INTRODUCTION AND BACKGROUND TO THE
OIL POLLUTION PREVENTION REGULATION
USEPA OIL PROGRAM'S OUTREACH
TO THE REGULATED COMMUNITY
The United States Environmental Protection
Agency (EPA), Oil Program has prepared a
series of guides to help facilities gain an
understanding of and compliance with the
Federal Oil Pollution Prevention Regulation,
Title 40 Code of Federal Regulations (CFR)
Part 112, which includes the Spill Prevention
Control and Countermeasures (SPCC) Plan
requirements and the Facility Response Plan
(FRP) requirements. Under the EPA Oil
Program, a workgroup composed of
representatives from each EPA regional
office and EPA headquarters compiled these
materials.
EPA has produced outreach materials for
selected industries that demonstrate how
the Federal Oil Pollution Prevention
Regulation specifically applies to different
industries. These guides are for bulk
storage facilities, electrical utilities, marinas
and other waterside fueling facilities, mines
and quarries, farms and ranches, vehicle
service facilities, and oil drilling and
production facilities. To obtain copies of
these publications, facilities should contact
any one of the EPA offices listed at the end
of this guide.
Safeguarding Human Health and Ecology
Oil discharges can have a severe impact on
human drinking water resources located in
inland lakes and reservoirs. Spills also
create the potential for explosion and fires
which, in turn, may lead to more equipment
failures, more spills, and endangerment to
humans and wildlife.
Moreover, oil pollution seriously damages
the terrestrial and aquatic environment and
marine ecosystems. It does not take a spill
of catastrophic magnitude to have a serious
impact on an aquatic habitat. The complex
food chain or web, from microorganisms and
plants to shellfish, mammals and birds, is
affected by even small spills. In fact, a
single pint of oil released into the water can
cover one aero of water surface area.
Ecosystems may take years to recover or
may never recover from spills.
Economic Ramifications of Off Spills
The cost of doing business should not
include the cost of responding to accidents
after the fact, but rather should include
instituting spill prevention through proper
Introduction and Background to the Oil Pollution Prevention Regulation - February 1998
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operations, maintenance, and training for
employees and managers.
What is an Oil?
Oils are defined under several statutes
including the Clean Water Act (CWA) and
the Oil Pollution Act of 1990 (OPA). As a
result, overlapping regulatory interpretations
exist. For this reason, the U.S. EPA and
the U.S. Coast Guard are currently
developing a nationally consistent program
policy and methodology for facilities to
determine whether a given substance is
considered an oil under the existing CWA.
Under the CWA, the definition of oil
includes oil of any kind and any form, such
as petroleum and nonpetroleum oils.
Generally, oils fall into the following
categories: crude oil and refined petroleum
products, edible animal and vegetable oil,
other oils of animal or vegetable origin, and
other nonpetroleum oils.
Many substances are easily recognizable as
oils (e.g., gasoline, diesel, jet fuel,.
kerosene, and crude oil). Under the CWA
definition, many other substances are
considered oils which may not be easily
recognizable by industry, including mineral
oil, the oils of vegetable and animal origin
and other nonpetroleum oils. Therefore,
facilities should work closely with the EPA
and USCG (if applicable) to make
determinations for the substances they store,
transfer, and refine;
The regulations are in place primarily to
require that facilities implement measures
that will prevent and control oil spills that
may result due to human operational error or
equipment failure. Facilities that are in full
compliance reduce the number and severity
of discharges and do not face the high costs
of environmental cleanup or additional
permitting requirements that could be
imposed in the event of a discharge.
Facilities that are not in compliance are at
greater risk to experience an oil spill that
may result in a discharge
into a navigable
waterway or adjoining
shoreline. The cost of
cleanup would not only
include repairing the
damage to the facility
(e.g., soil removal or
equipment repair) but could extend beyond
the facility's boundary to affected offsite
areas. Regulators and permitting agencies
may require modifications to operations or
revisions to plans.
Heavy fines and penalties are often
associated with oil discharges, especially
when negligence can be proven.
Incentives for compliance
withSPCC
/ Human health concerns
/ Legal liability
/ Protection of surface water quality and
ecology
/ Oil pollution cleanup costs
/ Positive public image
/ Property values protected
APPLICABILITY OF THE SPCC
REQUIREMENTS
EPA's SPCC requirements (40 CFR 112.1
through 112.7) apply to nontransportation-
related fixed facilities that could reasonably
be expected to discharge oil into or upon the
navigable waters of the United States or
adjoining shorelines, and that have (1) an
aboveground oil storage capacity of more
than 660 gallons in a single container or (2)
a total aboveground oil storage capacity of
more than 1,320 gallons, or (3) a total
Introduction and Background to the Ofl Pollution Prevention Regulation - February 1998
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underground buned storage capacity of
more than 42,000 gallons. The
requirements apply specifically to a facility's
storage capacity, regardless of whether the
tanks are completely filled. Some
transportation-related facilities or activities
may have components considered to be
"fixed" under 40 CFR Part 112 (e.g., certain
tanks at a pipeline facility, trucks containing
product stationed within a fixed facility).
Other facilities may not be regulated if, due
to their location, they could not reasonably
be expected to discharge oil into or upon the
navigable waters of the U.S. or adjoining
shorelines. This determination is made
without consideration of man-made
structures. The majority of facilities in the
U.S. have the potential to discharge to
navigable waters.
The facilities subject to 40 CFR Parts 112.1
through 112.7 are required to prepare an
SPCC Plan and conduct an initial screening
to determine whether they are required to
develop an FRP. SPCC-regulated facilities
must also comply with other federal, state,
or local laws, some of which may be more
stringent.
Those facilities that could cause "substantial
harm" to the environment must prepare and
submit an FRP to EPA for review.
As outlined in 40 CFR 112.20(0(1), a facility
has the potential to cause substantial harm
if:
+ The facility transfers oil over water to or
from vessels and has a total oil storage
capacity, including both aboveground
storage tanks (ASTs) and underground
storage tanks (USTs), greater than or
equal to 42,000 gallons; or
+ The facility's total oil storage capacity,
including both ASTs and USTs, is
greater than or equal to one million
gallons and one of the following is
true:
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cause "substantial harm" to the environment
by discharging oil into navigable water
bodies or adjoining shorelines must prepare
and implement plans, training, and drills for
responding to a worst case discharge of oil,
to a substantial threat of such a discharge,
and to discharges smaller than worst case
discharges.
EPA-regulated facilities are required to
submit their FRPs and certification of
response resources to implement the plan to
EPA for review. The Agency reviews and
approves plans from facilities identified as
having the potential to cause "significant and
substantial harm" to the environment from oil
discharges. Other regulated facilities that do
not meet the "substantial harm" criteria and
are not required to prepare an FRP are
required to document their determination.
This determination should be kept with the
facility's SPCC Plan.
GENERAL SPCC REQUIREMENTS
The owner or operator of a regulated facility
is required to have an SPCC Plan; which is
a written site-specific description detailing
how a facility's operation complies with 40
CFR Part 112. In order to comply with 40
CFR Part 112, the SPCC Plan must be fully-
prepared and implemented.
Regulated facilities in existence at the time
the regulation went into effect, on
January 10, 1974, were required to have a
Pjan prepared within six months of the
effective date of the regulation and to have
fully implemented the Plan within one year of
the effective date of the regulation.
Currently, newly constructed facilities must
prepare an SPCC Plan within six months of
the date they commence operations and fully
implement the Plan as soon thereafter as
possible, but not later than one year after the
date operations commence. Facility owners
or operators who are unable to implement
an SPCC Plan within this time frame due to
circumstances beyond their control may
make a written request for an extension from
the EPA Regional Administrator (RA) by
following the procedure explained in 40 CFR
Owners or operators of mobile or portable
facilities, such as drilling or workover rigs,
may prepare a general SPCC Plan that need
not be site-specific. However, SPCC Plans
for these facilities must satisfy all other
requirements of 40 CFR 112. When the
portable or mobile facility is moved, it must
be located and installed using the practices
outlined in the SPCC Plan for the facility.
The SPCC Plan shall only apply while the
facility is in a fixed, nontransportation
operating mode; however, no mobile or
portable facility subject to this regulation
may operate in a fixed mode unless the
SPCC Plan has been implemented (40 CFR
While each SPCC Plan is unique, certain
elements must be included in order for the
SPCC Plan to comply with the provisions of
40 CFR Part 1 12. If a section does not
apply to the facility, this must be stated.
These elements include, but are not limited
to, the following:
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Professional Engineer (PE) Certification
Plan Sequence Follows 40 CFR Part 112
The SPCC Plan must be reviewed and
certified by a Registered Professional
Engineer (PE) who is familiar with the facility
and with 40 CFR Part 112. The engineer's
name, registration number and state of
registration must be included as part of the
SPCC Plan. The engineer's seal should be
affixed to the Plan as part of the certification.
By certifying the Plan, the engineer is
attesting that he or she is familiar with the
facility, its SPCC Plan and the SPCC
requirements, and that the Plan has been
prepared in accordance with good
engineering practices.
In order to satisfy the requirements of 40
CFR 112.5, all subsequent amendments
must also be certified by a Professional
Engineer, as described above.
SPCC Plan Kept Onsite
If the facility is manned at least eight hours a
day. the owner or operator is required to
maintain a complete copy of the SPCC Plan
onsite. If the facility is not manned at least
eight hours a day, the Plan must be kept at
the nearest field office that is.
The Plan must be made available for review
by the EPA Regional Administrator (RA) or
his or her representative dunng normal
business hours.
Management Approval
The SPCC Plan should be approved by a
level of management with the authority to
commit those resources necessary to
implement the Plan. The appropriate
manager's signature should be included in
the SPCC Plan.
The SPCC Plan must include a complete
discussion of the facility's conformance with
all applicable SPCC requirements and shall
follow the sequence of 40 CFR 112.7. To
help facilities in preparing and reviewing
SPCC Plans, the EPA Oil Program
developed a sample Plan, which can be
obtained from any one of the EPA offices
listed at the end of this guide.
All spill prevention practices used at a facility
must be addressed and a complete and
accurate description of them must be
included in the Plan. It is possible that some
items in 40 CFR Part 112 are not applicable
to a facility. For example, under facility
transfer operations, the first item requires
that buried piping be protectively wrapped or
cathodically protected. Some facilities may
not have any buried piping. For these
cases, the SPCC Plan should indicate that
there is no buried piping at the facility.
Every item must be addressed in the Plan,
even though probably not every item will
apply to a facility.
Spill History
A facility that has experienced one or more
spill events since January 10,1974, should
include in the SPCC Plan a written
description of each spill, corrective actions
taken, and plans for preventing recurrence.
Spill Prediction
Where industry experience indicates a
reasonable potential for equipment failure,
the SPCC Plan should include a prediction
of direction, rate of flow, and total quantity of
oil that could be discharged from the facility
as a result of each major type of failure
mode.
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Examples of major failure modes to be
discussed in the Plan include, but are not
limited to, tank failure due to overflow,
rupture or leakage; pipeline failure due to
rupture or corrosion; leaking flanges,
gaskets, expansion joints, valves, or catch
pans; spills from bulk oil loading or
unloading operations; and leaks due to other
causes, such as failure of wastewater or
stormwater treatment or disposal systems.
Topographic maps are often useful for
predicting and illustrating the direction of
flow and bodies of water which might be
affected by a spill.
Plan Review
The SPCC Plan must be amended
whenever there is a change in facility
design, construction, operation or
maintenance which materially affects the
facility's potential to discharge oil into or
upon navigable waters.
In addition, owners or operators of regulated
facilities are required to review and evaluate
the SPCC Plan at least once every three
years from the time the facility becomes
subject to the SPCC requirements. Within
six months after this review and evaluation,
the owner or operator must amend the
SPCC Plan to include more effective
prevention and control technology
• if such technology will significantly
reduce the likelihood of a spill event from
the facility, and
• if the technology has been field-proven
at the time of the review.
In order to satisfy the requirements of 40
CFR 112.5, all such amendments must be
certified by a Professional Engineer, as
described earlier in this section.
Examples of facility modifications that
could necessitate amending the SPCC
Plan:
• the addition or removal of any oil storage
tanks
• change in spill control technology
• change in service status of tanks,
flowlines or other equipment
• modification or addition of dikes or other
containment structures
• changes to facility stormwater runoff
control systems
• modifications to, or additions of, loading
or unloading racks
• changes in method or frequency of
equipment inspections or associated
record keeping
• any other significant changes
Amendment by Regional Administrator
After review of the SPCC Plan and any other
information submitted, the RA may require
the owner or operator to amend the SPCC
Plan if it does not meet the SPCC
requirements or if such amendment is
necessary to prevent or contain future
discharges from the facility. The RA will
consider any recommendations made by the
state agency in charge of water pollution
control during this process.
If the RA proposes that the SPCC Plan be
amended, the Administrator shall provide
written notification specifying the terms of
the proposed amendment to the facility
owner or operator. Upon receipt of this
notification, the facility owner or operator will
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Introduction and Background to the Oil Pollution Prevention Regulation - February 1998
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then have 30 days in which to respond, in
writing, to the proposal, and offer any
additional information, arguments or
counterproposals.
The RA will then review all available
information and notify the facility owner or
operator of any amendment required or
rescind the original notice.
Usually, if an amendment is required, it must
be made part of the SPCC Plan within 30
days after the final notice and implemented
as soon as possible, but not later than six
months after the amendment becomes part
of the Plan, unless the RA specifies another
date.
The owner or operator may appeal a
decision made by the RA regarding an
amendment. Such an appeal must be made
in writing to the Administrator of the EPA
within 30 days of receipt of the final notice
from the RA. A copy of the appeal must
also be sent to the RA.
Secondary Containment or Contingency
Plans
The owner or operator of a facility is required
to install appropriate containment and
diversionary structures or equipment, such
as dikes, berms, and retaining walls, as
described in 40 CFR 112.7, to prevent
discharged oil from reaching navigable
water, unless it can be clearly demonstrated
that installation of such structures or
equipment is not practical or practicable.
What are Navigable Waters of the U.S.?
The legal definition for navigable waters is defined
generally under Clean Water Act (CWA) Section
502(7). EPA's regulatory definition can be found at
40 CFR 110.1.
For the purposes of 40 CFR Part 112, the term
navigable waters means the waters of the United
States, including the territorial seas, and includes:
• All waters that are currently used, were used in
the past, or may be susceptible to use in
interstate or foreign commerce, including all
waters subject to the ebb and flow of the tide.
• All interstate waters, including interstate
wetlands, mudflats, and sandflats;
• All other waters such as intrastate lakes,
rivers, streams (including intermittent
streams), wetlands, mudflats, sandflats,
sloughs, prairie potholes, wet meadows, playa
lakes, or natural ponds, the use, degradation,
or destruction of which could affect interstate
or foreign commerce including any waters that
could be used for recreational purposes, or
from which fish or shellfish could be taken and
sold in interstate or foreign commerce; or that
are used or could be used for industrial
purposes by industries in interstate commerce.
The CWA has been interpreted to cover all surface
waters, including any waterway within the U.S.
Also included are normally dry creeks through
which water may flow and ultimately end up in
public waters, such as a river, stream, tributary to a
river or stream, lake, reservoir, bay, gulf, sea, or
ocean within or adjacent to the U.S. The CWA's
jurisdictional reach may also include groundwater
jf. it is directly connected hydrologically with
surface waters.
Impracticability pertains primarily to those
cases where severe space limitations or
other physical constraints may preclude
installation of structures or equipment to
prevent oil from reaching navigable water.
Demonstrating impracticability on the basis
of economic considerations alone is not
acceptable.
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In the event that such impracticability can be
demonstrated, the owner or operator must
provide the following in place of containment
structures or equipment:
• A strong oil spill contingency plan
following the provisions of 40 CFR Part
109, and
• A written commitment of manpower,
equipment and materials required to
expeditiously control and remove any
harmful quantity of oil discharged.
FRPs developed by "substantial harm"
facilities can meet the above requirements
for a strong oil contingency plan.
Spill Reporting
Whenever a regulated facility experiences a
single discharge of more than 1,000 gallons
of oil or discharges oil in harmful quantities
into or upon navigable waters in two
reportable spill events during any twelve-
month period, the owner or operator must
submit in writing the following information to
the RA within 60 days:
• Name of the facility;
• Name(s) of the owner or operator of the
facility;
• Location of the facility;
• Date and year of initial facility operation;
• Maximum storage or handling capacity of
the facility and normal daily throughput;
• Description of the facility, including
maps, flow diagrams and topographical
maps;
• The cause(s) of such spill(s), including a
failure analysis of the system or
subsystem in which the failure occurred;
• Corrective actions and/or
countermeasures taken, including a
complete description of equipment
repairs or replacements; and
• A copy of the SPCC Plan and any other
information pertinent to the Plan or the
spill(s).
A complete copy of all information sent to
the RA must also be sent to the state
agency in charge of water pollution control
activities.
Performance-Based SPCC Requirements'
In addition to general requirements, the
SPCC rule also has performance-based
requirements in 40 CFR 112.7 for drainage
control, bulk storage tanks, transfer
operations (e.g., intrafacility piping), tank car
and truck loading and unloading racks,
various onshore and offshore production
facility operations, onshore and offshore oil
drilling, production and workover facilities,
security and training. These specific
requirements are discussed in detail for the
operations at bulk oil storage facilities and
other regulated facilities in separate guides
(refer to the list at the end of this guide).
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GENERAL FRP REQUIREMENTS
Initial Screening and Certification:
Determination Of Response Plan
Applicability
SPCC-regulated facilities that
could cause "substantial harm"
to the environment must
prepare and submit response
plans to the appropriate EPA
Regional Office.
Owners or operators of all facilities subject
to the Oil Pollution Prevention Regulation
must familiarize themselves with the rule to
determine whether their facility meets the
"substantial harm" criteria described at the
beginning of this guide. Under 40 CFR
112.20(e), facilities that do not meet the
"substantial harm" criteria (i.e., answer "no"
to all five questions) must document this.
determination by completing the
"Certification of the Applicability of the
Substantial Harm Criteria Checklist,"
provided as Attachment C-ll in Appendix C
of 40 CFR 112. This certification should be
maintained with the facility's SPCC Plan.
Facilities that meet the "substantial harm"
criteria must submit this certification to EPA
with their FRP. These "substantial harm"
facilities must certify to EPA that they have a
contractor or other means to implement their
response plan..
The 1994 FRP rule
added more specific
requirements for oil
spill response
training and
response drills and
exercises for facilities, which are
codified at 40 CFR 112.21. Under
Sec. 112.20(h)(8), Facility Response Plans
must include information about
self-inspection, drills, exercises, and
response training, including descriptions and
logs of training and drill or exercise
programs and documentation of tank
inspections, equipment inspections,
response training meetings, response
training sessions, and drills and exercises.
Consequently, Facility Response Plans may
be revised based on evaluations of the drills
and exercises. A program that follows the
National Preparedness for Response
Exercise Program (PREP) will meet EPA's
exercise requirements.
Key elements of a model
Facility Response Plan:
/ Emergency Response Action Plan (an
easily accessible stand-alone section of
the overall plan).
/ Facility name, type, location, owner,
and operator information.
/ Diagrams of facility and surrounding
layout, topography, and evacuation
paths.
/ Emergency notification, equipment,
personnel, and evacuation information.
/ Identification and evaluation of potential
spill hazards and previous spills.
/ Identification of small, medium, and
worst case discharge scenarios and
response actions.
/ Description of discharge detection
procedures and equipment.
/ Detailed implementation plan for
containment and disposal.
/ Facility and response resource self-
inspection; training, exercises and drills;
and meeting logs.
/ Security (fences, lighting alarms,
guards, emergency cut-off valves and
locks, etc.)
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EPA has developed an outreach guide, titled
Facility Response Planning, which contains
more specific information regarding the FRP
requirements and response training, drills
and exercises.
The PREP guidelines: USCG-X0191 and
the Training Reference for Oil Spill
Response: USCG-X0188 are available by
mail or fax.
TASC Department Warehouse
3341Q 75th Avenue
Landover, MD 2078S
FAX: (301)386-5394
When requesting copies, please indicate the
document name and publication numbers.
OTHER COMPLIANCE ASSISTANCE
GUIDES
EPA has prepared several guides, including
industry-specific guides, for compliance
assistance with the Federal Oil Pollution
Prevention Regulation:
• SPCC Requirements and Oil Pollution
Prevention Practices for Bulk Oil Storage
Facilities
• SPCC Requirements and Oil Pollution
Prevention Practices for Oil Production
and Oil Drilling/Workover Facilities
• SPCC Requirements and Oil Pollution
Prevention Practices for Farms and
Ranches
• SPCC Requirements and Oil Pollution
Prevention Practices for Mines and
Quarries
• SPCC Requirements and Oil Pollution
Prevention Practices for Electncal
Utilities
• SPCC Requirements and Oil Pollution
Prevention Practices for Vehicle Service
Facilities
• Spill Prevention Requirements for
Facilities Conducting Large Volume
Transfer Operations
• Spill Prevention and Control for Marinas
and Other Waterside Fueling Facilities
• Sample SPCC Plan and Sample
Containment Volume Calculations
• Facility Response Planning
• Oil Spill Notification, Response, and
Recovery
• Other Regulatory Programs Relating to
Oil Pollution Prevention
• Who's Who: Federal Agency Roles and
Responsibilities for Oil Spill Prevention
and Response
* What to Expect During an SPCC/FRP
Inspection
• List of Acronyms and Glossary Relating
to Oil Pollution Prevention
• Full Text of the Regulations
Visit the Oil Program at
http://www.epa.gov/oilspill
To report oil and chemical
spills, call
1-800-424-8802
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FEDERAL AGENCY CONTACT INFORMATION
EPA's Oil Pollution Prevention Regulation
David Lopez, MS 5203G, U.S. EPA
401 M Street, SW, Washington, DC 20460
(703) 603-8707 or
EPCRA/RCRA/Superfund Hotline at (800) 424-9346.
U.S. Coast Guard's Facility Response Plan Regulation
LCDR Mark Hamilton, U.S. Coast Guard, Commandant (G-MOR),
2100 2nd Street, SW, Washington, DC 20593,
(202) 267-1983 (E-mail M.Hamilton/G-M03@CGSMTP.uscg.mil)
DOT/RSPA's Pipeline Response Plan Regulation
Jim Taylor, U.S. Department of Transportation, Room 2335,
400 7th Street, SW, Washington, DC 20590
(202) 366-8860 (E-mail OPATEAM@RSPA.DOT.GOV)
OSHA Regulations
Contact either your Regional or Area OSHA office by calling directory service or the
OSHA National Information Line at (800) 326-2577
DOI/MMS Facility Response Plan Regulation
Larry Ake, U.S. Department of the Interior- Minerals Management Service, MS 4700,
381 Elden Street, Hemdon, VA 22070-4817
(703) 787-1567 (E-mail Lany_ Ake@SMTP.MMS.GOV)
EPA's Risk Management Program Regulation
William Finan, U.S. EPA, Mail Code 5101,
401 M Street, SW, Washington, DC 20460,
(202) 260-0030 (E-mail homepage.ceppo@epamail.epa.gov)
RCRA's Contingency Planning Requirements
Contact the EPCRA/RCRA/Superfund Hotline at (800) 424-9346
Introduction and Background to the Oil Pollution Prevention Regulation - February 1998 «11 •
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EPA REGIONS
U.S. EPA Headquarters
David Lopez (703) 603-8707
Dan Chadwick (202) 564-7054
401 M St. SW
Washington, D.C. 20460
Region 1 Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont
Dennisses Valdes (617) 573-5715
Dave Tordoff (617) 573-9693
JFK Federal Bldg.
Boston, MA 02114
Region 2 New Jersey, New York, Puerto Rico, U.S. Virgin Islands
Matthew Garamone (908) 906-6838
Christopher Jimenez (908) 906-6847
2890 Woodbridge Ave. (MS-221)
Edison, NJ 08837-3679
Region 3 Delaware, Maryland, Pennsylvania, Virginia, West Virginia
Linda Ziegier (215) 566-3277
Jean Starkey (215) 566-3292
841 Chestnut Building, 9th Fl.
Philadelphia, PA 19107-4431
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Region 4 Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
Tennessee
Bob Rosen (404) 562-8761
George Starr (404) 562-8768
61 Forsyth St.
Atlanta, GA 30303-3415
Region 5 Illinois, Indiana, Ohio, Michigan, Minnesota, Wisconsin
Barbara Carr (312) 886-7187
77 W. Jackson Blvd.
Chicago, IL 60604-3507
Region 6 Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Richard Franklin (214) 665-6489
1445 Ross Avenue
Dallas, TX 75202-2733
Region 7 Iowa, Kansas, Missouri, Nebraska
Robert W. Jackson (913) 551-7952
726 Minnesota Ave.
Kansas City, KS 66101
Region 8 Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming
Martha Wolf (303) 312-6839
999 18th Street, Suite 500
Denver, CO 80202-2466
Region 9 Arizona, California, Hawaii, Nevada, Guam, American Samoa,
Trust Territories of the Pacific
Steve Calanog (415) 744-2327
75 Hawthorne Street
San Francisco, CA 94105
Region 10 Alaska, Idaho, Oregon, Washington
Carl G. Kitz (206) 553-1671
1200 Sixth Ave.
Seattle, WA 98101
Donald L. Marson (907) 271-3433
222 West 7th Ave. #9
Anchorage, AK 99513-7588
Library
US EPA Region 3
1650 Arch St.
Philadelphia, PA 19103
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