,  should be initiated to evaluate the results
of program activities to achieve environmental

• Publications.
A series of publications should be developed to focus
on noteworthy environmental results activities and to
facilitate technology transfer.

• Indicators.
OMSE will  work with Headquarters and the Regions
to assemble the best available indicators from
existing data  for the short-term, and begin the
process of developing over the long-term better
indicators to report environmental accomplishments.

• Monitoring Strategies.
OMSE has assumed the responsibility of the DAA
Committee on Monitoring and Information
Management and will focus on air, water, and
hazardous waste to improve  the current monitoring
networks, data systems and quality assurance.

Summary  of
Before holding the Workshop on Managing for
Environmental Results, staff of the Environmental
Results Branch of the Management Systems Division
of OMSE visited the EPA Regional Offices and
identified a number of activities individual Regions
have undertaken to manage for environmental
results. OMSE asked Regional managers to make
presentations on the most successful and promising
of these activities at the Workshop.
  The Regional presentations, when coupled with
later presentations by representatives of the program
offices at Headquarters, provided a clear picture of
where the Agency currently stands in managing for
environmental results. The Regional  presentations
also highlighted some of the technical difficulties in
meeting this goal.
  In their presentations. Regional staff specifically
discussed how environmental data is used to identify
major environmental problems, to set priorities, and
to target resources to activities that will  have the
greatest environmental impact. The activities that
were presented fall into two basic types:

• Regional efforts to design overall Regional
strategies to achieve environmental results across all
media; and

• program-specific activities to identify major
environmental problems and causes  within a

This section presents abstracts of the Regional
Environmental Results in
Overall Regional Management

Several Regions are working to develop overall
management schemes for identifying environmental
objectives and tracking progress in meeting those
  The most successful efforts use the State-EPA
Agreement (SEA) process to work with states in
identifying priority problems and develop joint
programs to address these problems.
  At the Workshop, Regions 2 and 8 discussed their
identification of environmental problems as part of
the SEA process and their use of SEAs to manage for
environmental results.

"Environmental Status Reports as the Basis for
  Negotiations with States" — Region 2

Joann Brennan, Environmental Protection Specialist
Office of Policy and Management
EPA — Region 2
FTS: 8-264-4297
Commercial: (212) 264-4297

Dan Sullivan, Chief
Monitoring Management Branch
EPA — Region 2
FTS: 8-340-6782
Commercial: (201) 321 -6782
Region 2 staff discussed the approach the Region
has taken to develop environmental status reports
(ESRs) as a successful means for providing a
baseline of environmental data that is used as a
starting point for setting Regional priorities and for
developing  State-EPA Agreements. This approach is
displayed in Figure 1. The ESRs are 25-30 page
documents that use a variety of environmental
indicators in each medium to identify environmental
problems, environmental improvements, the sources
of environmental pollution, and data needs. Tables 1
and 2 show how environmental information is
analyzed to identify specific problems in the air and
water media.
  The ESRs, which are concise summaries of
environmental data, have been used successfully as
the basis for State/EPA Agreements. An  ESR has
been developed for each state in the Region. As
future reports are prepared, the Region is working
with states in the Region to resolve the following

• How frequently should ESRs be prepared to meet the
Agency's needs? The Region is considering a two-year
preparation cycle instead of annual  reports.

• What better environmental indicators of both
ambient and source control can be developed? The
Region is planning a project — "Results-Oriented
Oversight of State Programs" — that will provide:

— a set of agreed-upon ambient indicators for at
least the conventional air and water pollutants;

— a set of agreed-upon source-control indicators
for each of the major programs;

— a set of agreed-upon managerial indicators to be
used for oversight of state performance.

• How should ESRs address toxics?

• Can or should ESRs serve as both management
tools and public information documents? The Region
feels ESRs need to be  used primarily as management
tools. State sensitivity  increases and ESR content
suffers when ESRs are viewed as public information
documents  as well.
Figure 1.
Region 2 Overall Management Presentation
ESR as Technical Basis for Establishing Priorities
               ESR/Program Reviews
               Preliminary List of Priorities
                 an it be handle
           routinely/adequately through
                 e Grants Proce
                     Do the
            consider it a high priority
               SEA Priorities
               SEA Strategies
Grant    	»| Program Grant Work Plans
Activities      '      	_	

Table 1.
Region 2 Overall Management Presentation
Summary of Source Control Priorities by Region
Niagara Genesee- Southern Southern Hudson NYC and
Frontier Finger Lakes Tier West Tier East Central Northern Valley Long Island
Point Sources
Area Sources
Mobile Sources
Long Range Transport
03 L
03 L

03 L

03 L



03 L
03 L


Acid Rain
03 L

03 H

03 H
03 H
03 H
Oxidants H
S02 = Sultur Dioxide  TSP = Total Suspended Paniculate   03 = Ozone   CO = Carbon Monoxide
Table 2.
Region 2 Overall Management Presentation
Summary of Water Quality Management Problems by Basin


                           1            •   1
                           J   O  °|   |   g
                                        S   5
                                                 <  s
|  Sj|  g




Municipal Discharges
Industrial Discharges
Combined Sewer Overflows
Urban Storm Runoff
Acid Rain
Hazardous Waste Sites
























"Joint Environmental Planning with Each State"
 — Region 8

Jim Lehr, Deputy Director
Air and Waste Management Division
EPA — Region 8
FTS: 8-327-2407
Commercial: (303) 837-2407
State-EPA Agreements (SEAs) are the cornerstone
for managing for environmental results in Region 8.
Key aspects of Region 8's SEAs that make them
successful for this purpose are that they:

• focus on environmental problems,

• normally include as priority objectives specific
environmental problems that are multi-year, multi-
agency or multi-program in scope,

• ensure full participation of top management and
program staff in the process in order to ensure that
they see themselves as "owners" of the product (i.e.,
the SEA) and use it,

• rely on credible environmental information for
problem identification and priority setting,

• are developed in such a way that they reflect  and
focus on the environmental problems of greatest
concern to state officials,

• provide a  comprehensive planning and
management tool for priority problems —  in
particular, they serve as tools for the Regional
Administrator and other Regional and state managers
to track progress in resolving  environmental
problems through the year — tracking is conducted
in such a way that timely corrective action can be
taken where necessary,

• eliminate the need for separate Regional operating
plans — since all Regional activities are specified in
the SEA, there is no need for a separate operating
• eliminate the need for separate grant workplans
for the States — SEA workplans serve also as grant
workplans, so there is no need for the state to draft
two sets of workplans, and
• are kept brief and to the point — unnecessary
detail is eliminated and reporting requirements are
kept to a minimum.

  The Region emphasized that it is not necessarily
the product — the SEA document — that is
important, but the process by which the SEA is
developed and used to meet identified objectives. The
process, which is shown in Figure 2, begins with a
meeting between senior EPA and state managers, in
April of each year, to agree on long-range priorities
and on specific objectives for the coming year. EPA
and state staff then work to identify specific activities
and levels of funding for each objective. These
negotiated workplans (which  also serve as the
narratives and workplans for  program grants)  become
a critical part of the SEAs, which become final in
September of each year.
  One final characteristic of the SEA process  in
Region 8 that makes it successful are the quarterly
evaluations of SEA activities,  and the mid- and end-
year on-site reviews by senior staff. The key to
making the SEA process meaningful is to ensure that
Regional managers embrace  it as the process they
themselves use within the Region to plan and
Figure 2.
Region 8 Overall Management Presentation
Water Quality Planning and Management for Results
  Data collection and storage
  Data retrieval, analysis
  summaries — statistics
Identify critical pollutants and
stations where beneficial
uses are impaired
Publish Regional Air
and Water Trend Report

Provide analytical reports to
States for support of 305(b)
Report activities

  Meet with State 305(b) reps to
  review and agree on priority
  problems based on  results of
  Regional Use Impairment
  Studies and State305(b) Report-
  identify sources and severity
  Senior mgrs. EPA and State
  determine goals and objectives
  for coming year and long-range
  Develop planning strategies
  and funding policies based on
  goals and objectives
  State/EPA negotiations on
  State submittals of Water
  Quality Management strategies
  Develop State/EPA Agreement
 State/EPA Tracking Evaluations
 (1 year period)  quarterly and
 mid-year reviews

manage their own programs and to conduct Regional
oversight of state programs. This ensures that
Regional and state activities fully complement each
other and constitute a true state-EPA partnership.
  A major selling point of the Region 8 SEA process
with the states is that there has been enough
reduction in  detail and in reporting requirements that
the SEA process is less resource intensive than the
old grant workplan development process. Another
important selling point has been the Region's
willingness to negotiate separately with each state to
determine what purpose the SEA is to serve and who
(the Region or the State) is to be responsible for
developing and carrying out the various elements in
it. The Region has allowed these understandings
regarding the what and the who of the  SEA to vary
significantly  from state to state.
  Region 8 raised the concern that EPA be careful in
changing state reporting requirements in order to
better manage and track environmental results.
Regional staff said the SEAs are negotiated on a
yearly basis and that EPA should not change them
mid-year, or  else state agency managers will not
have much faith in the SEA process and EPA will
lose credibility as a partner with the states. A "partner"
who keeps changing the rules in midstream is not a
trustworthy or reliable partner. In particular, Region 8
is now negotiating FY 83 reporting requirements —
any new reporting requirements need to be
incorporated now or wait until next year's process.
Results  Management
in Regional  Air Programs

The Air program  is, by statute, oriented towards
managing for environmental results. The statute
requires that ambient air monitoring data be used to
designate geographic areas as in attainment or not in
attainment with air quality standards. State
Implementation Plans (SIPs) provide strategies for
bringing geographic areas that do not meet ambient
air quality standards into compliance. In addition,
OMSE staff found that in several Regions air data is
used not only to designate non-attainment areas, but
also to set priorities among non-attainment areas
and to identify  monitoring needs. At the Workshop,
Regions 7, 9 and 5 described their use of air data to
manage for environmental results.
 "Reviewing the Appropriateness of Monitoring Sites
  and Non-Attainment Designations" — Region 7


 Tom Holloway, Chemist
 Environmental Services Division
 EPA — Region 7
 FTS: 8-758-4461
 Commercial: (816) 374-4461
 Region 7 prepares a Monitoring Activities
 Coordination (MAC) Report that summarizes
 monitoring data and defines data needs throughout
 the Region. The MAC Reports have been used most
 successfully in the Air program.
   The analysis of Air monitoring data includes:

 • the location of current standards violations,

 • an analysis of air quality trends,

 • an assessment of air monitoring needs — i.e.,
 identification of unmonitored areas where violations
 of standards might reasonably be suspected because
 of high emission density or population density,

 • the analysis of the usefulness of air monitors,
 including identification of air monitors that are not
 essential, and

 • an  analysis  of the apparent  appropriateness  of
 current attainment and non-attainment designations.

   The fiscal year (FY) 1981 reports contained hand-
 produced maps that displayed county summaries of
 recent monitoring data, attainment status
 designations, emission densities, and population
 densities. Composite overlays of these maps, a
 sample of which is shown in Figure 3, identified
 unmonitored areas which  have high population
 density and high emission density. The Region has
 contacted the states with these unmonitored areas
 and encouraged them to consider putting monitors in
• these areas.
   The FY 1982 analyses use an extensive computer
 mapping system developed by the Region in
 coordination with the National Aerometric Data
 Branch, in EPA's Office of Air Quality Planning and
 Standards. Since the mapping software has no
 inherent geographical limitations, it can be applied to
 any Region. The maps provide information on the
 location of monitors; ambient air quality and trends
 by monitor; non-attainment area boundaries; and the
 locations, stack heights, and emissions for large point
 sources (>100 tons per year). The maps overlay this
 information on state and county outlines. They are
 used to identify problem areas, probable causes of
 the problems, and areas where additional monitoring
 is needed.
   The evaluations attempt to identify ways to focus
 the limited monitoring resources of state and local
 environmental agencies on the areas with the
 greatest monitoring needs.

  The Region works with each state in preparing
the reports. The Region indicated that, because of
this approach, the states consider the analysis of air
data and air monitoring recommendations in the
MAC Reports to be constructive management tools
that they find helpful.

Figure 3.
Region 7 Air Presentation Ambient TSP
Data  — Des Moines Area

Editor's Note: The original map was produced in four colors. Those
colors are indicated in parentheses on the adjacent Legend for
Ambient Monitoring Data Maps.
Legend for Ambient Monitoring Data Maps
i	1.
I	11
     Unclassified Area (Black)
I    i Secondary Nonattainment
I	1 Area (Blue)
I   ' (Primary  Nonattainment
I	-I Area (Red)
Annotation for Standards Violated
A Annual PrimaryStandard(Red)
24 24-hour Primary Standard
24 24-hour Secondary Standard
8 . 8-hourPrimaryStandard(Red)
3 3-hour Secondary Standard
1  1 -hour Primary Standard (Red)

Monitor Symbol Sizes
State Maps
      o  Middle Scale
         Neighborhood Scale
         Urban Scale
         v Regional Scale
Monitor Symbol Colors and Flag
 • No Violation of Standard
 • Violation of Secondary
   Standard (Blue)
 • Violation of Primary Standard
   rExceedance of Alert Level

 Annotation for Trends
 t Increasing Trend
 A Probable Increasing Trend
 — No Trend
 V Probable Decreasing Trend
 i Decreasing Trend
 (Where two trend symbols are
 shown, the first is for annual
 averages, the second for 24-hour

 Data Completeness
 • At least 75% completel 979-81
 A At least 75% complete! 979-80
 O Less than 75% complete
'The Emission Inventory as the Key to Managing
 Air Quality" — Region 9


David Howekamp, Director
Air Management Division
EPA — Region 9
FTS: 8-454-8201
Commercial: (415) 974-8201

Ambient data is an appropriate indicator of current
air quality and is the ultimate test of program
effectiveness over the long term. However, ambient
quality is not suitable as a short-term indicator of
progress in improving air quality because of the
considerable year-to-year variability in ambient levels
due to essentially random  meteorological factors. For
that reason. Region 9 is planning to use data on
emissions and emissions reductions as the principal
short-term indicator of progress and therefore as the
principal tool for day-to-day management of the
Region's Air Program.
   Ideally, state and local agencies would ensure that
emissions inventories in non-attainment areas are
fully current, complete and accurate. Unfortunately,
even a strong state program which places high
priority on maintenance and use of accurate
emissions inventories (e.g., California) may require as
much as a two year cycle to fully update its emissions
inventory. Region 9 therefore is proposing to  use a partial
emissions inventory of key classes of sources as its
principal tracking tool. The use of a  partial inventory
would give the Region a data base that would facilitate
closer scrutiny and more frequent updating.
   Conceptually and operationally, the use of emission
 inventories has always  been a central element in the
 SIP process. Furthermore, the 1977 CAA
 Amendments required annual reporting of current
 emissions against a reasonable further progress
 (RFP) line (showing projected reductions in emissions
 over time) to be contained in the SIP.
   In practice, however,  a state has been given credit
 in the SIP for the emissions reductions at the time
 that a new control rule  has been adopted, rather
 than when actual emissions reductions are confirmed
 to have taken place in the field. As a result, states are
 credited with emissions reductions  based on projections
 when in  many cases evidence from the field clearly
 shows that those projections, were  unrealistic.
   To correct for this. Region 9 therefore is proposing
 to adjust estimated emissions reductions to reflect
 the reality, of what is happening in the field. In the
 case of VOC control in particular, observations of
 state and local  inspection procedures clearly indicate,
 in many cases, that the initially projected reductions
 from a given class of sources  are not being achieved.
 In the future, when Region 9 staff become aware of
 such operational shortfalls, they will work with the
 state to help see to it that one of the following types
 of corrective action is taken:

 • where appropriate, improve the training of state
 and local inspectors so that more of the emissions
 reduction potential of the  existing rule can be

• alternatively, amend the rule to make it more
enforceable, or

• if the basic structure of the current rule is such
that it is inherently unenforceable, develop a
substitute rule that is enforceable to achieve the
required degree of emissions reduction.

  The responsibility for performing this key role of
assessing emissions reductions and assigning and
tracking emission reduction credits will be assigned
to a special analytical group — the Technical
Evaluation Section — within the Air Management
Division. This group will be the nerve-center of the
Air Management Division. In particular, it will assess
the air quality impact of current and of proposed
activities of the other operational units in the
Division and it will assimilate and assess the impact
of operational  problems encountered by these other
units. In this way it will provide the analytical support
necessary for the Division Director and the other air
program managers to run Region 9's air program as
a coherent whole. It will provide analytical support to
the Division Director to assist him in coordinating the
activities of the other operational units within the
"Integrated Data Assessment for Problem Scoping
 and Targeting" — Region 5


David Kee, Director
Air Management Division
EPA — Region 5
FTS: 8-353-2212
Commercial: (312) 353-2212

The Region 5 Air Division has initiated a
comprehensive study of pollution in several major
non-attainment areas. The first of these is a study of
TSP problems in Detroit. Regional staff presented the
methodology and conclusions of the Detroit TSP
study as an example of one way to plan and manage
air pollution control programs to maximize area-
specific environmental results. Mr. Kee acknowledged
that the Region will need to do a  revised analysis
after the Agency promulgates the proposed inhalable
paniculate standard and that
the revised analysis may
lead to somewhat dif-
ferent conclusions.   ^      Ambient
                          Air Quality Data
Figure 4.
Region 5
An Approach to
                                    The objectives of the study were: 1) to develop a
                                  systematic way to compile and present data from all
                                  available sources, including population exposure
                                  data, ambient data, source information, and
                                  enforcement data;  2) to determine the relative
                                  contribution of point and area source emissions and
                                  other factors (e.g.,  plant closings) to the TSP trends;
                                  and 3) to develop revised program and enforcement
                                  strategies where necessary.  Figure 4 displays the
                                  sources of data the Region uses.
                                    The analysis resulted in several significant

                                  • It is important to consider the impact of specific
                                  sources (especially major, non-complying sources) on
                                  observed standards violations at specific monitoring
                                  stations. Individual sources may be the cause of site-
                                  specific violations more often than we realize.

                                  • Meteorological data — especially windrose data
                                  (data on wind speed and direction) — can be very
                                  useful in helping to determine which sources are
                                  likely contributors to standards violations at specific
                                  monitoring stations. (See Figure 5.)

                                  • With regard to Wayne County (Detroit) Michigan
                                  specifically, the Analysis showed that:

                                  — There has been significant progress in TSP control
                                  since the early  1970's.

                                  — The designated non-attainment area should be
                                  reduced in size to take into account the highly
                                  localized and source-specific nature of the
                                  remaining TSP  problems.

                                    The Region 5 Air Division is working with the State
                                  of Michigan to act on the results of the Detroit TSP
                                  analysis. The Region is also beginning to apply this
                                  study methodology to other pollutants (e.g., ozone)
                                  and to other non-attainment areas.
                                  Figure 5.
                                  Region 5 Air Presentation TSP Pollution Roses for
                                  Steady Wind Direction Days, 1977-79
                                   Ford Motor
                                   Steel Plant
                            Detroit Coke Co.
                                     Detroit Sewage
                                     Treatment Plant/
   •^  r
Great Lakes Steel — Zug Island
                                                          Detroit Edison — River Rouge
                                                          Great Lakes
                                                          Steel —
      Development  Data
                    Total Information Integration

                                                                             .ajug/m 3

                                                                     Indicates 75 u/m 3

   Results Management
   in Regional Water Programs

   In preparing for the Workshop, OMSE staff found
   that the Regional Water Divisions have a number of
   efforts under way to manage for environmental
   results. Three Regions were asked to discuss their
   systems for the collection, analysis, and use of
   environmental data for managing for environmental
     Region 8 staff described a system that relied primarily
   on ambient data. Region 6 staff discussed systems for
   integrating all available ambient, source, and emissions
   data to identify water quality problems. Both of these
   systems are used to identify problems areas and to
   screen available information to determine if further
   analysis is needed in particular areas.
     Region 4 staff discussed the Region's use of
   biological data to identify water quality problems.

   "Comparing Ambient Data with State Standards
   for Initial Problem Screening" — Region 8


   Jack Hoffbuhr, Director
   Water Division
   EPA — Region 8
   FTS:  8-327-4871
   Commercial: (303) 837-3895

   Irv Dickstein, Director
   Tom  Entzminger, Data Analysis Branch Chief
   Environmental Services Division
   EPA — Region 8
   FTS:  8-327-4935
   Commercial: (303) 837-3895

   Region 8 staff made a presentation on the work
   they have done to improve the collection, analysis
   and reporting of ambient water data and to use the
   analysis to identify priority areas for highlighting in
   State-EPA agreements. To introduce their
   presentation, they defined three essential elements
   the Agency must have to manage for environmental

   • environmental objectives,

   • managerial commitment, and

   • credible environmental information.

     The Environmental Services Division, the Water
   Division, and the states have worked closely together
   to incorporate these basic elements into water
   program  management.
     The Region works with the six states in the Region
   to ensure that they enter ambient water data into the
   STORET water quality file. The ESD uses a comput-
   erized system to perform state-by-state use-
   impairment analysis and compares the ambient
   water quality measurements in STORET to the
   individual state standards for those water quality
   parameters relevant to each beneficial use.
  A standard methodology is used to determine the
frequency and severity of standards violations and to
indicate where designated uses of stream segments
are likely to be impaired. Trends in pollutant concen-
trations are cited where possible. Table 4 provides
information on the computer program Region 8 uses
for its Beneficial Use Impairment Analysis.
  In this way, the Region uses ambient water quality
data to identify possible problem areas. The Region
then works with the states to factor the analysis into
the setting of priorities at the start of the State-EPA
agreement (SEA) process. The full process—from
collection of data to development of State/EPA
Agreements and evaluation of those agreements—is
shown in Figure 2 on p. 6.
Table 4.
Region 8 Water Quality Presentation
Program for Determining Beneficial Use Impairments
Input to the computer
program consists of:

(1) A modified criteria
matrix adjusted for
specific state standard
(2) Proper STORET
Agency and Station
codes for all
monitoring sites to be
analyzed, preferably
ordered by river basin.
The computer output provides the
following information for each
beneficial use at each sampling

(1) The average monthly multiple
of criteria exceedence by
parameter (including only
parameters that have potential for
beneficial use impairment).
(2) The average annual multiple
of criteria exceedence by
(3) The  probability of  criteria
exceedence for each parameter.
(4) An impairment level due to
each parameter.
(5) An impairment level affecting
each use (average impairment
due to each offending parameter).
(6) A summary which includes:
  a. impairment levels for all
stations analyzed by use
  b. a ranking of impairment by
use for each station
  c. monthly concentration
severity analysis by parameter for
critical stations.
"Using Ambient, Discharge,, and Flow Data for
Preliminary Determination of Priorities" — Region 6


Myron Knudson, Director
Water Management Division
EPA — Region 6
FTS: 8-729-2656
Commercial: (214) 767-2656

The Water Management Division, assisted by the
Management Division and the Environmental
Services Division in Region 6, has developed and
tested the Water Management System (WMS) as a

means of better incorporating environmental criteria
into State and EPA decision making. WMS is a
technically oriented approach toward analyzing
available information on ambient water quality and
sources of pollution. The WMS was developed as a
pilot approach with one state. The Region has
encouraged other states to adopt it, but it is not a
requirement. The WMS reflects Agency concerns
expressed in EPA's Operating Year Guidance for FY
1982. The Agency emphasized the development of
basic methods and tools to promote sound
management  decisions. Emphasis was also given to
improving the Agency's ability to measure the
effectiveness  of its programs by  using environmental
data. The WMS is a careful compilation of the best
data available to guide the planning, decision making,
and tracking of programs required  by the Clean
Water Act. The insights that result from  the analysis
in the system can be used to guide effective water
management  decisions. The WMS provides a
mechanism by which the program can budget its
increasingly limited resources toward  solving
problems on a "worst-first" basis and consequently
provide the most results from the available

  The steps in the WMS are as follows:

• Compile ambient water quality data  available in
STORET and compare to state standards,

• Screen data for "significant" problems,

• Rank problems in order of severity,

• Identify potential causes, and

• Implement action plans for those municipal,
industrial, and nonpoint sources that are significant
 contributors to the observed water quality problems.
  Figure 6 shows the kind of graphic display of
"causal" information for a stream  segment that is
possible in the WMS. Maps and acetate overlays can
be developed  that show, for a stream  segment, types
of dischargers along the stream  (in PCS); NPDES
permit compliance status, including permitted
effluent limits and  magnitude and  frequency of
violations (from DMR files); construction grant status,
to provide information on what steps are being taken
to correct the problem (in GIGS); types of pollutants
contributed by non-point sources (from 208 and
305(b) reports);  and naturally occuring conditions.
Figure 7 shows how  Region 6 categorizes problems
in its Action Plan.
  The WMS approach is applicable to any pollutant,
or set of pollutants, for which ambient data have
been gathered and recorded over a period of three or
more years. In most cases that would  limit its
present application to studies of conventional
pollutants. However,  as more data are collected for
toxics under the EPA Integrated  Toxics Strategy,
WMS could become an increasingly useful tool for
approaching the toxics problem.
Figure 6.
Region 6 Water Quality Presentation Potential Sources
at One Stream Segment Analyzed by WMS Process
Potential Upstream Sources

        Gosnell 0
    Major Municipal

    Major Industrial

    Minor Municipal
    Minor Industrial
NC — non compliance
FC — fecal coliform
BOD — biological oxygen
TSS — total suspended
Turb — turbidity
SO4 — sulfate
P — phosphate
              ^Monitored Segment in Violation for:
Figure 7.
Region 6 Water Quality Presentation
Action Plan for Water Management System

Municipal      • Construction grants funding
Problems      • O & M program

Industrial       • Enforcement actions
Problems       • Adjust permits

Nonpoint       • 208 planning
Problems       • Land use management

Naturally       • Monitor
Occurring      • Consider standards revisions
 "Use of Biological Information for Water Quality
  Management" — Region 4

 Dr. Don Raschke, Chemist
 Environmental Services Division
 EPA  Region 4
 FTS: 8-250-2294
 Commercial: (404) 546-2294

 Region 4 encourages the development of bio-
 monitoring programs in each of the states  in the
 Region. In the presentation. Dr. Raschke identified
 the bioparameters and biological testing procedures

   used in Region 4 to support decision-making by
   water program managers. Region 4 provides
   technical support to states in site investigations and
   provides technical assistance and training to develop
   bio-monitoring capability in the states.
     Region 4 believes that there is a  need for a
   national strategy that will incorporate biological data
   into the Agency's decision-making  processes. Dr.
   Raschke showed how biological data is used by
   Region 4 for:

   • management decisions — allocation of resources
   based on:

   — types and magnitude of problems, and

   — location of problems.

   Major classes of problems in the water medium
   were identified together with the biological
   parameters utilized for developing  sound decisions.

   • operational decisions

   — NPDES permit decisions

   — 404 permit decisions

   — setting and evaluating water quality standards

   — determining whether use classification are being'met
   — measuring progress.

   The biological parameters critical to making decisions
   for these operational programs were identified.
     The Region also sees a need for a  nationally-
   funded biological data base, such as the  BIOSTORET
   system that has been designed but is currently
   Table 5.
   Region 4 Water Quality Presentation
   Water Quality Problems
                                          Table 6.
                                          Region 4 Water Quality Presentation
                                          Operational Decisions
Bio Parameters
Taste & Odor
Fish Kills
Septic Conditions
Human Health
Animal Health
Aquatic Life
Nuisance Conditions
Fish Kills
Impoverished Biota
Sea Grass Beds
Coral Reefs
Drinking Water
Shellfish Production
Water Contact
Algal Assay
Autotrophic Indices
Standing Crop

Reproductive Success
Species Composition
Residue Analysis
Mutagenic Tests

Standing Crop
Autotrophic Indices
Species Composition

Habitat Inventory
Species Composition

Bacterial Analysis
                                           A. NPDES Permits
                                           • Establish Permit Requirements
                                           • Adequacy of Permit Requirements
                                                       316 A& B Studies
                                           B. 404 Permits
                                           • Jurisdictional Boundaries
                                           • Permit Denial
                                                       Vegetational Studies
                                                       Metabolic Studies
                                                       Organic Import-Export
                                                       Quality of Biota
                                           C. Water Quality Standards
                                           • Establish Criteria
                                           • Determine Use Classifications
                                           • Evaluate Status
                                                       Algal Assay
                                                       Chlorophyll & Organic
                                                       Species Composition
                                           D. Measurement of Progress
                                           • Trends in Quality                Standing Group
                                           • Progress (Goals, Objectives, Policy) Reproduction
                                           — Fishable-Swimmable            Growth
                                           — Biointegrity                    Species Composition
                                           — Toxics                         Condition
                                                                           Autotropic Indices
"Using Compliance Data to Target State Activities
and Evaluate Effectiveness in the Drinking Water
Program" — Region 6

Myron Knudson, Director
Water Management Division
EPA - Region 6
FTS: 8-729-2656
Commercial: (214) 767-2656

 . The Water Management Division in Region 6 has
developed a system which analyzes and uses
compliance data on public water systems to plan and
evaluate activities in the drinking water program. By
analyzing the number and types of monitoring and
reporting violations (M/R) and maximum
contaminant level (MCL) violations in terms of the
population served by each system, they were able to
assist the states in better  targeting program activities
on the most significant problem areas.
  An assessment of compliance data for Arkansas,
Louisiana, New Mexico, Oklahoma, and Texas was
conducted by Region 6 to  identify progress in
improving drinking water quality and to identify
remaining water system needs. Five major problem
areas were generally found to be evident in each
• Small systems  have a majority of the drinking
water violations.

• Each state has one or more violation categories
showing widespread violations (i.e., bacteriological
MCL violations, bacteriological monitoring and
reporting compliance, etc.) each of which should be a
given specific priority for program action as compared
with other known program needs.

• Repeat violators (systems with 2 or more
violations) cause a large portion of the violations.
(See Figure 8.)

• Compliance with the  public notice requirement by
water systems with MCL violations is woefully low.

• A series of formal enforcement actions of increasing
stringency for the recalcitrant violator is needed in all
states except Texas.

  To address these problem areas, Region 6 worked
 with the states to develop a compliance strategy to
 focus state activities on multiple violators and on
 assistance and training of operators of smaller
 systems in order to bring more systems into
 compliance. Their analysis has shown that more
 systems throughout the Region are now in
 compliance as a result  of these targetted efforts. (See
 Figure 9.)
Figure 8.
Region 6  Drinking Water Presentation
Bacteriological M/R Violations, Community PWS's
FY'80, New Mexico
Example: 45% of the violating
systems had 3 or more months
of violations and accounted for
75% of the total violations.
JO ~
10 I
o i£

                              Figure 9.
                              Region 6 Drinking
                              Water Presentation
                              Comparison of
                              FY'79 and FY'80
                              M/R Violations by
                              District Community
                              PWS's New Mexico
                                                         Health Districts
                                                                                        3      4
01    234567
Frequency of Monthly Violations
                10  11   12
Results Management  in
Regional Hazardous Waste

Managers of the Resource Conservation and
Recovery Act (RCRA) and Superfund programs have
indicated that, by their very nature, these two
programs are oriented towards environmental
results. The programs are designed to prevent the
releases of hazardous materials to the environment or
to clean up  uncontrolled sites, and thus achieve
environmental results.
  The RCRA and Superfund programs have
developed techniques to assess the probable risk
from sites and are developing techniques to rank
problem sites. The hazard evaluation model (the
MITRE model) ranks potential Superfund sites based
on their probable hazard.
  Since both of these programs are still in their early
stages of development, a number of questions have
arisen as to what type of information is needed for
risk assessments and to set program priorities.
Region 9 discussed this issue at the Workshop.

  "Data and Information for Setting Priorities and
  Targetting Resources in RCRA and Superfund
  Program" — Region 9

  Harry Seraydarian, Deputy Director
  Toxics and Waste Management Division
  EPA   Region 9
  FTS: 8-454-8137
  Commercial: (415) 974-8137

  While the MITRE model is used uniformly among all
   Regions to rank Superfund sites there is no comparable
   national model for the RCRA program. To fill this
   void. Region 9 developed such a ranking  model
   consistent with the criteria issued by the Office of
   Solid Waste. This model makes use of data which
   facilities submitted in Part A of their RCRA permit
   applications, as well as additional information such
   as the compliance history and the general quality of
   operations at each RCRA site. To use this model (and
   to meet other operational needs) Region 9 has
   assembled a computerized data bank that allows
   quick access to the available information on RCRA
   sites in Region 9. Region 9 has used the model to
   rank sites in priority order for call-ins for Part B of
   the RCRA permit application and to set priorities for
   site inspections.
     Mr. Seraydarian emphasized the need for annual
   surveys in the RCRA program. Region 9 feels
   strongly that a comprehensive annual survey (rather
   than the  proposed 10% sample) of treaters, storers
   and disposers is necessary for two years to establish
   an information base upon which regulatory decisions
   can be made. He suggested that the survey then be
   conducted once every three years to update the data
   base and track progress in hazardous waste
   reduction and adequacy of treatment. He specified
   several reasons why the comprehensive survey is
• to establish a data base for industry in siting
hazardous waste facilities;

• to assess the degree of hazard in terms of waste

• to cross-check the manifest system; and

• to track trends in hazardous waste reductions.

  Mr. Seraydarian also raised important issues he
said must be resolved in order for Superfund
program managers to effectively manage for
environmental results. These were:

• Funds Are Needed for State Superfund Sites.
Mr. Seraydarian said that state involvement in the
entire Superfund program is necessary.  Recognizing
the limitations of the initial priority list of 115
hazardous sites, he urged that the Agency allocate
resources to the states so that they can  make
preliminary assessments of other potential Superfund

He said that without adequate resources for such
preliminary assessments, it will not be possible to
apply the MITRE model in a meaningful  way to rank
sites and assure that Superfund dollars  are
directed towards the sites presenting the greatest,
most immediate hazards and in this way ensure the
greatest possible environmental results from the
Superfund program.

• Guidelines for Cost-Effective Clean-up Are
Needed. Mr. Seraydarian said these guidelines
would be used to determine the appropriate degree
of clean-up at any one site, given the potential
hazard it presented and the relative costs of the
remedial alternatives available. These guidelines
would then be a key factor determining the extent of
the environmental results that should be anticipated.

Summary of
The afternoon of the first day of the workshop was
devoted to presentations by Headquarters Managers
in the Office of Water, Office of Air, Noise, and
Radiation; Office of Pesticides and Toxic Substances;
and Office of Solid Waste and Emergency Response
on the national efforts under way in their program
areas to collect better information on environmental
status and on the environmental results of their
activities and to use it more  effectively in  planning,
resource allocation, program management, and
  The material that follows summarizes the
presentations that were made.
Results Management in
the Water Quality and
Drinking Water Programs"


Rebecca Hanmer
Deputy Assistant Administrator
Office of Water

Ms. Hanmer began her presentation by discussing
the shifts in the philosophy and approach of the
Water program that have occurred since the 1960's.
She pointed out that early on the program had
attempted to make decisions on the basis of water
quality standards, with relatively weak technology
requirements. The Agency then moved to a period of
strong technology requirements tied to permits, and
is now swinging back to a water quality based
approach. She emphasized that managing for
environmental results is not new — that it is a very
old direction that we are coming back to.
  Ms. Hanmer then discussed several areas where
the Office of Water (OW) plans to put increased
emphasis on using environmental information and
assessing environmental results.  In the FY'83
guidance process, OW is emphasizing the need to
make water quality based decisions. In the guidance,
states will be asked to review their existing
procedures for determining which streams are water
quality limited (i.e., those streams that would not be

  able to meet water quality standards just by putting
  on technology based controls, and that would
  therefore require more stringent permit limits) and
  which streams are effluent limited (i.e., could meet
  water quality standards if they put on technology
  based controls). Specifically, OW will be asking the

  • to review the priority water bodies;

  • to rank those water bodies in terms of the
  seriousness of pollution control problems;

  • to look at their procedures for setting water quality
  based limitations;

  • to review the feasibility of achieving the water
  quality standards in those places where technology
  based limits are not enough.

     OW is asking the states to re-evaluate their water
  quality standards programs. Specifically, OW is
  asking the states to conduct an assessment of
  stream classifications, use designations, water
  quality criteria, and the mix of point and non-point
  sources  of pollution contributing to non-attainment.
  States are to answer four basic questions:

  • What  is the  use to be protected?

  • To what extent does pollution contribute to the
   impairment of  the use?

  • To what extent will pollution from control of point
  sources  — basically what we have been regulating —
   restore or enhance this use?

  • Do the benefits of attaining the use bear a
   reasonable relationship to the costs?

     OW wants states to refine water quality standards
   by incorporating everything that is known about the
   stream — emphasizing that site-specific biological
   information is  to be incorporated  as well as the
   chemical information the Agency has been using
   over the years. Headquarters will produce guidance
   documents to assist the States in ranking their water
   bodies. It will outline screening techniques and
   suggest priority weighting factors. It will discuss the
   development of priority water body lists, and the
   inclusion of these lists in states' 305(b) reports.
  Through this analysis of water quality information,
   the 305(b) reports should be more useful for making
     Ms. Hanmer also discussed how the concept of
   environmental results is being incorporated into the
   NPDES program. She stated that since the NPDES
   system was put in place in 1972, the Agency has
   made decisions under NPDES on an engineering
   basis, defining in engineering terms what best
   practicable treatment would achieve, setting limits
   derived from that engineering analysis, and putting
  them in  enforceable form in NPDES permits.  OW
   plans several changes in NPDES permit policies that
   it believes should enhance the Agency's ability to
   measure and see environmental gesults.
  OW will be issuing a second-round industrial
permitting strategy. First priority will be given to
rewriting and reissuing permits where there is a
known impairment to water use or other significant
known water quality problems. Second priority will
be rewriting permits where BAT guidelines have now
come out. Third priority will be issuing permits where
we do not have effluent guidelines. OW's last priority
will be reissuing expired permits that already
incorporate adequate technology. (Under the
Administrative Procedures Act these permits are still
in effect.)
  Ms. Hanmer indicated that all of these efforts will
require that OW give attention to the collection,
analysis, and cost of information. OW is taking more
of an interest in getting its managers to articulate
what information they need to make good decisions.
OW is developing a revised monitoring strategy that
will generate a data base to support decisions and
that encourages local governments and industry to
assist EPA in data gathering. The strategy will
emphasize biological surveys and the types of
monitoring that will help the program get a better
handle on measuring results in cleanup. Ms. Hanmer
asked for help from the Regions and states to identify
how different monitoring techniques can best be
  In the Drinking Water program, where
environmental information is used to target non-
compliance problems and then to encourage the
states to focus on these problems, OW uses the
information to know where new strategies need to be
developed. EPA and the states have agreed on
definitions of persistent or major, and intermittent
or minor, violations of bacteriological and turbidity
standards. This allows OW to analyze trends, identify
categories of systems that are most likely to have
serious violations, and to compare performance at
the district, state, and Regional levels.
  OW will look now at three dimensions when
deciding how resources ought to be spent:

• Do we have a mandate and how strong is it?

• How significant is the problem we are trying to
address before controls are in place? What information
dp we have that indicates that a problem is a
significant environmental problem?

• What is the marginal utility of EPA's involvement
using the tools the Agency has available — permits,
standards, and enforcement actions?

  Ms. Hanmer concluded by paying that the whole
concept of environmental results can be used not
only in program operations but also in structuring the
Agency's thinking about what programs we support
and what priority to give them.

Results Management in
the Air Program"


Paul Stolpman, Director
Office of Policy Analysis
Office of Air, Noise, and Radiation

Mr. Stolpman focused his presentation on how
Headquarters is fashioning its position with regard to
the Clean Air Act (CAA) Amendments, based on his
view that the statute is the thing that most clearly
drives environmental results in the program.
  He identified five areas the Administrator has
indicated should be amended and discussed from an
environmental results standpoint, the thinking that
went into those decisions. He said that while the
Agency didn't intentionally make environmental
results the driving factor in the CAA revision process,
that was, indeed, the case. The areas he then
discussed follow.

The Automobile Standards

The Administration is suggesting adjusting the
carbon monoxide standard from 3.4 grams per mile
up to 7 grams per mile. The goal of the Clean Air Act
in setting auto standards was to get a 90 percent
reduction in the fleet emissions average. An analysis
of available data shows that the 3.4 gram per mile
standard is a 96 percent reduction from the
uncontrolled fleet, while the 7 gram standard is a 92
percent reduction from the uncontrolled fleet. The
data also show that in 1976, the fleet CO average
was about 87 grams per mile.  In 1980 the fleet
average  had dropped to 48.2 grams per mile. Thus,
between 1976 and 1980 tremendous drops were
attained in the average CO emissions of the fleet.
  When the Agency projected into the future  against
the 7 gram and 3.4 gram standards, we found that in
1987, at the 7 gram standard, the fleet would emit
an average of about 26.6 grams per mile on average.
At 3.4 grams, it would emit 26.3 grams per mile —
three-tenths of a gram difference. The reason for that
small difference is that once you start to squeeze the
automobiles' average emissions over 90  percent,  it is
not the stringency of how a car is produced on  the
assembly line that makes the difference, but rather,
how the car is operated in the hands of the consumer.
  The Agency also discovered that, in terms of cost
effectiveness, a 7 grams per mile standard would
result in CO reductions costing nineteen dollars a
ton. At the 3.4 grams per mile standard, the cost
rose to seventy-one dollars a  ton. Based on that the
Administration recommended a 7 gram standard,
basically because there were no additional
environmental results that came from reducing the
standard down to the 3.4  level. Also, when the
Agency looked at attainment status, we found that by
1990, virtually every air quality region would be in
compliance with the ambient CO standard. Therefore,
again for the environmental indicator, a change in
the standard will make virtually no difference, in
terms of the environmental effect.
  The data on the NOx standard is similar to that for
the CO standard. Only two areas of the country,
Denver and Chicago—outside of California  — were
out of compliance with the NOx standard, and there
are no ambient air quality problems for NO2. These
data suggest that there is no great need to keep the
standard at one gram as  opposed to two grams.
Therefore, the Administration is recommending a two
gram standard instead of the one gram standard that
is presently in the law. Also, in 1970 the NOx fleet
average was 3.7 grams per mile. In 1980 it had
dropped to 2.9. At the two gram standard, that will
continue to drop through the decade. A change in the
standard will have virtually no effect on the
attainment status of any  areas of the country.
  In terms of cost effectiveness, the Agency found a
similar but much more dramatic trend to the one that
we found with CO. The 2 gram standard gave us
reductions at about fifty-seven dollars a ton. At 1
gram the cost rose to over six hundred dollars a  ton,
increasing cost by a factor of ten.

The Percent Removal Requirement on Coal  Fired
Power Plants

The Administrator also recommended eliminating the
percent removal requirement on coal  fired power
plants and coal fired industrial boilers. That provision
calls for not  only an emission standard, but actually a
reduction in  the emissions of sulfur and nitrogen, as
they come through the plant, so that no untreated
fuel could be used. The provision was written into
the 1977 Act in order to protect the jobs of miners in
the Midwest. It had little  to do with environmental
protection. There is also a substantial economic
rationale for getting rid of the percent removal
requirement. If you relax  or eliminate the percent
removal requirement, there will be some modest
increase in emissions. Depending on where you  set
the alternative standard, the increase is anywhere
from a 2 percent to 10 percent increase in  SO2.
However, the cost savings are from $200 million to
as high as $3.6  billion a year. Not only that, in terms
of dollars per ton, the cost runs as high as  seventeen
hundred and fifty dollars  a ton for every ton of SO2
removed, whereas on average today in most utilities,
you can get a ton of SO2 out for about 300 dollars a

Acid Rain

Another area where the Agency has taken  this same
stand is in the area of acid rain. There we've taken
the approach that we don't know enough about the
environmental results of  emissions control  programs
in order to take a position with regard to regulations.
Therefore, our stand has  been that we need to do
more research, more rapidly, in order to understand

   those environmental results. We want to know what
   we're buying before we develop what would basically
   be about a four billion dollar per year program in
   order to achieve a ten million ton per year reduction.

   Hazardous Pollutants

   In the hazardous pollutant area, our philosophy is
   slightly different. Since 1970, when the hazardous
   pollutant program was first called for in the Clean Air
   Act, the air program has only managed to list seven
   pollutants. Of those seven, we  have only managed to
   promulgate regulations for four. One of the reasons
   that our record is as dismal as  it is, is because of the
   requirements the Agency must meet once a pollutant
   is put on the hazardous list.
     The Agency is making some  recommendations to
   the Congress for more flexible  treatment for both the
   process of listing hazardous pollutants and for the
   regulatory process. Although this appears to be a
   relaxation of the requirement, in the end, OANR
   believes the environmental results will be much
   more significant. These changes will allow EPA to start
   listing pollutants more  rapidly, with the knowledge
   that once the pollutant is listed, the Agency will have
   some flexibility in dealing with that pollutant and
   imposing reasonable regulations on the industry.
     There was also substantial evidence that the  SIP
   process, with the Federal review put in place, had
   become a  burdensome, wasteful process. One report
   showed that in one Region in December 1980, there
   were 160  SIP  revision actions pending. (There are
   about 500 revision actions in a year in the Agency on
   average.) Of the 160, 71, according to this study, had
   been in this system for over a year. That implies that
   the industrial community is not getting the kind of
   responsiveness it needs in order to plan  under the
   general guidance of attaining air quality standards
   and that EPA is basically not trusting its partner, the
   states, who under the Clean Air Act are given
   primary responsbility for attainment of the ambient
     EPA's goal is to change this  situation dramatically,
   to put in place programs which accelerate that
   review process. In fact, the Agency is recommending
   that the review process be eliminated as a mandatory
   requirement and that, instead,  we work with each
   state on developing an  overall strategy. It would then
   be the state's  responsibility, within that strategy, to
   go ahead with revisions where appropriate. EPA
   would have the ability to step in and review; only as
   a default mechanism within a certain limited time
Results Management in
the Toxics  Program"


Don Clay,  Director
Office of Toxic Substances
Office of Pesticide and Toxic Substances

Mr. Clay began  his presentation by emphasizing that
the Toxic Substances Control Act (TSCA) and the
Office of Toxic Substances are different from other
programs  in the Agency and so must have a
different approach to measuring and managing for
environmental results.
  He identified the purposes of TSCA as encouraging
the development of health and environmental effects
data by manufacturers and processors of new and
existing chemicals and shifting the nature  of
chemical  production and use so as to encourage
safer products in manufacturing processes. He also
discussed the fact that the program regulates only as
a last resort.
  Mr. Clay said  that in measuring for environmental
results, the Office of Toxic Substances has broken
the toxics program into three types of indicators —
input indicators, output indicators, and process
indicators. Using the asbestos in school regulations
as an example,  an output indicator would be an
estimation of the actual reduction in asbestos-caused
cancer which results from that program. While a
good indicator, it would be difficult or impossible to
measure. A process indicator for the asbestos
program would  be the reduction in the concentration
of asbestos fibers to which school children are
exposed. That reduction could be estimated, but
relating it to health effects would be more difficult.
An input  indicator would be the development of the
regulation itself.
  While these are easy to count, Mr. Clay  pointed out
that they are a long way from the output indicators
which he  envisions as necessary for measuring
environmental results — health effects indicators,
such as acute or chronic effects, the number of
cancers estimated, the number of birth defects —
and environmental indicators, such as fish kills. He
added that we should also consider economic
indicators, for example, the number of companies
forced out of business, and innovation indicators,
such as the number of new products that  are
   Mr. Clay then turned to a discussion of the
difficulty of measuring environmental results in the
Toxics program. He compared the situation in Toxics
to RCRA, which must try to measure the
effectiveness of preventing things from happening.
He also pointed that results may show up long after
a program action. For input indicators, such as
getting rules out, he noted that it is difficult to know
whether people are actually complying and whether
the chemicals that will be substituted for one which
is taken off the market or restricted, are,  in fact,
safer. For output and process indicators, Mr. Clay
indicated that the length of time before results are

measurable is a serious problem. He used the
example of the incubation time for cancer — twenty
to forty years. Models to predict health effects, he
said, are very uncertain. Other difficulties he
identified include selection of appropriate units to
measure, since we are controlling to prevent
negative health effects; relating tons of production to
exposure; the absence of good baseline data; and
measuring deterrent effects — for example, what
chemicals are not even produced and submitted to us
because EPA and TSCA are here.
  The actions OTS is taking to manage better for
environmental results through input indicators

• development of a "One Hundred Day Plan"
identifying input indicators and goals of the Toxics
program, tracking  negotiated, voluntary, and
regulated accomplishments;

• prioritizing existing chemical testing or control
actions; and

• reorienting the program's budget and planning
process along input indicator  lines.

  Regarding output and process indicators,  Mr. Clay
stated that some baselines are currently available to
the office. These include information on chemical
substances and poundage, although it is somewhat
dated; limited data on the number of chemicals
introduced annually; and records on new substances
introduced between 1979 and 1982. OTS also plans
to require exposure and other data for certain
chemicals of concern.
  Using these data, OTS is considering comparing a
random sample of pre-TSCA inventory chemicals
with premanufacture notifications to see whether
there have been trends toward safer chemicals or
chemical manufacturing processes, or toward
lowered environmental releases. The program also
will examine the data available on  8-A chemicals to
determine production trends and will try to  measure
the effect of test rules and negotiated agreements on
use and production of volatile chemicals.  Further, the
program will identify changes in the number of
chemicals introduced annually to try to measure the
impact on innovation. And finally, the program will
monitor, on a limited basis, ambient and human
exposure levels to establish baseline trends.
  Mr. Clay concluded by saying that managing for
environmental results remains a great challenge, but
is an effort which is certainly worth doing.
Results Management in
the Solid Waste and
Emergency Response


Rita Lavelle
Assistant Administrator
Office of Solid Waste and Emergency Response

Ms. Lavelle began her presentation by
summarizing the environmental results achieved by
her office's enforcement  activities in the Superfund
and RCRA areas. She mentioned several examples
including violators who have been jailed recently (in
cooperation with State and local authorities) in
Pennsylvania, New York,  Vermont and North Carolina
for improper hazardous waste handling and disposal
practices; Superfund enforcement efforts which have
brought in $59 million in private funds for cleanup of
23 hazardous waste sites; and 10 Superfund sites
which have been cleaned up. Ms. Lavelle emphasized
how enforcement creates an incentive for voluntary
compliance. She offered the example of the Hooker
Chemical Company which signed a consent decree
costing it an estimated $30 million for cleanup at
Niagara, N.Y., at an enforcement cost to EPA of less
than one-tenth that amount. Such an enforcement
outcome also is a deterrent against another Love
  Speaking of hazardous  waste control through
compliance monitoring, Ms. Lavelle noted that this
function was being shifted steadily to the states in
accordance with President Reagan's New Federalism
initiative. She said 30 states were already authorized
to conduct compliance monitoring of generators and
facilities that treat, store  and dispose of hazardous
waste.  In 1981, states conducted 4,515 inspections
and EPA conducted 1,742, but the weight of actual
inspections is shifting steadily to the states with
EPA's Regional Offices assuming more of an
oversight role. Ms. Lavelle then listed other
enforcement methods employed by OSWER —
administrative orders, judicial action and criminal
  Turning to a more detailed discussion of results-
oriented activities in, first, Superfund, and then
RCRA,  Ms. Lavelle emphasized the importance of
"consistent application" of the philosophy of
cooperation, rather than confrontation. As an
example,  she cited the ABM-Wade suit in which 36
responsible parties had agreed to pay $1.6 million
toward cleanup at  that site. EPA is prosecuting
responsible parties which are not settling. She noted
that EPA  may sue for triple damages if Superfund
money is expended and responsible parties are
  In summary,  Ms. Lavelle said the Superfund
enforcement program follows a  dual-track system in
which the Agency proceeds with cleanups where
responsible parties are slow to "step to the table,"
but at the same time the  Agency works with

  responsible parties to ensure they will make the leap
  in the most expeditious manner possible. If the
  responsible parties fail to respond, they are taken to
  court while the cleanup continues. OSWER tries the
  carrot first, but if it does not succeed, the Agency will
  use the stick. She noted that above all, consistency
  was the goal.
    Ms. Lavelle then discussed the philosophy and
  difficulties in accurate measurement of
  environmental results. She noted that the purest
  form of measurement would be a tabulation of lives
  saved, illnesses prevented and birth defects avoided.
  Proving a cause and effect relationship is difficult,
  however, and proving a negative cause and effect
  relationship is even more difficult.
    The Superfund staff is now developing practical
  ways to measure environmental results  attributable
  to its cleanup activities. At the 115 interim priority
  sites, the measurement of results is facilitated by the
  detailed data collected as part of the hazard-ranking
  process established in the Mitre Model.  A kind of
  baseline will be derived against which to compare
  results of cleanup activity. The hazard ranking system
  provides information about substances,  pathways and
  target populations or receptors. A rough estimate of
  the threatened population can be derived from the
  number of people living or working near a site. These
  data can serve to approximate a baseline case, from
  which the benefits from remedial action can be
  inferred. However, she cautioned that cleanup results
  may not be known for several years.
     In a more detailed discussion of RCRA, Ms. Lavelle
  said the great bulk of Federal regulation governing
  hazardous-waste management will be in place by the
  end of July. She said such an accomplishment is a
  "result" in its own right. In  the meantime, she
indicated that her staff was poised to take two more
results-oriented steps: First, to arrange visits to some
200 facilities to check their compliance with
groundwater protection standards and regulations;
and second, to focus our permitting strategy on the
2,000 incinerators and land-disposal sites among the
10,500 facilities that now treat, store and dispose of
hazardous waste.
  RCRA is also looking for other methods of
managing for environmental results. For  instance, it
is conducting an annual survey of generators and
hazardous waste facilities which will provide
information on the national capacity for proper
disposal, waste reduction by recycling, reuse and
recovery, and the extent to which waters are being
properly managed. One approach is by developing
environmental standards which have a strong
influence on environmental results and provide
regulated parties with the greatest flexibility. She
said they were difficult to develop and apply in
practice, however. The second approach is with
design and operating standards which are somewhat
removed from the direct environmental benefit
sought,  but provide for prevention of harm to the
environment and public health.
  In conclusion, Ms. Lavelle said her staff was
working with the Office of Planning and Resource
Management to improve the measurement of results.
Priorities are being established in both RCRA and
Superfund, and there will be a greater reliance on
States, in keeping with  President Reagan's New
Federalism policy and also consistent with good
management. The quest will be to achieve real
results in environmental protection, "without fakery
or fluff."

Summaries of
Presentations  on
the  Use of
Biological and
Public Health Data
"Biological Data"


Dr. Tom Murphy, Director
Environmental Research Laboratory/ORD
200 S.W. 35th Street
Corvallis, Oregon 97330
FTS: 8-430-4601
Commercial: (503) 757-4601

Dr. Murphy discussed the limitations of the current
chemical toxicity approach to monitoring and
suggested a course to improve the use of
  Two frequently used techniques to evaluate
attainment of EPA's statutorily set biological goals
were discussed: developing chemical criteria which
can be used to predict the suitability of the
environment for life (e.g., DO in water), and direct
measurement of suitability of the environment with a
bioassay. While both are quantitative and useful they
also have disadvantages because they are based on
toxicity, primarily chemical toxicity. This ignores the
influence of hydrologic and habitat modifications
which may in many cases place greater limitations
on attainment of the biological goals.
  Dr. Murphy suggested that two considerations
are necessary: 1) what do we want out of the
environment, i.e., what is its desired use; and 2) if
we want the quality of streams to permit  uses that
depend on a "healthy" biological system, we have to
look at all determinants of this, not just pollutants or
chemical criteria. The Environmental Research
Laboratory at Corvallis has concluded that:

• probably more miles of streams are biologically
degraded by habitat modifications than by toxics; and

• in many cases, planned habitat improvements are
a cheaper and more effective way to biological
improvements than traditional pollution control.

The limitations of the chemical toxicity approach can
be overcome by direct field biological surveys. This is
not a new approach, it is very straightforward, but it
is also one of the least understood and most ill-used.
The fundamental problem is: what reference point do
we use to evaluate a biological system? What do
terms such as "integrity" or "propagation of fish and
wildlife" mean when applied to biological systems?

     Dr. Murphy concluded that our criteria must go
   beyond chemical criteria; we must face the problem
   of different levels of use and the different chemical
   and habitat limits for these uses. We must also
   further research the use of "least disturbed
   comparable systems" as a means of defining a
   desired state of stream "health" with the
   understanding that natural variation does occur and
   must be allowed for.
     The problem  is that there  is no magic formula:

   • We can't come up with a cookbook for all
   situations; but we must or can go beyond the current
   situation of relying on each  biologist's judgement.

   • Guidelines are possible, if we accept that they'll
   never be entirely simple and that there will always
   have to be some judgement.

   • It is difficult to write a regulation for biomonitoring
   and we may  have  to rely more on a process of
   managing expert biological opinion while using a set
   of accepted individual assessment techniques.
   "Public Health Data"


   Dr. Jacob J. Feldman, Associate Director
   Office of Analysis and Epidemiology Programs,
   National Center for Health Statistics
   3700 East-West Highway
   Hyattsville, Md. 20782
   FTS: 8-436-7026
   Commercial: (301) 436-7026

     Dr. Feldman discussed in some detail a few
   examples of the use of health data in assessing
   environmental results.  He focused on certain of the
   issues involved in using body burden measurements
   to monitor pollution. He emphasized the need to take
   into account how a substance is metabolized, how it
   passes through the body, and the toxic response
   curve in designing the  measurement and analytic
   protocols. He illustrated his message with two case
     Blood lead levels were determined from a sample
   of 10,000 individuals as part of NCHS's National
   Health and Nutrition Examination Survey (NHANES
   II). Blood lead levels do not fluctuate widely in the
   short run; the  rate of excretion of accumulated lead
   is generally slow enough for current blood lead level
   to provide at least an indication of exposure prior to
   the last few days. The absorption of  lead from the
   ingestion of deposited lead dust tends to make blood
   levels less sensitive to  day-to-day fluctuations in the
   ambient air levels. The risk of hematological or
   neurobehavioral effects or other health damage can
   be gauged from blood lead levels. The trend over
   time in the parameters of the blood lead level
   distribution for a population can thus be a good
   indicator for assessing  environmental results.
     Dr. Feldman presented data from NHANES II
   showing an applicable downward trend in mean
blood lead levels over the 4 years of the survey, 1976
to 1980. The trend was apparent in various
demographic subgroups and at different seasons of
the year.  Declines were shown for the 1976-1980
time period in the amount of lead used in gasoline
production and in ambient air levels. While the
decline in the blood lead levels could have been due
in part to other factors such as decreased
consumption of food from lead-soldered cans and the
continued downturn in exposure to lead-based paint,
there is presumptive evidence that the reduced use
of lead in gasoline was responsible for a substantial
part of the decline.
  Carboxyhemoglobin determinations were made on
over 8,000  individuals from NHANES II.
Carboxyhemoglobin levels are more unstable than
are blood lead levels. Carboxyhemoglobin levels are
quite sensitive to day to day fluctuations in ambient
levels and smoking. Furthermore, it has been
suggested that the major health risks due to carbon
monoxide exposure are acute in nature. Relatively
short-term exposure to exceptionally high levels of
carbon monoxide may cause adverse cardiac
symptoms or episodes in persons suffering from
coronary heart disease. The distribution of days by
ambient carbon monoxide levels in a  given locality is
extremely skewed. To use body burden measures to
assess exposure to high  levels of ambient carbon
monoxide in a given locality, it is necessary to
conduct Carboxyhemoglobin determinations for
residents of that locality on a great many different
days. Dr.  Feldman presented NHANES II data
showing the percent of examined individuals with
Carboxyhemoglobin greater than 1.5 percent in each
of a number of different  unidentified communities.
The great variability of this measure between
communities undoubtedly reflects in part differences
between  specific communities in the tendency for
episodes  of high ambient carbon monoxide. However,
a particular community where only a small fraction of
individuals were found to have relatively high
carboxyhemoglobins may have been
mischaracterized. There could actually have been
only a few days with high ambient carbon  monoxide
levels during the period of the survey in that
  Brief reference was made to the collection by
NCHS of drinking water samples as part of the
NHANES I Augmentation Survey. In addition, urine
and blood speciments from NHANES  II were tested
for selected pesticide residues or metabolities.
  The National Death Index (NDI), administered by
NCHS, facilitates the conduct of follow-up  studies. It
is a file of all  deaths in the United States beginning
in 1979.  It permits the identification of which
individuals in a study cohort had died during a given
time period. The State in which the death  occurred
and the death certificate number can be provided to
the investigator for each person who had died  in the
study cohort. This enables the investigator to obtain
from the  State, the death certificate, containing

cause of death information. The NDI can be of great
value in the long-term follow up of individuals who
have been exposed to possibly toxic substances from
a waste disposal dump or an industrial mishap. The
presence or absence of high rates of premature
death or an excess of deaths from particular causes
could provide evidence regarding toxicity.
  To use the NDI, it is necessary to submit a file of
names (both first and last) of those being followed in
conjunction with either their respective dates of birth
or social security numbers. Certain additional items
of identifying information can  be useful in either the
search procedure or in determining the quality of
possible matches. To receive copies of the User's
Manual and application forms, write:
    National Death Index
    Division of Vital Statistics
    National Center for Health Statistics
    Room 1-44, Center Building
    3700 East-West  Highway
    Hyattsville, Maryland  20782
NCHS is currently analyzing the 1980 National
Natality Survey (NNS) and the 1980 National Fetal
Mortality Survey (NFMS). Information was collected
from mothers, physicians,  hospitals and associated
medical sources. These data will  be useful  in
identifying certain fetotoxic substances. Dr. Feldman
indicated that such vital record surveys can be
extremely powerful tools for environmental
epidemiology. For further information regarding the
NNS and NFMS, contact Dr. Paul Placek, Division of
Vital Statistics, NCHS, (301) 436-8954.
  Clues to health effects of particular pollutants can
sometimes be discerned from geographic patterns of
mortality or morbidity. Unusual air, water, or
industrial characteristics of localities can occasionally
be linked to exceptionally high mortality rates from a
specific cause. The National Cancer Institute (NCI)
has produced, from the mortality data compiled by
NCHS, maps showing geographic differentials for a
number of causes of death. For further information
on this work, contact: Dr. Thomas J. Mason, NCI,
  Dr. Feldman also referred to the following review
prepared by NCHS, as a good  source of information
on data currently available from Federal data
collection systems on health effects.
    Environmental Health
    DHHS Publication No. (PHS) 80-1248,
    National Center for Health Statistics
    3700 East-West Highway
    Hyattsville, Maryland  20782

Summary of
Presentations on
Approaches to
'The Program
Integration Project's
Geographic Approach"

Michael Alford
Office of Management Systems and Evaluation, OPRM
401 M Street, S.W.
Washington, D.C. 20460
FTS: 8-382-4016
Commercial: (202) 382-4016

Michael Alford discussed the overall purpose of the
Program Integration Project (PIP), formerly the Toxics
Integration Project, and described the design of the
new demonstration project which has just begun.
  The Agency's activities have historically been divided
by medium. This approach worked with most conventional
pollutants, which are typically high volume and without
intermedia transfers. This approach does  not, however
work as well for toxics, because of the transfer of toxics
from medium to medium. The medium by medium
approach makes it difficult to be sure, even when dealing
with conventionals, that we are addressing the worst
problems first. Further, it contains no mechanism for
assessing the cumulative burden imposed on any specific
industrial sector through the regulatory activity of all the
media programs. The purpose  of PIP is to  look for scien-
tifically determined control priorities on the basis of
exposure and risk, to consider  the economic impacts of
existing Federal, state, and local controls, especially their
cumulative costs, and to analyze control options within a
frame work of cost and benefits for the ultimate goal of
achieving greater environmental protection with less cost.
  The Agency has considered three integrative approaches:
the geographic approach, looking at individual high
impact areas; the industry approach, looking at all pollution
streams of a given  industrial sector; and the chemical
approach, looking at individual, unusual risk chemicals
that appear widely in the environment in  different
industrial sectors. The Office of Toxics Integration, OPTS,
is continuing to work on the chemical approach.  PIP will
look at the geographic and industry approaches.
  The geographic approach is based on the premise
that there are areas that have concentrations of
sources that yield high levels of exposure and
presumably unusual health and environmental risks.
Within these areas we should define the  most cost-
effective strategy for correcting the problems, rank

  them in order of importance, and emphasize state
  and local controls other than conventional command
  and control regulation. In 1981 PIP reviewed the
  Agency data  bases for geographic-specific
  information by county. That analysis suggested that
  when we look at any given parameter (e.g.,
  population, ozone levels, chemical  production,  etc.) a
  small number of counties account  for the large
  majority of the contributions of that parameter
  nationwide. For  example, thirty percent of the total
  tonnage of all chemicals produced  in the country
  come from ten counties. All the data bases PIP
  looked at share this same phenomenon. PIP used a
  rough screening model to combine the scores for
  each parameter by county.  This model estimated that
  one percent of the three thousand  counties
  nationwide account for between twelve and twenty-
  four percent  of the nation's environmental problems.
     Chloroform levels  in a section of the Kanawha
  River Valley was discussed as an example of the kind
  of analysis of a high pollutant concentration area the
  geographic approach will use. By looking at  pollutant
  loading based on source and ambient data, various
  options can be developed to achieve different uses.
  For example, in  looking  at drinking water,  options
  could include either  source restrictions in  some reaches
  of the river (possibly in combination with increased dis-
  charges elsewhere) or other control options such as
  moving the intake upstream from a major source.
     In focusing on individual cities in the
  demonstration project planned for  this year, PIP will
  review the current regulatory plan at all levels of
  government for that local area — i.e., who is being
  regulated and what are the actual  environmental
  problems — to see if the regulations match the
  problems and if some problems are unnoticed,
  unmanaged, or over-regulated. They will look at what
  are most cost-effective controls, not just the high
  cost source-oriented controls,  but also other options
  such as the interruption of exposure pathways.
     In the long term, this is the  direction that  PIP is
  proposing. By combining various sources of  data we
  can develop intermedia  priorities, interpollutant
  priorities, and interplant priorities on specific local
  conditions in areas of unusual risk.
   "NEIC Multi-Media Assessments"


   Gary Young
   National Enforcement Investigations Center
   U.S. E.P.A.
   Building 53, Box 25227
   Denver, Colorado
   FTS: 8-234-4650
   Commercial: (303) 234-4650
   Gary Young described the multi-media assessments
   the National Enforcement Investigation Center (NEIC)
   is undertaking as a way to select facilities for com-
   pliance inspections. He described a multi-media case
   study of the Niagara Frontier in northern New York
   State, the procedure used for multi-media complaince
   audit inspections, and issues and related activities
   for further development of the multi-media concept.
  In the Niagara Frontier study NEIC used "FINDS"
(Facility Index System) developed by Region 2 to
generate an inventory of known municipal, industrial,
and commercial facilities and active or inactive waste
disposal sites. The initial list of more than ten
thousand facilities in the two counties included in
the study was reduced to a  second list of 940
facilities identified as potentially significant sources
of chemical substances. The location of the facilities
on the second list was graphically displayed using  a
Region II computer graphics program—MAPS.  Using
overlaps of different data set maps, NEIC was able to
identify instances where several different names
were recorded for the same facility. NEIC then
developed rating criteria to define the relative
significance of actual or potential releases of
chemical substances to the air or water pathways or
as a result of hazardous waste handling. The criteria
were designed to group facilities by the degree of
activity in each  pathway. A  high rating against the
criteria did not indicate that the facility had a
significant environmental problem; it simply indicated
that the potential for release was high. From this
listing  NEIC identified a  series of follow-up activities
for New York State to undertake with support from EPA.
  A second case study, in the Beaumont-Lake
Charles, Louisiana area, was a pilot of the multi-
media compliance audit inspection concept. After a
review of facilities similar to the inventory produced
for the Niagara  Frontier Study, a plan was developed
for compliance audits of facilities rated as having
high potential for release of chemical substances.
The plan consisted of reviewing background
information on each facility from existing data bases;
developing a specific project plan including
justification, tasks required  to fulfill the objectives,
and how the results will be reported and when; and,
finally, notifying the facility of the intent to inspect to
ensure that the facility's technical and legal
personnel would be present at the inspection.
  Based on the results of the pilot study, Mr. Young
suggested several issues which should be addressed
to improve multi-media compliance audit inspections:

• better training of EPA personnel is needed to develop
technical skills necessary for multi-media assessments;

• present data filing systems need to be revised to be
consistent with the uniform data generated by the
multi-media ranking scheme for facilities; and

• the philosophical basis of compliance monitoring
needs to be reoriented from the present emphasis  on
demonstrating high levels of compliance to greater
efforts to identify violations*and probability of
continuous compliance or continuous violations.

  In conclusion Mr. Young mentioned three related
NEIC activities:

• a draft procedures manual on multi-media
compliance audits has been developed and is
available for review;

• the initiative to verify compliance with consent
decrees is continuing; and

• NEIC is working with the  Regulatory Reform Staff
to develop the concept of environmental auditing.

Panel  Discussion on
EPA  and  State  Roles
in  Managing  for
Environmental  Results
Introduction by Lewis S. W. Crampton, Director
Office of Management Systems and Evaluation

Mr. Crampton began the session by noting that
during OMSE's visits to the Regions, the issue
of EPA versus State roles in managing for
environmental results was repeatedly raised as a
major concern. Especially as the Agency delegates
more programs to the states and our role becomes
more of an oversight rather than program
management role, the question of how we work with
state environmental officials to manage for
environmental results becomes all the more
 The panel members were: Gene Welsh, Chief,
Water Protection Branch, Georgia Department of
Natural Resources; Robert Burd, Director, Water
Division, Region 10; Bern Steigerwald, Director,
Regional Programs Office, OAQPS; Ned Notzon,
Acting Director, Office of Analysis and Evaluation,
Office of Water; and  David Gibbons, Chief,
Environmental Branch, OMB.
 Mr. Crampton asked the panel members to discuss
several specific questions in their discussions.

• Once a program is delegated, how can EPA
promote managing for environmental results?

• Who is ultimately responsible for setting
environmental priorities, EPA or the States?

• Who should be held responsible for whether the
desired environmental results are achieved? Should
states be accountable?

• How should we best work with the states to
achieve environmental results? How do we  best
promote managing for environmental results with
voluntary SEAs?

• Managing for environmental results depends on
the collection of good environmental data. Many EPA
grants to the states have been cut. How can we best
ensure that EPA and the states have the data they

 The full text of the panel members' discussion

  Individual Presentations

  Presentation by Gene Welsh, Chief, Water Protection
  Branch, Georgia Department of Natural Resources
     I would be presumptuous to speak for all the states
   in this country. I think I'd be fortunate if I can
   express a little philosophy for the State of Georgia. I
   think the philosophy that I express has been carried
   out in Georgia. And, I think our basic philosophy is
   that the  environmental program in the state of
   Georgia  will be run by the State of Georgia. For the
   benefit of you people who are not aware of it, we
   have taken on all the delegations except UIC, which
   is in process right now. But, we basically believe that
   the state should run the environmental programs.
     Following that philosophy, I think we need to
   discuss the roles of the federal, state, and local
   governments which lead into priority setting. We
   believe that the federal role should be one of
   standard setting and  overview, that is, funding those
   high priority national issues, such as superfund or
   construction grants and supporting research and
     I think we should also follow the concept of the
   existing  legislation, that is, a state cannot or does
   not want to carry out some of these  environmental
   programs, then it probably falls on EPA to do it. And,
   EPA certainly should be in a position to provide the
   technical assistance that many states may need.
     The state role, in our view, should be one of
   operating the control over the environmental
   program. This would  include carrying out national
   program priorities, delegation  of national programs,
   measurement of the  results, and the monitoring.
   Don't lose sight of the fact that many state programs
   have priorities established by their own elected
   officials. I  think we must keep in mind, that there are
   national priorities and there are state priorities.
     The third participant in this ball game, so to speak,
   is the local government. We believe  that they should
   manage the facilities, be they industrial or municipal.
   They should do some monitoring. They should
   operate  some types of local programs, such as they
   do in air pollution control. And, they should carry out
   their responsibility somewhat under the overview
   and supervision of the state, similar to the state-
   federal relationship.
     If we accept these  approaches, then the priorities
   follow. There are certain national priorities
   established by law, backed up by funding, which
   must be established at the federal level. It would be a
   mistake to establish those priorities without some
   state discussion or some state inputs. I think that
   national priorities can be arrived at through an open
   discussion between the state and the federal agency.
     By the same token, as I indicated earlier, there are
   many state priorities. When the General Assembly in
   Georgia  appropriates money, or passes laws for
   enforcement, they establish their own priorities on
   many areas. I think we must recognize these state
priorities. They may need to be discussed and worked
out with the federal agency to assure that they're
consistent and compatible with the national
  I believe that the way to work with the states is to
pursue two very important points. One is a full
partnership approach. The second is open
communication. I think we  have achieved  much of
that with our associates  in Atlanta, with the Regional
office, because we do have good communications.
Let me give you an example of some of the
communication we're having right now. The Region
is allowing us to develop our own Section 106 water
program plan, under our own guidance, provided it's
consistent with the law,  the regulations, and the
priorities. But, we will develop our own progr?«;n
plan. And, we will define those activities or it>ose
results we intend to accomplish. This is going to be a
first attempt at giving the state the flexibility to carry
out its own defined plan. I don't know whether it's
going to work. We're going to try it. But, I  think that
it's going to be a innovative approach, and well worth
the try.
  As you well  know, states come in about fifty-seven
different varieties. There are many states  interested
in carrying out environmental programs. There are
many states that couldn't care less. I think the thing
that I would recommend throughout  all of this is that
we do not get too hung up on generating  new data or
instituting new reporting procedures, so that we get
to the point where we're so busy reporting data or
collecting data that we lose sight of the forest out
there, that is, environmental control. We've seen
experiences within our own state of agencies who
are so busy preparing reports, that in a short time
they do not have much to report on, except the
number of reports.
  Finally, I think we've got to keep in mind that we're
here to control and protect the environment. And, we
ought to manage it on the basis of much of the data
which is already being generated. Thank you.

Presentation by Robert Burd, Director, Water
Division, Region 10.
Our experience in Region 10 in managing for
environmental results hasn't been that much
different than what you've heard from  the other
Regional offices. But, I would like to say that we've
had a good reputation in Region 10 as being able to
work well with the states. And, I think that is true.
We've worked with the states in Region 10 for five or
six years on managing for environmental  results. In
fact, when we started five or six years ago, I think we
even used that term, managing for environmental
results. At that time we  agreed that we ought to take
a look at what's good for the environment. We
started a process of doing state by state assessments
to find out where the real problems were, and to try
to direct our resources to those real problems.
  I would like to mention, by the way,  in hindsight,
that the workshop  should spend some  time thinking

about pollution prevention, as Region 9 commented
yesterday. It's particularly important to the western
Regions. I hope out of the workshop this afternoon
and tomorrow we can come up with some creative
ideas on how to include pollution prevention in our
managing for environmental results strategy also.
  Getting back to environmental assessments, what
we did in Region 10 was to work with the states to
produce what we call the environmental profiles.
That term has had both good and bad reception  here
at Headquarters. But, this was a tool for managing
for environmental results, where we and the states
got together and produced a document that identified
the problem areas and laid out some programs, as
well  as priorities in dealing with  those problem
  We put out the first profile in 1977. We  made a
mistake in that one in that we lumped all the states
into one profile. They objected to that because it
seemed to them that we were comparing the bad
features of one state versus the good feature in
another. Following that, we came out with separate
profiles for each  state. Profiles turned out to be
something the states reluctantly went  into, but
eventually became very enthusiastic about, because
it gave them a good tool that they could use when
talking to their Governor, talking to the legislatures,
talking to the public, their constituents, about the
real environmental  problems in that state.  They have
picked up on that. Even though we are not at Region
10, anyway, producing environmental profiles this
year, the states are continuing to do those
assessments, and have found them to be quite
  I would like to  offer something constructive here,
and hope to stimulate some dialogue. I don't want
Lew  Crampton and  the other folks at Headquarters to
get away without having to participate in a real
meaningful way in this workshop. So, I'd like to talk a
little bit about some constraints in the Headquarters
guidance and what that guidance may or may not do
for us in terms of managing for environmental
results. An example: Headquarters' guidance told us
that the Idaho Air Program had to be run the same
way as the New Jersey Air Program. And,  I think it
took some discussion on that point before we
convinced folks that maybe Idaho's program doesn't
need to be the same as the New Jersey Air Quality
  I'd also like to speak to the reporting systems that
have been required, in the past anyway. The Regions
have tracked around four  hundred separate counts,
or beaning counting as we all call it. Some of those
bean counts, I think, weren't too meaningful in terms
of environmental results — things like how many
public meetings were scheduled; how many press
releases did we come out with; and, one I  know I had
to track in the Water Division was the number of
EPA approved designated management agencies
implementing approved plans or  parts of plans for
control of national priority problem areas. I really
didn't think that that was  a very constructive activity
for me to track. Some days there were more people
keeping track of these beans than there were doing
something about creating a good environment.
  We often said we had to do it because it kept
Headquarters happy. And, we obviously want to keep
Headquarters happy. But, we think that the Regions
and the state, working in a partnership, can  manage
for environmental results, rather than for maximizing
bean counting. The guidance that we're seeing this
year is very good and very constructive and goes a
long way in avoiding the excessive bean counting
that we've seen in the past.
  As far as delegations and reporting go, John
Spencer (Region 10 RA) talked to the Governor of
Oregon the other day about taking on further
delegations. The Governor said he would only be
interested if EPA let the State of Oregon run the
program the way that they thought it best to run that
program. The State would want  us to minimize
oversight and minimize reporting. In  effect, they don't
want EPA telling them how to run their program.
They will meet the goals that we set up, but they
don't want us telling them in minute detail how
they're to accorr plish those  goals.
  On the point of reporting requirements, my
suggestion to Headquarters  would be that any
reporting requirements that we do have to comply
with do match the guidance that Headquarters sends
out. We shouldn't be telling Idaho that they have to
run an air program just like  New Jersey's. And, we
shouldn't necessarily be telling any state to ignore an
minor permits, to only concentrate on majors. This
thought came home to me when I was doing a mid-
year review in Idaho last week. We began the mid-
year review by displaying a major basin in Idaho,
ranking all the streams in Idaho  by a water quality
index, and then  taking a look at our construction
grant activities,  permitting activities,  and
apportionment activities relative  to that water quality
index to see if they matched up.  Out  of that
discussion the state of Idaho pointed out that many
of their real water quality problem areas were caused
by minor discharges, and  yet guidance that they've
gotten  in the past, anyway, was  to focus on major
discharges and not to worry about minor permits. Not
to worry about enforcement against minors. And yet,
here was Idaho  telling us that the major water
quality problems now in that State were due to minor
discharges. That often  is true in  the West where you
don't have, in some streams anyway, a lot of flow.
So, this is a point we may need to address in head-
quarters guidance. Thank you.

Presentation by Bernard  Steigerwald, Director,
Regional Programs Office,  Office of Air Quality
Planning and  Standards

I'm going to focus on the setting of air priorities. It's
a job I've been involved with at the Headquarters
level, and I've seen it operate some at the state and
Regional level. Air has, I think, the same problem
that most of the older environmental  programs have.
We have become stable in size and we don't have
enough resources to do the  statutory job. Therefore,
priority setting becomes key to us and it's something
that we do have to face very year.
  We heard yesterday that the Air program has no

problem setting priorities because we are air quality
oriented and we automatically manage for
environmental results. Talking to a lot of the Air
people, we think that that's unfair. We do have great
problems setting priorities. The air quality standards
are there, but some of the problems stem from the
fact that air quality is highly variable, often changing
block by block, and hour by hour; that looking at
exposure, which is a better measure of the problem,
is more complicated than it is in the water program
because we haven't got any faucet to sample and
because people are mobile, and they do move
through air of highly different quality.
  We have the  ambient air quality standards, it's
true. They are often based, by law, on extremely rare
events. You often have to characterize an area, a
whole city, by the  highest day or the highest hour in
a five year period at the worst site. That leads to
problems. Many state agencies think that we have
set the air quality standards at a level unnecessarily
strict to protect public health. And, they don't agree
that that's a good  measure of the environmental
  We have a lot of problems with the source receptor
relationships. We have long range transport. We
have transformations taking place in the air. So, we
end up having problems agreeing with states on
what are the actions that should be taken. And,
finally we have many sources whose control
influence people directly: automobiles, and so on.
  So, there are many technical reasons why it's not
easy to set priorities with the states. If you add to
those the normal philosophical one of what should
the federal government do, and what should the
state do, I think that we end up with a wide range of
priority setting  modes in the air program. I don't
believe that we're going to be able to define the best,
or the norm, or the proper role. I've seen states that
don't follow our guidance very well, and some that
do  almost everything we say. It's  not clear to me that
one has any better air program than the other one
does. We'll talk about that a bit later. For purposes of
our discussion  here, I've put down a few factors that
might influence the role of the federal or the state
government in  setting priorities. One consideration
that we haven't heard much about is who pays the
bill. It's not a good thing to talk about, but I believe
when you sit down to negotiate priorities with a
state, that does come up. And, air grants are not
priority grants.  We pay out about  seventy million
dollars in grant money, the states put up about
ninety million dollars, and the local agencies put up
about fifty million  dollars.
   First, we pay ten percent of the bill in some states.
We pay seventy-five percent of the bill in other
states. I think that has a big influence as far as  I can
see on who comes first when  you start to  pick the
priorities and pick the options. It also, I think, puts
the locals in the picture. We have not talked here
much about the local agencies. But they do pick up a
significant share of the tab for air pollution control
work. I think they have to be considered.
  Second, the Air  Act details what should be done
in many cases and who should do it. It not only sets
goals, but it outlines tactics. It defines procedures,
and it says who's going to carry out these
procedures. And it says when you're suppose to
attain the standards. It gives the allowable PSD
increments. It tells you the sources that have to be
covered. It gives you the basis for extending time to
attain. It even spells out what the make-up of state
air boards should be. It talks about permit fees. It's a
very, very detailed bill — not just goals, or here's the
general philosophy,  but here's how it will be done. I
think that has to be  taken into account.
  Third, we have litigation which is an extension of the
Air Act, and it often sets absolute priorities. There are
many situations, like on  prevention of significant
deterioration (PSD),  where Congress or the Courts
have imposed their  priorities on whatever a state
wants to do. And, in those cases we haven't got all
the options to do what the state wants.
  Fourth, we have differing state capabilities. Many
states are large in the air pollution area; they are
experienced. They feel they know what's best. And, I
think that they often do. And, they want to go their
own. Many other states  are new at the air pollution
prevention business and small. And, they tend to go
along with EPA's judgment in these  matters.
  We also have to consider the general attitude of
the states towards the federal government. You can
take Texas or you can take Alaska and you can take
other states, and their whole attitude toward the
federal government, toward what is the proper role of
the federal government, is vastly different. There are
complicated by the political timing. They're
complicated by the personalities in the Regional
office and the state. And so, we've seen different
attitudes change overnight as you get a new
governor in a state.  And, I think that has to be taken
into account.
  And, finally, I think that the top EPA policy makers,
in defining what should  be our partnership role with
the states, should take into account the question:
How much do we trust states? The answer can push
us one way or the other.
  In summary, I think that the role of the state is
highly variable; that we  shouldn't be aiming at some
norm. I think that it's so complex that you've just got
to give the Regional offices the right and the
flexibility to make the appropriate compromises at the
time that they have  come to hard programatic
decisions. Thank you.
 Presentation by Ned Notzon, Acting Director, Office
 of Analysis and Evaluation, Office of Water

 I can make my remarks somewhat brief, because so
 far nothing's been said that I think any of us would
 really take exception to. It is clear, however, that
 there are a lot of conflicts. In terms of the Office of
 Water, and in terms of who's responsible for setting
 environmental priorities, I don't think there's any
 question among all the senior management that the
 states have the lead in setting environmental
 priorities. There's a clear perception that they're
 closest to the problems, that an environmental
 debate has to take place before priorities can be set,
 and that the interested parties in this debate are the
 local  governments, the communities that will be

affected, and the industries that will be impacted.
There is also a perception that in general, there's no
other place you can get all the data together. There's
also a sense, particularly as we get into looking at
toxic pollutants, that there will be an extreme
scarcity. And, unless you want to have a situation in
which somewhat arbitrary national criteria are
applied to local situations, where they may not be
appropriate, you may well need local data generated.
And, the most likely people to generate such data
would be the industries that otherwise might be
  The same answer comes out when you ask who's
responsible for achieving environmental results. In
the programs that are delegated,  it's clear that the
states have the lead role. For non-delegated
programs, the state is not willing to act or is not able
to act. In that sort of a situation, EPA would have to
take the lead. Nonetheless, there are a couple of
areas in which EPA has  a responsibility,  not in terms
of necessarily achieving  the environmental results,
but in terms of being aware of the environmental
results and helping to influence future choices that,
either the Executive Branch or the Legislative Branch
may set. EPA has a responsibility to  report, both to
the public and to the Congress, on what the status of
the environment is. Are our waters clean? To what
extent are they clean? To what extent are they dirty?
To what extent are we learning about new problems?
To what extent are old problems being solved? This
need to report presents a conflict because one way to
generate all that information would be to set up an
elaborate reporting mechanism. And, many times in
the past, that has been what was done. What we've
tried to do in the Office of Water is to take most of
this sort of information and centralize it in one
document, which is the states' 305(b) report. In
previous years we had specified formats and said
that if states would answer certain questions, we
would array the information in a meaningful way to
present to Congress or to the public. What we
frequently found was that a number  of states would
ignore the format and have extraordinarily good
analysis. And, other states would check in all the
boxes, but when you probed further, you found they
had very little data to back up their assertions, or lots
of conclusions and not a lot behind them. Hence,
their conclusions were suspect.
  What we've done is to try to re-focus the 305(b)
report on five questions that we're interested in. And,
if these questions are answered, then the state will
have a great deal of information about the waterways
on which decisions can be made and priorities can
applied. We're not asking for the data behind the
answers to the questions, nor are we asking for
these to be submitted in any sort of a format. It's a
free format report.
  This puts a tremendous burden on us. A couple of
years from now when we go to talk to Congress, it's
going to be very hard to  assess nationally what's
happening. On the other hand, it  allows the state to
devote almost all of its attention to answering the
questions that they want to answer,  to set priorities,
and to measure results.
  The other area that is a problem is identification; I
think this is the area where almost all  of the
monitoring for environmental results has been
concentrated  in the last five or six years. The flip side
of that, measuring for environmental results, relates
to what you look for after control programs have   .
been implemented. And, this is an area that's been
almost a vacuum as far as EPA is concerned. Almost
all of the measuring for environmental results goes
on after a program has been carried out. And, people
are saying how are we going to prove that this
program was  good so people will trust  us to
administer programs in the future.
  In both monitoring for problem identification and in
monitoring for environmental results, the really
critical player turns out to be the Regional office,
because it's going to be the Regional staff that have
to answer to everybody. When a state comes in and
says these are their waterways and these are their
problems and this is the impact of point source
controls, the impact of non-point source controls, and
this is our assessment of whether it's worthwhile to
go out and do these things. The Regional office will
have to decide whether we think that State has a lot
of data and thought behind their analysis, or whether
we think this  is just a conclusion, whether there's
nothing to back it up, whether they're shirking their
  The other problem that arises is just the whole
timing of the planning and budgeting cycle. When
you set up a program, you identify a problem and
now you're all set to implement the program, and
then look for results. If that time interval is longer
than a year and a half, it's completely longer than
the whole planning-budgeting process. Right now we
haven't even internally set fiscal year 1984
programs. We don't know what they're going to be.
We suspect what they're going to be, because to
some extent they're a logical extension of 1983
programs. But, if you had a problem identified and  it
was going to take you eighteen months plus two
weeks — just barely into fiscal year 84 — there's no
way in the world that you and I can communicate in
such a way that we're locked into measuring for
those environmental results. It's something that
essentially has to be done person to person, project
manager to project manager. It has to have a life of
its own because the institutional system will not take
account of it.
  The question is, if these are all the conflicts, what
can we do in  terms of trying to see  to it that we do
come to a reasonable assessment of problems and
that environmental results do get measured. It seems
to me there are really three things that can be done.
One is a lot of interaction with the states at the
problem identification stage, not necessarily the
priority setting stage, but in terms of coming to an
agreement. Yes or no, where are the problems? The
state has the  lead in setting the priorities. To some
extent EPA may be able to provide technical
assistance or  guidance, particularly in looking for
toxics or where we expect to find them, or in
suggesting biological surrogates to minimize the
amount of laundering that has to take place.

    Second is, up front before control programs are set
  up or before program strategies are developed, to
  achieve a consensus on what we want to look for at
  the end as a change. As, how are we going to tell
  whether or not the environmental results that were
  postulated were actually achieved. Are we going to
  look for a return of different species? Or, are we
  going to look for the improvements in dissolved
  oxygen  levels? Or, are we going to look for the
  elimination of  metals and sediments?
    And, third, as much as possible we need to
  institutionalize our approach, to lock it into the
  programs. If everyone in the agency changes jobs
  every two and a half years, we don't want all this to
  disappear at the same time because we don't have a
  budget planning process to keep track of it. And, so,
  you've got to look for ways to lock that in. For
  example, in a construction grant application, part of
  the construction grant application can include the
  follow-up monitoring to establish whether you had
  dissolved oxygen  levels, whether you still have
  accumulations of sludge in the bottom .of the river. In
  a permitting decision you can put a lot of
  requirements on the permittee. If  monitoring
  requirements are in his permit, somebody ought to
  remember a year and a half from  now.
    On balance  there's no question but that this is the
  thing to push. There are a lot of problems associated
  with carrying it out, and almost all of them, depend
  on the Regional staff, in terms of  making them work.
  Thank you.

  Presentation by David  Gibbons,  Chief
  Environmental Branch, Office of Management and

  Hopefully, I will be able to give you some idea about
  finances. I usually start out sessions like this by
  making a statement about the assumptions that
  really go into the entire funding programs for states
  and what is to be achieved with those funds. And,
  usually when  I make this statement, half the room
  gets up and leaves and the other  half applauds. We'll
  see how it goes.  Certainly, it gets people on edge.
    I'll'start with this statement: The original intent
  of the  legislation  in terms of grant funding to
  states from the federal government was to provide
  funds, help the states set up the program, and get
  out. And, that means that from our perspective as
  budgeteers, the sole responsibility for environmental
  results lies with the states. There's one odd twist to
  this, which is  that, unlike a lot of statutes, most of
  the environmental statutes do have a federal backup
  if the states decide they don't want to do it. That's
  where, from our perspective,  all of the negotiation
  starts taking place on how funds get used, and who
  gets how much; because it is used as an incentive to
  get states to take on added responsibilities over time.
    Whether you agree or not with  that original
  premise which OMB has been using for a long time
  to budget for grant funds on the EPA budget, I think
  that you will agree that, in fact, that has occurred. It
  has occurred because when a new program is
  instituted, you will see that we fund it at fairly rapid
  increases through the first three,  maybe, four years,
after which, theoretically, we would institute fairly
rapid declines in financial support as the states take
on more and more of the financial responsibility and
substantive responsibility themselves. In fact, over
time what has happened is that the funding level  has
tended to become constant. It has been reduced in
real terms by the inflation rate for a long number  of
years. I think those of you who are in the states are
realistic about the fact that this has occurred, and
have had to make adjustments in your own planning
process and your own funding requests to state
legislatures in order to try to accommodate the  fact
that federal dollars in real terms are declining, and,
as I'll discuss in a moment, that you can anticipate
that they will continue to decline. Whether or not the
actual dollar levels you see in the federal budget
decline or stay constant, in real terms, states are
taking on more and more responsibilities.
  In terms of what we look for in the future, I think
that it is this Administration's position quite clearly
that the states are primarily, if not solely, responsible
for achieving the environmental results that are
intended in the various pieces of legislation. And, it
is also this Administration's position that the current
legislation has been a major inhibitor in allowing  the
states to adopt those responsibilities.
  As you also are aware, I'm sure, most of the  major
pieces of environmental  legislation are up for re-
authorization this year. If you look at these re-
authorization packages as we send them up to the
Hill, you will see that there are very definite trends in
the legislation towards increased flexibility and
increased responsibility on the part of the state. For
example, we just sent the water bill up yesterday,
and there are some very major changes in the
pretreatment program, which will allow state and
local governments to self-certify that they can run
this program. It even shifts the base of that
responsibility from technology to water quality.  And,
that is a very fundamental kind of shift. I think you
will also see in several pieces of legislation where
we are going to attempt  to eliminate some of the
mandatory provisions in  these Acts, like inspection
and maintenance programs in the Air Act. Whether
we'll be successful or not, I'm only trying to indicate
the drift and the trends that you can see from this
  We're also trying to institute substantial reductions
in federal oversight of state activities  through the
personnel levels in the agency and through some
regulatory reform activities which will reduce the
kind of reporting requirements that states have been
facing in the past, and the construction grant
amendments and the subsequent regulations, which
I think are now out, at least in proposed form. I am
told they reduced reporting requirements by over
thirty percent, so that states should have the
opportunity to spend a lot less of their resources and
their manpower on responding to federal
requirements and spend a lot more time and
resources trying to achieve actual environmental
   However, inevitably, the discussion about
achievement of environmental results comes down to
who pays and how much. As I said before, there's

already a trend, just in real terms, towards lower
federal spending, lower federal contributions to these
sets of activities, and a higher state contribution.
What you see in the 1983 budget is a very significant
reduction  in actual dollar levels for state grants from
$225  to $180 million. That's spread across all of the
programs  in differing degrees, but, there is an overall
reduction  and, whether we get the bipartisan
substitute, the freeze level, the balanced budget
substitute, or which ever of the nine bills that I am
currently trying to track up in Congress, none of
them  provide for increases. The best the states would
be able to do, or the best that can happen in terms of
higher dollar levels, is basically the 1982 level, which
was about $225 million.
  I think that we all have to come to the realization
that we can back out of a lot of oversight — at least
the onerous part of oversight. We can also reduce
reporting requirements. The bottom line still is going
to be  that the states are. going to have to make
adjustments in their own management of their own
affairs to try to not only get the responsibility, but the
financial independence to carry out that
  I'm  not sure if you all have copies of the
President's 1983 budget, but there is a page in the
theme document that addresses state grants. It
makes one very important point that I would like to
bring  to your attention, which is that there is now a
fairly  strong assumption that states will and must
institute permit and license fees in the operation of
their program, to recover funds, to either meet what
is in the federal statute or to obtain additional
funding, to go out and do the  kinds of activities that
they would like to do on their own. I think about
seventeen states, now, have actually gone to their
state  legislatures and obtained this kind of authority.
One of the things you will note in the Air Act and the
Water Act, and the Solid and Hazardous Waste Act,
all of  which  are currently on the Hill, is that we are
trying very hard to put in those statutes and clarify it
where it is ambiguous whatever language is needed
to give states the authority to charge permit and
license fees.
  We look at this, in a sense, as an untapped
reservoir. There's a lot of discussion that we've had
with state directors over the political feasibility of
trying to institute these kinds of charges. I am not
here to say that I think this is an  easy thing to
achieve, but I think it's an absolutely necessary one.
And, I think that the ball has to get rolling along this
line. Once the states start initiating these kinds of
user charges, they will not only be able to get more
environmental results, but they'll be able to do a lot
more  of the things that they think are important as
opposed to what the federal government might be
mandating. Thank you.

MR. WELSH: I would like to make two comments on
what Dave has said. First of all, we're moving
towards state funding of environmental programs.
Then you're going to see state assumption of
responsibility, and EPA will have a hard time getting
much out of them in terms of reporting. The
exception, of course, is the 205 (g) program, which is
funded with federal money. But, the general
philosophy we get from the General Assembly in
Georgia is that he who provides the money writes
the requirements.  Keep that in mind, because I think
that is exactly where many state Assemblies are
coming from.
  Point number two: I agree with  the fees for
permits, except our experience in  Georgia is just the
reverse. If you issue a permit for several years, the
charge of issuing that permit and  maintaining
surveillance on it runs into thousands of dollars. The
economy or the attitude is not there to support that.
We recently took fees off of two permits in our land
reclamation program, which is a state program. We
found that the cost of collecting the money and
accounting for it exceeded what we were taking in.
So, I think that this is something we've got to look at
very carefully; fees may be a partial support, but
they're certainly  not going to bear the full freight.

MR. STEIGERWALD: I'd like to ask Dave about
industry or the states' concern over consistencies. It
seems like that's a fairly strong driving force that, at
least, industry does not particularly want fifty state
programs that are widely different. And, the states
are concerned over permit fees, over new sources
coming in. They don't particularly  want some states
to be able to decide to be really soft and possibly,
therefore to influence them economically. Can you
comment on that at all?

MR. GIBBONS: Yes. When I addressed the National
Governor's Association, they raised that point with
me as well. I'll be the first to admit up front that I
don't have the absolute solution to the problem. A lot
of states want to institute permit fees on the basis of
the discharge, itself, either tons of pollutant emitted
or pounds of toxic pollutant emitted out of the water
discharge. Other states simply want to recover the
cost of operating the  program. As  Gene pointed out
earlier, sometimes the cost of recovery is  equal to
what you're getting; and,  a lot of that has to get
worked out.
  I can say one thing, though. One of the pushes
that we have made and have been fairly successful
with in most of the legislative review is to extend the
permit period from five to ten years. I think that may
help. Hopefully, if we stretch out the permit period a
little bit, and, maybe do something slightly different
with new sources versus  existing  sources, you can
get around some of these problems.
  I am not saying that this kind of approach is
problem free. And, certainly, if states think that tht
can go to their state legislatures and get more mon
to substitute for the federal dollars out of their
general revenues, then that's their option. My own
sense of it is that it's not  only federal dollars that are
declining. That state legislatures are also starting to
reduce theirbudgets, and the environmental
agencies are  not immune from that, just as they are
not at the federal level. So, I think that what we're
trying to do is to suggest a new idea. And, I think the

  states basically have been put on notice. I don't really
  see a way out of starting to institute these kinds of
  fees. But, I do admit that there are some problems
  with it. I'm the first to admit that we don't have
  all the solutions.

  MR. BURD:  I'd like to ask Gene how he feels about
  the State/EPA Agreements because that's a
  mechanism where we can do much of the up front
  kind of agreement negotiation that  Ned talked about.
  What experience have you had?

  MR. WELSH: I think the State/EPA Agreement in
  our particular case has matured. It  has moved away
  from programmatic  issues and is getting into multi-
  media issues which you have to resolve on an
  Agency-wide basis.  I think it has matured to the point
  where we have a good working relationship set up
  with the Regional office to zero in on a few priority
  issues, not great numbers of them. And, I think it will

  MR. GIBBONS: Does it make 3 difference whether
  the funding is attached to that State/EPA

  MR. WELSH: In our case, no, Dave. Because I think
  if you have a priority problem and you want to
  resolve it, you'll find a way to fund  it. That's what
  management is in our case.

  MR. CRAMPTON: Any questions out there in the
  audience that you'd like to ask of any of the panelists

  MR. ABRAMSON: What  kind of contingency
  plans do we have?

  MR. GIBBONS: There are, as far as I can see, no
  great contingency plans.  Certainly the President has
  made it very clear that federal personnel is on the
  decline, not on the  incline. And I fully expect that
  pattern to continue. I see no turnaround in that for
  the next few years. So, in terms of having massive
  increases in federal personnel to manage the state
  programs which get returned, there won't be any, not
  at this time.
MR. CRAMPTON:  EPA, and my Office in particular,
are getting involved in working directly with states
and state organizations to deal with the question of
mitigating the impacts of decreased grant funding.
The first shot in this effort was fired out in Region 8,
where they did a study on this in a great deal of
detail. We convened a group of folks from
Headquarters programs and from the Regions to
further refine that study, and we now have a set of
initiatives which is now circulating among the
Headquarters program offices. Once that's done and
we've also shared it with the Regions, we'll then go
to the state associations. Eventually, we expect to get
into a direct dialogue with the states in terms of
what makes the most sense and what can we really
bring off  here in terms of: (a) reducing the reporting
burdens that are on the states that take up their
funds; (b) making the grant process itself more
flexible; and (c) helping states come up with alternative
sources of funding. But, with respect to the big
question, if all of a sudden fourteen states were to
give us back their air program or their water
program, there  is no contingency in EPA for that
right now.

MR. NOTZON:  There's one other mitigating
circumstance. It's unlikely that states would say:
Today we've got a hundred percent of the program;
you've cut our budget; therefore, we now want zero
percent. What you're really going to have is
something in between. The states will say, we don't
wf»nt the ultimate responsibility for this, but we're
willing to do this much work,  as long as we can
influence the program in these ways.

MR. CRAMPTON: I think in the context of this panel,
Allan Abramson has asked a legitimate question. But,
with respect to  what we're here about, it is a fact
that certainly with respect to the Air and Water
programs, I think EPA is becoming much more of a
steward. We really are going to be responsible for
monitoring what's going on with respect to
environmental results.

Panel  Discussion
on Planning,
Resource Allocation,
and  Evaluation
Introduction by Lewis S. W. Crampton, Director
Office of Management Systems and Evaluation

The panel on planning, resource allocation,
accountability and evaluation addressed those
important aspects of the management process that
should be used to enable us to get the job done and
to produce environmental results. Mr. Crampton
introduced the panel by saying that EPA's
management systems currently emphasize process
activities rather than environmental results outcomes
and make limited use of environmental data. He
briefly reviewed the way environmental  information
is currently used in management processes. In  the
planning area, operating year guidance has
emphasized expectations with regard to processes,
with almost no emphasis or reference to expectations
about expected environmental results of those
actions. Although the Office of Management Systems
and Evaluation is working to develop a strategic
planning system for the Agency that would consider
environmental status and trends and set
environmental goals, such a system is not currently
in place either Agency-wide or within most
  With respect to resource allocation, the budget is
developed without explicit consideration of current
environmental status or anticipated problems. Some
program administrators may build these
considerations in when preparing their budgets, but
there is no comparison at the Agency level of
problems and needs within and across programs.
  The Administrator's accountability system is
currently oriented to goals and objectives using
numbers of activities completed. We are mainly
talking about bean counting without factoring in the
importance of one activity over the other from an
environmental results standpoint. We have to work to
improve the accountability system from this
  The Agency has no policy that the success of a
program should over time be determined by
measurable or observable improvements in
environmental quality. To date, only a few measures
of program effectiveness have been developed that
are related to improvements in the environment.
  Environmental data is not often used by managers.
EPA puts little emphasis on using information on
environmental status or on the effect of EPA actions
on the environment to manage its activities. As a
result, managers have little incentive to maintain

   good, complete data, to integrate all available data for
   analysis of problems and trends, or to push for better
   monitoring. In addition, ambient, source, or other
   environmental data available to the Agency are
   generally not reported in a form useful for planning,
   resource allocation, program management, or
   program evaluation and redirection. And, technical
   reports and other analyses are not well reviewed to
   determine their policy implications, nor are they
   normally disseminated to key Agency managers for
   their use in decision making.
     These issues were  identified by Mr. Crampton as
   being the heart of the panel discussion.  He asked the
   panelists for their views on  how the Agency can
   better incorporate environmental information into
   planning and management activities and how we can
   evaluate our long  term and short term progress in
   making environmental changes. The full text of that
   discussion follows.
     The panel members were: John Wise, Director,
   Office of Policy and Resources Management, Region
   10; John Chamberlin, Deputy Director, Office of the
   Comptroller; Randy Smith, Chief, Resources
   Management Branch, Region 10; and Billy Adams,
   Deputy Director, Environmental Services Division,
   Region 4.
   Individual Presentations

   Presentation by John Wise, Director, Office of Policy
   and Resources Management, Region 10
   The theme of the workshop we've been attending for
   the last day and a half is appropriately titled,
   "Managing for Environmental Results." Many of the
   ideas, however, that we've discussed so far really
   deal with a somewhat different subject — measuring
   environmental results. We have spent a lot of time
   talking about various ways to characterize the status
   of the environment. We've talked about
   environmental status reports or profiles. We've heard
   some very creative ideas about how some of the
   Regions are using their data and applying it to
   various programs, such as water quality in Region
   8 and Region 6, and air quality in Region 5. I think
   these are very impressive and very  important ideas to
   share. But my concern is that we must also expand
   our horizon to a significantly higher plane. We must
   expand our vision to focusing on managing, truly
   managing, for environmental results. Specifically, we
   need to manage the Agency for environmental
   results. And I really want to underscore managing
   the Agency. Because I think this is  an Agency-wide
     If EPA is to accomplish environmental results, as I
   think we are all now dedicated to doing, I suggest
   that the Agency must establish an overall
   environmental management process. We must define
   the environmental mission of this Agency. And we
   must put in place a management structure and
   process to carry out that mission. This management
   structure must incorporate the traditional disciplines
   of planning, resource allocation, accountability, and
   program evaluation. This panel is going to speak to
those four issues. My immediate task is to provide
some stimulating ideas on the planning phase.
  Specifically, what I'd  like to do is to define for you
and share with you a concept of planning which I
hope  may stimulate us  on behalf of the Agency to
manage for long term environmental results. My
concept of an Agency-wide planning for
environmental results system would incorporate
eight features. What I'll do is walk quickly through
them and itemize them, then step back and explore
them a little bit more thoroughly in the subsequent
  The eight features that I'm going to focus on are: 1)
the statutory mandates, 2) the media orientation, 3)
the time horizon, 4) the strategic nature of the
planning process that I  envision, 5) a need to balance
abatement with preventative measures, 6) a need to
integrate the planning process with the budget
development process, 7) a need to integrate the
budget process, the planning process, with the
annual operating plans, the State EPA agreements,
and the program grants that we offer to the states,
and 8) a foundation based on the accomplishment of
environmental results.
  Now, with those eight points in mind, as a
conceptual framework, what I'm going to do for a few
moments is just sketch out what I  mean by each one
of those points. Let me warn you that much of this is
really conceptual. And  it is my purpose to be
conceptual. I want us to start thinking about an
Agency-wide process.
  First of all, statutory  mandates. Our planning,
clearly must honor the  express intent of Congress.
We cannot do otherwise. The Administrator has very
explicitly said, as EPA policy, that we will focus on
statutory demands. And, if necessary, to the
exclusion of all other discretionary activity. The
statutory mandate provides  us with the best possible
basis for establishing environmental goals and
objectives for environmental results planning.
  The second feature is the media orientation. This,
of course, is widely known and accepted by all of us.
But let me just underscore it. Planning should
continue to be oriented toward a media focus.
Because, number one,  that's the way our statutes
are mandated. Number two, it relates directly to the
manner in which we find our environment. And
number three, and importantly for John Chamberlin,
^that's the way our budget is built.
  The time horizon is also very important. We've
got to get out in front of ourselves. Accordingly,
we need to look at a systematic planning process that
spans an advanced period of three to five years. I say
five years because that's far enough out to make
reasonable projections, and yet at  the same time it's
far enough in to make programmatic changes in the
process that we're contemplating.
  The fourth feature is that it's strategic in  nature.
Strategic is not really a magic word. It just means
that we need to orient  ourselves to developing overall
strategies of how we're going to accomplish our
statutory goals and objectives or how we're going to
accomplish environmental results. The strategy will
clearly establish the criteria for prioritizing our
activities to produce the highest environmental  payoff

for the Agency as a whole. I think Rebecca Hanmer
had some very profound words when she outlined to
us the Office of Water's intent to do a permit strategy
— a strategy for issuing the second round of
industrial permits. In that, she clearly articulated a
strategic perspective, and clearly set up criteria
which would prioritize what that strategy were to
  The fifth point, and one that's very important for
the Western Regions in particular, is that we have to
find a balance between those activities  necessary to
abate a pollution problem or a public health problem,
and those activities necessary to prevent new
problems from occurring. Also, in the same breath,
we have to take those steps necessary to preserve
the gains that we've already made, such that our
accomplishments are truly lasting and long term in
  The sixth point, and one that is critical to the
overall concept of this panel, is that we have to
seriously begin to integrate our environmental
planning with the budget cycle. The statutory bound,
media oriented, long range strategies would provide
the basis for budget development and budget
justification. I think that a well developed strategy in
direct response to statutory goals and objectives
should provide a very defensible position, a very
defensible basis for us to go to OMB and the
Congress with a budget that is sufficient to finance
the kinds of activities that we want to perform under
the strategy. It's important to get that into the
budget. And that's really important from a long term
perspective, because, as most of us know, we are
now entering the 1984 budget cycle, while we're still
operating in 1982.
  We have to get out in front of ourselves. Related to
this, is we also have to integrate the planning
process with the annual planning cycle. This is our
bread and butter; we operate on an annual cycle.
The near term component of this three to five year
plan would become the basis for what I call an
environmental action plan which would be
implemented in our familiar ways of EPA's operating
guidance, the State-EPA Agreements, the program
grants that we negotiate with the states, and indeed,
our very own regional work plans.
  Lastly, the environmental results. And this is really
the outcome of the whole process. I think that the
implementation of the annual program plans by the
Regions and by the states, if it's done consistent with
this overall strategy, would really accomplish the
statutory goals and objectives and yield  the intended
environmental payoff. At the same time, competent
measuring of those environmental results, using
many of the techniques that we've discussed here in
the past day and a half, could really contribute to the
continuing planning process. It would guide us
toward that  next increment of improvement, or it
could act to  preserve the gains that we've already
  Now, having said all of that, and also  having
warned you  that is was conceptual  in nature, let me
confess that it is very theoretical. It's a concept, one
that perhaps ought to exist, but let me acknowledge
that it doesn't. And there are two big problems that
we have to overcome before we would ever get to
this place. First of all, the first problem is, we have to
get in front of ourselves. If this is truly to be advance
planning, we've got to invest the resources now to
develop these environmental strategies, these media
oriented strategies,  to effect our actions  in a  1985,
1986 and 1987 time frame. The 1984 budget cycle is
on us right now. It may be too late to do it now, so
we've missed a year. That is inherent in  the cyclic
nature of the budget process, so we have to get
ahead of the  curve.
  The second major problem is one that  is familiar to
all of us. And I'm going to say this partially to set up
John Chamberlin. This is the resource allocation
process. As all of us well know, resources are
allocated to each of the ten Regions by means of so
called workload allocation models. Our experience
with these has sometimes been good —  often been
bitter. The models are theoretically intended to place
the resources where the problems are, and if they
were enabled or allowed to operate freely, they
would do just that. Resources would flow to where
the environmental problems are.
  However, by some measure of what I call greed,
we all seek to maximize Regional gains and minimize
Regional losses. And the outcome of the workload
allocation  process simply becomes a status quo, with
adjustments made at the  margins. You go up a little
bit here, and  maybe go down a little bit there. But
basically, all we've accomplished is to preserve the
status quo. And if that's the way we're going to
allocate resources to the Regions, we cannot
aggressively move toward an environmental planning
  Another way to characterize the resource problem
is what I call  the ownership issue. It seems that each
national program manager expects that their
resources  would be dedicated in each region for their
programs. It's not a  direct demand,  it's a  clear
expectation. That the activities in your workload
model are really the activities that you will perform
for the balance of the year. And this, to a large
measure, locks us in, and prevents a Regional
Administrator from really  moving away from the
rigidity of a workload and modeling process, toward
accomplishing something productive in terms of
environmental results.
  So I think these are some inherent problems that
we have to overcome, and overcome rather quickly, if
we're going to get on with the business of
environmental planning. Now, having painted myself
into a corner, I'd like to offer a radical solution. I call
it radical because it's different. But  it's needed.
Because if we are to break the resource allocation
deadlock, as I see it, we have to do  something
different. We have to get to a position that enables
us to devote the energy to accomplishing
environmental results.
  What I want to propose, or just suggest for
starters, and hopefully this will come up  later in the
workshops, is the following idea. Suppose the
Agency took its total operating budget and skimmed
ten percent off the top and put that into a separate
fund. The remaining ninety percent would be
allocated to the regions in the traditional manner,

  using workload allocation models. Hopefully better
  models, but, nevertheless, some kind of an allocation
  procedure. That ninety percent would fund what I call
  the base environmental program, consistent with the
  national  program manager's guidance. Each Regional
  Administrator would be accountable for performance
  of his base program.
     Now, what becomes of the ten percent which
  we've skimmed off and put into a bank account? I
  will call this an environmental results incentive
  program. With  this incentive fund established, each
  Regional Administrator (RA) would propose an
  environmental  results performance contract to
  accomplish one or two of the top priority environ-
  mental projects in the Region.  Each Region would
  compete. Each RA would compete with the other RAs
  for that money. And the allocation of that fund would
  be made based upon environmental payoff to the
  Agency. These are big, glamor products that have
  immediate and visible payoff to the Agency. The RA
  could manage these funds in any manner that was
  productive. He  could use it to fund direct EPA staff,
  he could fund contracts, he  could do a cooperative
  agreement with the state or any combination of the
  above. It would be discretionary cash that they could
  devote to a specific objective. The RAs jobs would
  rise or fall on the performance that they're able to
  make in accomplishing this environmental result. I
  know this is a  radical proposal. I know it's different.
  But, at least it's a suggestion that would take us
  specifically towards managing  for environmental
     Now, I want  to summarize very quickly, and leave
  some time for the other panelists, that out of all that
  I've said, and much of that's conceptual, that we
  really do need  to focus on moving beyond the so
  called measuring effort in which many of us find
  ourselves, to a managing system for the Agency. We
  just have to pull ourselves up by the bootstraps and
  put a management system into place. And I hope that
  the comments  I've made do  serve to stimulate, not
  only the panel, but the audience and the workshops
  later on this afternoon. Thank you.
   Presentation by John Chamberlin, Deputy Director,
   Office of the Comptroller

   I was listening carefully to what John said and I
   won't respond to all of it now. But I will say that of
   these three pieces we're going to talk about,
   planning, resource allocation, and accountability or
   evaluation, it is my firm belief that if we are going to
   make some substantial change in the  degree to
   which we take environmental  results into our
   system, probably the most important place to put it in
   is as he suggests, in strategic  planning. In the past,
   we had, at least on paper, the requirement that
   national program managers develop strategic plans
   by media. Where that happened it was quite helpful.
   When you have a strategic plan, that makes it a lot
   easier for the Administrator to put together a rational
   budget guidance, taking into account environmental
     I think the other most important place that we can
   make a change is in the evaluation of  programs. In
the Comptroller's Office, we are locked into a one
year cycle. We can only do evaluations that can
occur in a year. But an awful lot of the problems that
the Agency has to deal with don't fall in neatly to
that cycle. And there  have to be evaluations of those
programs, with the results of those evaluations fed
into the budget process whenever they occur.
  And finally, the resource allocation process. If you
had strategic plans and evaluations, obviously,  we
can refine and improve the workload models. I  don't
know that I would agree with Johns' suggestion
there, but the technical construction of those models
can clearly be improved, even if you didn't include
environmental results. But certainly, if you did, you
can improve them.
  I'm going to go quickly now through the resource
allocation process that we follow. I think most of you
are familiar with it. So I will try to move right along
and then I'd like to get back to your questions, to
some of the other issues that John raised. I don't
know that I agree with Lew's assessment of the
resource allocation system as a black box, but we
can talk more about that too. The process, as you all
know, starts with the Congressional enactment of
authorizing legislation, that sets out the statutory
deadlines, gives us a  general program design and the
basic legislative intent with  regard to environmental
results. Then each spring, the Administrator issues
budget guidance to her  National Program Managers.
That guidance lays out the broad program priorities,
identifies key issues to be examined, provides
resource targets, and lets people know the process
that's going  to be followed to develop the budget. The
National Program Managers take that guidance,
develop their budget proposals for the out year, and
submit the proposals to the Office of the Comptroller.
We review the submissions for their compliance with
guidance, and identify problems and policy options
for the Administrator.
  The Administrator then  holds hearings with each
of the National Program Managers in which she
includes the lead Region in each hearing. This  year
she is going to have a separate hearing for the
Regions to let the lead Region critique each National
Program  Manager's submission. After that set of
hearings, OPRM makes an internal passback to the
program  managers. They appeal that, and the
Administrator makes final decisions and sends the
budget to OMB on the fifteenth of September.
  OMB reviews that budget, usually holds hearings
within the first week after they receive it, and passes it
back to us in November. We go through a series  of
appeals, and normally have a budget settled by late
December. In January we submit a Congressional
justification  to the Congress, of the President's
Budget. By that time decisions have been made by
appropriation, by media, by program element, and by
object class. This is important in what we're talking
about because, by that phase in the process, you are
getting really narrowed down as to your flexibility. It
takes an enormous effort  by then to switch between
appropriations and there are limits on us as to  how
much we can move between program elements,  and
even object classes. We have ceilings on some object
classes, and are limited on moving into or out of

Personnel, Compensation, and Benefits, depending
on the year. I think for this group to spend too much
time thinking about how you shift around then, is
misdirected. The Administrator, the program
managers and the Comptroller then present this
budget to the Congress, the various authorizing
Budget and Appropriation Committees in both
Houses, and that hearing process frequently drags on
into early May.
  Once we have sent the budget to the Congress, we
start the  workload analysis process. This is the place
where I think the Office of the Comptroller can
probably  do the most to at least satisfy Regional
concerns. We in the past have kicked the process off,
gotten the National Program Managers to start
developing the models, and  encouraged them to
include Regions. As you know, some have done that
better than others. There are some excellent models
around, and there are some around that aren't quite
so excellent. The workload analysis process hits us at
a time when we are very busy putting together a
Congressional justification. So it's not a time when
we tend to be able to put a lot of our staff on
improving the models. But it is something that we
intend to improve by starting earlier next year and
trying to  improve those models to take into account
environmental results to the extent we can.
  What the models are intended to do is show how
much each  Region would need to accomplish all of
the activities under that particular program element
in a perfect world, if there were  no resource
constraints. Obviously, there are resource
constraints. We can't carry out all those activities nor
should we probably. We certainly as a nation can't
afford to. So, you get the ideal world.
  Then the  National Program Manager has to say
"this is what I would do if there  were no constraints.
Given the constraints I have, how will I shift, how
will I distribute these resources?" That's why, you're
paying these people to manage national programs.
They should have some pretty good ideas of where
the environmental problems are  in their programs.
And in my view, when they  make those decisions,
they ought to be putting their  resources where they
have environmental problems.
  It's a little naive to think that the only criterion
upon which they should make their resource
distribution is environmental results. We don't want
to have to manage a Region, or any other part of the
Agency, with a big swing up in resources or a big
swing down. From either the point of view of a
particular Region or the Agency as a whole, you
don't want to have enormous shifts going on each
year as the sexy items of the year or the problems
shift. You have to moderate  that possibility for shifts
to some extent, or you will have  havoc.
  The Regions get the results of the raw distribution,
modified  by the National Program Managers'
judgements. They then have a chance to review
those and appeal them to the Administrator. She
makes final decisions and issues resource targets for
the operating plans. The Regions then develop their
operating plans, send them in, and we review them.
The Administrator approves  them and, from then on,
they are modified only to keep them in compliance with
Congressional action or any subsequent executive
  I'd like to point out one thing: that we have a lot of
complaints about the resource  models in this
allocation process. It's very significant to me that in
the 1983 operating plans, not a single Region
proposed a single reprogramming of a single
permanent, full time equivalent for  1983. In other
words, what they're saying in those plans, is that
with the resources they have, they think at least the
permanent full time work years, and as a matter fact,
the other than full time work years, are distributed in.
an optimal way. No one suggested a reprogramming,
although there were some minor shifts of dollars to
cover personnel compensation costs. Thank you.

Presentation by Randy Smith, Chief, Resources
Management Branch, Region 10

The basic question that you have to ask once you've
planned what you're going to do, gotten the
resources and gone out and started to do it, is: Are
we accomplishing what we intended to do? And I
think that accountability systems, reporting systems
and program evaluations are all designed to do that.
Let me say a word about how they differ. First of all,
accountability, particularly at the Regional level,
really means individual performance tracking
systems. And those systems have a few
characteristics. They have specific commitments
made in advance, targets or milestones. They have
clearly defined responsibility to  those targets or
milestones. They have reporting on  those and they
have rewards.
  In Region 10, performance agreements and a
specific Regional performance tracking system are
the two ways that we do that. Reporting systems are
another form of accountability.  Most reporting
requirements, in my observation, use an incentive to
look good or not to look bad. They send signals about
what's important to the people who design the
reporting system, even if they don't include any tie to
specific rewards or punishments and even if they
don't contain specific milestones or targets. I really
think that much of the Administrator's accountability
system at this stage falls into this kind of
  Finally, program evaluations are really longer term
looks at how a program is doing. More often,
divorced from the accomplishments of specific
organizations or individuals, but they still are
designed to answer the same question. Region 10's
experience is that in 1980 we decided to try to go
after the problem of fitting environmental results into
an accountability framework. We set out to design an
accountability system that was  organized by media.
Within each media, we had four levels of indicators.
We tried to get a performance indicator of the
change in ambient conditions that would result if the
program were successful. We tried to set up targets
or measures of performance or  sources, compliance
levels, emissions, that sort of thing. The third level
was the actions that we expected the states to
accomplish in a given year. And the fourth level was
the EPA actions.

    Originally, we had an idea that we could put
  together a performance tracking system that covered
  the whole ball of wax. We found that we couldn't.
  We spen* about three months working it up and
  when we put it together we found that we really had
  overreached ourselves. One of the reasons that we
  had is that a performance tracking system, or  an
  accountability system, in the narrow sense really
  needs data that is timely. You can't have significant
  lag times built in. You cannot have data that has a lot
  of variability due to other causes built into it. And
  you cannot rely on data that is not readily available
  or that costs a lot to collect.
    If you think  of those characteristics I just outlined,
  much  of our ambient data falls into that category. So,
  in short, indicators of change in ambient conditions,
  in my  mind, really don't belong in performance
  tracking systems. There are some cases where we
  can find something that fits. But by and large, I think
  it will  take more effort and it will cost more than
  we're  really willing and able to do.
    So what can we do about it? What we proposed in
  our submission which went into the background
  paper  on overall management, is that there be
  annual reporting on the results of EPA programs that
  ties together reporting in environmental terms,
  reporting on what the programs are  designed  to do.
  In effect, what I'm saying  is that environmental
  status reports by themselves divorced from programs
  are fine in that they tell you what's going on.  But
  they don't directly tie into the management of the
  program. If you tie that together with data  on
  compliance and you tie that together with data on
  what the programs are doing, then you've got to look
  at what a program in total is accomplishing. What we
  suggested  is that each RA and each AA could
  annually report to the Administrator in terms of:
  What  are the  problems in my area? What is their
  current status? How are my programs directed at
  those  problems? And what changes do I expect to
  see in the next year?
     The AAs could frame their evaluation of Regional
   programs in the same way. And the Regions could do
   the same with states. As  Bob Burd mentioned this
   morning, he conducted his mid-year review of the
   Water program in Idaho by going through essentially
   that framework. And we  have tried to set up our
   SEAs in that way. I think that kind of framework
   followed consistently could produce a fair connection
   between what we know about the environmental
   condition and what our programs are doing.
     Finally, periodic evaluations of individual programs
   can really get at the longer term issues. They can, in
   an in-depth way, get at the links between  changes in
   source compliance  and ambient levels. They can  help
   us understand cause and effect. They can  take a
   longer view and, as John Wise said at the very
   beginning, that is quite important. I think it's
   necessary to do more of those.
     That's what I have to say about accountability and
   evaluation. I wanted to take another minute to make
   a couple of remarks about the tasks that the
   workshops will address themselves to. And they're
   sort of related to the reporting requirement problem
   in part. There have been a lot of shots taken at some
things that were really a part of the Planned Program
Accomplishment (PPA) system. The PPA system is
basically dead, but the death of PPAs, to me, doesn't
mean that there are no reporting incentives left in
EPA that run contray to an environmental results
  There are a lot of reporting systems in this Agency
besides the Administrator's accountability system.
They include the reporting systems run by each
program. They also include the workload models.
Each of these affects the way the Regions act; they
affect the way the states act.
  I think one useful question for each workshop to
address is: What reporting requirements exist? Are
they environmentally oriented? Are they
counterproductive? If they're counterproductive, what
changes could be made? That I think would produce
one set of agenda of things for this Agency to work
on. Finally, another way of analyzing what needs to
be done to manage better for environmental results
is to look at: What controls the decisions that  get
made in each media, what laws, what regulations
what guidance? What requirements allow flexibility
among states and Regions? I  know what Region 10
was saying earlier about the need to let Idaho run a
different program than New Jersey. What are the
requirements that force us to try to make programs
more similar to each other than they should be?
What are the requirements that cause us to run
programs  in ways that diverge from an
environmental focus? And what can we do about
those? Answering these questions is another way of
coming up, I think, with an agenda for action. Thank
 Presentation by Billy Adams, Deputy Director,
 Environmental Services Division, Region 4.

 I came with the Agency or the Public  Health Service
 in 1962. And at that time I'm not sure what kind of a
 management system we had, or what kind of
 accountability system we had. But we did have the
 flexibility to operate our programs to meet the needs
 of the Agency at that time. In 1971, when the
 Agency was formed, we were operating under a
 management by objectives concept. The general goal
 of the Agency at that time was to achieve a quality
 environment by minimizing the adverse  impacts of
 manmade pollution. We had a series of  intermediate
 steps that we  had to go before we could reach that
 goal, and we're still not there. I think  it's time that
 we took a look at where we were, where we have
 been and where we need to go. That's the way I
 have approached the strategy I have for managing for
 environmental results.
   In 1968, when I came to Region 4,  the first thing
 we did was to establish a data base. We collected
 environmental data  and analyzed it for the
 conventional parameters at all river basins in the
 Southeast. That information was used to develop the
 use criteria for the water quality standards that were
 'Mr. Adams' full list of possible indicators for accountability and
 evaluation is included in the summary of proceedings in Appendix III.

developed. It was also used for the permit limitations
that were placed on the states' programs. We moved
on from there to the achievement of ambient air and
water quality standards. The BPT regulations that we
were supposed to set for regulating the discharges
and emissions really were never implemented, but
we moved on with a series of administrative actions
whereby we were issuing permits, conducting
compliance inspections, and taking enforcement
  In 1974 we initiated a very active compliance
monitoring program in Region 4. We looked at some
fourteen hundred discharges that year. The next year
we reduced the number down to seven hundred, as
the states began to pick up the activity as they
assumed the program. By 1976 all of the states in
the Region had committed to assume that activity,
although they may not have accepted delegation.
  I think it's time to establish a new set of objectives
or activities to drive the activities and the  needs of
the Agency at the current time. We're locked into
the resource accountability system and the workload
models. I can tell you for Region 4, if our resources
are going to be based on the planned program
activities (PPAs) in those models, that's where  our
activities are going to be, regardless  of whether
that's where need exists. In a  lot of areas we need to
let the states take over those activities. We need to
adopt an overview role for those activities and
establish a new set of criteria which will drive  our
federal activities.
  My proposal is that we first  assess the current data
base. Quite frankly, if I were a Congressman, I don't
think I would approve an EPA  budget, because the
Agency couldn't show me any improvement in  the
environment, based on environmental data, that
has resulted from the expenditures it has made in
the past. Getting that data base is our first need.
That data already may be available. It may be in a
state's files. But right now we don't have the
flexibility to go in and look at the data. In Region 4, in
a lot of states the data is there, the biological data as
well as the chemical data.  For toxics data, however,
we and the states would need to monitor. If studies
are necessary to get adequate data I  think we should
work with a state and initiate a program to get the
necessary data.
  The next thing I think we need to do is to
document the environmental results  or abatement
control actions. We need to develop a protection and
restoration plan. And then we need to implement
that plan. This all sounds fine and dandy, but there
are a few barriers that we will probably run into. One
is the resource constraints that we may have in
determining the current data base. Two, is whether
we are going to be able to tell after we get through
with all this work, if we really have a cleaner
environment than we did in 1970. We can tell  if the
conventional parameters are better, but I'm not sure
that we know what the toxics  status was at that
time. With some three thousand new compounds
being introduced into the environment almost yearly,
I  don't think we really know what our data base is or
what the environmental impact of those compounds
are. We really don't know what the use is to be
protected. And to what extent does pollution
contribute to the impairment of the use? What is
necessary to restore or enhance the use? Are we
collecting good quality data?
  As you know we are  now in the process of
implementing quality assurance plans throughout the
Agency to improve the data that's collected in the
future. I think we have  a good base for doing this.
But I don't think we have sampling and  analytical
techniques that we need to measure toxics,
especially in Air. It was Region 4's experience, in
Memphis, Tennessee, with the Hollywood hazardous
waste dump site, that we do not have that capa-
bility, nor does it exist in OANR. We also don't
know enough about the fate and transport
characteristics of pollutants we measure. What
environmental significance do they have? What
indicators do we  have to measure the health impacts
of air pollutants, water  pollutants?
  I think we also should develop accountability
systems for the Administrator that are oriented to
environmental results. Since she is responsible for
providing clean water, she should know how many
water bodies are fishable and swimmable and how
many stream miles do not meet that goal. We can
measure that by the percent of total miles of water
bodies  with fishable use classification or higher. That
accountability system would be one way that we can
get the Agency focused on environmental results in a
very short time frame. And that is going to drive
other activities for our program managers. For
instance, I think that the AA for water would be
concerned about the uniformity of water quality
standards and associated criteria. The measures that
he could use are: the miles of major water bodies
with fish and wildlife use classifications or higher;
miles of major water bodies with use classification
less than fish and wildlife; the number of states with
current acceptable  water quality standards; the
number of revisions needed to the standards; the
comparability of use classification and associated use
classification from state to state; the miles of water
quality limited stream segments.
  Another measure that the program offices would
be interested in and should be responsible for are the
development of basin evaluations — comprehensive
basin evaluations. This  idea is in agreement with
what Eric Eidsness is saying, and Rebecca Hanmer
told us yesterday, that we need to look at the waste
load allocations and the total maximum  daily loads.
They are to be completed for each basin. We should
look at the adequacy of the ambient water quality
monitoring programs to determine results; the
number of waste water treatment plants with
acceptable plant performance; the number of major
POTWs constructed with federal funds that are
providing secondary or  better treatment; the miles of
major water bodies affected by discharges for
industrial facilities; and the identification of major
non-point sources causing water quality degradation.
  The Administrator's environmental results
accountability system should reflect what progress
there is in the hazardous waste  clean-up program.
One way of measuring  this and evaluating the
effectiveness of this program is the percent of

   hazardous waste landfills under a management
   control plan. Activities for the program officers would
   be the number of sites for preliminary and secondary
   evaluation; the number of hazardous waste sites with
   ground water contamination potential; and the
   number of hazardous waste sites causing water
   quality degradation.
     Another activity that should trigger some action by
   ORD would be determining the fate and transport of
   toxic pollutants. Those are the types of indicators I
   think we should evaluate environmental results
   against. Thank you.

   MR. WISE:  I'd like to explore an issue with John
   Chamberlin and I respect what  he has said about the
   structural constraints. I want to discuss for a moment
   with John about an issue which both of us are
   well familiar.  But it's one that's important —
   important to the Agency if we're going to a process
   of managing for environmental  results. The problem
   is that we are locked into a budget structure  at a
   micro-level  of detail  at program element and  object
   class codes. Once that appropriation is made, we are
   locked in. And we have to get Congressional  approval
   to reprogram. That kind of structural constraint
   within the accounting/budget scheme really
   precludes our ability to move resources to  points of
   maximum payoff.
     The question I have for John  is, can we begin to
   explore with the Appropriation Committees some way
   to break that deadlock?

   MR. CHAMBERLIN: Yes, of course we can. The
   history of it is somewhat interesting. Until 1976 or 1978
   our budget structure was much more flexible. When
   we changed subcommittees, the new subcommittee
   did things by object class. As a  result, they have
   enormous power to encourage us to do things the
   way they want it. They tell us what program
   elements they want to see, and they tell us what
   object-classes they want to see. In their view, we
   were, in the past a little too footloose and fancy free,
   so constraints got put on. We used to  have ten
   percent reprogramming authority between
   appropriations, between media, but in their view we
   overdid it, so  now we cannot reprogram anything
   between appropriations without an act of Congress.
   And we're restricted to  a $250,000 limit between
   program elements. Those are things that they have
   increased the restrictiveness on us over the past two
   or three years. We can explore  this, it's not locked in,
   but I  think the prognosis for some drastic change is
   not really excellent.

   MR. CRAMPTON: When we get into the work groups
   later, and we  start to look at recommendations of
   things to do, I would urge you to try to divide your
   recommendations up into two categories. The first
   are the so called radical proposals, and I don't think
   they're that radical, but the kind of proposal that
   John Wise put forward, and the second would be the
   kind of proposal that would fit within the existing
system, or would be a manipulation of it. An example of
a radical proposal would be let's just do away with
all the workload models. The other type might be the
more modest proposal which might say, if we're
stuck with the same workload  models this year, and
the assumption  is that we're going to work to change
them in the following year, can we get  an agreement
from the Office of the Comptroller not to spend much
time evaluating  any requests that we would make to
make  changes internally in our own operating plan?
  That is something that it seems to me is feasible,
always understanding Congressional strictures and
so forth. There is some  room. It's not a  rigid zero
sum game here. But, I also urge you to make more
radical proposals. We need to get both. Because, as
far as I'm concerned, things are not set in concrete.
It certainly isn't as far as the Administrator is
concerned. But we  also have to deal with reality. And
there  may be ways to manipulate the system that
will make it more effective to our own purposes.

MR. CHAMBERLIN:  I don't know if you're asking me
for a commitment that we won't look at repro-
gramming. Because I can tell you that for any
reasonable reprogramming request, we will
recommend that it be approved. Obviously there are
Administration policies. The Administrator  herself
has policies. And there  are also laws, that we will
see don't get violated. But if you all are suggesting a
reprogramming  into something that makes sense, we
will support it.

MS. CARUTHERS: I'm Leslie Caruthers from Boston.
I had a question for John  Chamberlin. I thought I
heard you say that you assumed from the fact that
none of the Regions requested reprogramming in
their operating plans for 1983  that we were
therefore satisfied with  the workload models. That
simply cannot be true.

MR. CHAMBERLIN:  I didn't quite mean that. I meant,
I have to assume that you were satisfied with the
results of the workload  models in your  Region.

MS. CARUTHERS: We may have agreed to the
overall distribution of resources, but there are a
number of reasons for that, maybe it would help you
to know them. I don't want you to go away thinking
that the Regions think that decision  units are (a)
alright, and (b) focused for environmental results,
  First of all, most of us are trying to figure out how
to adjust our workforces to meet the 1982 cuts, and
secondly, trying to absorb our reorganization. And
third,  in the states, as in the Regions, there's a major
uncertainty as to what really is going to happen with
the 1983 budget. Under those circumstances, and
considering the fact that it is not unprecedented for
programs to  retaliate if you reprogram out of their
decision units, I think it would be very unusual to
find any Regions, or very many, asking  for
reprogramming. It's a minor point and I don't want to
get off into a discussion about it, but I was a little

MR. CHAMBERLIN: It's not a minor point. The reason
it surprised me, Leslie, is because we have made a
major effort this year to take care of the retaliation
problem. We have made this known to the
Management Divisions and the DRAs. The base for
the 1984 budget is your operating plan. So, if you
want to change and you want that carried over, that
will do it. Now obviously, the Administrator gets a
whack at it; OMB gets a whack at it; and the
Congress gets a whack at it, as they should. And so
there are no guarantees in this game. But, in the
past, not all the way in the past,  but in the recent
past, the President's budget has been the base for
the out year planning. And so any operating plan
changes you make got lost in the wash and you were
subject to retaliation. But we  made the change
known and in that climate nobody suggested  any

MS. CARUTHERS: I think there is reprogramming for
environmental  results going on in the Regions that
does not show in any of our reports.

MR. CHAMBERLIN: I am sure you're right. Of course,
the problem with that is that as long as it's done that
way it never shows up in a workload model.

UNIDENTIFIED: Well, Lew, we're going to go  through
this exercise, the purpose  of which is to put
environmental  results much higher on the list. But,
in the end, the RAs are going to sit down and cut the
deals that say, where you really have a one man, one
vote situation, or one Region, one vote, how can the
Agency deal with the fact that environmental
problems and environmental results are not spread
on a basis of one-tenth per Region? That is a major
continuing concern to my Region. We can go through
this exercise. And we can all spend a lot of very
valuable time doing it, but if at the end of the process
we have one man, one vote, in a system that it
basically makes all Regions equal, I assure you that
our end result will not be environmental results.

MR.  CRAMPTON:  There speaks, of course, someone
from a large Region with a lot of environmental
problems. But of course this is an issue that from
time immemorial has plagued the whole resource
allocation distribution process. And it's  something
that ought to be dealt with in those workshops as
  I'd be curious to know how some of us who from
the smaller regions feel about the issue of resource
allocation to environmental problems. Because if you
follow the implications of environmental results,
what you're  saying is that we're going to put our
resources where the problems are, not  necessarily
where the active DRAs or RAs are. We're not going
to follow that same old process. I hope that we'll get
a lot of good recommendations out of the workshops.

Summary of
Discussions and
 Introduction by Lewis S. W. Crampton, Director
 Office of Management Systems and Evaluation

 Before the workshop broke up into individual
 workgroups, Mr. Crampton spoke briefly to workshop
 participants about the specific charge they were to
 address in those workgroups.
  He asked the group first of all to deal with big
 picture items, the big contextual issues, but not to
 spend a lot of time talking about, for example, the
 importance of environmental results and how difficult
 it is to manage for environmental results with our
 current budgeting system. He asked them instead to
 focus their work and recommendations on the
 following questions:

 • First, what do we need to do to improve the
 availability of useful data? Do we have the
 information we need? How are we going to get
 information from states? Do our monitoring networks,
 as they are currently established, get the job done?

 • Second, what kinds of improvements need to be
 made in our management systems, planning, budget,
 accountability,  guidance, SEAs, and oversight to
 manage for environmental results?

 • Third, what kind of recommendations do you have,
 and what kind of agreement can we get, on the
 usefulness of the trend indicators and status
 indicators we have? He said that, based on the
 recommendations in the workgroups, OMSE would
 make some decisions about the kinds of measures to
 use in the accountability system, and the kinds of
 measures or indicators the Agency should use in
 reporting to Congress and for internal use within the
 Agency for management decisions.

 • Fourth, what are the most effective ways of
 reporting on our progress in managing for
 environmental  results both from the standpoint of
 our internal decision making and from the standpoint
 of marketing ourselves to the world at large?

  The group then broke up into workgroup sessions.
 A complete list of questions considered by the
 workgroups can be found in Appendix IV. There were
 concurrent sessions on managing for environmental
 results in the Air and Water programs followed by
 similar sessions on Drinking Water and
 RCRA/Superfund. At these  sessions, each group

    appointed someone from that group to summarize for
    the full workshop the discussion and
    recommendations of that workgroup. The full text
    of these summaries is presented below.
   Presentation of the Water Quality Workgroup
   by Jack Hoffbuhr, Water Division Director, Region 8

   The Water Quality workgroup's discussion focused
   not on whether there is life after delegation, but on
   whether there is life in STORET.
      In starting the discussion, I would like to refer back
   to the three key factors that Irv Dickstein mentioned
   in Region 8's presentation on Walter Quality — the
   fact that in order to do that you need, (1) envi-
   ronmental goals and objectives, (2) management
   commitment, and (3) reliable environmental
   information. Keep that in mind as I go through the
   questions that were posed to  the workgroups, and
   see whether, in fact, those three factors are met by
   what we discussed.
      The first question we were  to address was whether
   or not management systems are currently in place to
   allow the Agency to manage for environmental
   results. We had a variety of responses on that within
   the work group, from  "The last thing we need is
   another management system, whether it is in place
   or not", to 'There  is already one  in Headquarters and
   all we have to do is stimulate it somehow." As a
   matter of fact, Eric Eidsness, in the Office of Water,
   has produced a document that is a combination of
   guidance and an accountability system. Attached to
   that is also an evaluation system where the Office of
   Water will come out next year and evaluate all the
   water media programs. The way it is now it is rather
   fractured — Construction Grants does one. Water
   Quality Management  does one. Drinking Water does
   one, during different parts of the year. What this will
   do is combine those evaluations and measure the
   Regional water programs overall, based on the
   indicators and the measurements that are in that
   accountability system. In addition, each program, for
   example. Drinking Water, Construction Grants, Water
   Quality Management, is working  on a strategy for
   this coming year.
      The consensus of the work group is that what we
   really need is to get a little bit more in front of
   ourselves and quit fighting fires. We should do some
   long range planning, set some goals for where these
   programs are going, set the environmental objectives,
   and then come up with strategies to meet those
   objectives. Perhaps this will drive the type of
   accountability system we have, the kind of data we
   collect, and what we do with that data.  So we saw a
   need to go beyond what the Office of Water has done
   this year to another step and  come up with a strategy
   for each media and then put together a combined
   strategy for the Office of Water on where these
   programs are going. Some of  that is being done in
   the Water Programs. For example, Rebecca Hanmer,
   talked about the permit strategy that is being used,
   and that is more long term in scope. There is a water
   monitoring strategy under preparation right now. I
   am not sure as to what the scope of that will be but I
hope it is longer term than just for the next year. We
really need something that tells us where we want
that monitoring program to go, because it really will
determine what type of information we gather.
  Within the strategy we certainly think that one of
the issues that is going to have to be faced, is how
we balance the prevention aspect of our
responsibilities with our clean-up tasks. In other
words, how do we keep clean what is already clean?
We really do need some sort of method of balancing
prevention, and then some way of measuring it.
  What the strategies also should get at is the
question of what we want to show with the
programs. What is it that we really want to say about
water three years or five years from now? That is the
key to the type of data we gather, the type of reports
we write, and the type of measurements that we
decide to use. We have not really done this yet. So,
the first key factor is to set environmental objectives,
and also determine what it is that we want to say
about them, or how we plan to meet them in three to
five years.
  The second question was whether the Agency has
the data it needs to manage for environmental
results in the program. We had a wide variance of
responses during the workshop, everything from the
opinion that there is plenty of data in STORET crying
to get out and be used, to other responses including
the view that even if the data in STORET were used
it wouldn't show us whether or not we are managing
for environmental results because it was intended to
show trends, not cause-effect relationships. But the
consensus of the workgroup was that we  do have
lots of data, and it probably is useful. It can be used
to show trends, and also it can be used to indicate
how streams are doing compared to the water quality
criteria established by the states.
  There are data gaps, however. For example, we
probably can't say much about the biological health
of the stream, other than by inference from the
chemical data — the pH is right, the DO is right, and
so there has got to be fifty pound trout there. When
you don't catch any that is your fault, not  the
stream's fault. You probably can't show, using the
data, whether or not our criteria are overprotective of
a particular stretch, without doing more intensive
surveys, inlcuding biological surveys.
  And we probably can't show improvement in many,
many cases where we would like to, using the
present data. We may not be able to show
improvement due to the Construction Grants
Program in certain cases,  because perhaps some of
those fixed stations aren't in the right places to do
that. You might be able to make some very general
comments but perhaps nothing too specific. Also it
would probably be difficult to show improvement due
to best management practices as a result  of some of
the area wide agencies because of the same
  So that gets to our second point, and that is,
credible or reliable environmental information. We do
have a lot of environmental information in STORET,
and other places. Regions are making good use of
that. States are making good use of it. However,
there do appear to be some gaps, as I mentioned. I

think one caution of the workgroup throughout is
that we don't want to make the full swing and do
nothing but biological surveys in the  next few years
and throw out all the chemical data,  because you
need a balance of both types of information in order
to make rational  decisions regarding  priorities in the
Water Program.
  The third and fourth questions are: what indicators
should you use to show environmental status and
environmental results for the water media? Again,
we had a full range of responses. Some said that the
Regional Administrator should be pulled behind a
boat through water quality limited segments, others
that the Regions  should be required to come up with
their own measurements in environmental results, so
that you would essentially have ten different ways of
showing that we were doing what we were supposed
to do. I think everyone pretty well decided  though,
that it is not a good idea to have each state or each
Region go off and develop their own  measurement
system, although we certainly don't want to destroy
anyone's incentive.
  The consensus was that there should be some sort
of a measurement system in general  terms that we
are all following, so that we can have a  national
report. But on the other hand if a state or region
develops a slick method of showing environmental
progress, they ought to be allowed to do that, and
perhaps that could be factored in some how in an
addendum to the report in order to show a specific
case — success stories, fn other words.
  When we started talking about indicators and what
should we be measuring, I think we essentially
categorized those things into three basic areas:
(1) ambient monitoring, (2) pollutant removal, and
(3) activity indicators, in other words, the old PPA
system, essentially. We thought that  these three
areas all need a closer look. And we  certainly didn't
have time to look at each one of those in very great
detail to see if there are indicators in those three
areas that could be used successfully to show
environmental results and environmental progress.
And perhaps some  of those can be different than
what we have used in the past. For example,
concerning ambient information, I think the thing the
public is worred about is, "Can you fish  in it and can
you swim in it? Does it smell  bad? Is  it going to give
me a rash?" What we are doing  now may  not answer
those questions.
  However, if we probably use some  other measures,
such as, fish kill, maybe even fish production. Those
figures are available, and certainly they have
visibility. These are not anything new. The Agency
has used these in the past, certainly. I think they
have kind of fallen off in favor, but it  may be
worthwhile taking another look at them.
  Another way, of course, to do ambient monitoring,
is the traditional  monitoring networks which we have
now. One thing that we might want to consider  in
this area is to take a look at what other Agencies are
doing. And we have typically cooperated with
U.S.G.S. and state agencies in looking at data, but I
am not sure that we have taken a hard look at a lot
of other agencies, such as the Corps  of Engineers,
that also collect data. Also, there are  the industrial
 groups that have done a lot of biological monitoring
 in applying for energy permits, or other things. We
 probably should take a look at what is actually out
 there before we try re-inventing the wheel and spend
 a lot of money on data production.
  We did not come up with a check list of indicators
 that everybody was uniformly excited about to use in
 measuring  environmental results and status.  I think
 we felt that the regions and the states, and we did
 have a couple of state representatives in the group
 that gave us some good ideas, have developed
 systems. We  really need to take a look at those
 before we decide on a set number of indicators that
 we are going to live with for some time. So, we
 would strongly recommend that, either through the
 monitoring strategy group, or some other group, that
 a look be taken at what the regions and the states
 are doing before we come  up with a set list of
 indicators that we will use.
  Finally, once we have the data, and we are
 satisfied with the  indicators we are using, how do we
 report it? There was a discussion on exactly what or
 who are we looking at. Are we looking to report this
 to the public? Are we looking to report it to Congress,
 or just to the  administrator? I think we decided that
 we don't want to be in a position of preparing a
 report for each specific community or group. The
 reporting system we come up with ought to be
 something we can use as a tool, and perhaps the
 Administrator may decide to  use part of that for a
 report to the nation, so to speak, on environmental
 quality as far  as water is concerned, and certainly
 use portions of it in reports to Congress.
  I think everyone felt it was a good idea if each  R.A.
 did submit an annual environmental report to the
 administrator on the status of the environment
 within a region, and in our case, the status of
 environmental results in the water area. The regions
 felt that the basis of that regional report as far as
 water is concerned, would be the 305 (b) reports
 received from the  states, and in some cases, that
 may mean that improvements are needed in the 305
 (b) reports in order to get the type of information that
 the region and the administrator are interested in. I
think the recommendation was that the regions then
would probably summarize the 305 (b) reports from
the states in a status  report, both to Eric Eidsness
and to the Administrator on what water quality is like
within that  particular region.
  Well, in summary, I think the group felt that a good
time was had by all, that we got to say a lot of things
about data that we have been dying to say for years,
but we needed far more than an hour in order to
come  up with answers to the specific questions that
were asked. I  think the key recommendations  would
 be that we do need some long term environmental
objectives in the water program, and that in setting
those, we must balance prevention with our efforts
to clean up segments. Certainly, we ought to take a
 hard look at what we have before we generate
anything  new, identify the gaps, and hopefully from
that be able to determine what we want to say about
the water program, what type of information we need
to say it, and then the best way to go about saying
that. Thank you very much.

   Presentation of the Air Workgroup by David
   Howekamp, Director, Air Management Division,
   Region 9

   We had a lively session, but as I went through my
   notes I did find areas of consensus and many
   divergent views. We had enough time to cover four
   areas: planning, allocation of resources, indicators,
   and reporting. We never got to data, and maybe that
   was a good idea, because we didn't have a lot of
   time for other discussions.
     In the planning area, I think we did have a
   consensus that there is a need for a three to five
   year strategy prepared by the Regional offices on a
   state by state basis, or perhaps an area by area
   basis. We keyed on John Wise's presentation right
   before the workshop. I think across the board we all
   felt that we really are lacking in that area  in most
   Regions. Some  Regions, I think,  are doing that.
   Region 8, in particular, said that they have a five year
   strategy for some of their states.
     Beyond the consensus on that issue, we came up
   with several issues. First of all, the states definitely
   have to be involved in developing such a strategy.
   But we have to be careful not to tax them too
   heavily, with declining resources and the budget
   cuts, it is something we can't add on.  It has to be
     Second, the size and complexity of the strategy
   must vary with the state. Dave Kee used the example
   of Minnesota as a place where he wouldn't spend a
   whole lot of time developing the strategy  because it
   is basically a clean state. Others responded that
   perhaps all you need is a prevention strategy, a very
   short two page document, or something like that.
   One thing that we found in our discussions is that
   you really have to define upfront what a strategy is. I
   think a lot of us had  different conceptions of what a
   strategy document amounts to.
     One of the possibilities that we came up with, and
   it is certainly not the only one, is that a strategy
   document consists of an environmental assessment
   based on the national standard and, probably,
   emissjon levels, an action plan, and then  a yearly
   update, once you get the basic document in place. A
   yearly update could have changes in the trends on
   national standards and emission levels and then
   adjustments to the strategy to make it a living
     Some of us brought up that there is a possible
   need for a headquarters Air Program strategy. But
   most of our discussion really keyed on the need for a
   state by state strategy prepared by the Regional
   office in conjunction  with the state. The concern on a
   national strategy was that Headquarters perhaps
   wouldn't be able to live up to the commitments laid
   out in that strategy.
     Next, we talked about allocation of resources, and
   we had a ninety percent consensus here. One Region
   was in the minority. Ninety percent of us, by Region,
   felt that the current workload model in Air was
   adequate. It was pointed out that it is based, to a
   certain extent, on environmental indicators. About.
   twenty-five to thirty per cent of the work years are
   based on those kind of indicators. But the remaining,
   seventy to seventy-five percent really funds the base
program in the Regional offices. It is the critical mass
concept. Those critical mass factors relate to program
operations and size, rather than environmental
  One of the issues we came up with is that the
strategy should impact back on the workload model,
that is allocation of resources. The problem  there is
the way we have structured ourselves with  overhead,
etc. We are really only, talking about only twenty-five
to thirty percent of the resources. The point  was
made that the critical mass, or base, of the Regional
offices is probably going to change this next year, or
in the next year after that, because enforcement and
programs are not put together. So there should be
some economies of overhead or scale.
  Finally, we talked a  little bit about John Wise's
proposal for a ten percent pot of resources reserved
for environmental results: It was met with mixed
reactions. The biggest problem raised was dealing
with the year to year fluctuation, mostly with
positions.  If you really move the work years  around
from Region to Region, to match an environmental
need, you could have severe dislocation. I think we
have seen that in enforcement decision units over
the past few years, where there was some wide
fluctuation that really was counter-productive.
  On environmental indicators, we again had a
problem with perceptions about what environmental
indicators were going  to be used for. Here again,
some clear defining needs to be done at the front
end. Some people were thinking in terms of the
accountability system, while others were thinking in
terms of planning and resources. But the consensus
when we got to the bottom line after a half-hour
discussion is that in the near term, environmental
indicators probably should not be in  the
Administrator's accountability system. What regions
should be accountable for are the  indicators that are
developed and are factored into planning or
strategies. This is in the near term.
  We talked about two levels of indicators. The first
is a three to five year  level of indicator, basically for
measuring trends, and for strategy development,
priority study, and generally focusing on problems.
We all felt that the national ambient air standards as
they exist are adequate for this. A good point was
made that you really should factor in population
exposure in some fashion so that you really get the
impact of your problem based on health. We talked a
little bit about welfare effects also. I think the
consensus was the real focus environmentally is for
public health in the national primary standards.
  A second level of indicator could be classified as
year to year.  And again we agreed that emission
levels are a good surrogate. Perhaps they could be
area specific or pollutant specific.  A couple  of people
pointed out that voluntary compliance and other
indirect actions, that we or a state might take, should
somehow be factored in because it does have a
positive effect on emission levels.  It may not be the
result of a classic enforcement action or a records
development. Theoretically, if you  have a good
system for measuring emission levels you should
have a way to show this, but perhaps not. The third
point is that emission inventories  are generally pretty

 weak in most states, and therefore you need to target
 what you are going to be looking at in terms of
 sources or categories.
  The last thing we looked at was reporting. One
 point that was made was that there really is a
 different level of reporting for states, Regions, and
 Headquarters. The state needs a certain amount,
 generally the most, information for their day to day
 operations. The Regions need less for oversight and
 technical assistance. Headquarters needs even less
 that that that, basically a report for Congress and for
 national program  management. We really didn't have
 a consensus on the number and type of reports.
 There was a disagreement here. Some felt that two
 reports would be the way to go — one aimed
 primarily at the public, an external report focusing on
 trends and profiles, and another internal  report that
 was more management oriented, with more detailed
 back-up information. Others in the group felt strongly
 that that was the wrong way to go, that one report is
 appropriate, and we could get into some real
 problems with consistency if we had two Reports.
  The point was made in this group as well as the
 Water group that you really don't need any new
 reporting systems. A lot of the systems currently
 exist in various areas of the Air Program. There was
 also concern that any new reporting not be instituted
 until FY 1984, since the states have not been
 plugged in at all. The State-EPA Agreements and
 grants for FY 1983 are underway or are almost done
 in some cases. For the immediate future, indicators
 should really only be used for planning and strategy
 development in order to see how it goes. We should
 then begin a new way of reporting towards the end
 of FY 1984. That was it, thank you.
Presentation of the RCRA/Superfund Workgroup
by Stephen Wassersug, Director, Air and Waste
Management Division, Region 3.

In general, we had a fairly good consensus in our
group. There was a real feeling that something
needed to be done in the entire Superfund/RCRA
area. This is possibly due to the emerging program
issue, the sensation that what is happening here is
that we are not telling the full story. In fact, most
people agreed that we were in fact not managing for
environmental results. This is a high interest
program, and there is a lot of intense pressure from
the Congress, local communities,  and everyone else.
  There is a great difference between Air and Water
and the Hazardous Waste programs. There was a
feeling here you  are dealing with  ambient standards
per se. You are dealing with issues that relate to
dump sites or Superfund sites. So that gives you a
different feeling, perhaps, in trying to localize  the
problem and deal with the issues  as we are facing in
the RCRA/Superfund area. We were dealing with
things from the beginning of the dumps site program
which generated a lot of attention and a lot of
interest. The feeling of the group  was that something
has to be done to show that we are in fact managing
for environmental results.
  There was a general feeling in the workgroup that
we are not managing for environmental results, but
that partial things are being done in the program
area that may be considered to be managing,
perhaps on a site by site, basis. At this point in time,
however, we are not doing any kind of a full system
that could really be called managing for
environmental results.
  Should we have a system? Yes. Short term? Some
people felt we should have a one or two year system,
or that at least between  now and two years
something should evolve. There was also a strong
feeling that we should have a planning system that
was long term, something perhaps over a five year
period. There is one comment I want to make here
which I think is very important. I introduced this into
the group because I happen to be working on a
national task force right  now to develop a workload
model in the  Superfund/RCRA area. This is the issue
or reviewing the priorities, the resources, and the
concerns. I think one of the things that is happening
here is that there is a tremendous feeling, and it
came out of the group, that we were being asked to
do everything in the hazardous waste area. We are
being asked to manage all these sites, deal with the
heat from the public, the Congress, and so forth. So
that what is evolving right now, at the same time
that we are talking here  about managing for
environmental results. There is a task force that has
now evaluated the resources that are  allocated to the
RCRA/Superfund area, and is looking at those
resources based on a priority basis. What should
evolve out of this effort is something that will analyze
the priorities  in the program, define those and
perhaps give  us an expression of where those
priorities should be set. The concern is that it doesn't
necessarily reflect management for environmental
results in perhaps the way we have been talking over
the last two days.
  In dealing with RCRA/Superfund, we are dealing
with two programs. There was concern that we not
lump those in a sense into one program, although we
are talking about the total hazardous waste picture,
and looking at it from that perspective, it is one
issue. But in managing for environmental results, we
are also talking about two separate and distinct
program areas.
  Now, this is interesting. I guess I was a little
concerned about trying to deal with this workshop
because, unlike the information which existed in Air
and the other programs over the years we did not
have STORET or very much of a data base.  But I
think there was a general consensus again that a lot
of information is available, through the abandoned
sites, the Superfund lists, the notifier lists, and
various other types of information like this which
provided an excellent place to start, and could be
used as the basis for developing the kinds of
strategies and indicators that could be used for this
particular program. I think there was a consensus
that we could all begin to look at this. Perhaps what
it comes down to is that  the information is there and
maybe  it is a  matter of interpretation in terms of how
it is being used and how it ought to be explained. In
terms of the sites themselves, it was recognized and
brought out by a number of people that we  do prioritize
right now. It may not be  that in certain areas and certain

  Regions we are prioritizing the same way in each
  and every case, but there are priorities that are
  generally set in terms of dealing with some of these
     In terms of the information that is available on each
  site, when we talk about the universal site list, we
  are talking about thousands and thousands of sites. It
  doesn't mean, in fact, that complete information is
  available for all  of them. Certainly for many, we have
  no information, and that has to be reflected.
     Perhaps just dealing with listed sites, getting
  information and removing them from the lists ought
  to be an indicator. In other cases, the indicator may
  be simply improving upon the  information and then
  dealing with the clean up in that program area. A lot
  of people had ideas as to what indicators might be
  appropriate in dealing with Superfund. Some
  suggested that the definition of Superfund equals
  cleanup, but others felt that we need to define what
  we mean by cleanup, if we use cleanup in some
  fashion  as an indicator.
     For example, do we use actions per site, rather
  than dollars. I think there was a comment that the
  dollars we are spending on a site is not necessarily a
  good indicator of cleanup of managing for
   environmental results. On the Air side, they
   mentioned minimizing the risks of hazardous wastes
   to a segment of the population. What was discussed
   here was that if you have population affected around
   a certain site, perhaps from a  drinking water
   standpoint, the comment was that as you deal  with
   the site in some way, you are not removing the risk,
   but maybe we could say you were minimizing the
   risk. The other indicator discussed was population
   directly  exposed. We would have  to work to define
   what that might mean in terms of the population
   exposed vis-a-vis one site or an area.
     There was also a concern that the voluntary efforts
   and actions taken by the states, and the voluntary
   efforts that may be taken by the companies to clean
   up and deal with these sites, are  not in fact reflected
   in any system today. When you look at the total
   environmental results picture, they may be a better
   indicator in the long run, or there may be more
   actions  and more effectiveness in using many of
   these as an indicator, than perhaps the sites that
   EPA is cleaning up. So some way those voluntary
   efforts need to be reflected in the system. There is
   also a down side to this which I will get into later on,
   and that is the additional reporting burden which
   might be placed on a state and what that means and
   how to deal with that.
     From  an ambient standpoint, it was suggested that
   maybe what we ought to do in order to look at the
   long term picture, is to look at ground water trends.
   Since this appears to be the only program collecting
   that data at this point in time, maybe that would give
   us a fairly good assessment of how we are doing as
   we clean these sites.
     We talked about the hazardous ranking system
   where you rank the site, you score it, and you give it
   a number. After you clean up the site, maybe you
   give it a new number and re-rank it. Maybe a good
   indicator would be the quotient of one number over
   the other. Everybody recognized that out  of the
hazardous ranking system you are making an
evaluation of the population, and you are looking at
them from a standpoint of groundwater and other
environmental factors. A closer look could be taken
to see whether or not that could be used for
determining environmental results.
  In addition,  perhaps the work that some regions
are doing regarding biological assessment, might be
tied into the efforts in the Spills Program area. The
question was  asked, should we look at direct health
effects? And the response back was that it would be
suicidal. The CDC and perhaps others agencies are
looking into that, and also the issues and the feeling
of the communities about the direct health issue. We
also discussed how we properly relate back to the
communities regarding the clean up of sites without
talking about the health issues. So there is a problem
how we deal with that, and I guess that must just be
  On the RCRA side, it was suggested that
compliance is the proper management tool. Simply
having the sites or a percentage of the sites in a
compliance category, may be as good a picture as
you can get for RCRA in terms of  managing for
  We talked about improving the  state reporting, and
I underline the word "improve". The feeling
was, I guess, that Superfund/RCRA has come  into
the program a little late, and maybe is a little
resource poor. We do not have the advantages of the
amount of reporting and certainly the data base that
had been collected in the other program areas. The
issue  is, how  much reporting should there be that is
not burdensome, but where the states would also try
to show the same picture of managing for
environmental results? We are all going down the
same road right now, and we are  all  trying to reflect
the same story.  How could we work with the states
so that that story is reflected and  so they also can
tell the story in terms of their need to close or deal
with the sites in their state?
  The need for an annual report was brought up in
our discussion in terms of defining the managed
waste. Are we going to have inspections or surveys,
or are we  going to have an annual RCRA report in
this whole waste area? If we cut reporting at the very
beginning of this program it was suggested, without
a good data base, that may not be the way to develop
the picture that we would like to show that there is a
program that  is being managed here, going from a
paramount of waste that is in the environment,
uncontrolled,  or spoiling the environment to the
amount of waste now in the environment that is
under some form of control.
  We talked about permit strategies, and thought we
should avoid counting. Maybe we could  look at the
waste that goes to high technology incinerators. We
can see we have a lot of indicators here. And the last
indicator we talked about was individual success .
stories. More effort should be spent on that. A couple
of Regions brought out that perhaps we are not
spending enough time showing within certain
geographical areas or site by site, what the effect
and what the position actions have been.
  I mentioned the state reporting issue before, but I

will bring it up in another context. One of the
problems in this particular area with the state
reporting is that there are no state Superfund grants.
So you are working with the states in a manner in
which certainly you can't require some of the
reporting that you can in other areas. There is a real
concern in the Regions, that we look once again to
make sure that the states are adequately put into the
system with the adequate support, so we can call  on
them in developing the data and the entire efforts of
carrying out the job that is there.
  Everybody felt we  needed to have a planning
system that is going to direct us, rather than the
system we have now which causes us to react. In
that system, we should look and define where and
how much heat the Agency can accept, knowing that
we have a resource  limitation, knowing that it is all a
volatile issue, but that we must deal with some of
the heat. That has to be  looked at from the strategy
standpoint. We must deal with the public opinion
issue. In dealing with any reports we issue — for
example, a report which maps out in one state the
sites or the amount of waste generated in that area,
or the amount of waste stored — each of these
reports are going to generate another public reaction
to the entire hazardous waste problem. It is not
necessarily going to solve it, and it is not necessarily
going to tell the community that there is a solution.
Therefore, in trying to manage environmental results
here, we have to be  very careful to deal with the
public opinion issue.
  In  summary, we need a reporting system. Our
group was open to suggestions. The available data
that  is already in the system, with better
interpretation would probably produce some pretty
good results as far as developing an environmental
results picture, although there may not be
information from a trend line standpoint, because we
are talking about an emerging program.
  The workload model and the new priority setting
that is being done in this program area alone  should
be dove-tailed into this entire picture. Environmental
results is a high Agency priority. The increased  data
gathering, though, if it evolves here, is going to
mean more resources, and will raise tough state
issues. Environmental results and the issues they
raise have to  be looked at rather carefully. Thank
Presentation of the Drinking Water Workgroup by
Allan Abramson, Director, Water Division, Region 7

A small, but gallant band met in the hot-box at the
end of the corridor, and discovered that the Drinking
Water program is at least thrice blest. First, it is,
compared to everything else, extremely simple.
Second, it deals exclusively with humanity, rather
than critters. And three, it is predominately a public
health program, which means that it is directly in the
arena of managing for environmental results,
responsible for benefits to people and public health
protection. That created a sense of complacency and
certainty in our workgroup that we were in the right
ball park. We went past a lot of the considerations
that the other workshops dealt with rather quickly to
an end point of measures.
  What kind of measures do we want to consider?
How do we want to evaluate this program? I will try
to summarize our discussions.  In terms of the kinds
of measures that we came up with, there was fairly
general agreement that this is appropriate. Some of
these are overlapping, or variations of one with
another. So they need a little refinement. But at the
end of a relatively short period  of discussion, we felt
that this was close enough and good enough and
probably reflective enough of the program that it
could be sold and implemented.
  These are the measures. They echo what you have
heard from other workgroups.
  The first measure we started with was person-days
exposed. In listensing to the  other presentations, it
really struck me as significant that we  are drifting
toward person-day exposure  rates in all of our
programs as a  means of measuring the significance
and the impact of our programs. Second, maximum
contaminant level (MCL) violations were suggested as
a means of reporting. These can be refined and
categorized by the individual  drinking water standard,
segregated by significant violations rather than trivial
ones that we don't really care about, amplified by
attaching to them the risks to public health
associated with that kind of an exposure, that is, the
risk of bacterial exposure is significantly greater than
the risk to your smile because of a fluoride violation.
So, it has to be explained to people that not all MCL's
are created equal. And one can also distinguish
persistent  from random violations, that is, the focus
on individual systems which  tend not to keep their
plants operating, versus a lot of small systems which
tend to go in and out of compliance all the time.
  Another kind of a measure to add to  that, because
these are exclusively focused on MCL violations,
would be to publicize and focus on persistent
systems which refuse to monitor, persistent non-
monitoring cases, and attach to them an estimate of
the population at risk because you don't know
whether they are  in compliance or not, since they are
refusing to monitor. So we agreed that that should
be in our tracking system.
  The other end of the spectrum is to track, record,
and publish the person-days  of those persons
obtaining safe  water, that is those getting water from
systems in compliance. Now, when this one came
up. Jack Hoffbuhr and I put our heads together and
agreed that that it made us somewhat  nervous,
because we have  this intuitive  sense of the Drinking
Water program that if you compare the number of
those obtaining safe water each year, with this
number, those exposed to violations, we will end up
demonstrating quite clearly that we are about ninety-
eight percent in compliance in the country, and we
don't really need a program anymore. And that is a
potential problem for those who care about
bureaucratic survival. Nevertheless, it may be a valid
  The next one is a surrogate for these more direct
measures  of risks to public health. It is the
percentage of systems with compliance, or brought
into compliance in any given year. Another way of

  looking at the population, rather than person-days, is
  to estimate the percentage of the population
  protected each year. That is just another way of
  cutting what I have gone over already.
    In terms of measuring program effectiveness,
  particularly the state programs, almost all the states
  have the Drinking Water programs, and they do a lot
  of things to prevent violations for which they are not
  obviously credited. One way to track the
  effectiveness of a state program is to count the
  number of water supplies put on bottled water or
  emergency notices each year. This tells you
  something about the responsiveness of the program
  to a need to protect public health. You can do that by
  counting system days on notice and attach to that
  the population effected, or collapse those two back
  into person-days effected by an emergency notice
each year. It is not a bad way to track that item.
  Then finally, the measurement that we all tip-toed
toward, and then run away from, was water-borne
disease statistics, actual public health statistics. My
own opinion is that recognizing the difficulty,
recognizing all the uncertainties, and the fact that a
correlation  is not cause and effect demonstration,
and that they are very expensive, I feel the Agency
should move into the arena of public health  statistics
and try to do a lot better job than we have in the
past. Now this would be an indirect measure, to be
sure, but a  clear measure of the effectiveness of our
  So, that is basically the summary of our work
group. It really focused on the endpoints and left out
a lot of the other considerations that the other
groups discussed. Thank you.

Panel  Discussion
on Workgroup
After the workgroup presentations, a response panel
commented on the findings and recommendations of
of the workgroups. Members of the panel were:
Harry Seraydarian, Deputy Director, Toxics and
Waste Management Division, Region 9; Barbara
Metzger, Director, Environmental Services Division,
Region 2; Fran Phillips, Deputy Regional
Administrator, Region 6; and John Chamberlin,
Deputy Director, Office of the Comptroller.
Individual  Presentations

Presentation by Harry Seraydarian, Deputy
Director Toxics and Waste Management Division,
Region 9

  I got a sense during the workgroups that everybody
has a natural inclination towards environmental
results. There seemed to be from the indicators that
were either discussed, or suggested, a natural
tendency to recognize that there are not enough
resources to do a complete job, and you are going to
have to set priorities and then measure your results.
  There seems to be an overall consensus in the
workgroups of avoiding bean counting, and looking at
what we can do to really evaluate the progress in our
programs. I did notice a difference between the old
programs and the new programs. Having been in
some of the old programs,  water, especially, and
sometimes in air, I can understand why that occurs.
It seems like people sit in a room and know what
they are supposed to be talking about, and
immediately assume their roles, even though they
may be a little more forward thinking when they are
actually involved in new programs.
  I noticed that every workgroup agreed to long
range planning as far as the water, air, and
RCRA/Superfund although I don't think it was
discussed in drinking water.
  Every workgroup also discussed resources. I think
the water and air people spent the most time on
resources, indicated the difference in regional
opinions, and probably got  bogged down discussing
resources more than they discussed how to address
the problems-in the program.
  There was a general consensus in each group to
consider the population affected as an indicator. We
do have to develop some tools to address that. Air
mentioned that they should look at population

   affected to give some indication of the public health
   aspects. RCRA and Superfund and the Drinking
   Water workgroup also talked about this. Water
   seemed to be more oriented toward the fish, than
   populations, and here, we could measure the fish
   days effected.
     Some positive trends were indicated as necessary
   for measurement, for example, prevention and
   abatement. We do need ways of showing how we
   are moving towards a better situation for the public
   and the general environment. But we also have to
   show what we have been preventing in the long run.
   Presentation by Barbara Metzger, Deputy Director,
   Environmental Services Division. Region 2

   I think for all the programs, except perhaps the
   drinking water, the following four major points will
   apply. First I think the program offices, both in the
   regions, and in headquarters really need to identify,
   and rank in priority order, the environmental
   results  questions they want the monitoring programs
   to answer. Without that, the monitoring programs go
   off in all directions, serving no one. Second, I  think,
   that, especially in the water, and perhaps in the air
   and eventually under RCRA and Superfund, some
   select group has to be set up to determine what
   parameters, both the old ones and some new  ones,
   should  be included in monitoring programs in  order
   to answer program management questions. Third, we
   must determine how that data should be manipulated
   so that the data can be  presented to the managers as
   answers to the questions that they have asked.
     I think we also have to make sure that there are
   standard methodologies available to measure  the
   parameters in order  to obtain good and acceptable
   data. I think if we start going into biological
   monitoring, and under RCRA if we want to look at
   hazardous waste sites, we don't currently  have the
   kinds of standard methodology so that we  can
   generate comparable data, or universally acceptable
   data. So, there is a role here for R and  D in some of
   these programs if we are going to start changing our
   environmental  results that we are measuring  through
   monitoring programs.
     And last, but not least, and probably the most
   important of all, we  have go to get our act together
   up front, two years before the budget comes down
   the  pike, so that when we decide to make  these
   changes there are some resources available to carry
   them out.
   Presentation by Fran Phillips, Deputy Regional
   Administrator, Region 6

   I think all of the speakers this morning have
   absolutely given us excellent information. I think all
   the evaluators gave some excellent presentations of
   what we have done so far.  I feel like I am in a
   position of just trying to reiterate and re-say what
   has been  said before, but let me say it in my own .
   words because I did take the time to write some of it
  First of all, and I guess to summarize the main
point of what I would like to say, is that we must be
careful as we proceed, and here are some of the
  First of all, I think we heard for the first day and a
half, how you can take the data that is already
available and identify a problem. Some how we
jumped from the problem to an environmental result.
As a manager, I had the hardest problem with the
gap between identifying the problem and getting an
environmental result. That is where I would posit
most of your resources are. All the data in the world
can tell me I have got a problem in Houston, Texas,
and I know what an environmental result would be,
but the resources, the talent, the science, in between
is the gap that gives me the hardest problem. So, I
think we may need to spend some  more time on the
gap in between problem identification and
environmental results.
  Second, I think you need to be concerned from an
overall standpoint, as to the purpose for which we
are going to identify and work with environmental
results. I would think it would be a complicated, if
not impossible, task to try to get environmental
results that would cause an overall change in the
historical program direction of all our programs, and
in the historical statutory directions that we have
been given by Congress. I think it is a relatively
simple task in all our programs to try to identify
environmental results for purposes of telling our
story to Congress and telling our story to the public.
  Next, I would like to give a reminder that in the
areas we dealt with, most of us only considered
conventional pollutants. There is something about
the toxics area that made us all nervous and we
didn't discuss it in any great depth. I think that is the
thing that causes me more uneasiness in the
environmental business these days than anything
  Third, the concept of population exposure. Please
be careful with that concept. I think, somehow, it is
factored into all the programs that  we had in place,
from major permits to minor models to air risk
assessments. I am very nervous about bringing it to
the forefront as a major indicator. It reminds me of a
story that I think maybe many of you have heard or
read about when a state agency, faced with cutbacks,
decided to drop an immunization program that
caused young children trimethal double death if not
immunized. They dropped it because it only affected
one percent of the school children. At public hearing,
a little old lady in tennis shoes stood up and
explained the gruesome death of her only child, who
had not been immunized. She said, "it may be only
one percent of the population to you, but it was a
hundred percent of my child." So be very concerned
about population exposure.
  Also be very careful about health effects indicators.
This, too, has already been developed, I believe, in
our long term planning process. It won't work on the
short term. You cannot ask me to determine whether
I can prove a causal relationship between
somebody's cancer and somebody's source before
you let me take  an action. I need to know quicker
than that.

  In the data area, I would say that what we heard
the first day and a half was how each and every
region, in its own way, has been able to take the
data that has been collected, and translate it into a
system to identify a problem. I thought it was very
interesting that not one region could stand up and
say they had done it for all media for all programs. I
think there  is a rather simple answer to that and that
is resources, not having the available resources to do
that. I think an interesting thing to do would be to go
back to the  systems that have been developed Region
by Region. First, look to see if we used all the data
that was collected to come up with the problem of
  Next, on the data collection, in support of that, I
would like to say that I heard little  in any of the
programs, or in any of the discussions of data
collection for enforcement  purposes, whether you are
talking voluntary compliance  enforcement or actual,
to the courthouse, enforcement compliance. I would
say, in our region I know we  have  gone to Federal
Court, effectuated a cleanup with a skew of six
samples. I think that can be done,  and we need to
preserve that tool.
  Next, and lastly, I wanted us to think very seriously
about the institutionalization  of environmental
results.  I don't want us to buy it hook, line, and
sinker as something that needs to  be in  the
management accountability system. I think that
several people on the program in some way
mentioned that. I think the most important planning
is that we take into account in our decision making,
environmental results. We  saw what happened in the
environmental impact statement process when the
process  became an end of  itself. I would posit that
the most significant thing we got out of the E.I.S.
process  was considering the environmental results
before we took the action. I think the same thing can
work here, as long  as we factor environmental
results into the system. I don't get  so concerned
about the process.
  And lastly, saying all those "be carefuls", if I were
were to  say let us go ahead and do the thing, I would
probably rank our media in the following order as to
which one that I think you  could  incorporate
environmental results in with the best results.  First,  I
would say, Drinking Water, perhaps because it is the
most simple. I  would look at the fact that we are
going to lose our Drinking Water program as a result
of it, but I think it is the simplist right now, most
focused, and most delegated. And since that is the
mode we are moving into, that might be an easy one
to start with.
  Second, I would take RCRA and Superfund, maybe
because that is the newest, but also because I  think
that is what the public is going to demand. The
public and the  Congress will demand to  see some
actual environmental results from that program, and
although we have not defined the total universe
there, it is focused  in that we do have specific sites
to work  on.
  Air, I think, is a historical program, and so I rank it
third, because  it has all the information you need
from a data system collection point. You might want
to go back and see what do we not need in that
program. I think in air, the difficulty is going to be in
formating, and getting what you really want.
  I would rank Water last. I am still not as convinced
as you are Lew, that all the information in the water
bank, STORET, is adequate data for us to  use. I think
it is the most diversified and that it is going  to be the
  In closing, please don't let my ranking at the end
effect my other comments. That was very much a
personal reaction. Thank you.
Presentation by John Chamberlin, Deputy Director
Office of the Comptroller

Luckily there weren't too many resource allocation
questions raised this morning, so my comments will
be brief. I think the question of how our current
program goals fit in with what has been discussed
over the past three days and what Fran just said is
fairly interesting. My guess is that if you talk to most
of our managers in this Agency, from the
Administrator on down, they would tell you that they
are already managing for environmental results. And
I think they are. I think the problem is that we
perhaps haven't had a system that allowed us to
show, in the beginning where we were headed, and
measure our progress along the way, and then tell
people what we did once we were finished.
  That leads me into what both Jack Hoffbuhr and
Dave Howekamp said in  following on Jim Wise's
comments yesterday. I believe we do need to get
national strategies out of each one of our program
managers by media. I haven't thought it through
carefully enough yet to say, whether on a national
basis, we should break it down by state. But there
definitely need to be clearly stated national goals.
Those probably need to be broken down by state,
probably at the regional level. I wouldn't think that
should be done in Washington.
  We also need follow up evaluations. If those can
be done in a year or two or three, or whenever some
environmental results can be achieved, we can make
decisions along the way. As I said yesterday, that
kind of evaluation in my view is probably one of the
cleanest vehicles for getting these environmental
results into the resource allocation system.
  The one item that did come up with regard to
resource allocation is John Wise's idea of yesterday.
That was to take ten percent off the top, hold it in a
pot, and I guess it would go to the most attractive
bidder at some point in the process. I think, I would
like to make a few comments on that, and if anybody
else has any comments,  I would be happy to discuss
it. I think we currently have the flexibility to do that.
It is an extremely difficult timing question. I find it
hard to imagine the Administrator going through this
detailed examination of an out-year budget which
she will start doing in mid July, and  have something
in the neighborhood of four hundred work years and
sixteen to twenty-five million dollars sitting there in  a
pot which she wasn't quite sure how it was going to
be used, but she would let somebody know in a few
years. If she was willing to swallow that, which I
don't think she would, we would get  a curious

  reaction from O.M.B. when we say we want four
  hundred work years for some, as yet undefined
  purpose. I suspect that we would never get out of
  that box, and we would even get a more curious
  reaction from the Congress.
    But I think that if one were to decide that is the
  route they want to follow, my guess would be you
  should tell Regional Administrators now, that they
  have the flexibility. If they have some environmental
  project there that isn't funded, the first thing they
  ought to do  is to look at their own budgets, and see if
  there isn't something of lower priority that could  be
  postponed. They should come in and propose a
  reprogram to cover their environmental project. If,
  however,  they decided it is really important, but not
  quite important enough for them to reprogram into,
  they can always ask the Administrator if there isn't
  somewhere else in the Agency that she feels she
  could take resources from.
    I  think,  in  my view, that this is the  wrong
  approach. I think we should set out national
  strategies by media  tied to environmental results. I
  think people's performance standards should be
  written around those. I think people should be
  rewarded  when they achieve them, and given
  negative incentives  when they don't  achieve them. I
  believe that in our workload models,  if our national
  program managers say their problem is in Region 10,
  and somehow Region 10 doesn't solve that problem,
  I don't believe that what we should do is shift
  resources away from Region 10. I think we ought to
  talk to the management in Region 10. Having said
  that, I would be happy to discuss it further. Thank

MR. STEWART: I am Tim Stewart from the Office of
Water. And I would like to respond to one thing, that
I am a little bit concerned about. I think we would
have to agree with Fran Phillips that we are not
really sure we have the data in the Water Program to
answer the questions. The work that we have had
today does not really in our judgement, measure the
quality of waters. As you may know, we have had
some problems with the chemical criteria. We also
found in many cases, it may not be water quality, it
may be habitat, or other types of things that are
causing the problem and you  really can't tell.
  So we feel that the monitoring networks are very
helpful and a useful tool, but  they don't get us to the
bottom line. The other concern we have is that we
are often not closing the  loop to see the effects on
environmental control actions. For example, we put a
permit in place. We put a construction in place. But
then we don't go back to see  if that really gave us
the environmental result that we thought it should.
So those are two concerns I think we have.
  We are working and developing a water strategy
along the lines that have been discussed, to try to
address and to get some resolution of the issues. I
think  we agree there is a need to more clearly define

Summary  of
and  Next  Steps

Lewis S. W. Crampton, Director
Office of Management Systems and Evaluation

My role in summing up here is not an easy one,
given the complexity of the task of the workshop, the
number of viewpoints on managing for
environmental results, and the occasional clash
between those viewpoints that took place over the
course of the presentation and in the workshops.
Nevertheless, we have had a number of solid
accomplishments here. I will try to summarize those
and then review the recommendations on follow-
through that you have made and that my office will
  Our first accomplishment was that we met. We all
came here, we all sat down, and we all discussed the
question of how to manage for environmental
results. To my knowledge this was first Agency-wide
meeting that has taken place on this subject. We
were talking about doing something that is positive
from the standpoint of bringing facilities into
compliance, cleaning up the enviornment, and
getting the job that we as professionals want to get
  We shared a lot of experiences, and we shared a
lot of information.  I, for one, was suprised, in seeing
some of the presentations, at all that is happening in
certain areas. Even in the Region I came from.
Region 5, I wasn't aware of how far David Kee had
taken his approach to getting environmental results
in the Air Programs. And I didn't know what Irv
Dickstein, Tom Entzminger, and Jack Hoffbuhr were
doing out in Region 8. I am sure that each of you will
take parts of those concepts, or the whole approach,
back with you to your Regions and try to  institute
those approaches where that is appropriate.
  We identified several barriers to managing for
environmental results. These include the fact that the
Agency lacks overall strategic guidance, or front end
planning, and priorities with respect to environmental
results. This situation is changing. We have
discussed the fact that Eric Eidsness and the Water
Program are developing planning guidance that takes
environmental results priorities into account.
Similarly,  Rita Lavelle and her staff are developing a
strategic plan, a set of priorities for handling
situations in the Superfund and RCRA programs.
  We agreed that the resource allocation process is
not flexible enough in most cases.

    We found that there is a lack of consensus on the
  indicators of environmental status and environmental
  results that we should use, and we heard about
  problems with the kinds of environmental data
  available, the quality of environmental data, our
  limited ability to integrate environmental data to give
  a complete picture, and lack of clarity over cause and
  effect relationships. David  Kee's presentation on TSP
  in Detroit and Wayne County was very revealing in
  that regard. His presentation used good  techniques in
  terms of managing for environmental results and
  narrowing down the Region's focus to concentrate on
  those facilities that were contributing most to
  environmental problems. But as David said, it is very
  difficult to determine whether improvements in TSP
  levels are due to abatement and control and
  enforcement activities, or to a downturn in the
  economy in the city of Detroit.
    We asked the question, environmental results for
  what? Why are we interested in environmental
  results? EPA is interested in environmental results
  for  a couple of reasons. One reason is to report on
  our accomplishments. We need to make it clear to
  people whether EPA is being effective in cleaning up
  the environment and protecting public health.
  However, we also need information on environmental
  results to help us make better internal decisions — to
  plan better, to evaluate our programs better, to make
  better budgetary decisions, and to hold managers
  accountable. Until we add that information into our
  decision making formula, the quality of our decisions
  will be limited.
    Even if we went nowhere else with this workshop,
  even if we stopped right here and all went back and
  did exactly what we have done before, we would
  have accomplished a lot. But, we went further than
  that during this workshop. We agreed on a number
  of actions the Agency needs to pursue.
    As managers, our charge from the Administrator
  and other senior managers in the Agency is clear.
  Environmental results. Environmental results and
  environmental results. We as managers have to
  produce them and be able to report on our
  environmental progress. We simply cannot sit around
  and bemoan the fact that we don't have all of the
  data at hand, that we don't have all the issues neatly
  categorized in one box or another, and that
  everybody's role is not precisely clear. We have to
  tolerate a certain amount of ambiguity if we are
  going to get the job done.
    You  all know that the information we need to
  report environmental status and results is out there.
  The techniques to collect, analyze, and report it are
  known. And we do have some flexibility in our
  resource allocation process to allocate resources to
  the most critical environmental problems. If we know
  what the goal is and point ourselves toward it, we
  will solve the problem.
    In this vein; we will try to push the Agency toward
  the goal of managing for environmental results even
  though all the questions about how to proceed
  haven't been answered. Our approach will be go get
  something out there to you for you to comment on,
  criticize, or complain about. You may shoot our ideas
down from time to time, but we will keep coming
back to you with others.
  I have established a Division in my Office in
Headquarters that will work with you on managing
for environmental results. You have identified a
number of activities that my office, working with you
and other appropriate Headquarters and Regional
staff, should pursue. Let me try to summarize briefly
what those activities are.

Strategic Planning

Over the short term, we will be working with the
Assistant Administrators to prepare short, succinct —
probably no more than ten page — strategic plans
and guidance from  each AA that focus on how the
Agency is going to produce environmental results by
medium. Based  on your recommendations, these
strategies will take  a one to three year perspective.
Separate documents would be prepared by the Air
Program, the Water Program, and the Hazardous
Waste  Program, at  least.
  In  addition to that, OMSE  will prepare a short,
succinct, strategic plan for environmental results that
will integrate the work that is prepared by the AA's,
and that will add perspective on intermedia effects
and other issues that wouldn't be covered in a
presentation for a specific medium.
  It is possible to tie our budget guidance process,
our budget decision making  process, our operating
year guidance, and all those other things into an
integrated, coordinated whole. When I first came to
EPA, I looked at documents  which  display how the
Agency plans activities and allocates resources, and
there were obviously two  missing links. One is the
front end — planning and projecting into the future.
The other  is the back end, which is the accountability
system. That is, how do we know we actually
achieved those results? The accountability system
has been developed. Now we need to move to the
front end. And that may be the hardest task of all.
But we will work on that. All of you know that we
have to do this, because the Agency is changing. In
all of our programs, such as Air and Water, we are
taking on much more of a "stewardship" kind of role.
It is  not going to be our responsibility anymore to run
programs on a project by project basis. That is not
our role. We now have to be concerned  with
questions of oversight. And once we get into an
oversight mode  in those programs, that  has great
implications for enforcement and for abatement and
control decisions, and obviously for how we work
with the states.

Environmental Status Reports
We will be looking  for short, succinct
environmental status reports from the Regions,
probably state by state, like  Region 2 is  doing right
and an overall state-of-the environment summary of
the entire Region. We will work with you to ensure
that  there is some consistency in approach and in
what each Region presents, but if you have another
way to report Regional status, and overall it is con-
sistent with what other Regions are reporting, we will
try not to inhibit your creativity, or get in the way of your
describing best what is going on in your Region.

  We are not looking for a big tome. This is not a
redraft of the Profiles effort, necessarily. But the
Administrator does want a state-of-the-environment
report from each Regional Administrator and my
Office will work to integrate that report into an
overall state-of-the-environment report for the nation
as a whole.

An Improved Resource Allocation Process

In the area of resource allocation, my office will
work with the Administrator, the Deputy
Administrator and the Comptroller to improve the
resource allocation process so that it more directly
supports getting environmental results in the Regions
and in Headquarters. We will work to try to find a
way, if we can, to develop more incentives for
program managers to manage for environmental
results, where that can be shown. We want the
workload model process to show a bit more flexibility
than it does now.

Improved Accountability Measures

With respect to the accountability system, our
objective here is not to load you down with yet  more
to report. What we will try to do is to replace those
measures we have now that are basically "bean"
and "widget" counting with better measures from
the standpoint of environmental results.
  We will try to improve qualitatively, as opposed to
quantitatively, the kinds of environmental results
measures that are used in the accountability system.
Those measures, of course are what your Regional
Administrators and Assistant Administrators are
being held accountable for to the Administrator. This
will be possible in a number of places. For example,
in the enforcemen; area while we  may be starting
out reporting numbers of cases, administrative
orders, or compliance orders, we expect to move over
time toward reporting compliance rates, which of
course are the ultimate measure in this area.

Pilot Program Evaluations

In the area of program evaluations, we will identify
one or two pilot projects that the Program  Evaluation
Division of OMSE and the quality assurance portion of
the accountability system will work on which will high-
light and display environmental results.


We also may initiate a series of publications that
focus on current environmental results projects that
are going on in the Agency that are particularly
noteworthy and should be viewed by others in the

Better Indicators

Next, the question of  indicators of environmental
status and of environmental results. Over the short
term, I suspect it is a  case of cut and paste — of
making the best of what we have now. Obviously a
long term task is to get better indicators of status and
trends and better indicators of results. We will have
to identify and fill the data gaps that exist.
  We will have to start with the true environmental
indicators, the best surrogate indicators that we can
find, and the "beans and widgets" we need to
complete an environmental picture. We will initially
need to use a combination of ambient data, pollution
removal data, compliance data, and activity indicators
(the "beans" and "widgets"). Gradually we want to
move toward indicators that reflect the ultimate
impact of pollution and Agency actions on people,
wildlife, plants and the environment, but we know
we don't have that information now. And so we must
start where we can.

Improved Monitoring Strategies and Resource

Over the long term, we want to work with the
program offices — Air, Water, Solid and Hazardous
Waste, etc. — to  improve monitoring strategies and
monitoring  networks. OMSE has acquired  most of
the functions of the old DAA Committee on
Monitoring, which had responsibility for monitoring
policy and monitoring decisions for the Agency. In
addition, we hope to develop a strong relationship
with the Environmental Services Division and
Regional program division directors. We will also
work directly with Courtney Riordan and his staff on
improving quality assurance.
  One  of our principal objectives working with
Morgan Kinghorn and John Chamberlin, and others,
will be to produce up-front analysis and reports on
the status of our  existing monitoring networks, so
that the budget decisions that are going to be made
for FY 1984 in this coming year, will be made on the
basis of good knowledge of where we are  now with
regard  to monitoring and where we want to go.

Better Reports

We will also need to develop more effective ways
of reporting. And that too, is a long term task.
  We have  created a constituency with this meeting
for managing for environmental results in  this
agency. There were the last time I looked, about ten
thousand people  in EPA. We had about a hundred of
you here today, and yesterday, and the day before, so
one percent of the agency knows about what we plan
encourage working towards environmental results
right now. This is a small group, certainly, but as far
as I am concerned, one percent is enough to create a
critical mass, particularly when the Administrator*
herself is on board.
  What we have  talked about today in terms of long
term tasks or even the short term tasks, isn't going to
happen tomorrow, or next week, or even in a month
or two. Don't go back to your Regions and expect that
the world is going to be turned upside down for you
in one or two months. It won't happen. We will have
to proceed  carefully, cautiously, with a healthy
appreciation of the problems that are involved — the
problems that Fran Phillips articulated so well.
  We are going to follow the "KISS" principle of
"keep it simple, stupid".  We are going to move and
do what we have to do slowly and carefully. But let's
get out there and get the job done.


Sherron Hiemstra, Chief
Environmental Results Branch
Office of Management Systems and Evaluation

I would like to make three points. First, I would like
to thank you for coming to and staying at the
workshop. We appreciate that very much. We know
how tight the  travel budgets are both in the states
and in the Regional offices, and  had you not come,
we wouldn't have had nearly so successful a group.
Second, I would like to thank Lew for agreeing to be
the moderator for the full three days and keeping
everyone on track. For that he deserves a great deal
of thanks from us, which  I am sure he will extract in
some way.
  Finally, I would like to say that you haven't seen
the last of us. Please don't think that when you leave
that will be it. All of those things that Lew listed that
we are going to  do — are going to be done with you,
with your participation and with your input. And the
more participation the better, both in Regional offices
and in Headquarters. I think the  next thing that we
want to do very  early on, is going to be to go around
to all the Headquarters offices and try to make the
same kind of close contact with  those offices that we
have made with the Regional offices.
  In addition,  we want to work closely with the
states, and with other organizations and agencies
that we can learn from. We made a conscious
decision to have representatives of organizations
here but not to invite a whole range of state
representatives until we had a better idea of your
interests and concerns in the area of environmental
results. While we have certainly appreciated the
participation of the state people who joined us, we
have a lot of work with the states to do. We are
going to be calling on you to help us identify people
in your states with whom we should work.
  So, in closing, please keep in mind that you are
going to hear  more from us, and soon. You will be
getting copies of the proceedings of the workshop
along with the handouts that were made available
  Thank you for making this a very successful

   Appendix  I

   Managing for
   Environmental Results
   Tuesday-Thursday May 25-27,1982
   May 25





Coffee and Registration

Managing for Environmental
Results: What We Hope to

OPRM's Role in Managing for
Environmental Results
OMSE's Charge and Workshop

OMB Perspective on Managing
for Environmental Results
                                  Water Quality

                                                               Lew Crampton
    Presentations oh Innovative Approaches

    9:30-10:45    Overall Management


                Environmental Status Reports as
                the Basis for Negotiations with

                Joint Environmental Planning
                with Each State

    10:45-11:00   Break

    11:00-12:00   Air


                Reviewing Appropriateness of
                Monitoring Sites and Non-
                Attainment Designations

                The Emission Inventory as the Key
                to Managing Air Quality

                Integrated Data Assessment for
                Problem Scoping and Targeting

    12:00-1:30     Buffet Lunch
Dr. John Hernandez
Deputy Administrator

Joseph A.  Cannon
Assistant Admin-
istrator, OPRM

Lew Crampton
Director. OMSE

Jim Tozzi,
Deputy Administrator
Information and
Regulatory Manage-
ment, OMB
                              Lew Crampton

                              Kevin Bricke/Joann
                              Sullivan, Region II

                              Jim Lehr
                              Region VIII
                              Lew Crampton

                              Tom Holloway
                              Region VII
                              David Howekamp
                              Region IX

                              David Kee
                              Region V

Comparing Ambient Data with State Jack Hoffbuhr/lrv
Standards for Initial Problem

Using Ambient, Discharge, and
Flow Data for Preliminary Deter-
mination of Priorities

Use of Biological Information for
Water Quality Management

Drinking Water


Using Compliance Data to Target
State Activities and  Evaluate



Data and Information for Setting
Priorities and Targeting Resources

Region VIII

Myron Knudson
Region VI

Lee Tebo
Region IV
                                                                                                             Lew Crampton

                                                                                                             Myron Knudson
                                                                                                             Region VI
                                                               Lew Crampton

                                                               Harry Seraydarian
                                                               Region IX
                                  Program Presentations
                                  (30 minutes each — includes presenta-
                                  tion and brief questions and answer
Water Quality/Drinking Water




Social — United Way South Room/
Ramada Inn
                                                                Rebecca Hanmer, OW

                                                                Paul Stolpman, OANR

                                                                Rita Lavelle, OSWER

                                                                Don Clay, OTS

 May 26





Introductory Remarks
               The Potential for Using Biological
               and Public Health Data To
               Characterize the Environment
 9:00-10:00     Biological data

Public health data
What are EPA and State Roles
in Managing for
Environmental Results?

Presentation of Issues

Panel Discussion

Who should be responsible for
setting environmental priorities?

Who should be responsible for
whether desired results are

How should we best work with
the States to achieve environ-
mental results?
Buffet Lunch

Introductory Panel on Planning,
Resource Allocation, Ac-
countability and Evaluation


Resource Allocation

Accountability and Evaluation
                                                 Lew Crampton
                                  Tom Murphy,
                                  Research Laboratory,
                                  Corvallis, Oregon
                                                 Jacob J. Feldman,
                                                 Associate Director,
                                                 Office of Analysis
                                                 and Epidemiology
                                                 Programs, National
                                                 Center for Health
                                      Charge to the Workshops

                        2:15-2:30      Break

                        2:30-5:00      Simultaneous Workshops
                                      Discussing: How We Can Better
                                      Manage EPA Programs Using
                                      Environmental Information in
                                      Planning, Resource Allocation,
                                      and Accountability/Evaluation

                                      Availability of Environmental
                                      Information and Indicators.

                                      Adequacy of Ongoing Monitoring
                                      Activities to Provide Data.

                                      Adequacy of Data to Meet Program
                                      Management Needs.

                                      Use of Data for Planning, Resource
                                      Allocation, and Accountability/

                                      Concurrent Workgroups:

                        2:30-4:00      First Session:    A. Water Quality
                                                                                                          Lew Crampton
                                                                                                                        Chair: Jack Hoffbuhr

Lew Crampton
Steve Schatzow, OW

Bern Steigerwald,
David Gibbons, Chief
Branch, OMB
Gene Welsh, Chief,
Water Protection
Branch, Georgia
Department of Natural
John R. Spencer, RA
Region X


May 27

B. Air

Second Session: A. RCRA/Super-
B. Drinking Water

Introductory Remarks
Presentation of Workgroups
Findings on:
Water Quality
Drinking Water
General Discussion of Workgroups
Chair: David
Chair: Stephen
Chair: Myron Knudson

Lew Crampton

Lew Crampton
                                                John Wise, Region IX

                                                John C. Chamberlin,

                                                Billy Adams, Region IV
                                                Randy Smith,
                                                Region X
               Integrated Approaches to
               Environmental Assessments

10:30-11:00    Program Integration Project's
               Geographic Approach

11:00-11:30    Multimedia Assessment

11:30-12:00    Next Steps

                                                                        Mike Alford
                                                                        Program Integration

                                                                        Gary Young

                                                                        Lew Crampton

  Appendix II
   List  of  Attendees
   Environmental  Results
   Region 1
   Leslie Carothers
   Ed Coniey
   Paul Keough

   Region 2
   Herb Barrack
   Joann Brennan
   Barbara Metzger
   Dan Sullivan

   Region 3
   Peter Bibko
   Greene Jones
   Stan Laskowski
   Al Montague
   Steve Wassersug

   Region 4
   Billy Adams
   John Eagles
   Michael Lev!
   Ron Raschke

   Region 5
   Steve Goranson
   David Kee
   Beverlee Lawrence
   Shirley Mitchell
   William Sanders

   Region 6
   Ken Kirkpatrick
   Myron Knudson
   Fran Phillips

   Region 7
   Allan Abramson
   Billy Fairless
   Tom Holloway
   Rowena Michaels
   Gene Ramsey
   John Wicklund

   Region 8
   Irv Dickstein
   Tom Entzminger
   Jack Hoffbuhr
   Jim Lehr

   Region 9
   David Howekamp
   Michele Pla
   Sue Sakaki
   Harry Seraydarian
   John Wise

   Region 10
   Bob Burd
   Gary O'Neal
   Alex Smith
   Randy Smith
   John Spencer

Office of the Administrator
John Hernandez

Mike Alford
Ron Brand
Samuel Bryant
Kathleen Burke
Peg Burney
Joseph A. Cannon
Jean Caufield
John Chamberlin
Joanne Clark
Lori Cohen
Lewis S.W. Crampton
Bill Garetz
Sherron Hiemstra
Rena Kieval
Joan La Rock
Loretta Marzetti
Tim Matzke
Jim McCormick
Charles W. Murray
Alicia Rood
James Sanderson
Chris Scoby
Cleora Scon
Mark Tobey
James Vickery
Cheryl Wasserman
John Wilson

John Elliott
Carol Finch
Cynthia Puskar

Michael Brown
Colburn Churney
Sanford Harvey
John Lyon
Jim Nelson
Bill Peterson
Kathy Summeriee
Catherine Winer
Gary Young

Elizabeth Anderson
Donald Eh reth
Marvin Fast
William Lacy
Robert McGaughy
Tom Murphy
William Rosenkranz
Carl Shafer
Herbert Quinn
Sid Verner
James Chamberly
Rebecca Hanmer
Arnold M. Kuzmack
Fred Leutner
Edmond Notzon
Jim Plafkin
Tim Stuart
Peter Wise

Peter Cosier
Bill Hunt
Barbara Luden
Howard Right
Bernard J. Stiegerwald
Paul Stolpman
Robert Wright
Joe Carra
Don Clay
A.E. Conroy
Arne Edelman
Ed Johnson
Karen McCormack
Jake McKenzie
Judy Nelson
Marsha Ramsey
Paul Shapiro

Truett DeGeare
George Earland
Bruce Englebert
William Hedeman
Barry Korb
Rita Lavelle
Gene Lucero
Carol Schwab
Outside EPA

Office of Management and Budget
Rob Fairweather — Budget Examiner, Environment Branch
Dave Gibbons — Chief, Environment Branch
Terry Grindstaff — Budget Examiner, Environment Branch
Jim Tozzi — Deputy Administrator for Information and
                   Regulatory Management

General Accounting Office
Clarence Seigler — GAO Evaluator

State Agencies
Lyn Eichmiller — Association of State and Interstate Water
              Pollution Control Administrators
Leonard Ledbetter — Director, Environmental Protection
                 Division, Georgia Dept. of Natural
Gene Welsh — Chief, Water Protection Branch, Georgia
            Department of Natural Resources

National Center for Health Statistics
Jacob Feldman — Associate Director, Office of Analysis
               and  Epidemiology Programs
Kate McGuire — Chief, Environmental Studies Branch,
              Office of Analysis and Epidemiology Program

Council on Environmental Quality
Dinah Bear — Deputy General Council
Nancy Nord — General Council

List of Participants

Water Quality Workgroup
Allan Abramson
Billy Adams
Frank Andrews
Rick Brandes
Kathleen Burke
Bob Burd
Leslie Carothers
Lori Cohen
Edward Conley
John Elliot
Thomas Entzminger
Billy Fairless
Marvin Fast
Carol Finch
Sherry Hiemstra
Jack Hoffbuhr
Kenton Kirkpatrick
Myron Knudson
Arnold M. Kuzmack
Joan La Rock
Stanley L. Laskowski
Robert E. McGaughy
Barbara Mitzger
Al Montague
Beverlee Lawrence
Michael H. Levi
Loretta Marzetti
Robert E. McGaughy
Barbara Metzger
Al Montague
Tom Murphy
Gary O'Neal
Bill Peterson
Michele Pla
William A. Rosenkranz
Carol Schwab
Paul Shapiro
Tim Stuart
Daniel Sullivan
Sid Verner
Gene Welsh
John Wise

Air Workgroup
Bill Garetz
Steve Goranson
Jim Hammerle
Tom Holloway
David Howekamp
Bill Hunt
Dave Kee
Paul Keough
Jim Lehr
Tim Matzke
Rowena Michaels
Shirley Mitchell
Gene Ramsey
Cleora Scon
Alex Smith
Bern Steigerwald
Richard J. Sullivan
Jim Vickery
Cheryl Wasserman
Robert Wright

RCRA/Superfund Workgroup
Billy Adams
Kathleen Burke
Edward Conley
Elizabeth Cotsworth
Irv Dickstein
John Eagles
John Elliott
Carol Finch
Steve Goranson
Sherry Hiemstra
Tom Holloway
Paul Keough
Barry Korb
Stanley L. Laskowski
Jim Lehr
Loretta Marzetti
Robert McGaughy
Jake McKenzie
Rowena Michaels
Barbara  Metzger
Albert Montague
Tom Murphy
Gary L O'Neal
Fran Phillips
Gene Ramsey
William Sanders
Harry Seraydarian
Paul Shapiro
Alex Smith
Randy Smith
Daniel Sullivan
Richard Sullivan
Sid Verner
Jim Vickery
Cheryl Wasserman
Stephen Wassersug
John Wilson
John Wise
Robert Wright
Drinking Water Workgroup
Allan Abramson
Bob Burd
Lori Cohen
Thomas Entzminger
Bill Garetz
Jack Hoffbuhr
Kenton Kirkpatrick
Myron Knudson
Arnold M. Kuzmack
Beverlee Lawrence
Michael H. Levi
Tim Matzke
Shirley Mitchell
Michele Pla
Gene B. Welsh

   Appendix III

   Billy Adams, Deputy Director
   Environmental Services Division
   Region 4
   Clean Water

   Uniform WQS
   and Associated
   fund — H.W.

   H.W. Site
   of Monitoring
Evaluation Measure
• Percent of total miles of water
bodies with fishable use classification
or higher.
• Miles of major water bodies with
fish and wildlife use classification
or higher.

• Miles of major water bodies with
use classification less than fish and

• Number of states with current,
acceptable WSQ.

• Number of revisions to WQS.

• Number of states with comparable use
classifications with associated criteria.

• Miles of WQ limited stream

• Number of WLAs/TMDLs completed
for each basin.

• Number of revisions necessary to
update ambient WQ monitoring program.

• Number of wastewater treatment
plants with acceptable plant

• Number major POTWs constructed
with Federal funds providing secondary
treatment or better.

• Miles of major water bodies affected
by discharges from industrial facilities.

• Miles of major water bodies effected
by discharges from POTWs.

• Number of major non-point sources
causing WQ degradation.

• Miles of stream segments affected
by non-point discharges.

• Number of waste landfills contributing
to WQ degradation.

• Percent of hazardous waste landfills
under a management control plan.
• Number of sites for primary/
secondary evaluations.

• Number of hazardous sites with
groundwater contamination potential.

• Number of hazardous waste sites
causing WQ degradation.
and fate of
toxic pollutants

of acid rain
  Number of pollutants evaluated.
• Percent of U.S. affected by acid rain.

• Number of acid rain monitoring
systems established.

• Number of lakes with aquatic life
significantly effected by acid rain

Appendix IV

List of  Questions
Considered  by Workgroups
The participants in each workgroup at the workshop
on managing for environmental results were asked to
discuss, for each program, and make recommenda-
tions on the following questions:

• whether management systems are currently in
place to allow the Agency to manage for
environmental results and, if not, whether changes
in the systems should be made—i.e., in each
program area, what are the tools available or needed:

  — to define environmental goals for clean-up or
prevention of degradation in specific geographic

  — to translate these goals into  short and long-
term objectives that achieve environmental results;

  — to allocate resources to those activities that will
have the greatest environmental results;

  — to select indicators to track progress and/or
success in meeting these objectives;

  — to use the indicators to periodically evaluate the
programs' progress/success in meeting these
objectives; and

  — to redirect program activities  if necessary.

• whether the Agency has the data it needs to
manage for environmental results  in the program;

  — are current monitoring activities in the program
sufficient to obtain the data that will provide the best
information on environmental status and on
environmental results?

  — what significant data gaps are there? What
other problems are there with data collection and*
analysis in the program?

• What the best indicators of environmental status
are for the particular medium.

  — what additional work is needed to develop these

• what the  best indicators of environmental results
are for the particular medium.
• how and by whom information from data collection
and analysis should be reported.

  — written/printed reports, oral presenations, or

  — individual program reports or centralized report?

  — by state, by Region, or nationwide?

  Appendix V

  Briefing  Package:
  Environmental  Results
   Ramada Inn
   Alexandria, Virginia
   May 25-27, 1982
   Environmental Results Branch
   Office of Management Systems and Evaluation
   Environmental Protection Agency

   May 17, 1982

• Purpose of the workshop

• What's in the package "

• OMSE's Next Steps

Managing for Environmental Results: Current Regional
Activities, Issues and Proposals

• Overall Management

• Air Quality

• Water Quality

• Drinking Water

• Superfund

Each of these sections is divided into the following areas for

— Current Regional Activities

A. Planning
B. Technical Decision-Making
C. Resource Allocation
D. Evaluation
E. Accountability

— Issues

— Proposals

This package presents background material that was
distributed prior to the Environmental Results Workshop
that was held May 25, 26 and 27, 1982.

Purpose of the Workshop

The Environmental Results Workshop is designed so that
senior managers:

• will be more aware of what tools have already been
developed throughout the Agency to manage for
environmental results;

• will jointly identify further opportunities to focus Agency
efforts on  environmental results; and,

• will develop a consensus on what direction the Agency
should now take to further  manage for environmental

What This Package Provides

The Office of  Management  Systems and Evaluation laid the
groundwork for the Workshop by soliciting ideas and
proposals  from senior managers on how the Agency should
move toward  managing for environmental results and by
visiting each  of EPA's Regional offices to identify current
activities to use environmental data for program manage-
ment. This package highlights the current activities, issues,
and proposals included in the responses to our inquiry and
that Regional staff raised during our visits.

The package contains:

• a  description  of  currrent  Regional  efforts  to  use
environmental data for overall management of their programs
and and a summary of related issues and proposals; and

• an individual program section for Air, Water, Drinking
Water, RCRA, and Superfund that describes current
Regional activities to manage for environmental results in
each program, identify specific issues regarding use of data
in the program, and present Headquarters and  Regional
managers' proposals for better incorporating environmental
data into management of each program.

In each of these sections, the material on current activities
is organized according to the major program  management
functions  of the Agency — planning, resource allocation,
technical decision making, accountability and evaluation.
We grouped the activities in this way to help identify
particular  aspects of Agency and program management
that need  to be strengthened.
We have been impressed both with the extent of the
efforts already under way to manage for environmental
results and with the support we have received. We have
found that while environmental data  have been used  in the
planning phase of many programs, the data are used  to a
lesser degree for accountability and evaluation. And
because of the nature of the budget process,
environmental data have not been used to allocate
resources among Regions based on the nature and extent
of the environmental programs needed in each Region.

Obviously, we were not able to include in this package
every idea or activity that we encountered, but we hope at
least to begin the exchange of information to set the
general direction for the discussions at the workshop, and
to uncover additional activities and ideas.

OMSE Activities After the Workshop

The Environmental Results Branch will serve as a focal
point for promoting environmental results activities within
the Agency.  In this capacity, after the Environmental
Results Workshop, the Branch will follow up with
Headquarters program offices, the Regions,  and the States
on activities identified in the workshop that  would
contribute to the Agency's ability to manage for
environmental results.

Some of the activities we may pursue are:

• Working with the program and  Regional offices to
identify the best indicators  for  assessing environmental
status and environmental results;

• working with the program and Regional offices to
coordinate the preparation of Environmental Status Reports
for FY '82;

• working with the Office of the Comptroller to determine
how environmental status and trends can best be
incorporated into the budget process;

• working with the OMSE Accountability Branch to
develop goals, objectives, and measures for  the
Administrator's Accountability System to track
environmental results; and

• providing support to Agency efforts to improve collection
and analysis of environmental  data.

  Overall  Management

  Activities,  Issues, and

  Proposals to  Manage for

  Environmental  Results

  This section identifies current Regional activities to
  manage all of the Region's activities with an environmental
  perspective, and  presents those issues and proposals
  Headquarters and Regional managers made regarding
  overall management of the Agency and its programs from
  an environmental results perspective. These activities,
  issues and proposals were identified during ERB's Regional
  visits and in the  responses to OMSE's request for ideas on
  managing for environmental results.

  Current Regional Activities

  • Regions use State-EPA agreements to highlight and set
  environmental priorities.

  — Region 8 sets SEA priorities using environmental
  data. This has been most successful in the Water Program,
  where the ESD has developed an analytical methodology
  for using ambient water monitoring data to identify stream
  segments that are possible problems and to assign initial
  priorities among  them.
  — Region 2 develops an environmental status report (ESR)
  for each state. The ESR identifies environmental problems
  and then  uses that information as the basis for State/EPA
  Agreements. The Region prepared two ESRs and expects
  all the states in the Region to prepare them in the future.
  The ESRs at this time are more of a narrative than a
  graphic presentation, but the Region intends to move to the
   use of more graphics and less narrative in future reports.
  — Region 10 uses SEAs as mutual performance
  agreements based on a negotiated list of 25 problems in
  each state. The Region has requested that each state
  prepare an environmental assessment as a precursor to
  the SEA development process this year.
  Some Regional planning systems focus on long-term
  environmental objectives.
  — Region 10 has instituted a system to identify long
  term (3-5 year) environmental goals with specific one
  year objectives and to track progress on those goals. The
  goals and objectives are revised annually; activities are
  tracked quarterly. The objectives of the tracking system
  are explicitly put in managers' performance agreements.
     The basic cycle for the Region 10 system is as follows:
  — A retreat for senior managers is held each October
  to review long-term environmental goals (e.g., all areas
  in attainment in  three years); these goals are usually
  couched in the language of environmental problems.
  — Individual prog'rams develop short-term objectives
  or "administrative targets" that they believe will allow
  them to meet the long-term goals. These are tracked
  — The goals are  also used in the SEA negotiations for
  the coming year (10 months  in the future).
  The system is evolving. Region 10 staff ultimately want
to move to yearly objectives more directly linked to
environmental results, such as ambient quality or
intermediate measures of ambient quality (e.g., polluter
compliance levels).

• Regional Operating plans will be used to focus on
environmental  results.

— Region 10 is experimenting with drafting the highlight
statements for each program's operating plan in the
language of environmental results. The purpose is to add
specific environmental objectives into the plan. As a pilot,
two or three programs in the Region have developed results-
oriented highlights for the FY '83 operating plans. The
highlights will refer to goals and objectives in the Region's
tracking system and to items identified by the

• Development of a Regional  strategy for environmental

— Senior staff in Region 5 met recently to discuss how
to incorporate an environmental results focus into the
planning  of Regional program  activities. The Regional
Administrator established an environmental planning
committee consisting of representatives of each program
office in the Region to develop a strategy for environmental
planning  in FY'83. Media coordinating committees are set
up to develop workplans based on the priorities in the

• Coordination of Regional ambient monitoring activities.
— In December, Region 2 completed an internal study
on "The Use of Ambient Monitoring Data in Regional
Decision-Making." This report made several recommenda-
tions that are now being implemented. These recom-
mendations include the establishment of a Monitoring
Management Branch to better coordinate ambient
monitoring activities and to improve the quality of
monitoring data.

• Initiation of a pilot geographic approach to an  integrated
assessment of toxics problems.

— Region 3 participated in a pilot study that EPA
headquarters conducted of the toxics problems in the
Kanawha Valley of West Virginia, particularly in the City of
Charleston, West Virginia. Region 3 participated in
identifying sources discharging to the area, modelling the
discharge from  these sources,  and assessing the  impacts
of different ways to control for toxics problems.

• Development of an Enforcement Strategy to Focus on
Cases with Greatest Potential forlEnvironmental Results

— Region 2 is developing an enforcement referral
strategy to focus on cases which would result in the
greatest public health and environmental benefits. This
effort applies to all enforcement activities within the

Technical Decision-Making

• Development of multimedia  data bases.

— Region 2 is working to integrate two data systems,
the Facilities Index System (FINDS) and the Region's
environmental mapping system (MAPS) so that the

 integrated data base can be better used for a variety of
 decisions, including design of monitoring programs and
 targeting of enforcement actions.

 — The ESD in Region 10 has been working for two
 years on a multimedia data base which, when  completed,
 will integrate all available environmental, demographic,
 industrial facility, and chemical process information and
 display it by geographic area. The effort was initiated in
 order to set up a toxic priority pollutant monitoring  system
 for (surface) waters. In the last year, the focus  was
 broadened from toxics to include a multimedia  assessment
 of water quality data.

 Region 10 staff are currently working on a joint project
 with Oregon to develop an operational multimedia data
 base. The project will pull together ambient data, source
 data, and biomonitoring data, as well as narrative
 descriptions of water quality from the literature and from
 field investigation.

 • Evaluating the Use of Environmental Indicators.

 The ESD in Region 2, 4, and 6 have formed a task force to
 evaluate the use of environmental indicators as measures
 of management effectiveness.

 Accountability/ Evaluation

• Review of priority areas

 — Region 4 is preparing reports on changes which have
 occurred in priority areas which were intensively surveyed
 in 1972. One Regional staff person is going back through
state files to compare pollution levels in 1972  to current
 levels. One report — on the Birmingham,  Alabama area —
 has been drafted so far.

 — Region 3 would like to collect samples from the
 Monongahela River to compare new data  with the data
collected in the priority basin study in 1972-1973 but has
very few resources for this effort.

• Development of a Regional Accountability System —
Region 7

— The Regional Administrator in  Region 7 has asked the
 Planning and Management Division to design an
evaluation/accountability system to evaluate EPA and
state progess in improving environmental quality as a
means of getting beyond "bean-counting". To develop the
system, the Division has asked the states  what measures
are appropriate to judge the success of environmental
control programs. One of the states' major suggestions
was to have joint State/EPA audit teams conduct program
audits of the Region's as well as the States' performance.

• Publication of annual environmental quality  reports

— Region 1 publishes a "Regional Administrator's
Annual Report: Environmental Quality in New England" at
the end of each calendar year. The report  is a narrative
summary of Regional  activities in every EPA program with
some graphics to display the status of the enviornment by
media. Major problems are also identified.

The report is primarily intended as a public information
document, but is also useful for the Region as a
mechanism to force the programs to collect and assemble
data and to demonstrate results from year to year.
Overall  Management Issues

During ERB's Regional visits and in the responses to
OMSE's request for ideas and proposals on managing for
environmental results, EPA managers raised a number of
issues that they felt need to be resolved as part of the
Agency's effort to manage for environmental results.

• How Can We Resolve the Apparent Conflict between
Environmental Results and Other Agency Policies?

Managing  for environmental results was perceived to be  a
policy that conflicts with  several other priorities of the

— Delegation to  the States. Once a program is
delegated, how can EPA  promote managing for
environmental results? Who will be ultimately held
accountable for environmental results? What is the role of
EPA vs. the States?

— Reductions in monitoring resources. Managing for
environmental results depends on data of adequate quality
and such data is often expensive to obtain. State agencies
conduct most of the ambient monitoring required by EPA,
and EPA funds a substantial  part of the state monitoring
programs through grant  funds. Because state grant funds
are being  reduced, states are cutting their expenditures for
monitoring activities. EPA has not  provided guidance as
to what monitoring should be continued.

EPA has also made cuts  in Headquarters expenditures for
monitoring activities. Headquarters and Regional  staff felt
that in some cases these cuts were made arbitrarily, and
without a careful look at  what data we actually need.

— Reduced Reporting Requirements. Can  we maintain a
a policy of reducing the reporting burden on the states and
at the same time expect to get environmental information
we need to manage for environmental results?

— Making State-EPA Agreements Voluntary. Those
Regions that have made  progress in managing for ER have
tended to rely very heavily on the SEA process as the
principal method for planning and  tracking progress to
correct agreed-upon environmental problems. Can the
Regions as effectively use this mechanism to promote
managing for ER now that the SEA process is voluntary?

•  There Is Too Little Long-Term Planning. The Agency and
individual programs lack an Agency-wide planning process
to identify major environmental problems and trends,
describe long range plans to deal with them, and establish
near term objectives (1 -2 years) by which senior managers'
performance can be tracked. Regions reported that they
can not plan—that they  are forced to do "fire fighting,"
responding to problems  on an ad hoc basis.

• Administrator's Accountability System (AAS) Focuses on
Numerical Quotas, Not the Environmental Impact of
Activities. Both Regional and Headquarters staff were
concerned that the AAS currently  reports against numbers
of activities completed without taking into consideration
that some activities may take longer and be more difficult
but, if completed, will have greater environmental impact
than easier activities. They urged that somehow the AAS be
modified wherever possible to reflect the  environmental
importance of the activities tracked.

   An example of how this might be done was provided for
   the SIP process. One Region suggested that reports on the
   completion of SIPs should give some weight to their impact
   on the environment—that SIPs that would have the
   greatest environmental impact should  get priority attention
   when backlogs were being reduced, etc. Regional staff said
   that the way the accountability system is now designed, it
   encourages the completion of the easiest SIPs first in order
   to make a numerical quota. This concern also applied to
   other program activities.

   • Programs Are Not Evaluated Against their Environmental
   Results. Headquarters and Regional staff indicated that the
   Agency does not routinely evaluate the environmental
   success of its programs, and that we need to develop
   agreed-upon indicators of environmental success and then
   evaluate our programs against them. One problem in doing
   this that was raised was that environmental results often
   take a long time to show up.

   • Environmental Results Must Include Preventing
   Environmental Degradation.  Definition and assessment of
   "environmental  results" must not only take into account
   pollution abatement, but also consider how successfully
   EPA prevents environmental degradation and maintains
   current environmental quality where it is already good.

   •  We Need to Increase the Credibility of EPA's Technical
   and Scientific Knowledge. Managing for environmental
   results largely depends upon the credibility of the Agency's
   technical and scientific knowledge. If the public doesn't
   trust  EPA's technical competence to determine that a given
   problem  presents little risk, and therefore warrants a low
   priority, EPA will have trouble getting  public acceptance of
   its priorities.

   • Problems with Data Systems Foil Managing for
   Environmental Results.

   The Agency's systems for storing data have a number of
   problems that hinder their capability to provide timely data
   for environmental results management.

   — We need to create incentives for states to put data
   into our.data systems, and to put the data in a timely way.
   This is particularly true of the STORET system, which some
   states do not use at all.

   — There is a need for better procedures for generating
   and transmitting data in order to decrease the delay from
   data collection to input into ADP systems.

   — There are too many independently  managed data
   systems. As a result, data frequently can not be integrated
   and interpretation of the complete range of data available
   to us is difficult.

   • Surrogate indicators do have value. Senior staff in a number
   of Regions urged that the Agency not totally abandon existing
   surrogate indicators of program progress in favor of
   dependence solely on ambient measures of environmental
   status and improvement. They feel that many surrogates are
appropriate and useful although they do have to be used in
combination with more direct measures of environmental

• Data Interpretation Is Tricky.

Environmental monitoring data must be carefully

In the Water program, for instance, information about the
location  of the fixed station monitors must be considered
so that naturally occurring conditions are not
misinterpreted as being controllable pollution and
expensive treatment plants are not built unnecessarily.

ERB staff were also cautioned not to try to integrate data
from every study that has ever been done to  get a picture
of environmental status. Regional staff pointed out that
one-time studies done for specific purposes can not be
used wholesale to draw general conclusions  about the
entire country.

• EPA Must Know How To Interpret Information to the
Public and Be Prepared to Commit Resources to Solve
Problems Once We Identify Them.

EPA is increasingly in the business of going into a
geographic area to determine what pollutants are present
and whether there  is an imminent danger to  the public.  In
many instances, we find the presence of substances that
we know are hazardous in certain quantities, but that we
have no present standards for. We do not know what their
presence at that concentration means from a public health
or environmental standpoint.

What do we tell the public when we know there are
concentrations of chemicals but do not know what harm
they may cause?

The Regions raised this issue to highlight that, in trying  to
document environmental status, we need to be extremely
careful not to unnecessarily alarm the public, and that,
when we do go into an  area, we must be willing to follow
up on any problems that we do identify.

• The Budget  Planning Process Does Not Explicitly
Consider Environmental Problems and Allocate Resources
on that Basis.

Regional staff consistently raised the concern that the
budget process does not currently look specifically at what
environmental problems exist in the states in each Region
and allocate resources based on those problems. They said
that we currently allocate resources on the basis of
historical patterns rather than actual environmental
problems.                   »
Once Regions have their Regional allotment of resources,
they say that they have little flexibility to allocate resources
to the real environmental problems in their Regions
because National Program Managers expect  them to
allocate their resources to activities in accordance with  the
workload models.
• Federal Budget Development is Out of Phase with State

— The State budget is set before Regional targets (State
fiscal years begin in July) and the Regional targets are
therefore too late for use in Regional negotiation of State
problem priority and resource commitments.

 Proposals for Managing the Agency for
 Environmental Results


 • Each RA should be accountable to the Administrator for
 reporting environmental problems and anticipated and
 actual environmental results.

 — Managing for environmental results will work best
 when each Regional Administrator and Assistant
 Administrator is held accountable to the Administrator for
 reporting to her on their existing environmental problems,
 what they plan to do to correct them, and the extent of the
 improvement in environmental quality achieved. Such
 reporting could be included in their performance appraisals
 and be tracked in the accountability system. To implement
 this system, the RAs and AAs would meet with the
 Administrator to describe the expected environmental
 results from specific proposals and to evaluate the previous
 year's commitments and achievements (or lack of achieve-
 ments). (Region 10)

• Revive the concept of "Media Strategies"

— These strategies, which the Agency used in 1974, would
be developed by National Program Managers to identify major
environmental problems, to describe their  long range plans
(10-20 years), and to establish short-term (1 -2 year) objectives
 which would be tracked. Previous attempts got too long and
 bogged down in detail,  but if the strategies were strictly
 controlled they would provide a mechanism for relating
 performance measures with environmental goals. (OAQPS)

 •  Use the Evaluation Planning Mechanism to manage for
 environmental results (Standards and Regulations Division,

 — The Office of Standards and Regulations developed an
 Evaluation Planning System to lay out a strategy for
 collecting information about the manner of implementation
 and the effects of newly issued regulations. This method
 could be adapted to program planning. The method lays

 1. the program logic—i.e.,  its assumptions and

 2. a plan which can be used for evaluating success (or
 results), i.e., the degree to  which expectations are
 fulfilled and,

 3. indicators for possible inclusion in the Administrator's
 Acountability System.
 •  Rely on source data as well as ambient and
 ultimate impact data to evaluate environmental status.

 — Source data can indicate when a facility is out of
 compliance (i.e., polluting the environment beyond its
 allowable level) and can be used for ranking facilities in
 accordance with problem priorities. Activities such as
 inspections, development of some monitoring  strategies
 and technical assistance would be performed with the
 intent of bringing existing facilities back in compliance. The
 environmental results attributed to their compliance status
 could be modelled and subsequently used as a measure in
 determining a program manager's performance. (OANR)
• Prepare Two Volumes of National Profiles.

If national profiles are prepared again, one Region
recommended that we prepare two documents. The first
would be a graphic summary of environmental quality and
trends for public distribution. The second would be a
technical description of the data  and method used to
prepare the first document. This  would be useful for
managers. (Region 5)

Resource Allocation

• The agency should focus on activities with the greatest
environmental impact.

For example, for those activities which yield low-level,
indirect environmental results, often called "program
results", the Agency can:

— apply decision methods (such as benefit cost analysis,
risk assessment, and cost effectiveness studies) to specify
the level of results appropriate to those activities.

— redirect program management toward higher level
results through budget and policy guidance.

— "Lock-in" policy decisions regarding acceptable levels
of results by lowering funding priority of low-result
program activities during the budget formulation  process.
We can also assign a "discount" factor to the pricing  of
these activities in the workload models. Activities with
more demonstrable and immediate environmental results
would thus be more heavily weighted and would receive a
higher percentage of requested resources than other
activities. (Region 8)
Technical Decision-making

•  Existing data systems could be used to design
monitoring programs and to target enforcement actions.

— The Agency should integrate FINDS (Facility Index
System) and MAPS (Environmental Mapping System) —
two general purpose software packages developed by
Region 2 — to use existing ambient source and permit data
to track ambient problems back to likely sources, to identify
potential "hot spots" and to target compliance efforts to
sources in the most significant geographical problem areas.
(Region 2)

•  As appropriate objectives and measures  of "environ-
mental results" are developed for each program, they
should be added to and tracked as part of the
Administrator's Accountability System.


•  "Success stories" were recommended as a way to
demonstrate environmental improvements.  Regions would
submit success stories when they had events to report —
such as beach re-openings, shellfish  harvesting returning
to an area, or a once-polluted river being  able to once
again maintain a fish population.

•  One Regional manager recommended that we look at the
indicators that groups like the Sierra  Club and the National
Wildlife Federation use,  and  use those as our indicators of
environmental status and results.

  Air  Quality

  Managing for Environmental Results:
  Current Activities, Issues,  and Proposals

  The Air program is, by statute, oriented towards managing
  for environmental results. The program uses ambient air
   monitoring data to designate geographic areas as in
   attainment or not  in attainment with air quality standards.
   State Implementation Plans (SIPs) are the principal
   planning tool required by the Clean Air Act for the
   implementation, maintenance, and enforcement of air
   quality standards. In SIPs, states provide strategies for
   bringing geographic areas that do not meet ambient air
   quality goals into compliance with air quality standards by
   1982 and for keeping them in attainment after that time.
   As part of their SIPs states are to indicate how they plan to
   to make reasonable further progress towards attaining air
   quality standards in areas where they are not currently
   meeting the  standards. SIPs are also to show how states
   plan to prevent the significant deterioration of air quality in
   areas which are  cleaner than the ambient air quality
   standards require.
     Other parts of the Air program, while they do  not use
   ambient air quality as directly, nonetheless are tied to long-
   term ambient improvements. New Source Performance
   Standards (NSPS) have as their long-term goal the
   establishment of  a national base of industries with good
   pollution controls, thus minimizing future air pollution
   problems. In the short term, NSPS provide a minimum
   national standard which allows State and local
   governments to protect their environment without fear of
   losing industry and jobs to states with more lenient
   environmental standards.  In addition, EPA sets NSPS
   priorities according to the quantity of pollution emitted by
   candidate source categories and the extent to which such
   pollution may reasonably be expected to endanger public
     ERB staff found that in some Regions, air data are used
   not only to designate non-attainment areas, but also to set
   priorities among non-attainment areas and to identify
   monitoring needs. The extent to which each Region uses
   environmental data to set priorities and  to identify
   monitoring needs varies. A few Regions are calling upon
   the States to give them Reasonable Further Progress (RFP)
   reports toward showing how they plan to attain  air quality
   standards in non-attainment areas and what improvements
   they have made.
     In our visits we found general agreement among the
   Regions that emissions data can be used to evaluate short
   term progress and ambient data can be  used to  determine
   trends and long term progress. We also  identified  a
   number of current environmental results-related activities
   in the Air program. Highlights of these activities are
   presented below.

   Current Regional Activities — Managing
   for Environmental Results

   This section  discusses the Regions' current use  of
   monitoring data for program management. We have
   current activities in this Section around  the major
   management activities they support — planning, technical
   decision-making, resource allocation, and accountability
   and evaluation. We summarize only the  activities that were
highlighted during the initial inquiry conducted by the
Environmental Results Branch; there may be other efforts
under way that we are not aware of.


• Regions use air data to set Air program priorities in

  — Regions use air quality data to negotiate specific Air
program priorities as part of their SEAs. (Regions 8, 9, 10).
Several other Regions use the SEAs as more general
agreements or for highlighting multimedia problems.

  — At the annual senior managers' retreat in Region 10,
long term (3-5 year) priority goals are set  and then
incorporated into the SEA negotiations. States also provide
a list of key problems to be negotiated for inclusion in
SEAs. Based on the agreements in the SEA, each division
then sets one year objectives for its operating plan.

• Ambient data are  used to identify serious non-attainment
areas that may require specialized control strategies or
additional resources.

Region 5's Air Division has initiated a comprehensive study
of pollution in several major non-attainment areas. The
first (to be completed Spring '82) is a study  of TSP in
Detroit. The goals of the study are: 1) to develop a
systematic way to compile and present data from all
available sources, including population data, ambient
information, source  information, and enforcement actions,
in order to better define problems on a geographic basis; 2)
to determine the relative contribution of dischargers and
other factors (e.g. plant closings) to the decreasing TSP
trends; and 3) to develop revised program and enforcement
strategies where called for.

•  Regions are developing control strategies to target
resources where they are most likely to achieve  further
environmental results.

Region 9 staff are working with the states in their Region
to focus on reducing ozone levels because,  in Region 9,
ozone is the pollutant that exceeds the standard by the
greatest margin and affects the largest number of people.
In contrast, they have found that SO2 and NO2 problems are
very localized and that CO can only be corrected through
car emission controls and inspection and  maintenance
(I/M) programs.

• Regions are beginning to plan control  strategies for
for non-criteria (i.e., air toxics) pollutants.

— Region 3 is supporting the City of Philadelphia's plan
to assess the extent of the air toxics problem and define an
appropriate control strategy.
 — Region 1  is forming an air toxics workgroup of EPA
 and state officials to assess state activities, to identify
 additional actions needed, and to define EPA/state roles.

 Technical Decision-Making

 • Some Regions are improving the presentation of air data
 in their Air Quality Reports so that it is more useful to
 program managers for decision making.

 Most Regions prepare air quality status and/or trends
 reports. The reports differ substantially in purpose.

frequency, and content. The reports are used for different
purposes in different Regions. In ERB visits, Regional staff
identified the following uses for the reports:

1) Showing location of ambient air monitors and
evaluating appropriateness of current monitoring locations.

2) Indicating air quality trends for criteria pollutants;
  — numerical quantification of the extent of changes
  — indication of "up or down" trends

3) Indicating violations;
  — source
  — ambient

4) Evaluating the size of populations affected by

5) Ranking problem areas;

6) Evaluating need for changes in attainment designations.

The most significant developments  ERB staff identified for
using Air Quality Reports to help managers use the
information they contain are:

  — Computer mapping and graphics capability in
Region 9. Among the graphics Region 9 staff produce are:

1) Three dimensional state maps which plot air quality at
each monitor location.

2) Graphs indicating the number of days above NAAQS
alert levels and the population of the affected area.

  — Monitoring Activity Coordination (MAC) Reports in
Region 7 that identify what monitoring is being done in
each State. These reports contain:

1) A map showing the location of current monitoring
stations overlaid with maps showing population density
and emission density. This gives the Region  a basis for
determing if presently unmonitored areas should be
monitored for standards violations.

2) A map showing the violation status of monitored areas.
Using this information, the Region can review siting of
monitors in areas that meet the standards, and decide
whether to discontinue monitoring at those sites, or move
monitors to another site.

3) A map showing current non-attainment areas is overlaid
with a map showing areas where current standards
violations are occurring. The Region uses this information
to evaluate whether geographic areas currently designated
as non-attainment areas are consistent with current
violations data.

  — The Region 5 ESD has developed computer packages
to map an integrated picture of ambient air and emissions
data and to summarize ambient air  quality status and
trends. The computer program the ESD has developed
ranks air quality in counties based on:  population, point
and area emissions by pollutant, the number of violations,
current attainment status, and source compliance.

• In some Regions a  strong working relationship between
between the Air Division and the Environmental Services
Division promotes use of data for decision-making.
  — The Air Coordinating Committee in Region 7 meets
monthly and is chaired by the Air Program Branch Chief.
Members include staff from ESD, Air Compliance Branch,
and Planning and Management Branch. The Committee
plays a key role in setting air program priorities and making
key Air program decisions. In this way ESD can develop
data analysis to meet decision makers' needs. For example,
at the request of the Air Branch, ESD did a careful
validation of the monitoring data for Kansas City and
discovered errors on the high side. As a result a much less
stringent SIP was possible.

  — In Region 3, close cooperation between the Air
Program Branch Chief in Air and Waste Management
Division and the Air Branch Chief in ESD has resulted in
identification of major problems due to local anomalies
near the monitors that produced the original "'design
values" for three non-attainment areas. Much less
stringent SIPS are now appropriate.

• Collection of ambient air data are accompanied by
stringent quality assurance requirements.

There is strong agreement in all Regions that since the
National Air Monitoring System (NAMS) and State and
Local Air Monitoring Systems (SLAMS) criteria were
established, the air monitoring  data are of much higher
quality; except for limitations due to the strong influences
of meteorology and the limited  number of stations, the data
do provide a good assessment of air quality against air
quality standards. The Regions said this improved quality is
is in part because, in the Air program, quality assurance is
required by regulation.

Resource  Allocation

• Limit Monitoring to Critical Months — Redirect the
the Resources Saved

Region 7 has worked closely with its states to make
extensive use of program guidance that allows monitoring
to be limited to critical peak months in which violations
have historically occurred. The  Region is working with
states (particularly Kansas) to cut back monitoring for
ozone and CO to these peak months to eliminate
unnecessary monitoring expenditures. Saved resources are
being re-directed to other monitoring in other critical areas.

Accountability and Evaluation

• To evaluate air pollution control strategies, ERB staff
found general agreement in the Regions that:

  —Emissions data should be used for evaluation of short-
term progress.

  — Ambient data should be used to determine current
status and verify long-term trends.

• Two Regions reported working closely with States to use
emissions data to track short term progress of SIPs through
Reasonable Further Progress (RFP) Reports.

  — RFPs in Region 7 are prepared annually by each state.
They include: 1) a list of point source and area source
emissions for each criteria pollutant, and 2) graphic
analyses of emissions reductions projected in SIPs and
actual emissions reductions. State reports vary in quality;
Region 7 is working with  each  state to update emissions
inventories to get as accurate data as possible.

     — Region 9 plans to develop RFP tracking as its principal
   tool for managing the air program. The Region is taking
   that approach to ensure: (1) that state efforts to develop
   new rules continue to focus on classes of sources that
   have the greatest potential for achieving emission
   reductions;  and (2) that emissions reductions projected at
   the time that a new rule is adopted are actually achieved.
   Where field observations of the state program  indicate that
   the projected reduction is not being achieved, EPA will
   work with the state to upgrade the effectiveness of state
   compliance efforts (e.g., through better training of state
   inspectors). Where efforts to improve the compliance with
   a current rule are ineffective, the Region will work with the
   state to develop a new, more enforceable rule for that class
   of sources.

   Air Issues

   The issues  below were raised by Headquarters and
   Regional managers in their responses to OMSE's request
   for ideas on managing for environmental results and by
   Regional staff during ERB's visits.

   • What indicators best assess short term progress in
   improving air quality?

   — Can methods to correct ambient data for year-to-year
   meterological variances be developed?

   • What indicators best assess the effectiveness of efforts
   to improve  air quality over the long term?

   • How frequently should Regions update attainment and
   non-attainment designations based on current ambient and
   emissions data?

   • Can we further reduce the number of monitoring sites or
   change their location without jeopardizing the  usefulness
   of the data?

   • How can EPA demonstrate environmental results in air
   toxics given that there are no historical data, no general
   agreement  on what pollutants are of concern,  no accepted
   sampling techniques, and no strategy or systematic
   approach for addressing these pollutants?

   •  Should Regions be given greater flexibility to allocate their
   resources in the Air program and focus on their  particular
   environmental priorities even when their decisions may not
   conform to national procedural requirements? For example,
   will Region 7 be able to divert resources from processing the
   Iowa SO2 SIP since SO2 is not a problem in Iowa, Iowa
   SO2 emissions do not contribute significantly  to national
   long-range transport totals, and the SIP processing will be
   very staff intensive for the Region?

   • Should EPA review what pollutants we are not
   successfully controlling and then consider shifting
   resources now going to those pollutants to other  areas?

   —  For example, even with the implementation of various
   control strategies, there has been little or no reduction in
   ambient ozone levels and many areas remain in non-
   attainment. Would the funds used to pursue environmental
   results for ozone (i.e., reduced levels) be better spent on
   other pollutants? Without the current level of activity on  ,
   ozone, would VOC emissions and ozone levels be likely to
   increase significantly?
— Should analysis of risk and compliance cost be
required for both criteria and "hazardous" pollutants so
that the Agency could determine which could be most
easily controlled and result in the greatest reduction of

• States have been responsible for collecting emission
inventories for many years but the quality of most of the
inventories is questionable. What would be required to
achieve adequate emission inventories to track
environmental  results?

The following proposals were offered in response to
OMSE's request or were mentioned by Regional staff
during ERB's visits.

• Indicators to measure environmental results in Air:

— Select priority areas for quarterly trends reports based
on ambient data; at least 5 years of data would be
necessary to develop a reliable assessment of trends
(Region 1).

— Publish an annual report on the number and size of
non-attainment areas (Regions 1 and 4).

— Report the number of SLAMS and NAMS not in
violation (Region 2).

— Report the number of AQCRs in attainment (Region 2).
— Report the number of stationary sources in
compliance (Region 2.)

• Track Air  Quality using Ambient Data and Emission
Modelling (Region 8).

EPA is not systematically tracking the most direct
measures of effectiveness  in the air program — ambient
air quality and changes in total emissions — for specific
non-attainment areas. Region 8  staff proposed that:

  — To assess progress in specific non-attainment areas
in the short term, EPA could track changes in total
emissions for that area but regular reports from major
sources would be required. Some states already collect this
information. Colorado uses Air Contaminant Emissions
Notices (ACEN) from  major sources.

  — Ambient data could be used to verify progress over
the long term.

•  Revamp the System of Incentives and Sanctions (OANR).

  —  Most incentives now  are for-'hnstallation of equipment;
there are few incentives for proper operation and
maintenance or for compliance with emissions limits.

  —  Effluent charges could stimulate greater efforts to
reduce emissions. As with municipal sewer charges, a
regular notice or bill would encourage  reduction.

Water  Quality
Managing for Environmental  Results,
Current Activities, Issues and Proposals
 The Office of Water developed and implemented a Water
 Quality Management and Evaluation (WQM) System in FY
 82 that provides an integrated view of the entire Federal
 and state water quality management program. The system
 will be expanded in FY 83 to include Drinking Water. The
 system will then cover all programs in the Office of Water.
 One of the key objectives of the WQM System is to show
 environmental results.
  The WQM System highlights the importance of
 managing for environmental  results in two ways. First,
 environmental results-related activities are included in the
 goals, objectives and priorities by which Regional offices
 are annually evaluated. For instance, specific evaluation
 measures will focus on:

 • Improvement of 305(b) reports — to encourage states to
 use the reports as a management tool for setting water
 quality priorities to focus on:  1) water bodies with the
 greatest water quality problems in terms of impaired water
 uses, 2) water bodies having a  high existing or potential
 economic or social value, and 3) water bodies with
 problems such that the greatest margin  of environmental
 protection can be provided for the resources expended.

 • Implementation of the revised water quality standards
 regulations — to encourage  states to rely more heavily on
 biological data and local  environmental data for establishing
 water quality criteria and standards and  to evaluate existing
 stream use  designations  and  the extent of current use

 • Development of updated  permit strategies —  to issue
 permits and work with states to  issue permits  to facilities
 discharging to areas where  water impairment  exists or is

 • Tracking effectiveness of POTWs — to complete "before
 and after studies" to  analyze water quality improvements
 from funded projects.

 • Development of monitoring strategies — to assist states
 in designing monitoring systems to collect information in
 order 1) to identify priority water bodies, 2) to collect data
 to make standards and TMDL decisions,  and 3) to establish
 cooperative sampling and analysis programs with local,
 state, and Federal participants.

 Second, the WQM System includes Case Studies  prepared by
the Regions as part of their annual review. The Case Studies
 delineate how  a Region manages its  programs  to solve
 specific water quality problems  in  a  specific  geographic
  In undertaking all of these activities, the Office of Water
 is moving towards relying on biological data for assessing
 water quality. The Aquatic Life Survey, which is being
 conducted by EPA and the Fish  and Wildlife Service, is the
first national effort of this kind.
  In addition, the Office of Water  is preparing an FY 83
 Operating Year Guidance and Accountability System. The
 guidance will articulate several  national  directions that will
require or encourage Regions and states to undertake
activities that will emphasize consideration of
environmental results in program decision-making.


  In OMSE's inquiry to the Regional offices to determine
how the Regions use environmental data to manage for
environmental results, we found that in a number of
Regions, there have been substantial efforts to improve
environmental data and to use the data as the basis for
water program planning. Environmental data are most
often used for indicating which stream segments are
potential problems. The systems developed thus far rely
primarily on ambient data from fixed monitoring stations.
Since the new thrust from HQ is to incorporate biological
data into water quality decisions, it is likely that the
Regional planning efforts discussed in this section will be
revised to give less emphasis to fixed station data and
more to incorporating biological data where possible.
Nevertheless, these systems do provide formal procedures
by which Regions are identifying potential problem areas.
  Regions are working to improve their technical decision-
making  capability through  development of biomonitoring
programs and evaluation of their monitoring needs. We also
found that a few Regions have begun to evaluate state water
quality programs. These activities are discussed  in the
following section.

Current Regional Activities  — Managing
for Environmental Results

This section discusses Regions' current use of monitoring
data for program management. We have grouped activities
in this section around the major management activities
they support—planning, technical decision-making,
resource allocation, accountability, and evaluation. This
section summarizes only the activities that were
highlighted during the initial  inquiry conducted by the
Environmental Results Branch.


A number of Regions have developed  systems to use
environmental data to identify Water program priorities.
These systems are, for the most part,  based upon ambient
data from fixed monitoring stations that measure the
concentrations of chemicals  in the water. Given the fact
that the  Office of Water is moving away from chemical
criteria to the use of biological data for decision-making,
we anticipate that the Regions will revise their systems to
incorporate biological data as it becomes available.

Methods the Regions are using to identify water problems,
set priorities, and design strategies to make improvements
are presented below.

• Consolidating  Planning Documents for Urban Areas

Region  3 has  consolidated into concise documents all past
planning documents for each of four Standard Metropolitan
Statistical Areas (SMSAs):  Baltimore; Washington, D.C.;
Philadelphia; and Richmond. The documents characterize the
current water quality problems, identify the highest priority
problems,  make specific recommendations, and provide a
consolidated schedule of all  major program actions in each
SMSA. The reports are being used as examples for states to
follow in consolidating  available planning information for
specific  geographic  areas   with water quality problems.
Although these are called  SMSA Plans, they are  to be

   assembled wherever there are water quality problems, not
   just in areas designated as SMSAs by the Census Bureau.

   • Using Schematic Mapping by Stream Use Designation to
   Evaluate Water Quality Trends

   The Region 4 Environmental Services Division (ESD) has
   undertaken a program to map all streams by the use
   designations for which they currently qualify. This system
   is relatively simple and can be used both to assess trends
   over time (in terms of changes in use designations) and to
   identify sites where onsite inspections should be conducted
   to investigate why some changes have or have not
   occurred. For each map the Region will:

   — show the use classification of each stream reach and
   indicate the specific location of monitoring  stations;

   — evaluate the number of streams and stream miles
   meeting the goals of the Clean Water Act;

   — assess the reason for a change in classification by
   reviewing the ambient data from the stations on the
   stream segment or by undertaking field studies.

   • Identifying Legislative Mandates and Objectives for
   Environmental Results Planning

   In Region 5, the Water Division  staff emphasized that data
   on environmental status cannot drive program activities—
   that you must begin with legislative mandates and program
   objectives. Only when such mandates and  objectives are
   agreed to can Regions and States manage for environ-
   mental results. Environmental data would be used to
   identify priority areas within the legislative mandates and
   objectives. With this in mind, the Water Division has
   outlined for each  Water program (construction grants,
   drinking water, water quality management) the legislative
   mandates and specific environmental and management
   objectives and  measures for each program. Regional staff
   are meeting with  state staff in each state in the Region to
   refine and reach agreement on specific environmental and
   management objectives for each state. The agreed-upon
   objectives will be the basis for all of the Region's activities
   with the states, including negotiations on delegation and
   development of State-EPA Agreements.

   • Piloting a Water Quality Management System for State

   In Region 6, the Environmental  Services Division,
   Management Division, and Water Division  have worked
   together to develop a water management system (WMS)
   which  uses ambient, point source, and non-point source
   data within a state to actively plan and manage all aspects
   of the water quality program. The WMS is  now being used
   by two  Region 6 states. A brief explanation of the WMS

   —  Compare ambient water quality data to state standards.
   Three to 5 years of ambient data from STORET is summarized
   and compared to  the appropriate state standard at each fixed
   station  to  determine  where   persistent violations  are

   — Screen data for significant problems. The analyzed
   violations data  is  run through a  series of "screens" to
   eliminate violations that are not "significant."

   — Rank order problems. Monitoring stations or stream
   segments are ranked to produce preliminary priority lists of
   water quality problems within each state.
— Identify potential causes. Potential sources are
identified by conducting a computer and file searching for
discharges and nonpoint source contributors in the
watersheds upstream from significant problem areas. A
variety of data bases are used in conducting this search.

— Produce maps. Maps are prepared for each state
showing the location of monitoring stations and of
significant violations. Acetate overlays are produced
showing the location of potential point and nonpoint source

— Develop state action plans. The results of the data
analysis and mapping are used in planning and evaluating
in the municipal wastewater, industrial effluent and
nonpoint source programs.

• Analyzing and Using Computerized Data to  set SEA

— In Region 8, the ESD Division, Environmental
Services Division (ESD), Water Division and the states have
worked closely together to improve the collection, analysis,
and reporting of water quality data and to use the analysis
to identify priority areas for highlighting in SEAs.

— Data Entry and Validation.  Regional staff work with
the states to ensure that they enter water quality data into
STORET. The states also validate the data to ensure proper
entry into the computer.

— Improved Data Analysis. ESD uses a computerized
system to compare ambient measurements of pollutant
levels in STORET to individual state water quality
standards. A standard methodology is used to determine
the frequency and severity of standards violations and to
indicate which possible designated uses of the stream
segment may be impaired. Information at each station is
analyzed for all possible uses, not just those uses for
which the segment has been designated. For each possible
use, the analysis includes only those parameters known to
affect that use.

— Standardized Analytical & Statistical Methods for
Data Analysis. ESD publishes annual trends reports of
STORET data and regularly distributes computer  printouts
of the analyzed data to the states for their use in preparing
their 305(b) reports. Analytical and statisticals methods for
305(b) reports are thereby standardized throughout the

— Problems are Highlighted in SEAs. The states and
EPA use the reported STORET data to identify possible
priority problem areas. The states then adjust the priorities
based on additional, explicit considerations and the state
and Region then, as part of the SEA process,  develop
strategies and allocate resources to address  high priority
water quality problems.

• Using a Multi-media Data Base to Identify Problem Areas
and Take Action

Region 10 is refining a multi-media data base that will be
used to develop monitoring and compliance strategies,
identify problems and conduct trends analysis. For
instance, they intend to use the system to target sites for
compliance inspections or facilities requiring tighter
controls. Where ambient data or narrative stream
assessments show that there  may be significant use
impairments, the Region will tap a variety of sources of
information about potential contributers to the problem.

This approach will allow them to focus on cleaning up
specific problem stream segments, even if only "minor"
sources are present, rather than simply going after "

"majors" or focusing only on large downstream areas where
results may be difficult to achieve. Region 10 has designed
its system using a combination of the Region 2 FINDS
computer system and the national STORET system.
Technical Decision-Making

• Biomonitoring or intensive survey data is being used
extensively for identifying water quality problems in some

Region 1 has a long history of emphasizing the use of
intensive surveys over stationary ambient monitors and has
received good cooperation from its states. A list of planned
intensive surveys is codified in the 106 grants as a result
of negotiations between the Region and each state. The
Region principally provides technical assistance but has
taken a more active role when more than one state is
involved. Several of the states do publish the intensive
survey data in hard copy but it is not entered into STORET.

— Region 4 has had a very strong  biological monitoring
program and has encouraged the development of
biomonitoring programs in each of the states in the Region
(all 8 states now have biomonitoring programs). There are
two basic functions of the  Region 4 biological monitoring

1) to provide technical support for investigations of site-
specific problems, and

2) to provide technical  assistance, training and backup to
develop biomonitoring expertise in the States.

The Region is preparing a Standard  Operating Procedures
manual for biomonitoring procedures, and for quality
assurance of biomonitoring data. The manual will be
distributed to all of the states as a guide for their
biomonitoring programs.

— Region 10 has devoted considerable resources to
specific problem sites identified by the states in the Region,
such as the Spokane River. They emphasize that success is
dependent upon up-front commitment to intensive surveys
to identify correctly the inevitable site-specific anomalies in
each problem area and upon careful assessments to
determine the probable implications of these anomalies.

— Until recently, biological monitoring  data were not
used by Region 7. The Region's Environmental Services
Division is now working on a pilot study with Kansas to
incorporate bio-screening into the state's ambient
monitoring network.

— Staff in the Planning and Management Division in
Region 7 have a small effort under  way to explore potential
sources of biological data, such as the State Fish and
Wildlife agencies.

They are looking first at the availability of data from the
Missouri Department of Fish and Wildlife, which has a long
history of using field techniques to assess the "health" of
fish populations.

• Evaluating Different Water Quality Models

— Region 10 staff have been evaluating water quality
models of different levels of complexity  to evaluate what
improvement in accuracy is gained by using models of
different levels of complexity. In general, they have
concluded that certain relatively simple models are
remarkably accurate and, if used instead  of more complex
models, can save considerable resources. The only
exception to this result is in systems with key organisms
having high "birth rates" (e.g., systems with rapidly
growing phytoplankton).

• Determining Monitoring Needs

— Region 4 staff are supportive of a concept developed
by Tennessee to decide whether to conduct fish tissue
analysis. The state prepares a list of all potential problem
areas, ranks them (based on population, permits, location
of industrial sources, etc.), and sites as many stations as
resources allowed, starting at the top of the list. If analysis
consistently shows no contaminant levels of concern, the
station will be discontinued; a new station will then be
established at the next ranked potential problem area on
the  list.
— Region 7 has developed Monitoring Activity
Coordination Reports (MAC) to define data needs for each
state in the Region.

— The Region prepares reports for each state that
contain the following descriptive information for each
water quality basin: a geographical description, the  major
dischargers and recent violations,  existing surface water
supplies, waste disposal sites, non-point sources,
suspected sources of toxic substances, and the location of
fixed monitoring stations.

— The Region analyzes the data to determine the
adequacy of the states' fixed station monitors  (e.g.,  number
of parameters  monitored and frequency of monitoring).

— The Region then notes the parameters violating
standards in each sub-basin with an indication of the
frequency and severity of each type of violation within the

— The ESD has found significant variation in  the
monitoring being conducted by each state in the Region
and  is  beginning to work with the states to determine
where  additional monitoring or different parameter
coverage is needed.

— The ESD is discussing ways to prepare a concise
summary of the data in the MAC report because the ESD
and  the Water Division agree that the current MAC reports
for water monitoring are too voluminous  to be useful to the
Water  Division.
Resource Allocation

• Distribution  of 208 Funds Based on Negotiated Problems

Region 10 requested that each state submit proposals to
correct priority problems using 208 funds (they planned on
receiving more requests than  money was  available). The
Region then negotiated with each  state on the projects to
be funded. The Region considered the likelihood of success
and  the commitment of local government  to implementing
the project when selecting proposals for funding. Only the
most viable projects were funded.  Although there is no
longer  a 208 program, these experiences  may be
transferable to 205(g) and 205(j) activities.

  Accountability or Evaluation

   • Annual Report Tracks Multi-Year Problems

   Region 1 water quality information comes from the 305(b)
   reports and is reported in  the RA's annual report. The
   annual report continues the format from the 305(b) reports
   and includes maps of "critical water quality areas" which
   track outstanding  multi-year problems, such as PCBs in the
   Housatonic River and contamination in Boston Harbor.

   • Study of NPDES Discharges

   Region 4 staff conducted  a study to compare the most
   recent available data from a select group of NPDES water
   dischargers to compare levels with those in 1972. They
   found a singificant reduction in the amounts of wastewater
   discharged. The Division felt this was a good indication of
   success but stressed that discharge reductions do not
   necessarily indicate improvement in environmental quality,
   which must be tracked  separately.

   • Region 5 has initiated an evaluation of the Illinois
   municipal compliance strategy in an attempt to link
   program activities to improved water quality. A pilot will be
   initiated this summer in Chicago to evaluate the
   effectiveness of the State's program by comparing permit
   compliance status over time with trends in ambient water
   quality. The results will be used to redirect program
   activities where appropriate.

   • Environmental Results  Demonstration Projects Required
   in 106 Grants Supplemental Guidance

   Region 4 directed each state, as part of the supplemental
   guidance for the 1982 Section 106 Grants, to conduct
   demonstration projects to evaluate the effectiveness of
   actions taken with 106 money. These are basically before
   and after monitoring studies which could be short-term or
   multi-year in  length. For example, Georgia is evaluating  the
   effectiveness of a spray irrigation project to reduce
   eutrophication in the Flint River. These  reports will be
   completed in  FY 82. No supplemental guidance will be
   prepared for FY 83; therefore, requirements for the projects
   will be discontinued.

   Florida has indicated that they plan to expand this program
   on their own  in FY 83.

   The issues below were raised by Headquarters and
   Regional managers in their responses to OMSE's request
   for ideas on managing for environmental results and by
   Regional staff during ERB's visits.
   — The emphasis from the Office of Water in
   Headquarters is to use  biological data for decision-making.
   While Regions generally agree that biological data need  to
   be incorporated into decision-making. Regions are also
   concerned that the Agency not totally abandon fixed
   monitoring stations or disregard the large amount of
   ambient data currently available since they think we  need
   historical data for trends and since they believe ambient
   data are often needed to  interpret biological data.

   — Do states have the capability to do biological
   monitoring? If not, should EPA take steps to develop their
• How severely will a lack of baseline data on toxics inhibit
efforts to determine the environmental results of current
and future toxics-related activities in the water program?

• Should existing major/minor industrial classifications be
revamped to place greater emphasis on site specific
environmental considerations?

• BIO-STORET, a subset of the STORET system for storing
biological data is strongly supported by many Regions,
particularly as the new emphasis in the water program is to
move towards the use of biological data. However, BIO-
STORET is still in a pilot testing phase, and resources are very
limited for implementation. Does the Agency  need to
provide more support for BIOSTORET in light of our
increased emphasis on biomonitoring?
• Should the new 305(b) guidance set detailed data
reporting requirements and specify a standard format
states should follow so as to facilitate preparation of Regional
or National water quality summaries?

The following proposals were offered in response to
to OMSE's initial request for ideas and  proposals as to how
the Agency should manage for environmental results or
were mentioned by Regional staff during ERB's visits.

• Possible Indicators to Measure Environmental Results in
the Water Program
— Track stream miles meeting fishable/swimmable
water quality using class "B" designated waters from
305(b) reports. This would require the development of
national guidance for 305(b) data collection and
presentations. (Regions 1 and 4)

—  Track results of biological monitoring (Region 1);
assemble data from periodic biological monitoring of key
stations. (Region 4)
—  Institute routine before-and-after monitoring and
reporting as  a requirement of each state grant or
construction grant. (Region 1)
—  Collect information on direct indicators, e.g., return of
sport fish to rivers,  number of beaches  reopened, acres of
shellfish harvesting areas reopened. (Region 1)

— Update with current data the  Priority Basin Studies
done in the early '70's:

  1) to determine the extent of and the cause of change
over the last decade—i.e. with an "evaluation" focus
(Region 3),

  2) to determine the extent of remaining problems (Region 4).
—  Use the National Water Quality Index (WQI) to assess
levels of conventional pollutants. (Region 2)

— Track the reduction in sources violating
NPDES/SPDES. (Region 2)
—  For toxics in water, establish  a routine fish tissue
analysis and macro-invertebrates program  at key stations
(Region 2)
• Develop New Strategies that Focus on Environmental
Results (Region 2).

— Develop a permit issuance strategy which considers
public health and environmental effects.

— Develop a state oversight strategy for NPDES and
Construction Grants that focuses on environmental results.

— Develop a long-term strategy that would require the
identification of waterways where standards are not being
met and where improvement can be gained by source
control. Evaluate the effectiveness of Agency expenditures
by looking at where the major commitments are being
made, and whether resources are being directed to
activities from which the most environmental benefit is

• Shift from the Calendar Approach for Permit Reviews to
Management by Hydrologic Basin (Region 4).

— EPA currently plans to reviews permits on a set
schedule, e.g. NPDES every 5 years.

— Instead EPA could review all water classifications,
standards, and permits simultaneously for a given
hydrologic basin under a master schedule that  would
ensure that all basins are reviewed in a 5-to-10 year

— This alternative approach would allow concurrent
examinations of current water quality, stream use
classifications, and standards to ensure that permits limits
throughout the basin were reasonable and consistent from
one program to another.

• Develop a Sequential Plan for Identification and
Abatement of Water Quality Problems (Region 8).

1) Improve the process for designating the intended
beneficial use of each stream segment.

2) Ensure that the standards are protecting each and every
beneficial use of the segment.

3) Identify segments where the standards are not being
met or where uses are not being protected and determine
the probable cause. (This would be done using  STORE! as
well as data from other sources such as the Corps of
Engineers, States, the U.S.  Fish and Wildlife Service, etc.)

4) Ensure that State and Federal resources are targetted to
the same segments where water quality problems are
indicated (best done through negotiated SEA process).

5) Conduct adequate intensive surveys within  the priority
segments to measure improvement.

6) Evaluate improvements and revise the priority list to
close the planning/implementation loop.

• Conduct a Regional Analysis of 305(b) State Water
Quality Reports

— Regions should take responsibility for  performing the
Regional analyses of the states' 305(b) Reports. The
Regional analysis could form the basis for the 305(b) (2)
report to Congress, as well as the water portion of
Regional "Status of the Environment" reports. (Office of
Drinking Water:  Public

Water Systems

Managing for Environmental Results:
Current Activities, Issues, and Proposals

The  Drinking Water  program has two  primary functions:
ensuring the quality of  public water systems (PWS) and
preventing contamination of underground sources of drinking
water from injection  wells.  The program also responds to
incidents  of  serious contamination  of ground  water,
particularly from volatile organic compounds (VOCs). Both the
drinking water and the underground injection control (UIC)
program  can  be  delegated to the states  with  technical
assistance and oversight by EPA.

  The principal measure of program effectiveness for
drinking water is the level of compliance of public water
systems. The National Primary Drinking Water regulations
established maximum contaminant levels (MCLs) for
biological and chemical contaminants, monitoring
requirements for public water systems, and specifications
for acceptable analytic methods for contaminant level
determinations. Systems report violations of the MCLs and
failure to conduct the required monitoring. Because
noncompliance with drinking water standards means that
there is an unacceptable risk to public health, the primary
goal of the programs is to  reduce noncompliance.  Priority is
to be given to serious health hazards determined by the
toxicity of the contaminant, the size of the public water
system, and the degree to which the standard is exceeded.
No formal criteria are used to rank non-compliant PWSs.
Headquarters prepares an annual compliance report which
describes the compliance rate for all PWSs nationwide and
the change in compliance  rates for the past fiscal  year.

  The UIC program is now being implemented. The
regulations have been promulgated and the major effort
this year is to implement the program and delegate it to
the states. The primary monitoring requirements for the
UIC program are 1) that existing wells get mechanical
integrity tests, and 2) that wells near injection wells be
evaluated as possible sources of contamination of
underground sources of drinking water.

Current  Regional Activities — Managing
for Environmental  Results
This section discusses the Regions' current use of
monitoring data for program management in the Drinking
Water Program. We have  grouped current activities in this
section around the major  management activities they
support-planning, technical decision-making, resource
allocation and accountability and evaluation. This section
summarizes the activities  that Regional staff highlighted
during the initial inquiry conducted by the Environmental
Results Branch; other efforts may be  under way that we
are not aware of.

• Regions use violation data from public water supply
systems to identify problem areas and set priorities.

— In Region 8, states submit quarterly reports on public
water system violations to the Region. The Region uses the
data to identify problem systems which require informal

   (warning) or formal (enforcement) actions. Priority problems
   are highlighted and tracked in the SEAs the Region
   develops with each state.

   — In Region 8, the Drinking Water staff works closely
   with Construction Grants staff to ensure that locations and
   design of publicly owned treatment works will not threaten
   drinking water supplies and to ensure that discharge
   permits are such that downstream  water is protected. This
   is an informal process, but one the Region says has
   worked well.

   — Region 3 is looking at new approaches to setting
   enforcement priorities within the program. Two types of
   information that will play a key role in setting priorities are:
   population served and systems with persistant violations.

   — Region 6 conducted an  analysis of the compliance
   data PWSs reported to identify drinking water compliance
   problems and set priorities for working with the states to
   resolve. The Region found  that most violations occurred in
   small systems. They had health districts in each state focus
   on enforcing against small systems with multiple
   violations. Regional staff noted that as the health districts
   began to focus on those multiple violators, the number of
   violations at that system decreased and the number of
   violations overall decreased. Three states will conduct their
   own analyses using this system this year.

   The Region 6 study revealed 5 main  problems which were
   generally present in every state  in the Region; (1) small
   systems have most of the violations, (2) each state has one
   or more particular types of violations (bacteriological MCL,
   bacteriological M/R) which accounts for a majority of the
   violations, (3) repeat violators (two or more violations)
   account for a large portion of the violations, (4) non-
   compliant systems rarely notify the public, and (5) more
   aggressive enforcement actions for recalcitrant violators
   are generally needed.


   • Region 3 plans to compare violations data from the past
   two years.

   RegJon  3 meets with the states in the Region frequently
   and the states submit annual reports that include the
   number of violations, the number of enforcement actions,
   etc. In the Spring of 1982, they plan  to compare two years
   of violation data.


   • What indicators should be used to assess environmental
   results in the drinking water program?

   • In states where there are few  injection wells, should the
   Regions have flexibility to use the UIC funds for other
   groundwater problems?


   • Proposed Indicators to measure Environmental Results

   — Track the number of violations of the parameters for
   which monitoring is required. (Region 1)
Resource  Conservation  and

Recovery  Act

Managing  for Environmental Results
Current Activities, Issues and Proposals
The Resource Conservation and Recovery Act (RCRA)
requires EPA  and the states to establish a nationwide
program to ensure the safe handling, transportation, and
disposal of hazardous wastes. To implement the program
EPA and the states must know what hazardous wastes are
being produced, track the activities of transporters of
hazardous waste, develop permit standards for treaters,
storers, and disposers of hazardous waste and monitor
these facilities for compliance with the standards.
  Because the RCRA program will be so dependent on
accurate information on the amount and type of waste
produced, how much waste is disposed of, and the manner
of disposal, managers both  in Headquarters and in the
Regional office indicated that having good data will be
critical to the  program's success. The question they are
now asking is, how much data do we need to collect, and
who — EPA or the states — should collect it?
  Initial draft  regulations for the RCRA program required
that producers of hazardous waste, transporters, and
managers of treatment, storage, and disposal facilities
submit detailed annual reports showing the type and
number of pounds of hazardous waste generated,
transported, stored, treated, or disposed of. However, the
Agency is concerned that we were creating too much of a
reporting burden on persons dealing with hazardous waste
and that EPA  would not be  able to handle the voluminous
information that would be generated by such reporting
requirements. It is likely that EPA will only collect the
annual report for one year.  Revised  regulations call for EPA
to conduct an annual survey of a statistically valid sample
of generators and hazardous waste facilities  to determine
available capacity for proper disposal, the extent of waste
reduction due to  recycling, reuse, and recovery; and the
extent to which wastes are being managed properly. EPA
will also do some field evaluations of the program.
  Although EPA may change its annual reports
requirements. Regional staff told ERB that many states
have indicated that they will require such information from
generators, transporters, and disposers. At this time there
are no arrangements, though, for states to share their data
with EPA or to summarize the information for the Agency.

Current Regional Activities — Managing
for Environmental Results
This section discusses the current use of monitoring data
for  program management. The Regions pointed out that
environmental data are used primarily for two major
management  functions—planning and resource allocation—in
the RCRA program.
   — The easiest way to look at groundwater quality would
   be to look at fluoride, nitrate, organics, etc., in public wat
   systems that use groundwater.


• Environmental data are used to set priorities for RCRA
permitting in some Regions. The sites which are deemed to
pose the greatest risk and the highest potential for
improvement receive priority.

—  Region 8 emphasized the site-specific data play a role
in setting priorities for calling in Part B of a RCRA permit.
Factors considered in setting priorities include the
presence/absence of secondary containment; location
within/outside a flood plain, the previous history of the
site, (i.e., general quality of operations, compliance history),
the degree of hazard of wastes in the site, etc.

Resource Allocation

• Facility information is coupled with environmental data
to target inspections.

— In Region 1, the Systems Analysis Branch of the
Administrative Services Division is using a software
program developed by Region 2 — FINDS (Facility Index
System) — to integrate  information in the RCRA inventory
of generators, haulers, and disposers, with other facility
information from permit, compliance, and construction
grants activities,  etc. to target potential hot spots for
inspections. Regional staff are currently loading the
Region's RCRA data into the computer. Once that is done.
Regional staff intend to look for facilities where data
points  "cluster"  These facilities will become priorities for


The issues below were  raised by Headquarters and
Regional managers in their response to OMSE's request
for  ideas on managing for environmental results.

• Is the RCRA program planning to collect sufficient data
to assess environmental results on a national basis?

— With present  proposed rulemaking to  replace the
requirement for annual reports for hazardous waste
generators, transporters, treatment, storage and disposal
facilities with a statistical survey of facilities, some RCRA
staffers are concerned that EPA will not have a clear fix on
the size or nature of the hazardous waste problem or how
to judge success in dealing with the problem.

— Regional staff consistently said that the proposal for a
survey of a sample of hazardous waste sites is an
inadequate substitute for the annual reports; that we can
not take a good sample from an unknown universe.

• What are good indicators of environmental status and
results in the RCRA program?

— In the last environmental profile exercise, the RCRA
program  used the number of pounds of waste going to
approved landfills as a measure of program success.
Region 6 staff said that this was misleading, however, as it
made states that have less strict criteria for land-fills look
better than states with  more stringent approval criteria.

• Is it possible to measure the effectiveness of prevention?

— Regional staff said that the development of good
indicators of success under RCRA will be difficult since the
program  is geared to preventing adverse  environmental
— Results are likely to show up long after program actions.

• EPA is not adequately planning for collection, treatment,
and disposal of leachate from municipal landfills. Without
considering the likely environmental impact of this
leachate, the program is not fully considering the
environmental results of the current program.

— Given the current RCRA regulations, some staff have
expressed the concern that EPA is achieving short-term
improvements in that hazardous wastes will be disposed of
in "high tech" landfills, but that we are not  moving to
control potentially hazardous leachate from municipal
landfills. In twenty years or so this could be  a tremendous
problem both technically (how to treat the leachate) and

• Does the grant formula for RCRA need to  be changed if
we are to  manage for environmental results?

— The grant formula takes into consideration the volume
of hazardous waste produced in a state, but does not
consider whether the waste is being disposed of within or
outside the state. Thus, it does not adequately reflect the
true potential for adverse environmental results that the
State faces. Also, there is no consideration in the formula
for the hazard of the waste.

• The small  generator exemption under RCRA C may pose
environmental hazards because small generators  may
comprise a substially higher percent of the universe of
generators than the Agency is currently aware of, and thus
large quantities of hazardous waste will not  be disposed of
in accordance with the disposal requirements required for
all other hazardous waste.

— In the RCRA C regulations, there is a small generator
exemption which exempts generators of less than 1000
kg/month of hazardous waste from complying with the
stringent wastes disposal requirements in Part C. Instead,
the small generator waste is controlled under Part D which
allows the small generators to dispose of the waste in
sanitary landfills.

— A related issue is that if the small generator waste is
not adequately controlled under RCRA, it may lead to
additional  sites under Superfund.


• Possible Indicators to Measure Environmental Results in
the RCRA  Program.

— track the  quantity of hazardous waste generated
based on a statistcal sample. (Region 1)
— track the  total volume of hazardous waste produced
(although EPA has suspended reporting requirements,
many States say they will continue to require this data).
(Regions 4 and 6)

— the number of sites which experience post-closure
problems could  be tracked over the  long term. (Region 6)

— track the capacity for or actual number of pounds of
hazardous waste going to high technology incinerator
facilities as a measure of safely treated waste. (Region 6)

— track the number of facilities, incinerators, and
transporters found to be out of compliance. Distinguish
between instances of substantive non-compliance and
administrative non-compliance. (Region 1)

— track the amount of waste escaping the manifest
system. Use data on manifest exemptions, amount and
type of unmanifested waste, and extent of manifest
discrepancies discovered by the states. (Region 1)

— Track the reduction in the number of sources. (Region 2)

— Track waste recovery rates. (Region 7)

• Set Priorities in the Hazardous Waste Program Based on
More Extensive use of Available Information

  — Reconstruct how much hazardous waste was and is
being produced, preferably based on annual reports. In this
assessment, we need to look at which industries use
and/or produce chemicals of concern. Under current RCRA
regulations, we only know who is producing certain
chemicals of concern.

—  Determine the degree of hazard for the waste
generated. Base assessment on "p" and "q" lists in the

—  Use the above information to set priorities for
enforcement. (Region 7)

Managing for Environmental  Results:
Current Activities, Issues and Proposals

  The primary goal of the Superfund program is to
establish mechanisms for effective response to the release
or threatened release of hazardous substances, pollutants,
or contaminants that present an imminent or substantial
endangerment to public health, welfare, or the
environment. The two basic types of actions involved in
this process are removal and remedial  actions. Removal
actions are generally short-term responses taken to abate
an immediate threat posed by the uncontrolled release of
hazardous substances at both sites and spills in all media.
Remedial actions involve longer term and more complex
solutions at hazardous waste sites. In addition, remedial
actions are generally more expensive than those involving
removal measures.
  In 1983, the Agency plans to focus the Hazardous
Substance Response activities on the containment and
cleanup of the most serious hazardous waste emergencies
and on continuing and initiating remedial actions at
uncontrolled sites posing the greatest threat to public
health and the environment. This phase of the response
program will require continued participation by the states.
To this end, the Agency will continue to develop
cooperative agreements and contracts  with states that are
able and willing to carry out any or all  of the remedial
response actions authorized by CERCLA. While the Federal
government will retain the power to determine when a
remedial response action is warranted, states will be
strongly encouraged to assume full responsibility for the
actual on-site cleanup actions.
  The Act provides the Federal government with the
capability to identify and, where possible, either compel
cleanup by private responsibile parties in lieu of Federal
response actions or to recover Federal expenditures
incurred through cleanup actions when the responsibile
party or parties decline to respond. These actions are
designed not only to compel private parties to assume
responsibility for their actions that have resulted in an
imminent and substantial danger to public health or the
environment, but also to preserve Fund resources so that
the greatest number of sites can eventually be addressed.

Current  Activities — Managing for
Environmental Results

This section discusses  the current Regional uses of
monitoring  data for managing for environmental results.
We have grouped current activities in this section around
the major management activities they support-planning,
technical decision-making, resource allocation and


• Use of environmental data for ranking priority sites

The Superfund program depends upon environmental data
collected by the EPA, state, and contractor resources at
uncontrolled sites. This data is analyzed through use of the
MITRE model, a model based on multimedia

considerations. The data is used to develop the statutorily
required national list of priority sites. The list of priority
sites is scheduled for completion in January 1983. An
interim list of 115 priority sites was completed in October

Technical Decision-Making

• Use of environmental data to define necessary remedial

Once a site is determined to be a priority, EPA takes
several steps to determine necessary clean-up activities
and whether Superfund monies will be used for  site clean-
up. A remedial Investigation/Feasibility study is conducted
to determine what the problem is, what needs to be done,
and the cost. The study must include balancing the cost
with the benefit of different types of control or clean-up,
An engineering design is then prepared and construction is
initiated. Concurrent with this process, the  Superfund
enforcement personnel will try to identify the parties
responsbile and negotiate site clean-up.

• Multi-media environmental and facility data are used to
target investigations at Superfund sites in Region 10.

Region 10 has used its multi-media data base in its work
at the proposed Superfund site at Commencement Bay,
Tacoma, Washington. By comparing the water and air data
with the SIC codes and knowledge of chemical processes,
the Regional staff were able to identify specific locations
where hazardous waste problems were likely to occur and
thus determine where to collect samples to analyze
pollutant levels.

Resource Allocation

• Superfund resources are allocated to priority sites as
ranked on the National list (see previous discussion)

Accountability and Evaluation

The following are a few of the major environmental
indicators that are being tracked in a computerized system
at both the Regional and national level.

— Number of sites where removal is under way

— Number of sites where remedial action is under way

— Number of enforcement  actions initiated

— Number of signed cooperative agreements

— Amount of money recovered through negotiations
with generators and disposers of hazardous waste

— Amount of money being  spent by private parties to
cleanup sites


• Should EPA attempt to measure environmental changes
at each site or  in the surrounding environment as part of
an accountability system or, in realizing the high  cost of
this proposal, should we continue to only track "program
outputs" such as the environmental indicators listed above
that are currently tracked by the program?
• Given the fund-balancing provisions of CERCLA, how
environmentally sound is "cost-effective clean-up"?

• The 10% cost sharing and State O&M requirements are
necessary to achieve the desired environmental results
from remedial activities. What will be the level of State
participation to the requirements for 10% cost-sharing
requirements and operations and maintenance

• What is the continuing Federal role at individual sites
after the six-month Federal monitoring period is complete?
Are States solely responsible for long-term  O&M at
individual  sites?

• Most Regions criticized the weight given  to different
parameters of the MITRE model. They were concerned that
the model does not necessarily give the most accurate
ranking  of priority sites.


There were no proposals for indicators of environmental
progress in the Superfund  program that have not already
been included in the program's tracking system.