United Slates
Environmental Protection
Agency
Enforcement And
Compliance Assurance
(2261 A)
EPA 30O-B-96-003
January 1996
&EPA
Federal Facilities
Sector Notebook:
A Profile of Federal
Facilities
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Sector:
SIC Code:
Number of
U.S.
Facilities:
Characterization
of the Sector:
Federal Facilities Sector
Notebook
Summary Profile
Federal Facilities Sector
Department of Defense (DoD)
Department of Energy (DOE)
Civilian federal agencies (CFA)
Various
15,880*
DoD
(5.412 f>c*M<)
341%
DOE
-(393
25*
CFAs
(10.075 faoMwi)
634%
Source FFTS. August 1995
* According to EPA Federal Facilities Tracking System (FFTS), August 1995
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Federal Facilities Sector
Notebook
Summary Profile (continued)
Primary Environmental Resource Conservation and Recovery Act (RCRA) -
Statutes that Federal Facilities Regulates handling and disposal of waste
Must Comply With:
Toxic Substances Control Act (TSCA) - Regulates
production and use of various toxic substances
Clean Water Act (CWA) - Regulates discharges of
pollutants into surface waters
Safe Drinking Water Act (SDWA) - Regulates drinking
water quality and treatment systems
Clean Air Act (CAA) - Regulates emissions of pollutants
and contaminants into the air
Other statutes as discussed in section 2 of this notebook
Common Activity*
Vehicle, vessel and aircraft maintenance
Electroplating
Printing and phmoprocessing
Wastewater treatment plant operations
Hospital operations
Laboratory operations
Office operations
Many other agency-specific activities
Media Affected
Air
Soil and groundwater
Water
Soil and groundwater
Surface water
Surface water
Air
Soil and groundwater
Surface water
Air
Soil and groundwater
Surface water
Air
Soil and groundwater
Surface water
Air
$oil and groundwater
Surface water
Various
Statute and program
that address the activity
RCRA. SDWA. CAA,
CWA
RCRA. CWA. SDWA
« RCRA, CAA, CWA.
SDWA
CWA, SDWA
RCRA, CAA, CWA
RCRA, CAA, CWA
RCRA (Subtitle D)
Various
* Detailed descriptions of these activities are provided in this notebook
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Federal Facilities Sector
Notebook
Summary Profile (continued)
Expenditures:
BUDGET AUTHORITY FOR ENVIRONMENTAL PROJECTS BY AGENCY
(in millions of dollars)*
Agency
DoD
DOE
CFAs
Total
FY91($M)
2,168
3,687
158
6,103
FY92($M)
4,172
4,434
250
8,556
FY93($M)
4,020
5,729
290
10,038
FY94($M)
5,246
6,175
201
11,622
Waste
Generation:
For the 1993 Biennial Report System (BRS) reporting year, the five RCRA
wastes generated in the greatest volume were:
Benzene
Corrosive waste
Chromium
Spent non-halogenated solvents
Wastewater treatment sludges from electroplating
For more information about the federal facilities sector
or about this notebook, contact:
Ms. Sarah Walsh
U.S. Environmental Protection Agency
Federal Facilities Enforcement Office (2261-A)
401 M Street, SW
Washington, DC 20460
(202) 564-2457
* Source: July, 1995 Draft "The State of Federal Facilities"
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Federal Facilities Sector Notebook:
A Profile of Federal Facilities
January 19%
Federal Facilities Enforcement Office
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
This document is designed solely to increase general knowledge and understanding about the federal
facility sector for the benefit of employees of the United States Environmental Protection Agency
(EPA) and state and local governments, tribal representatives, and the public. Descriptions contained
herein of any policies and procedures are not intended, and cannot be relied upon, to create any rights,
substantive or procedural, enforceable by any party in litigation with the United States. EPA reserves
the right to act at variance with these policies and to change them at any time without public notice.
The Federal Facilities Enforcement Office would like to thank those reviewers, both within and outside
of EPA, who provided comments on this document. For the most part, those reviewers comments
were addressed; unless resource constraints prohibited such revisions.
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CONTENTS
Section Eag£
1.0 GENERAL INTRODUCTION 1-1
1.1 SUMMARY OF THE SECTOR NOTEBOOK PROJECT 1-1
1.2 CONTENT AND PURPOSE OF DOCUMENT 1-2
1.3 OTHER SOURCES OF INFORMATION ABOUT FEDERAL FACILITIES .... 1-4
2.0 INTRODUCTION TO FEDERAL FACILITIES 2-1
2.1 CHARACTERIZATION OF THE FEDERAL FACILITY SECTOR 2-1
2.2 MISSIONS OF THE FEDERAL AGENCIES 2-7
2.3 ACTIVITIES COMMONLY CONDUCTED AT FEDERAL FACILITIES 2-9
2.4 ENVIRONMENTAL CHALLENGES FACED BY FEDERAL FACILITIES . . 2-11
2.4.1 Environmental Expenditures of Federal Facilities 2-13
2.4.2 Description of Environmental Programs 2-14
2.4.2.1 Department of Defense 2-15
2.4.2.2 Department of Energy 2-16
2.4.2.3 Civilian Federal Agencies 2-16
2.4.2.4 Government Wide Initiatives . 2-17
2.4.3 Waste Generated in the Federal Facilities Sector 2-19
2.4.4 Comparison With The Private Sector 2-21
3.0 COMPLIANCE AND ENFORCEMENT 3-1
3.1 NUMBERS OF INSPECTIONS 3-1
3.2 REVIEW OF MAJOR ENFORCEMENT ACTIONS 3-3
3.2.1 Review of Major Cases 3-4
3.2.2 Supplemental Environmental Projects 3-5
4.0 PROCESSES TYPICALLY FOUND AT FEDERAL FACILITIES 4-1
4.1 AIRCRAFT, VESSEL, AND VEHICLE MAINTENANCE 4-1
4.1.1 Routine Maintenance and Cleaning Operations 4-2
4.1.2 Parts Cleaning
4.1.3 Painting Operations .. .
4.2 FUEL STORAGE AND REFUELING OPERATIONS 4-5
4.2.1 Tanks and Pipelines 4-6
4.2.2 Management of Runoff and Environmental Controls 4-7
4.2.3 Tank Filling and Refueling Operations 4-7
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CONTENTS (continued)
Section
4.3 ELECTROPLATING 4-8
4.4 PRINTING AND PHOTOPROCESSING 4-10
4.5 HOSPITAL OPERATIONS - 4-11
4.6 RESEARCH LABORATORY OPERATIONS 4-12
4.7 WASTEWATER TREATMENT PLANT OPERATIONS 4-13
4.8 OFFICE OPERATIONS 4-14
5.0 P2 OPPORTUNITIES . . 5-1
5.1 EXAMPLES OF P2 OPPORTUNITIES IN AIRCRAFT, VESSEL, AND
VEHICLE MAINTENANCE . . . 5-1
5.2 EXAMPLES OF P2 OPPORTUNITIES IN FUEL STORAGE AND
REFUELING 5-4
5.3 EXAMPLES OF P2 OPPORTUNITIES IN ELECTROPLATING 5-5
5.4 EXAMPLES OF P2 OPPORTUNITIES IN PRINTING AND
PHOTOPROCESSING 5-5
5.5 EXAMPLES OF P2 OPPORTUNITIES IN HOSPITAL OPERATIONS 5-7
5.6 EXAMPLES OF P2 OPPORTUNITIES IN RESEARCH LABORATORY
OPERATIONS 5-9
5.7 EXAMPLES OF P2 OPPORTUNITIES IN WASTEWATER TREATMENT
PLANT OPERATIONS , 5-10
5.8 EXAMPLES OF P2 OPPORTUNITIES IN OFFICE OPERATIONS . 5-11
Appendix
A KEY STATUTES AND EXECUTIVE ORDERS THAT
AFFECT FEDERAL FACILITIES
B SUMMARY AND STATUS OF PENDING REGULATORS THAT
MAY AFFECT FEDERAL FACILITIES
OVERVIEW OF AGENCY POLLUTION PREVENTION STRATEGIES
D ACTIVITIES SPONSORED BY TRADE ASSOCIATIONS
AND FEDERAL FACILITIES
E RELATED EPA DOCUMENTS
F LIST OF ACRONYMS
G SECTOR MANUALS
H LIST OF REFERENCES
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CONTENTS (continued)
FIGURES
Fjgme Ease
1-1 Industries In Sector Notebooks 1-2
2-1 National Distribution of Federal Facilities 2-5
2-2 Total Number of Federal Facilities Per EPA Region 2-6
2-3 Distribution of Federal Facilities by Region (FY 1994) ..2-7
2-4 Breakdown of CFA Facilities 2-10
2-5 Distribution of Federal Facilities on the NPL (FY 1994) 2-13
2-6 Pollution Abatement Expenditures by Economic Sector (1992) 2-22
3-1 Changes in Federal Facility Compliance Indicators 3-2
TABLE
Table Eag£
2-1 UNIVERSE OF CIVILIAN FEDERAL AGENCIES TRACKED IN FFTS 2-2
2-2 IDENTIFICATION OF THE REGULATED COMMUNITY
OF FACILITIES WITH FEDERAL INVOLVEMENT 2-3
2-3 BUDGET AUTHORITY FOR ENVIRONMENTAL PROJECTS BY AGENCY
(inmillions of dollars [$M])* 2-14
2-4 TOP FIVE RCRA WASTES REPORTED IN 1993
TO BRS BY FEDERAL FACILITIES 2-20
2-5 TOP FIVE WASTE SOURCES REPORTED IN 1993
TO BRS BY FEDERAL FACILITIES 2-21
2-6 EXPENDITURES FOR POLLUTION ABATEMENT BY
ECONOMIC SECTOR (IN BILLIONS OF 1987 DOLLARS) 2-22
2-7 MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND
OPERATIONS 2-24
4-1 PROCESSES AND RAW MATERIALS USED IN AND WASTES GENERATED
FROM AIRCRAFT, VESSEL, AND VEHICLE MAINTENANCE ACTIVITIES ...... 4-2
4-2 PROCESSES AND RAW MATERIAL USED IN AND WASTES
GENERATED FROM PARTS CLEANING 4-3
4-3 RAW MATERIAL INPUTS AND WASTES GENERATED FROM PAINTING
OPERATIONS 44
4-4 PROCESSES AND RAW MATERIALS USED IN AND WASTES
GENERATED FROM FUELING OPERATIONS 4-6
4-5 ELECTROPLATING-RAW MATERIAL INPUTS AND WASTES GENERATED 4-8
4-6 RAW MATERIAL INPUTS AND WASTES GENERATED FROM
PRINTING AND PHOTOPROCESSING 4-11
4-7 RAW MATERIAL INPUTS AND WASTES GENERATED FROM HOSPITALS 4-12
4-8 RAW MATERIAL INPUTS AND WASTES GENERATED FROM
WASTEWATER TREATMENT PLANTS 4-13
5-1 P2 OPPORTUNITIES FOR AIRCRAFT, VESSEL, AND VEHICLE MAINTENANCE . 5-2
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CONTENTS (continued)
Table
5-2 P2 OPPORTUNITIES FOR VAPOR DECREASING 5-3
5-3 P2 OPPORTUNITIES FOR PAINTING OPERATIONS 5-4
5-4 P2 OPPORTUNITIES FOR FUEL STORAGE OPERATIONS 5-5
5-5 P2 OPPORTUNITIES FOR ELECTROPLATING 5-6
5-6 P2 OPPORTUNITIES FOR PRINTING
AND PHOTOPROCESSING OPERATIONS .5-7
5-7 P2 OPPORTUNITIES FOR HOSPITALS 5-8
5-8 P2 OPPORTUNITIES FOR LABORATORIES
AND RESEARCH INSTITUTIONS 5-9
5-9 P2 OPPORTUNITIES FOR WASTEWATER TREATMENT 5-11
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1.0 GENERAL INTRODUCTION
This sector notebook is one of a series of notebooks published by the U.S. Environmental Protection
Agency (EPA) to provide information of general interest about the status of environmental issues faced
by specific industrial sectors. In contrast to the private sector, the public-sector federal government
spans many industrial sector boundaries and faces unique and complex environmental challenges. EPA
prepared this document to provide a profile of the environmental activities performed by the federal
government sector, including compliance with regulations and pollution prevention (P2). The profile is
limited in scope. With the availability of more funds, the notebook will be expanded.
This chapter describes the sector notebook initiative and explains the purpose, structure, and content of
this document.
1.1 SUMMARY OF THE SECTOR NOTEBOOK PROJECT
Environmental policies based upon comprehensive analysis of air, water, and land pollution (such as
economic sector and community-based approaches) are becoming an important supplement to
traditional single-medium approaches to environmental protection. Environmental regulatory agencies
are beginning to embrace comprehensive, multistatute solutions to issues related to permitting of
facilities, compliance assurance, education and outreach, research, and regulatory development. The
primary concepts that inspire the new policy direction are that releases of pollutants to any
environmental medium (air, water, and land) affect other environmental media and that environmental
strategies must identify and address those interrelationships actively through policies of the "whole"
facility. One way to achieve a focus on the whole facility is to design environmental policies for
similar industrial facilities. Under such an effort, environmental concerns that are common to the
manufacture of similar products can be addressed in a comprehensive manner. The desire in the EPA
Office of Compliance to move forward with this "sector-based" approach led to the creation of the
sector notebooks.
Figure 1-1 below lists the 18 industrial sectors profiled in the other EPA sector notebooks.
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FIGURE 1-1
INDUSTRIES IN SECTOR NOTEBOOKS
Dry cleaning Nonferrous metals
Electronics and computers Non-fuel, non-metal mining
Wood furniture and fixtures Organic chemicals
Inorganic chemicals Petroleum refining
Iron and steel Printing
Lumber and wood products Pulp and paper
Fabricated metal products Rubber and plastic
Metal mining Stone, clay, glass and concrete
Motor vehicle assembly Transportation equipment cleaning
Appendix G presents a list of the sector notebooks, and the EPA contact.
13, CONTENT AND PURPOSE OF DOCUMENT
The purpose of this notebook is to provide a snapshot of the environmental programs, challenges, and
accomplishments of the federal facilities sector. The document provides staff of EPA and state
agencies with a broad overview of the status of activities at federal facilities nationwide. It does not
attempt to catalog all activities and programs. The information in this notebook answers such questions
as:
What is the federal facilities sector?
Where are the federal facilities located?
What types of activities are federal facilities engaged in?
How can federal facilities prevent the generation of pollution in the future?
What types of environmental challenges do federal facilities face and what types of
programs do they conduct?
How do the environmental problems, compliance rates and environmental expenditures
of federal facilities compare with those of the private sector?
What are some other resources that provide information about the federal facilities
sector?
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Because the federal facilities sector comprises many agencies that have diverse missions, it is difficult
to develop one summary that is applicable to all such agencies. Therefore, this notebook describes
activities that occur within three distinct segments of the federal community:
The Department of Defense (DoD), including the Departments of the Army, Navy, and
Air Force and the associated defense agencies
The Department of Energy (DOE), including national laboratories
Civilian federal agencies (CFA), (including such agencies as the Departments of the
Interior, Commerce, Agriculture, Veterans Affairs, Transportation, and the U.S. Postal
Service)
CFAs discussed in this notebook are those as reported in the Federal Facilities Tracking System
(FFTS). FFTS is a new computer tracking system. When facility data linking is completed, the system
will contain about 12,000 Federally-regulated facilities. Currently, the data includes items such as
Formeily Used Defense Sites (FUDS), and double entries of facilities due to misspellings. Based on
August 1995 data, the Departments of Transportation, Interior, Commerce, Agriculture, Veterans
Affairs, and the U.S. Postal Service make up the majority of CFA facilities. Because there are
numerous agencies in each of the departments, this document addresses the environmental activities at
CFAs in general, rather than attempting to present a comprehensive profile of all CFAs.
As in the industrial sector notebooks, the key topics addressed in this notebook are:
General information about the sector
Compliance history
Typical industrial processes conducted and applicable P2 opportunities
Information presented in each profile was developed through research of a variety of sources, and
usually was condensed from more detailed information about specific topics.
This document is presently in draft form and is not intended to be used as a source of definitive data or
assessments of the performance of federal facilities. Representatives of the federal facility sector have
not yet commented on its content. Further, the information contained herein is indicative only of the
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status of the federal facility sector in October 1995. It may not reflect current practices or
accomplishments.
13 OTHER SOURCES OF INFORMATION ABOUT FEDERAL FACILITIES
In addition to this federal facilities sector manual, several documents that describe the sector are
available from EPA. Appendix E presents a list of those documents.
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2.0 INTRODUCTION TO FEDERAL FACILITIES
This chapter provides a characterization of the federal facility sector, including the number of such
facilities in the United States and their locations.
2.1 CHARACTERIZATION OF THE FEDERAL FACILITY SECTOR
The federal government defines federal facilities as: buildings, installations, structures, land, public
works, equipment, aircraft, vessels, and other vehicles and property owned by, or constructed or
manufactured and leased to, the federal government. Federal facilities are required to comply with
various statutes, regulations, and Executive Orders (EO) administered by EPA. Recognizing the
unique nature of the federal facilities sector, EPA created the Federal Facilities Enforcement Office
(FFEO) to coordinate federal facility enforcement, compliance assurance, and assistance efforts for
those requirements. FFEO also serves as the lead communicator with Congress, other agencies, states,
and other stakeholders on these matters. For example.
The federal government is the owner of one-third of the nation's land area, and is the
nation's largest consumer of energy.
The federal government is one of the nation's largest consumers of paper and paper
products.
The federal government has been mandated by EO to be an environmental leader in
such areas as acquisition, recycling, and waste prevention.
According to EPA's FFTS, there are approximately 15,880 federal facilities nationwide, including
DoD, DOE and CFA facilities. CFA facilities are diverse; and include organizations such as those
listed in Table 2-1 below. Table 2-1 primarily presents the government department level CFAs that are
tracked in FFTS. There are numerous other separate departments, bureaus, and independent agencies
that are also tracked.
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TABLE 2-1
UNIVERSE OF CIVILIAN FEDERAL AGENCIES TRACKED IN FFTS
Department of Agriculture (DOA)
Department of Commerce (DOC)
Department of Health and Human Services (HHS)
Department of the Interior (DOI)
Department of Justice(DOJ)
Immigration and Naturalization Service (INS)
Department of Labor (DOL)
Department of Transportation (DOT)
Department of Treasury
Department of Veterans Affairs (VA)
Community Services Administration (CSA)
Environmental Protection Agency (EPA)
Federal Communications Commission (FCC)
Federal Emergency Management Agency (FEMA)
Federal Home Loan Bank Board (FHLB)
General Services Administration (GSA)
International Communications Agency (ICA)
National Aeronautics and Space Administration (NASA)
National Science Foundation (NSF)
Tennessee Valley Authority (TVA)
Smithsonian Institution (S.I.)
U.S. Postal Service (USPS)
Other sector notebooks focus on one standard industrial classification (SIC) code. It is not generally
possible to use SIC code information to develop a profile of the federal facility sector because federal
facilities are classified under several SIC codes, which may also include establishments that are not
federal facilities. For example:
DoD facilities typically are classified under SIC code 9711, national security.
CFAs, such as Coast Guard facilities, federal prisons, and VA hospitals, fall under SIC
codes such as the following:
96, administrative and economic programs
- 92, justice, public order, and safety
80, health services
- 806, hospitals and medical labs
- 9223, correctional institutions
- 9621, transportation programs
- 9641, agricultural marketing and commodites.
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When identifying the entire community of federal facilities, it is important to acknowledge that not all
federal facilities are owned and operated by the federal government. Federal agencies often have
complex relationships with private entities. At numerous federal facilities and on many public lands, a
private party or parties are involved at some level in operating the facility or leasing the facility or
lands for private use or other purposes. The regulated community of facilities at which the federal
government is involved includes government owned and government operated (GOGO) and
government owned contractor operated (GOCO), as well as several other types of facilities.
Table 2-2 provides definitions of the various types of facilities and federal leased lands that make up the
regulated community of federal facilities. The complex relationships between federal facilities and
private entities are not addressed in this notebook.
TABLE 2-2
IDENTIFICATION OF THE REGULATED COMMUNITY
OF FACILITIES WITH FEDERAL INVOLVEMENT
Acronym/Term
Definition
Classification for
Information System
Tracking Purposes:
GOGO
Government owned/government operated
facility is the traditional Federal facility
where the government owns and operates
all regulated activity.
Federal Facility.
GOCO
Government owned/contractor operated
facility is owned by a Federal agency but
all or portions of it are operated by
private contractof(s).
Federal facility (or GOCO in
some program information
systems).
COCO
Contractor owned/contractor operated
facility is a non-government owned,
privately operated facility that provides
goods and/services to a Federal agency
under contract.
Private party.
COCO(E)
Same as COCO, however, contractor
may be furnished government equipment
to manufacture a product or provide a
service.
Private party.
POGO
Privately owned/government operated is a
facility where the government leases
buildings or space for its operations.
Federal facility where a single
agency occupies all or most
space in a building.
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TABLE 2-2 (continued)
IDENTIFICATION OF THE REGULATED COMMUNITY
OF FACILITIES WITH FEDERAL INVOLVEMENT
Acronym/Term
Definition
Classification for
Information System
Tracking Purposes:
GOPO
Government owned/privately operated is
a facility where the government has
leased all or part of its facility to a private
operator for their operation and profit.
Federal facility.
Leasee
Parties granted use of government land by
a rental or real estate agreement or title
transfer with a reversionary clause
(municipal landfills, oil and gas, mining,
grazing, agricultural, industrial
operations, parks and marinas).
Federal agency lands.
Grantee
Parties having received a grant for
permanent authorization to use
government land or given a right of way.
Grants usually involve a single payment
for the land or transfer of land use rights.
Private Party.
Claimant
Parties having properly located, recorded
and maintained mining claims under the
1872 mining law on Federal lands for
which a patent has not been issued.
Federal agency lands when
available for entry under the
1872 Mining Law.
Patent Holder
A mining claimant who has met the
statutory requirements of the 1872 Mining
Law and has been issued a permit.
Private Party (when permit has
been issued).
Permittee
Parties granted a permit for short-term
use of government land.
Federal agency lands.
Withdrawal from
Public Use
Permit granted to a Federal agency or
instrument of the Federal government to
use land of another Federal agency for up
to twenty years administratively as long
as intended use does not involve
destruction of the land (i.e., military uses,
dams). Congressionally mandated
withdrawals are generally permanent
changes of administration of Federal
lands to accommodate more destructive
uses of such lands.
Federal agency administering
the lands.
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The federal government owns hundreds of thousands of buildings, located on millions of acres of land.
Figure 2-1 shows the national distribution of federal facilities in three categories: DoD, DOE, and
CFAs.
CFAs
(10,075 facilities)
63.4%
Source: FFTS, August 1995
DoD
(5,412 facilities)
34.1%
DOE
-(393 facilities)
2.5%
Figure 2-1. National Distribution of Federal Facilities
Federal facilities are dispersed throughout the United States, EPA Regions, and states, as Figures 2-2
and 2-3 show.
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Region IX
1997
(12.57%)
Region V
1597
Source: FFTS, August 1995
Region I
961
(6.05%)
Region II
1763 r\ v
(11.10%) \ t
Region VIII
1240
(7.81%) i
Region X
1791
(11.28%)
Region VII
949
(5.98%)
Region VI
1706
(10.74%)
Region III
1601
(10.08%)
Region IV
2275
(14.33%)
Figure 2-2. Total Number of Federal Facilities Per EPA Region
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2500
Source: FFTS, August 1995
Figure 2-3. Distribution of Federal Facilities by Region (FY 1994)
2.2 MISSIONS OF THE FEDERAL AGENCIES
The following discussion describes the missions of the various federal agencies.
The Department of Defense is charged with defending the interests of the United States anywhere in the
world. As such, DoD maintains thousands of installations across the U.S. to provide the necessary
infrastructure to support the armed services to meet this mission. The installations range in size from a
few acres to thousands of square miles; their missions range from logistics and training, to
manufacturing, and rebuilding aircraft and ships. Many of these installations are the equivalent of
small (and sometimes not so small) cities; therefore they will have all the infrastructure (such as
hospitals, sewage treatment plants, roads, airports, and other aspects) associated with city
environments. Much of the support activity associated with DoD's mission is industrial in nature.
Accordingly, DoD installations also may confront environmental issues associated with industrial
plants, including problems with air and water pollution and the generation of solid and hazardous
waste. DoD's mission has created environmental issues that are microcosms of those faced by cities
and industries in America today.
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DOE
In the past, the Department of Energy was charged with providing the technical information and the
scientific and educational foundation for the technology, policy, and institutional leadership necessary
to achieve efficiency in energy use, diversity in energy sources, a more productive and competitive
economy, improved environmental quality, and a secure national defense. In recent years, DOE has
shifted away from the design and testing of nuclear weapons and toward cleanup and disposal of
radioactive and hazardous mixed-waste sites. Most of DOE's 393 installations are dedicated primarily
to research. DOE has 9 major multi-program laboratories, 10 single-purpose laboratories, and a wide
range of special user facilities crucial to U.S. industry's global competitiveness. The laboratories
conduct research in a variety of areas including solar energy, battery development, energy transmission
methods, atomic energy, fossil fuel energy, and nuclear weapons. Some of the laboratories are located
in large compounds while others are part of university systems. In addition to research, industrial
activities are conducted at several DOE locations throughout the United States. DOE's industrial
activities include metal working, tool and die manufacture, manufacture and assembly of circuit boards,
and other activities. Like that of DoD, DOE's mission contributes to environmental problems in all
media.
CFAs
The majority of federal facilities subject to environmental requirements are those facilities that belong
to CFAs. Many of these agencies are highly specialized; however, their activities tend to mirror, on a
smaller scale, the activities of DoD and DOE. Although these agencies conduct widely varied
operations, albeit on a reduced scale, they require environmental management considerations. These
considerations include chemical (including fuel) use and storage, small-scale manufacturing operations,
management of fleet vehicles, and laboratory research.
Of the approximately 10,075 CFAs that are tracked in FFTS, the greatest numbers are under the
jurisdiction of:
Department of Transportation (1,464 facilities)
Department of the Interior (1,200 facilities)
U.S. Postal Service (1,026 facilities)
Department of Agriculture (836 facilities)
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General Services Administration (700 facilities)
Figure 2-4 shows the distribution of CFA facilities by agency tracked in FFTS. These counts include
some duplicative listings since facility data linking has not been completed.
23 ACTIVITIES COMMONLY CONDUCTED AT FEDERAL FACILITIES
Federal facilities serve a variety of missions, such as providing national security; conducting research
and development; delivering the nation's mail; and managing federal lands for agriculture, livestock,
mining, recreation, and other purposes. Examples of commonly conducted activities at federal
facilities include:
Maintenance of vehicles, vessels and aircraft
- Painting
- Parts cleaning
Fuel storage and refueling
Electroplating
Printing and photoprocessing
Waste water treatment
Hospital operations
Laboratory research
Office operations
Explosives manufacturing, storage, and disposal
Electronics facility maintenance
Firefighting and firefighting training areas
Housing
Drinking water provision
Ship building
Land management
Warehousing
Sections 4 and 5 of this notebook address a select few of these activities in detail. Future versions of
this notebook may expand Sections 4 and 5 to address more of these, or other, activities.
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1,600
1,400
10 229
""170
BlHu....
13 10 8 8 6 5 2 2 2 1 1
iFacilities
tracked
in FFTS
U.Z U.UJ~CJ-
eo
Source: FFTS, September 1995
Figure 2-4. Breakdown of CFA Facilities
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2.4 ENVIRONMENTAL CHALLENGES FACED BY FEDERAL FACILITIES
Federal facilities face a wide variety of environmental challenges, including:
Compliance with various environmental statutes and the implementing regulations
established under those statutes
Compliance widi federal EOs (e.g., EO 12856, EO 12989, and others) that direct the
environmental management approaches taken by federal facilities
Cleanup of contaminated federal property
Creating and implementing effective environmental strategies that emphasize
compliance, risk management, pollution prevention, and sustainable development
Acquiring resources for developing and improving environmental management
systems (for example, adequate budget, human resources, information management
systems, and technology)
Addressing issues related to environmental justice
Addressing the need for preservation of land and ecosystems
Those statutes and EOs that affect environmental compliance at federal facilities are:
Archaeological and Historic Preservation Act Clean Air Act (CAA)
Coastal Barrier Resources Act
Community Environmental Response
Facilitation Act (CERFA)
Conservation Programs on Military
Installations (the Sikes Act)
Endangered Species Act
Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA)
Federal Water Pollution Control Act
(FWPCA)
Hazardous Materials Transportation Act
Migratory Bird Treaty Act
Oil Pollution Act (OPA)
Resource Conservation and Recovery Act
(RCRA)
Coastal Zone Management Act (CZMA)
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA
or Superfund)
Emergency Planning and Community Right-
to-Know Act (EPCRA)
Federal Facilities Compliance Act (FFCA)
Federal Land Policy and Management Act
Fish and Wildlife Conservation Act
Marine Mammal Protection Act
National Environmental Policy Act (NEPA)
P2 Act (PPA)
Safe Drinking Water Act (SDWA)
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Toxic Substance Control Act (TSCA) Base Realignment and Closure Act (BRAC)
EO 12580 - Superfund Implementation EO 12856 - Right-to-Know and P2
Requirements
EO 12873 - Acquisition, Recycling, and EO 12902 - Energy Efficiency and Water
Waste Prevention Conservation
EO 12843 - Ozone-Depleting Substances EO 12898 - Environmental Justice
EO 12844 - Alternative-Fuel Vehicles EO 12845 - Energy Efficient Computers
EO 12989 - Federal Acquisition/ Community EO 12088 - Federal Compliance with
Right to Know Toxic Chemical Release Pollution Control Standards
Reporting
It is important to note that it is essential to know the function a particular federal facility serves to
determine which of the above-listed environmental requirements apply to it. Further, it is beneficial to
understand the modifications of operations that can be made and prevention measures that can be taken
to ensure compliance.
The federal government is focusing both on cleanup of past activities and on preventing the occurrence
of problems in the future. For example, past problems are often characterized by the ranking of a
facility according to the threat it poses to human health or the environment and listing on the CERCLA
National Priorities List (NPL).
The NPL is a list of the nation's highest priority abandoned hazardous waste sites that require cleanup
other than an emergency or time-critical removal response. Listing of a federal facility on the NPL
triggers a requirement for compliance with CERCLA section 120 and its associated deadlines for
ensuring a timely cleanup.
At the end of fiscal year (FY) 1994, 160 federal facilities were listed on the NPL (proposed and final)
(see Figure 2-5 below).
The distribution of types of federal facilities on the NPL by federal agency is:
DoD, 80.6 percent (129)
DOE, 11.9 percent (19)
CFA, 7.5 percent (12)
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DoD
(129 facilities)
80.6%
CFA
-(12 facilities)
7.5%
DOE
(19 facilities)
11.9%
Source: FFTS, August 1995
2.4.1
Fife-lire 2-5. Distribution of Federal Facilities on the NPL (FY 1994)
Environmental Expenditures of Federal Facilities
Federal facilities have a growing commitment to environmental excellence. One way in which they
manifest that commitment is through expenditures on environmental management and projects.
However, budgetary expenditures alone are not a complete indicator of an agency's commitment to
environmental excellence. Budgetary expenditures should be examined in combination with pollution
reduction initiatives adopted, corrective action measures taken, and cleanups accomplished. As
evidence of the government's increasing commitment to environmental protection, the budget for
cleanup and compliance at federal facilities rose from $3 billion in FY 1989 to $10 billion in FY 1993.
Table 2-3 shows that funding levels for environmental projects approximately doubled from FY 1991 to
FY 1994. Table 2-3 also illustrates how the funding levels are allocated among the various federal
agencies.
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TABLE 2-3
BUDGET AUTHORITY FOR ENVIRONMENTAL PROJECTS BY AGENCY
(in millions of dollars [$M])*
-'- - ' : :
Agency
DoD
DOE
CFAs
Total
FY91($M)
2,168
3,687
158
6,103
FY92 ($M)
4,172
4,434
250
8,556
FY93($M)
4,020
5,729
290
10,038
FY94($M)
5,246
6,175
201
11,622
* Source: July 1995, Draft "The State of Federal Facilities
DoD and DOE account for the vast majority of spending on environmental projects, 53.1 percent and
45.1 percent, respectively, of the total budgeted authority in FY 1994. While DoD and DOE devote
significant resources to environmental programs, CFAs are much smaller and often lack the
infrastructure, budget, and technical expertise to manage environmental problems effectively.
Although spending on environmental issues by all agencies has increased since FY 1991, the rates of
increase have slowed. There also are several differences between the CFAs, and DOE and DoD. For
example, over the period in question, spending by DOE and DoD increased by 67.5 percent and 140.1
percent, respectively, while spending by CFAs grew by only 27.2 percent until FY 1993 and then
declined in FY 1994 to pre-FY 1992 levels.
EPA has a means to track and review the environmental projects of federal facilities funded by the
federal agency's environmental budgets. FEDPLAN is a computer tracking system that is updated
annually with a list of environmental projects planned by federal facilities and the proposed cost of
those projects. The data provided by federal facilities includes both planning and completion
milestones. The requirement for federal facilities to provide this data to EPA is found in EO 12088.
2.4.2
Description of Environmental Programs
Federal facilities conduct numerous environmental programs. In addition, federal facilities have
formed successful environmental partnerships with EPA. Highlights of some of the key programs and
initiatives are presented below. When this notebook is revised, additional environmental programs will
be highlighted below.
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2.4.2.1 Department of Defense
DoD has an environmental program that is built on the principle that environmental responsibility must
be an integral part of the ethic of any large organization that conducts industrial activities. DoD, as the
nation's largest such organization, takes its environmental responsibility seriously. Responsibility for
ensuring environmental compliance lies with the Deputy Under Secretary of Defense for Environmental
Security [DUSD(ES)]. The responsibility of that office is to ensure satisfactory environmental quality
for both DoD and its stakeholders, while promoting military readiness. DUSD(ES), therefore, has
established an environmental program that has three broad tiers. The first tier, at the Secretariat level,
is responsible for development of policy and guidance. The second tier is at the level of DoD senior
staff and commanders of the various DoD components, which are the Army, the Navy, the Marine
Corps, the Air Force, and the Defense Logistics Agency. The responsibility at that level is for
implementation and oversight of environmental projects. Finally, program management and execution
of guidance are carried out by the commander of a base or installation, at the third tier of the program.
DoD environmental activities can be broken into three parts (Air Force, Army, and Navy). Each of
those service branches has taken different approaches and applied different emphases to environmental
issues. In addition, each service performs different functions that impact the environment differently.
However, to meet the intent of this notebook, DoD environmental activities have been combined under
one general heading of "DoD." Future versions of this notebook may break DoD environmental
activities into the three parts listed above.
Some of die many environmental programs underway at DoD are:
Fast-Track Cleanup Program for base closures to speed the cleanup process at military
bases slated for closure
Development and adoption of P2 strategies
Process and operation considerations to determine how all activities affect the
environment and where opportunities for P2 exist
Revision of all material specifications and standards with their environmental effects in
mind
Evaluations of the environmental effects of all major systems being acquired
Continuous reductions in disposal of hazardous waste
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Environmental Technology Program to coordinate and integrate environmental research
and development
Conduct of Environmental Baseline Surveys (EBS) to meet environmental
documentation and notification needs
2.4.2.2 Department of Energy
The mission of DOE's Environmental Quality (EQ) Program is to protect public health and the
environment by understanding and reducing the environmental, safety, and health risks and threats
posed by DOE facilities and to develop the technologies and institutions required for solving domestic
and global environmental problems.
Highlights of DOE environmental programs include:
Estimating the costs of restoration and waste management
Using the computerized Progress Tracking System to track program performance for
environmental restoration and waste management
Restructuring restoration and waste management contracts to improve contractor
accountability and performance to reduce costs
Converting defense laboratories to environmental technology (development programs)
2.4.23 Civilian Federal Agencies
Like DoD and DOE, CFAs must respond to recent legislative and executive actions to improve their
environmental performance. However, most CFAs lag behind other agencies; yet, they may be
responsible for significant cleanups and compliance problems.
CFAs often lack the infrastructure, budget, and technical expertise to effectively manage environmental
problems. At the heart of the problem is the failure of many smaller federal agencies to embody
environmental compliance in systems that seize their employees' attention, such as management
commitment, reward systems, or personnel performance evaluation criteria.
A CFA Task Force was formed to develop a strategy to improve the environmental performance of
CFAs. The CFA Task Force, led by EPA, includes members representing the following agencies:
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Department of Agriculture
Department of Commerce
Department of the Interior
Department of Justice
Department of Transportation
Department of Treasury
Department of Veterans Affairs
Bureau of Prisons
Central Intelligence Agency
Economic Development Administration
Federal Aviation Administration
Food and Drug Administration
General Services Administration
Indian Health Service
National Aeronautics and Space Administration
National Oceanic and Atmospheric
Administration
National Security Agency
Tennessee Valley Authority
U.S. Coast Guard
U.S. Postal Service
Some of the CFA environmental performance initiatives are:
2.4.2.4
DOT has implemented several P2 initiatives such as affirmative procurement,
development and adoption of a P2 strategy, and development of a database to track
procurement of recycled materials
DOT has also initiated an environmental auditing program
Government Wide Initiatives
As a result of Executive orders and other factors, such as the reinventing government initiative, federal
agencies have introduced significant changes in their daily operations. The changes address goals such
as compliance with numerous Executive orders to reduce emissions from fossil fuels, purchase of
environmentally preferable products, and implementation of environmental justice strategies. In
addition, several federal facilities have entered into partnerships with EPA. A few of the many
programs and initiatives underway across the federal facility sector are described below.
Strategic Environmental Research and Development Program
The Strategic Environmental Research and Development Program (SERDP) is a multiagency (DoD,
DOE, and EPA) science and technology program established to address the defense-related concerns of
both DoD and DOE. SERDP brings together the institutional knowledge and expertise of all
participating agencies. More than 35 percent of projects conducted under SERDP involve partnerships
with industry to enhance efforts in technology transfer with the private sector.
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Western Governors' Association Technology Group
EPA, DoD, DOE, and DOI have agreed to work with the Western Governors' Association (WGA) to
use federal sites in the west for developing innovative technologies to address mixed radioactive,
military, mining, and munitions waste.
Federal Facility Roundtable
The Federal Agency Environmental Roundtable, on which 50 federal agencies are represented, works
to exchange information on policy, strategy, standards, and regulations. Topics of discussion include
the hazardous waste docket, proposed EPA strategies for national programs, technical information
systems, the NPL, and military base closures.
Federal Facilities Environmental Restoration Dialog Committee
The Federal Facilities Environmental Restoration (FFER) Dialog Committee is an advisory committee
under the Federal Advisory Committee Act (FACA). Its purpose is to provide a forum to identify and
refine issues related to environmental restoration activities at federal facilities. Its members include:
Several federal agencies (EPA, DoD, DOE, USDA, DOI, NASA, NOAA, and Agency
for Toxic Substances and Disease Registry [ATSDR])
National and local environmental, citizen, and labor organizations
Tribal governments and Native American organizations
State government agencies and state government associations
Environmental Justice
In 1994, President Clinton issued Executive Order 12898 entitled Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income Populations. The concept of
environmental justice means that all people have an opportunity to live in a healthy environment. All
people should be able to breathe clean air, drink clean water, and consume uncontaminated foods.
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The EO directs all federal agencies to develop environmental justice strategies to identify and address
disproportionately high and adverse human health or environmental effects of their programs, policies,
and activities on minority populations and low-income populations. The EO also established an
Interagency Working Group on Environmental Justice, which EPA chairs. Member agencies of the
working group include DOC, DoD, DOE, DOI, DOJ, DOL, DOT, HHS, HUD, USDA, and several
civilian agencies, including the Council on Environmental Quality and NASA.
During FY 1995, FFEO undertook an initiative to characterize and map the demographics of
communities in the vicinities of federal facilities. However, because federal facilities are distributed
widely throughout the United States, it is difficult, if not impossible, to formulate a general statement
that describes the demographics of a "typical" area in the vicinity of a federal facility. Facilities are
located in various geographic locations for specific purposes. Among others, those purposes include
equal distribution of federal facilities nationwide, security for certain military and research initiatives,
and fulfillment of the geographic needs of a particular project. Therefore, a single broad statement
cannot be made about the status of environmental justice in the federal facilities sector.
Miscellaneous Recycling Initiatives
Under EO 12873, all federal agencies are establishing or strengthening existing recycling programs.
Some examples are:
HUD headquarters in Washington, D.C. has captured an estimated 40 percent of its
waste through its paper, aluminum, and glass recycling program.
Lake City Army Ammunition Plant in Missouri recycles 85 percent of the facility's
waste, including everything from used oil to such materials as ballistic blasting sand.
2.4.3 Waste Generated in the Federal Facilities Sector
Some data are available on trends in generation of waste at federal facilities. Federal agencies report
waste generation data to the RCRA Biennial Report System (BRS). Data in the BRS are submitted by
facilities that have been required to file hazardous waste reports if they met the definition of large-
quantity generators during the reporting year or if, during the reporting year, they treated, stored, or
disposed of wastes designated under RCRA as hazardous on site in units subject to RCRA permitting
requirements.
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As Table 2-4 shows, for the 1993 BRS reporting year, the five RCRA wastes reported to be generated
in the greatest volume are:
Benzene
Corrosive waste
Chromium
Spent nonhalogenated solvents
Wastewater treatment sludges from electroplating processes
In 1993, federal facilities reported a total volume of RCRA waste generated of 20,828,211 tons. As
Table 2-4 indicates, benzene and corrosive waste both were reported to constitute more than 30 percent
of the wastes generated by federal facilities in 1993. (Since the table outlines the top five RCRA
wastes, the volume of waste does not total 100 percent.)
TABLE 2-4
TOP FIVE RCRA WASTES REPORTED IN 1993
TO BRS BY FEDERAL FACILITIES
Chemical
Benzene
Corrosive waste
Chromium
Spent non-halogenated solvents
Wastewater treatment sludges
from electroplating processes
RCRA Waste Code1
D018
D002
D007
F003
F006
Percentage of Total Volume
of Waste Reported by Federal
Facilities in 1993 (%)
39
31
16
7
6
1 Wastes may be mixed with other RCRA wastes.
Table 2-5 shows, for the 1993 BRS reporting year, the top five sources of wastes reported by federal
facilities. Most of the wastes reported by federal facilities were generated from wastewater treatment
2-20
Version 1.2
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operations, at 46 percent of the total volume. Other processes other than surface preparation accounted
for 30 percent of the total volume of waste generated during that year.
TABLE 2-5
TOP FTVE WASTE SOURCES REPORTED IN 1993
TO BRS BY FEDERAL FACILITIES
Waste Source
Wastewater treatment
Other processes other than
surface preparation1
Caustic (alkali) cleaning
Electroplating
Stabilization
Volume of Waste (tons)
9,589,355
6,206,969
1,248,797
1,146,528
843,834
Percentage of Total Volume
of Waste Reported by Federal
Facilities in 1993 (%)
46
30
6
5
4
2.4.4
Comparison With The Private Sector
When federal facility expenditures and compliance rates are compared with private sector facilities, the
relative significance of environmental problems at federal facilities is apparent.
Comparison of Expenditures
Between 1972 and 1992, pollution abatement expenditures in both the private and the public sectors
have increased substantially. Table 2-6 below shows the extent of that increase:
'These processes were defined further in a comments field on the BRS reporting form. These comments were
unavailable at the time this draft was prepared.
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TABLE 2-6
EXPENDITURES FOR POLLUTION ABATEMENT BY
ECONOMIC SECTOR (IN BILLIONS OF 1987 DOLLARS)*
Economic Sector Area
Business
Personal (personal
consumption [e.g., motor
vehicle pollution abatement
devices])
Other (government capital
for publicly owned electric
utilities and public sewer
systems)
State (expenditures by local
authorities and federal
grants)
Federal (Federal
government)
1972$
$30.24
$3.45
$5.03
$3.69
$0.40
1992$
$55.99
$7.02
$9.54
$10.73
$1.04
* Source: 24th Annual Report of the Council on Environmental
Quality (1993)
Although the actual dollars spent have increased significantly, as Figure 2-6 shows, the proportion of
expenditures that is attributable to the government sector has remained stable.
Business $55.99
Personal $7.02
Private Sector
Government Sector
* in bMions of 1987 dollars
Federal $1.04
State $10.73
Other $9.54
Figure 2-6. Pollution Abatement Expenditures by Economic Sector (1992)
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Comparison of Compliance Rates
Below is a comparison of federal facility and private compliance rates where compliance indicates
percentage of facilities found to be complying with regulations.
Analysis of compliance rates under RCRA, CWA and CAA indicates that the federal facility sector has
compliance rates that are slightly better than those of the private sector under two of the statutes tracked
inFFTS:
Private sector compliance with regulations under RCRA governing treatment, storage
and disposal facilities remained the same between FYs 1993 and 1994; however,
compliance rates in the federal facility sector increased 6.2 percent over this period.
For major sources identified under the CAA, compliance by both the private sector and
federal facilities increased slightly between FYs 1993 and 1994. Compliance by the
private sector increased 0.5 percent while the compliance rate of the federal facility
sector increased 0.9 percent.
Private sector compliance with National Pollutant Discharge Elimination System (NPDES) regulations
established under the CWA increased slightly by 1 % between in FYs 1993 and 1994; however,
compliance by federal facilities decreased by 10 percent over this period. Chapter 3 of this notebook
provides more information about the compliance record of federal facilities.
Table 2-7 summarizes some of the environmental programs, activities, and operations of the federal
facility sector.
2-23 Version 1.2
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TABLE 2-7
MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND OPERATIONS*
Federal Agency and Its Mission
Department of Defense -- Maintain
readiness
Department of Energy - Provide
technical information and the
scientific and educational foundation
necessary to achieve efficiency in
energy use, diversity in energy
sources, a more productive economy,
improved environmental quality and a
secure national defense
Civilian Federal Agencies (see next
page)
As tracked by pFTS
Operations
Vehicle and aircraft
Maintenance
Fuel Storage
Electroplating
Printing and photo-
processing
Wastewater treatment
Hospital operations
Laboratory research
Office operations
Vehicle and aircraft
Maintenance
Fuel Storage
Electroplating
Printing and photo-
processing
Wastewater treatment
Laboratory research
Office operations
Vehicle and aircraft
Maintenance
Fuel Storage
Printing and photo-
processing
Wastewater treatment
Hospital operations
Laboratory research
Office operations
Number of
Facilities
5,412
393
* 10,075
CERCLA
NPLShes
129
19
12
Key Environmental Laws
RCRA (Subtitles C&D)
CERCLA
CAA
CWA
SDWA
NEPA
RCRA (Subtitles C&D)
CERCLA
CAA
CWA
SDWA
NEPA
RCRA (Subtitles C&D)
CERCLA
CAA
CWA
SDWA
NEPA
FY94
Environmental
Budget
$5,246,000,000
$6,175,000,000
$201,000,000
P2
Progr&iu
In Place
/
/
Varies
El
Program
In Place
/
/
Varies
Key EPA Sector Manuals
that Apply
Electronics, Inorganic Chemicals,
Fabricated Metal Products, Motor
Vehicle Assembly, Organic
Chemicals, Printing,
Transportation Equipment
Cleaning, Non-ferrous Metals
Electronics, Inorganic Chemicals,
Fabricated Metal Products,
Organic chemicals. Metal Mining,
Stone, Clay, Glass, and Concrete
Electronics, Inorganic Chemicals,
Fabricated Metal Products,
Organic chemicals, Metal Mining,
Stone. Clay, Glass, and Concrete
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TABLE 2-7 (continued)
MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND OPERATIONS*
Federal Agency and Its Mission
Department of Transportation -
Execute national transportation policy
and ensure the safety and reliability
of all forms of transportation
Department of the Interior - Provide
administration, conservation,
preservation, and management of
federal land, resources, and water
systems
U.S. Postal Service - Provide mail
processing and delivery services to
individuals and businesses within the
U.S.
Department of Agriculture - Address
national policy and programs related
to: farm income, agricultural
markets, poverty, hunger, and
malnutrition, and conduct research,
and inspections
Operations
Laboratory research
Office operations '
Vehicle aircraft abd vessel
maintenance
Printing and preprocessing
Fuel storage
Vehicle maintenance
Office operations
Wastewater treatment
Laboratory research
Printing
Vehicle maintenance
Painting
Office operations
Vehicle maintenance
Laboratory research
Printing
Number of
Facilities
1,464
1.200
1,026
836
CERCLA
NPLSHes
TBD
TBD
TBD
TBD
Key Environmental Laws
NEPA
RCRA (Subtitle D)
CAA
RCRA (Subtitles CAD)
CERCLA
SDWA
CWA
NEPA
RCRA (Subtitle C)
RCRA (Subtitles C&D)
CERCLA
CAA
FIFRA
TSCA
FY94
Environmental
Budget
TBD
TBD
TBD
TBD
P2
Program
in Place
^
/
/
/
EJ
Program
in Place
TBD
TBD
TBD
TBD
Key EPA Sector Manuals
that Apply
Printing
Transportation Equipment
Cleaning
Printing
Transportation Equipment
Cleaning
Printing
Transportation Equipment
Cleaning
Inorganic Chemicals
Organic Chemicals
Transportation Equipment
Cleaning
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TABLE 2-7 (continued)
MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND OPERATIONS'
Federal Agency and Its Mission
General Services Administration -
Address federal procurement, real
property management, information
resources management, and
management of diversified
government operations
Department of Veterans Affairs -
Operate programs to benefit veterans
and members of their family
Department of Commerce -
Encourage, serve, and promote the
nation's international trade, economic
growth, and technological
advancement
Department of Justice - Serve as legal
counsel for the citizens of the United
States
Department of Health and Human
Services - Implement policy on
health, welfare, and income security
Department of Labor - Implement
policy regarding wage earners, their
working conditions, and their
employment opportunities
Operations
Vehicle maintenance
Office operations
Printing
Hospital operations
Office operations
Printing
Aircraft and vehicle
maintenance
Fuel storage
Printing and photo-
processing
Wastewater treatment
Office operations
Vehicle maintenance
Office operations
Office operations
Office operations
Number of
Facilities
700
250
229
184
170
122
CERCLA
NPL Sites
TBD
TBD
TBD
TBD
TBD
TBD
Key Environmental Laws
RCRA (Subtitles CAD)
RCRA (Subtitles C&D)
RCRA (Subtitles C&D)
SDWA
CWA
CAA
NEPA
RCRA (Subtitle C)
RCRA (Subtitles C&D)
RCRA (Subtitle D)
FY94
Environmental
Budget
TBD
TBD
TBD
TBD
TBD
TBD
P2
Program
In Place
/
/
TBD
/
/
TBD
EJ
Program
In Place
TBD
TBD
TBD
TBD
TBD
TBD
Key EPA Sector Manuals
that Apply
Printing
Transportation Equipment
Cleaning
None
Printing
None
None
None
226
Version 1.2
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TABLE 2-7 (continued)
MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND OPERATIONS*
Federal Agency and Its Mission
Tennessee Valley Authority - Conduct
a unified program of resource
development for the advancement of
economic growth in the Tennessee
Valley region
Environmental Protection Agency -
Protect and enhance the environment
under laws enacted by Congress
Department of Housing and Urban
Development - Conduct programs
addressing housing needs, fair
housing opportunities, and
development of communities
National Aeronautics and Space
Administration - Research flight
within and outside the earth's
atmosphere
Treasury Department - Formulate
financial policy while serving as the
nation's financial agent, enforcing the
law, and manufacturing coins and
currency
Department of State - Advise the
President in the formulation and
execution of federal policy
Operations
Vehicle maintenance
Laboratory research
Office operations
Laboratory research
Office operations
Vehicle maintenance
Office operations
Office operations
Laboratory research
Wastewater treatment
Printing
Vehicle maintenance
Electroplating
Vehicle maintenance
Printing and
preprocessing
Office operations
Office operations
Number of
Facilities
121
87
68
57
33
13
CERCLA
NPL Sites
TBD
TBD
TBD
TBD
TBD
TBD
Key Environmental Laws
RCRA (Subtitles C&D)
TSCA
FIFRA
CWA
SDWA
RCRA (Subtitles C&D)
CWA
CAA
RCRA (Subtitle D)
RCRA (Subtitle D)
CWA
SDWA
NEPA
RCRA (Subtitle D)
RCRA (Subtitle D)
FY94
Environmental
Budget
TBD
TBD
TBD
TBD
TBD
TBD
P2
Program
In Place
S
J
TBD
/
/
TBD
EJ
Program
In Place
TBD
/
TBD
TBD
TBD
TBD
Key EPA Sector Manuals
that Apply
Transportation Equipment
Cleaning
Printing
Transportation Equipment
Cleaning
None
Transportation Equipment
Cleaning
Printing
Transportation Equipment
Cleaning
None
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TABLE 2-7 (continued)
MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND OPERATIONS'
Federal Agency and Its Mission
Federal Home Loan Bank Board
Department of Education - Establish
policy for, administer, and coordinate
most federal assistance to education
Federal Energy Administration (TBD)
National Science Foundation -
Promote the progress of science and
engineering
Smithsonian Institution - Provide
public education and national service
in the arts, sciences, and history
Federal Communications Commission
Regulate interstate and international
communication by radio, TV, wire,
satellite, and cable
Federal Emergency Management
Agency - Work to reduce risks,
strengthen support systems and help
people and their communities prepare
for and cope with disasters
International Communication Agency
Community Services Administration
Operations
Office operations
Office operalions
Office operations
Office operalions
* Laboratory research
Office operations
Office operations
Office operations
Vehicle maintenance
Office operations
Office operations
Number of
Facilities
10
8
8
10
6
2
2
2
1
CERCLA
NPL Sites
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
Key EnTrroomental Lam
RCRA (Subtitle D)
* RCRA (Subtitle D)
RCRA (Subtitle D)
RCRA (Subtitle D)
RCRA (Subtitles CAD)
RCRA (Subtitle D)
RCRA (Subtitle D)
RCRA (Subtitle D)
RCRA (Subtitle D)
FY94
Environmental
Budget
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD-
n
Program
In Place
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
EJ
Program
In Place
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
Key EPA Sector Manuals
-: iwitXW .<'*,
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
2-28
Version 1.2
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TABLE 2-7 (continued)
MATRIX OF FEDERAL FACILITY SECTOR PROGRAMS, ACTIVITIES, AND OPERATIONS'
Federal Agency and Its Mission
Immigration and Naturalization
Service - Facilitate entry of legally
admissible people, grant benefits to
those seeking naturalization, prevent
unlawful entry or receipt of benefits,
and apprehend illegal aliens
Operations
Office operations
Vehicle maintenance
Number of
Facilities
1
CERCLA
NPL Sites
TBD
Key Environmental Laws
RCRA (Subtil!: D)
FY94
Environmental
Budget
TBD
P2
Program
In Place
TBD
EJ
Program
In Place
TBD
Key EPA Sector Manuals
that Apply
TBD
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Version 1.2
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3.0 COMPLIANCE AND ENFORCEMENT
This chapter describes compliance and enforcement activities at federal facilities. Compliance with a
statute or regulation or with requirements of a program generally indicates that the obligation is being
met by the regulated community, as required by applicable laws, regulations, policies, and guidances.
EPA monitors compliance through the conduct of inspections. Enforcement comprises those judicial
and administrative actions (both civil and criminal) that are taken by the government enforcement
authority when a member of the regulated community is not in compliance.
3.1 NUMBERS OF INSPECTIONS
This section provides information from various EPA databases on compliance and enforcement
activities at federal facilities. Information for FYs 1992, 1993, and 1994 is presented in Figure 3-1 for
the following environmental programs: RCRA, CWA, CAA, TSCA, and SDWA. For a given
program, a number of indicators can be used to assess compliance at federal facilities. For example,
compliance can be expressed as the percentage of facilities inspected that were cited for violations or
the percentage of facilities having violations against which an enforcement action was taken.
Compliance indicators that are intended to measure the level of relatively serious noncompliance at
major federal facilities are listed below:
Statute Compliance Indicator
RCRA Percentage of inspected Treatment,
Storage and Disposal Facilities
(TSDF) found to be in compliance
CWA Percentage of inspected federal
facilities found to be in compliance
CAA Percentage of inspected federal
sources found to be in compliance
TSCA Percentage of inspected federal
facilities found to be in compliance
SDWA Percentage of federal systems found
to be in compliance
3-1 Version 1.2
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r»
8
Q.
O
O
140
120
100
80
60
40
20
FY 1991
FY 1992
FY 1993
FY 1994
Rounded off to the nearest 10 FY 1991
Figure 3-1. Changes in Federal Facility Compliance Indicators
Regulatory Act
RCRA
E3CWA
HCAA
STSCA
dSDWA
3-2
Version 1.2
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Using FY 1991 as the base year, Figure 3-1 standardizes each of the compliance indicators listed
above. Standard indicators measure changes in compliance for the various programs in the same way
the consumer price index measures changes in the rate of inflation relative to a given base year. The
purpose of standardization is to avoid potentially misleading comparisons of absolute levels of
compliance (that is, compliance rates) and to focus instead on measuring changes in compliance over
time.
As Figure 3-1 indicates, the level of compliance by federal facilities with most major environmental
statutes and programs has declined since FY 1991. The most significant decline occurred in programs
conducted under CAA and TSCA, with the percentage of inspected federal facilities in compliance
decreasing by almost seven percent, compared with FY 1991. Compliance rates under SDWA and
CWA decreased at rates ranging from 2.5 percent to 4.1 percent, compared with FY 1991. It should
be noted, however, that the level of compliance with CWA at federal facilities increased sharply during
FY 1992 and FY 1993, before declining in FY 1994.
In contrast, the percentage of inspected federal TSDFs not cited for Class I violations under RCRA
increased by nearly 14 percent, compared with FY 1991. It is important to note, however, that
changes in compliance do not necessarily indicate the absolute levels of compliance.
Figure 3-2 summarizes the number of inspections for FY 1994 conducted on the RCRA TSDF
program. As the figure indicates, DoD had the greatest number of inspections under the RCRA TSDF
program, a circumstance that is attributable to the large number of RCRA-regulated DoD facilities and
the intensity of EPA inspection activities at those facilities.
3.2 REVIEW OF MAJOR ENFORCEMENT ACTIONS
The Federal Facilities Multimedia Enforcement Compliance Program (FMECP) is a national program
designed to use multimedia inspections to assess the compliance of federal facilities with environmental
laws. Under the program, each of EPA's 10 regional offices conducts a series of coordinated
multimedia team inspections, in concert with the appropriate state officials. During FYs 1993 and
1994, FMECP inspections were conducted at a number of high-risk federal facilities throughout the
nation.
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EPA Regions and states participating in FMECP conducted 41 multimedia compliance inspections
during FY 1993. More than 80 percent of the inspections were conducted at DoD facilities. Together,
EPA and states issued 75 enforcement actions, ranging from warning letters to formal administrative
orders that included penalties. Inspectors noted violations of nine environmental statutes.
Approximately 51 percent of all inspected facilities were found to be in violation of more than one
statute. The four statutes violated most frequently were RCRA, TSCA, CAA, and CWA.
Below are brief descriptions of some of the major federal facility enforcement cases and creative tools,
such as supplemental environmental projects (SEP), that are being used in settling the cases. The
descriptions provided are intended merely as examples and are not comprehensive. A comprehensive
list of cases and SEPs can be obtained directly from FFEO.
3.2.1 Review of Major Cases
Since the passage of the FFCA, EPA has initiated approximately 20 enforcement actions against federal
facilities. Settlement has been reached in many of those cases. In even more, negotiations are
underway. Discussed below are several examples of enforcement cases involving federal facilities.
EPA has sought a penalty of $346,500 and closure of an open-burning and open-
detonation unit at Lackland Air Force Base in Texas.
At the Naval Construction Battalion Center (NCBC) in Rhode Island, EPA Region I
issued a complaint against the Navy, assessing penalties for violations of RCRA. An
inspection found a number of violations. The case was settled in June 1994, with the
penalty reduced by approximately 50 percent.
Fort Richardson and Fort Wainwright in Alaska were issued complaints for similar
violations. EPA Region 10 issued a complaint and compliance order to each
installation for failure to obtain a RCRA permit or follow the requirements of such a
permit.
At Fort Hood in Texas, EPA and the state enforcement agency are seeking substantial
administrative penalties and possibly criminal penalties for a variety of violations. The
actions by the agencies seek more than $1 million, one of the largest penalties ever
proposed against a military facility.
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3.2.2 Supplemental Environmental Projects
Although assessment of penalties sends an important and strong deterrent message to the regulated
community, penalties are not the only means of enforcing environmental goals. SEPs are
environmental projects and other measures for which, once negotiated, EPA can reduce penalties. The
reduction is made in exchange for enforceable agreements to complete environmentally beneficial
projects that go beyond the injunctive relief EPA otherwise could order. Through SEPs, federal
facilities can demonstrate with actions an improved attitude about environmental issues.
Since the passage of the FFCA, EPA has had time to negotiate only a few SEPs with federal facilities,
including those described below:
At the Iowa Army Ammunition Plant, EPA agreed to a $300,000 SEP that would
eliminate completely discharges of treated pink water by recycling the water into the
explosive melt-and-pour washdown operations. If the Army performs the SEP pursuant
to the settlement, EPA Region 7 will reduce the penalty by an additional $63,218.
At Shemya Air Force Base in Alaska, EPA issued a complaint at that base because the
base stored more than 15 tons of hazardous wastes without obtaining the permit
required and because the base violated an earlier agreement to correct deficiencies in its
waste management practices. EPA Region 10 has negotiated a SEP, valued at
$150,000, for the construction and operation of a RCRA 10-day transfer facility for
remote Air Force sites in Alaska. Under the SEP, the Air Force will construct a
covered diked area to contain as many as 10 aircraft pallets of hazardous waste.
A SEP, valued at approximately $17,000, was agreed upon at Ft. McCoy in Wisconsin.
Under the SEP, the Army will purchase five parts washers that are expected to reduce
production of waste solvent at Ft. McCoy by as much as 80 percent. Specifically, the
SEP involves changes in the industrial process to replace five solvents with hot water
and mild detergents.
Under another SEP, agreed upon at DOE's Fernald, Ohio site, DOE will pay a cash
penalty of $50,000, spend $2,000,000 implementing a SEP, and meet several other
requirements. Implementation of the SEP required under this settlement will reduce
significantly discharges of uranium from the Fernald site to the Great Miami River.
A 1995 multimedia inspection at Air Force Plant No. 6 in Marietta, Georgia found
them out of compliance with both RCRA and the CAA. The state of Georgia issued
compliance orders for both violations. As an SEP, the total penalty was reduced in
exchange for an accelerated compliance schedule.
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4.0 PROCESSES TYPICALLY FOUND AT FEDERAL FACILITIES
Because of the breadth of the government's mission, almost any type of industrial activity carried out in
the civilian sector likely is conducted somewhere in the federal sector. This chapter describes some of
the more common processes conducted by federal facilities in the pursuit of their missions. Such
activities include:
Aircraft, vessel, and vehicle maintenance
Fuel storage and refueling operations
Electroplating
Printing and photoprocessing
Hospital operations
Laboratory operations
Wastewater treatment plant operations
Office operations
The remainder of this chapter discusses those operations.
4.1 AIRCRAFT, VESSEL, AND VEHICLE MAINTENANCE
Aircraft, vessel, and vehicle maintenance include the simple routine procedures such as changing oil
and rotating and balancing tires, as well as the complete reworking of airframes, engines, and avionics.
Many DoD installations have motor pools that manage all aspects of truck and automobile maintenance
including car washes and paint booths. Other DoD facilities maintain facilities for the reworking of
aircraft. The National Park Service and the Forest Service, the U.S Post Office, NOAA, and the Coast
Guard and other federal agencies maintain facilities to repair vehicles. Many federal facilities have
some type of motorized watercraft on their property.
The remainder of this section discusses specific activities associated with maintenance. Such activities
include routine maintenance and cleaning, parts cleaning, and painting. Table 4-1 presents a list of
some of the processes and raw materials used in and wastes generated by such operations.
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TABLE 4-1
PROCESSES AND RAW MATERIALS USED IN AND WASTES GENERATED
FROM AIRCRAFT, VESSEL, AND VEHICLE MAINTENANCE ACTIVITIES
Typical Process
Removal of oil and grease
Cleaning of engines, parts, and
equipment
Cleaning of surfaces
Repair and replacement of
batteries
Oil changes
Rust removal
Typical Raw Materials Used
Degreasers, carburetor
cleaners, engine cleaners,
solvents, acids, alkalis
Degreasers, carburetor
cleaners, engine cleaners,
solvents, acids, alkalis,
cleaning fluids
Detergents, solvents, acids,
caustics
New batteries, lead casings,
acid
Oil
Naval jelly, strong acids,
strong caustics
Waste Generated
Ignitable wastes, spent
solvents, combustible solids,
waste acid and alkaline
solutions
Ignitable wastes, spent
solvents, combustible solids,
waste acid and alkaline
solutions
Wastewater, spent solvents,
waste acid and caustic
solutions
Spent lead casings, spent acid
Spent oil and oil filters
Waste acid and caustic
solutions
4.1.1
Routine Maintenance and Cleaning Operations
Routine maintenance can involve several processes, depending on the level of service performed. Routine
or periodic maintenance covers a broad range of activities, including fluid changes, tuneups, transmission
maintenance, brake service, battery repair or replacement, and front-end alignment. Routine maintenance
activities include replacing broken or worn-out parts; performing oil changes; lubricating moving parts;
and replacing fluids, such as transmission fluid and engine coolant (antifreeze). Periodic replacement of
batteries, tires, and brakes also is necessary. Routine maintenance also requires that parts from aircraft
and vehicles be disassembled and cleaned periodically. Parts cleaning is discussed separately below.
Cleaning operations typically are conducted at a washrack or area where vehicles, vessels, or aircraft are
washed. Wheeled vehicles often are put through the equivalent of a carwash, while such tracked vehicles
as tanks may drive through a pool to remove some of the heavier accumulations of dirt. For aircraft
cleaning hand-held spray nozzles, hoses, and brushes are used. Detergents are used to clean the outer
surfaces of aircraft and vehicles.
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4.1.2
Parts Cleaning
Many industrial operations at federal facilities involve cleaning of various parts. In aircraft, vessel, and
vehicle maintenance operations, cleaning of parts also is a significant portion of the operation. Typical
cleaning processes used at federal facilities include cleaning of parts (such as cylinder heads and gears) with
solvents, acids, or caustics or with detergents or surfactants. Solvent cleaning is used to remove dirt, oil,
grease, and paint. The most common types of solvent cleaning are vapor and ultrasonic vapor degreasing
and emulsified solvent degreasing. Detergents or surfactants can be used to remove dirt, oil, and grease
to prepare a surface for another operation or as part of a periodic maintenance operation. Table 4-2
presents some of the wastes commonly generated in parts cleaning.
TABLE 4-2
PROCESSES AND RAW MATERIAL USED IN AND WASTES
GENERATED FROM PARTS CLEANING
Typical Process
Solvent cleaning
Acid cleaning
Caustic cleaning
Typical Raw Materials Used
Halogenated and nonhalogenated
solvent, thinners
Acids (phosphoric, chromic,
hydrochloric)
Alkaline solutions (caustic soda,
phosphates)
Surfactants, aqueous cleaners
Waste Generated
Volatile organic compounds (VOC)
(1,1,1-trichloroethane; xylene;
mineral spirits), spent solvent,
ignitable wastes, solvent wastes, still
bottoms
Spent acid (possibly containing
metals), corrosive wastes, metal
wastes
Spent caustic solutions, corrosive
wastes, metal wastes
Wastewater
4.1.3
Painting Operations
Paint shops are among the most common establishments at mid-size and large federal facilities, such as
those operated by DoD, DOE, DOI, and DOC. Painting operations generate both solid and hazardous
wastes including waste solvent, paint, sandblasting grit, and rags, and can also produce air emissions and
discharges to wastewater treatment plants. Painting operations can range from spot painting with a spray
can to spray painting large vehicles, aircraft and boats. Paint shops also are responsible for painting
buildings, preparing signs, and providing other miscellaneous functions.
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There are three basic steps in most paint operations: surface preparation, painting, and equipment cleaning.
Table 4-3 presents a list of some of the typical wastes generated and the steps are described separately
below.
TABLE 4-3
RAW MATERIAL INPUTS AND WASTES GENERATED FROM PAINTING OPERATIONS
Typical Process
Surface preparation
Painting
Equipment cleaning
Typical Raw Materials Used
Clean blasting grit, solvents,
detergents
Paint, lacquer, varnish,
primers
Solvents, thinners, water
Waste Generated
Blasting grit, paint solids,
paint sludge, spent solvents,
wastewater
Paint solids, waste paint,
thinners, VOC emissions
Spent solvents, thinners,
wastewater, VOC emissions
Surface Preparation
Very few surfaces can be painted without some form of preparation. Proper surface preparation is essential
to ensure adequate adhesion, durability, and dependability of the coating. Without a properly cleaned
surface, even the most expensive coatings will fail to adhere or prevent corrosion.
Surface preparation involves two steps: removing the old finish and cleaning the surface for die new finish.
Processes used to accomplish those results include cleaning the surface with a detergent or solvent and
solid-medium or bead blasting. Detergents remove most surface dirt and residue. Solvents can remove
oils and greases and can be used to strip paint as well. Vapor degreasing and acid or caustic baths, which
can be used to clean surfaces, are discussed in more detail in die previous section. Solid-medium or bead
blasting involves removing the surface with hard pellets or beads. The impact of the pellets or beads cause
the paint on the surface to flake off.
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Painting
The coating material to be applied may be a primer, sealant, or finish coat or another type of material, such
as an anti-corrosion coating. The coating material will have different components and properties depending
on its intended use. Paint usually will consist of a binder, a pigment, a solvent or thinner, and a drier.
Paint may be water-based or solvent-based.
Most paint spray-gun operations take place in a paint booth. A pressurized spray gun applies the paint as
a fine mist or aerosol. The spray gun is passed over the surface of the part to be painted until the coating
is of the proper thickness. A pressurized spray gun usually will transfer approximately 50 percent of the
paint to the surface. The rest of the paint that misses or bounces off the surface is termed overspray. The
booth usually has a system that is used to remove paint aerosols and volatiles from the air. In many
operations, the exhaust will have a dry filter to collect solids, as well.
Equipment Cleaning
Paint spray guns, brushes, booths, and other equipment must be cleaned after each use so that they can be
used again. Water and detergent are used for cleaning equipment that apply water-based coatings, while
solvents are used to clean equipment used for applications of solvent-based paint. Paint thinner is used to
clean the spray gun and nozzles to prevent clogging.
4.2 FUEL STORAGE AND REFUELING OPERATIONS
Another operation that commonly occurs at federal facilities is that of fuel management (tank farms).
These types of operations are found at DoD facilities, where they are managed by the Defense Fuel Supply
Center, and at DOE and CFA facilities, where the GSA typically oversees operations. Fuels managed
include various jet and other aviation fuels; gasoline; diesel fuel; fuel oil; and, in some cases heavier grades
of oils. Fuel management operations include tank and pipeline management, management of runoff and
environmental controls, and management of tank filling and refueling operations. These operations are
similar at both DoD and CFA facilities; they are discussed below. Table 4-4 lists some of the wastes
commonly generated in fueling operations.
4-5 Version 1.2
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TABLE 4-4
PROCESSES AND RAW MATERIALS USED IN AND WASTES
GENERATED FROM FUELING OPERATIONS
Typical Process
Tank and pipeline operation
Management of runoff and
environmental controls
Fueling and refueling
Typical Raw Materials Used
Blasting grit, solvents,
lubricating oil
Solvents, inorganic chemicals
Petroleum products
Wastes Generated
Blasting grit, paint solids,
paint sludge, spent
solvents, tank bottom
water
Tank bottom sludges,
wastewater treatment
sludges, contaminated
petroleum, VOC
emissions
Waste petroleum products
4.2.1
Tanks and Pipelines
Typically, both aboveground and underground storage tanks (UST) are found at tank farms. Tanks
typically are constructed of steel, concrete (often widi steel or other types of linings), or fiberglass-
reinforced plastic. Many of the tanks at federal facilities are more than 25 years old. Volumes of such
tanks range from a few thousand gallons, the sizes typically found at gasoline stations, to more than 2
million gallons.
Tanks may be concentrated in one area of a facility, or diey may be found at several locations. Tanks may
be located either above ground or underground:
Aboveground tanks are constructed of steel and may have either floating or fixed roofs.
As the name implies, floating roofs move up and down with the volume of fuel in the tank.
Rather than being welded to the tank wall, the roof is fitted with a seal that allows the roof
to rest on the top of the product and move up and down with the volume of product.
These tanks often are fitted with a cover to prevent rain from falling onto the roof and
seeping into the tank itself. Some older tanks may have been constructed with compacted
clay bottoms, rather than steel bottoms.
The construction of underground storage tanks is much more varied than that of
aboveground tanks, and they may be constructed of any of the materials listed above.
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The term pipeline has two meanings in the context of tank farms. Internal pipelines and manifolds found
throughout the tank farm allow the movement of product between tanks and to fueling points. Such
pipelines may extend for several miles throughout the facility to piers to allow ships to fuel or tankers to
unload, to airports, or to power plants or other industrial operations. The tank farm also may be served
by an external pipeline that provides product to the tank farm or allows the transfer of product from the
tank farm to remote locations.
4.2.2 Management of Runoff and Environmental Controls
One of the major concerns at fuel farms is the management of runoff from rainwater and other
environmental controls. Care is taken in the design of the tank farms to minimize the potential that runoff
from "dirty" areas (those areas where fuel is managed) will make its way to areas where fuel is not
managed. Clean runoff is discharged directly to storm-water systems. Runoff from fuel management areas
generally is discharged to treatment units, where fuel and other contaminants can be removed before the
runoff is discharged to the storm water system. The treatment units may be as simple as gravity-based oil-
water separators, or they may be extensive treatment systems designed to salvage the fuel for reuse.
Increasingly, environmental controls are being installed to treat other wastes generated from tank farm
operations, such as tank bottoms.
4.2.3 Tank Filling and Refueling Operations
Tanks may be filled by a variety of methods, including transfers from ocean-going tankers, railroad tank
cars, tanker trucks, and pipelines. Ocean-going tankers may unload at a remote sea buoy or at dockside.
Product is pumped from the vessels to onshore manifold systems that control the location at which the
product is stored. Transfers from railroad cars or trucks take place at specially engineered locations on
the tank farm.
Depending on the volume of fuel, refueling operations may be as simple as gasoline stations or as complex
as fuel stands for military tanker aircraft. The tank farm also may be used to transfer fuel to railroad or
truck tankers. In such cases, the same locations used for filling the tanks would be used for filling the
tankers. The refueling locations may be widely distributed around the facility at which the tank farm is
located.
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43 ELECTROPLATING
A key component of metal finishing operations at federal facilities is electroplating. Operations in which
electroplating is used can vary widely from electronic circuit board manufacturing to application of surface
finishes to a wide variety of fabricated metal parts from handguns to aircraft engines. Table 4-5 provides
a list of some of the more common waste generated in electroplating.
Electroplating is a process in which a thin metal coating is deposited through electrochemical reactions on
another surface. Ferrous and non-ferrous metals may be coated with a variety of common metals (copper,
nickel, lead, chromium, brass, bronze, zinc, cadmium, or combinations thereof) or precious metal (gold,
silver, platinum, or combinations thereof). In electroplating, metals supplied through the dissolution of
metals from anodes are attracted and adhere to the surface of the part to be plated, which is the cathode.
Depending on the metals involved, electroplating processes use acidic, alkaline, or neutral solutions.
TABLE 4-5
ELECTROPLATING-RAW MATERIAL INPUTS AND WASTES GENERATED
Typical Process
Typical Raw Materials Used
Wastes Generated
Surface preparation
Alkaline cleaners (sodium hydroxide,
sodium phosphate), acid cleaners (sulfuric,
nitric, and chromic acid), solvents,
emulsions, salt baths
VOCs, acid vapors,
alkalis, acids, spent
solvents containing
base metals from
parts being cleaned,
RCRA D- and F-
listed wastes
Common metals
electroplating (copper,
nickel, chromium, lead, and
tin)
Alkaline cyanide, acid sulfate,
pyrophosphate, fluoborate, sulfate-chloride-
basic acid, cadmium cyanide, fluosilicicate
and alkaline stannate
Cyanide and acid
vapors, nickel,
chromium (total),
chromium
(hexavalent), zinc,
cyanide, fluoride,
cadmium, lead, iron,
tin, phosphorus, total
suspended solids,
RCRA D- and F-
listed wastes
Precious metals
electroplating (gold, silver,
platinum)
Alkaline cyanide, neutral cyanide,
phosphate or sulfate concentrates,
potassium-based silver baths
Cyanide vapors,
silver, gold, cyanide,
platinum,
phosphorus, total
suspended solids,
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Some of the purposes of electroplating are to provide protection against corrosion, to provide an anti-
frictional surface, and to increase wear- or erosion-resistance. Electroplating also is used to manufacture
electronic circuit or printed wiring boards. In those processes, conductive metal is deposited on the surface
of the piece, either as a blanket coat in which a circuit pattern will be etched or on a piece that has a circuit
pattern defined by a nonconductive barrier layer (photoresist). The photoresist prevents the metal to be
plated from adhering to areas of the circuit board where the circuit pattern is not desired.
There is much more to electroplating than the simple plating of metal. The typical process can be broken
down into three steps:
Surface preparation, which includes conditioning the base material for plating;
Actual application of the plate
Posttreatment steps
A typical electroplating process consists of a series of plating baths and rinse tanks in which one or more
coatings are applied. The baths may consist of acids, bases, and salts (for example, cadmium cyanide)
depending on the function of the bath. Each bath will plate a different metal onto the part. The part is
dipped successively into the baths and rinsed between each bath. Either a perforated barrel or a rack is
used to dip parts into the plating baths and rinse tanks.
Hundreds of different electroplating solutions have been adopted commercially, but only two or three types
are popular for copper, zinc, brass, cadmium, silver and gold. Non-cyanide alkaline solutions containing
pyrophosphate or another agent have been used for zinc and copper. Zinc, copper, tin, and nickel also can
be plated with acid sulfate solutions. Cadmium and zinc sometimes are plated from neutral or slightly
acidic chloride solutions. In some cases, metal coatings can be applied by eiectroless plating. Electroless
plating is an integral function of a number of industries, such as aircraft, ship-building automotive, and
heavy machinery manufacturing operations. It is associated, in general, with industries whose products
must withstand unfavorable conditions or significant wear and abrasion. Electroless plating coats a part
with a uniform conducting layer on the entire surface of the substrate without outside current sources.
Copper and nickel eiectroless plating for printed circuit boards are the most common operations. In
eiectroless nickel plating, the source of nickel is a salt, and a reducer is used to reduce the nickel to its base
state. A complexing agent is used to keep the metal ion in the solution.
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4.4 PRINTING AND PHOTOPROCESSING
Many federal facilities have operations that require printing and photographic processing. Federal facilities
often are responsible for training military and civilian employees and therefore produce a variety of training
manuals and educational materials. Other communications materials also are printed as part of the various
missions. The five most common printing processes are:
Lithography
Gravure
Flexography
Letterpress
Screen
Lithography is the predominant printing process and is the only one that will be discussed here. Since the
basic operations that generate wastes from other types of printing are somewhat similar to lithography,
much of this information can be applied to all printing processes. Lithography is categorized by the type
of ink and press used in the process. Inks can be either heatset or non-heatset. Presses can be web or
sheet-fed.
Modern lithography is a photographic process that uses a printing plate to carry the image to be
reproduced. The plate then is attached to a cylinder on the press from which the image is transferred to
paper through the application of ink.
Photoprocessing operations are conducted at many DoD facilities and some CFAs, such as hospitals and
the DOI. Processing photographic film requires the use of a number of chemicals to develop and produce
finished photographic products. Two types of processing are black-and-white and color. In black-and-
white processing, the film is first processed in a developer solution, an alkaline solution of organic reducing
agents. The developer reduces the exposed silver halide crystals on the film to metallic silver. To prevent
the unexposed silver halide from being reduced, the action of the developer is arrested by transferring the
film to a stop bath. The stop bath is a weakly acidic solution that neutralizes the alkaline developer carried
over on the surface of the film. After the stop bath, the film is immersed in a fixer solution that solubilizes
and removes the remaining unreacted silver salts, rendering the image on the film permanent.
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The film now contains a negative image of the scene that was recorded by the photographer, A positive
print is prepared by exposing film, processing the negative through a similar set of operations (developer,
stop bath, fixer, and rinse). Color processing is a more complex process than black-and-white processing.
However, the basic steps are similar: developing bath, stop bath, fixer, and rinse. Depending on the type
of application, the sequence and number of steps may vary. Table 4-6 provides a list of some of the more
common wastes generated in printing and photoprocessing.
TABLE 4-6
RAW MATERIAL INPUTS AND WASTES GENERATED FROM
PRINTING AND PHOTOPROCESSING
Typical Process
Typical Raw Materials Used
Wastes Generated
Image processing/
photoprocessing
Lead, silver, sodium hypochlorite, acetic
acid, organic compounds
Lead, silver, organic
compounds
Printing
Benzene, cadmium compounds, carbon
tetrachloride, chromium compounds,
cumene, dibutylphthalate, diethanolamine,
ethyl benzene, ethylene glycol,
formaldehyde, glycol ethers, hexane,
hydrochloric acid, isophorone, lead
compounds, methanol methyl ethyl ketone,
methyl isobutyl ketone methylene chloride,
perchloroethylene propylene oxide, toluene,
2,4-toluene disocyanate 1,1,2-
trichloroethane, trichloroethylene
vinyl chloride, xylenes -
Metal wastes,
solvents, other
organic compounds
4.5 HOSPITAL OPERATIONS
The Department of Veterans Affairs (VA) operates a number of hospitals, as do the military services.
Hospitals are unique compared to other industries; they generate a large variety of wastes, but the volumes
are small compared with those generated by industrial facilities. Hospitals use hazardous materials and
toxic chemicals for numerous diagnostic and treatment purposes. Typical operations performed at hospitals
include: laboratory analyses (hematology, clinical chemistry, microbiology, and histopathology); surgery;
and patient care, both routine and that provided in specialty and intensive care units. Hospitals also
provide emergency and outpatient care services, such as hemodialysis. Hazardous materials and wastes
commonly generated by hospitals are provided in Table 4-7.
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TABLE 4-7
RAW MATERIAL INPUTS AND WASTES GENERATED FROM HOSPITALS
Typical Process
Typical Raw Materials Used
Wastes Generated
X-ray processing
Lead, silver, sodium hypochlorite, acetic
acid, organic compounds
Lead, silver, organic
compounds
Clinical and surgical work
Chemotherapy and antineoplastic
chemicals, formaldehyde, radionuclides,
solvents, mercury
Biomedical wastes,
waste anesthetic
gases, infectious
wastes, waste
solvents, waste
radionuclides
Laboratory analyses
Radionuclides, solvents, other toxic,
corrosive, and miscellaneous chemicals
Radionuclides,
solvents, biomedical
wastes, other toxic,
corrosive, and
miscellaneous
chemicals
4.6 RESEARCH LABORATORY OPERATIONS
Federally owned laboratories and research institutions include those operated by the USD A, EPA, DoD,
DOE and other CFAs. Activities conducted at laboratories include provision of analytical services. These
laboratories also conduct bench- and pilot-scale testing. Chemistry laboratories generally generate the most
hazardous waste, followed by biology and other types (materials science, chemical engineering, physics,
geology, etc.) of laboratories. Until recently, many researchers working in laboratories that generate
hazardous wastes did not know the requirements for proper disposal of wastes they handle.
Laboratory wastes differ from those of typical generators of hazardous waste in that laboratories use small
amounts of a wide range of chemicals. Industrial generators in contrast may generate large quantities of
just a few different waste streams. The volume of waste generated at laboratories ranges from ounces to
hundreds of gallons depending on the experiments being undertaken. Because research is difficult to
categorize, a list of typical waste streams associated with laboratory operations is provided below instead
of the tables provided elsewhere. These wastes include:
Inorganic acids and bases
Organic solvents
Pesticides and fertilizers
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Metals
Radionuclides
Unused chemicals
Reaction products from experiments
Waste oil
4.7 WASTEWATER TREATMENT PLANT OPERATIONS
Federal facilities generate large quantities of process and sanitary wastewater from many of the operations
described above. Aircraft and vehicle maintenance and electroplating operations are just two of the
operations that generate large quantities of wastewater.
Industrial process wastewater must be treated to reduce metal, organic, and other contaminants before they
are discharged. Federal facilities that have wastewater systems may also treat non-process wastewater -
for example, water system blowdown, and sanitary wastewater. Specific unit processes at wastewater
treatment plants vary, depending on the contaminant being treated. Wastewater treatment plants at federal
facilities include some or all of the following unit processes and wastes listed in Table 4-8.
TABLE 4-8
RAW MATERIAL INPUTS AND WASTES GENERATED FROM
WASTEWATER TREATMENT PLANTS
Typical Process
Typical Raw Materials Used
Wastes Generated
Primary clarifier
Secondary biological
treatment unit
Secondary clarifier
Advanced treatment units
Chemical treatment units
Chlorination and
dechlorination units
Sludge handling
Polishing ponds or tanks
Lime (coagulants), chlorine
(disinfectants), hypochlorite
(oxidizers)
Sludge and wastewater
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4.8 OFFICE OPERATIONS
Given its mission, the federal government is one of the largest generators of wastes associated with office
operations. These wastes are generated as part of the normal functions of any large bureaucracy and their
generation is difficult to discuss in terms of process operations because the processes are so varied.
Government office operations, like any similar organization, generate such waste as:
Paper and cardboard
Photocopier cartridges
Laser printer cartridges
Solvents
Computer disks
Glass
Aluminum cans
Many of these wastes are solid rather than.hazardous waste and as such are subject to RCRA subtitle D
rather than subtitle C requirements..
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5.0 P2 OPPORTUNITIES
This chapter provides some examples of P2 opportunities pertinent to each of the operations discussed
in Chapter 4. Many federal facilities have already begun implementing these and other P2 measures.
The opportunities identified here represent a synthesis of the literature and include recycling and waste
minimization in addition to P2. The discussion is not intended to be all-inclusive. For additional
information on P2 opportunities, consult the appropriate EPA guides to P2 or EPA sector notebooks.
One P2 technique that can be employed as a first step in any situation is examining P2 opportunities by
conducting an audit that evaluates the operation, the users, and the volumes of waste generated. An
audit can be conducted on any of the processes discussed in this notebook.
5.1 EXAMPLES OF P2 OPPORTUNITIES IN AIRCRAFT, VESSEL, AND VEHICLE
MAINTENANCE
P2 activities for aircraft, vessel, and vehicle maintenance include segregation of wastes, recycling, and
application of good management practices. P2 opportunities related to routine maintenance activities
include the recycling of used oil and other fluids, such as battery acid and antifreeze; batteries; tires;
and other parts, such as tire rims. P2 techniques for surface cleaning are aimed primarily at reducing
the amount of wastewater and the amount of pollutants and residues in the wastewater. It is likely that
P2 opportunities currently being carried out are inspired by the costs of treatment or disposal of
contaminated wastewater and the cost of cleaning solutions. Some of the less costly P2 options include
minor modifications of processes, operational changes, and recycling of wastes. Table 5-1 provides a
brief list of some of the P2 opportunities in aircraft, vessel, and vehicle maintenance and cleaning.
5-1 Version 1.2
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TABLE 5-1
P2 OPPORTUNITIES FOR AIRCRAFT, VESSEL, AND VEHICLE MAINTENANCE
Used Oil
Prevent spills through good housekeeping.
Install special "oil extender" filters in vehicles.
Waste Antifreeze
Substitute propylene glycol for ethylene glycol.
Install on-site recycling equipment for waste antifreeze.
Air Conditioning Refrigerants
Use on-site chlorofluoro carbon (CFC) equipment for recycling.
Old Batteries
Recycle.
Maintain batteries according to operating direction.
Miscellaneous Wastes (tires, engine components, brakes, and gasoline)
(rebuilt components such as carburetors, and water pumps).
Filter and reuse waste fluids
Catalytic Converters
Recycle to recover precious metals.
Cleaning Operations
Develop closed-loop systems for wash waters.
. Use wash waters from the final phase of cleaning in the initial phase.
P2 techniques that can be applied to parts cleaning operations can be classified as modifications of
equipment or operations, substitution of materials, and application of good management practices.
Many proven emission reduction and P2 measures have been incorporated into the national emission
standards for hazardous air pollutants (NESttAP) for halogenated cleaners. Although most methods of
parts cleaning offer opportunities for P2, only opportunities for P2 in vapor degreasing operations are
illustrated in Table 5-2.
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TABLE 5-2
P2 OPPORTUNITIES FOR VAPOR DECREASING
Equipment Modifications
Add peripheral condensing coils above the condenser coils to increase the thickness of the cold air blanket and prevent
emissions from open-top vapor cleaners.
Replace water in the freeboard condenser coils with a more efficient refrigerant.
Add a water-cooled tank jacket to prevent convection of solvent vapors up the hot walls of the cleaning unit.
Add a gravity solvent-water separator or a canister of desiccant to prevent or delay breakdown of the solvent, corrosion
of degreasing equipment, and elevated emissions caused by accumulation of moisture.
Ensure that the cover is manageable and tight-fitting so that it will be used regularly and be effective in preventing
emissions.
Process Modifications
To cause fewer emissions use mechanical or ultrasonic cleaning. The effectiveness of ultrasonic cleaning is improved
when solvents are heated to specific appropriate temperatures.
Material Substitutions
Aqueous cleaners, with or without added saponifiers, surfactants, detergents, agitation, pressure, alkalinity or heat
Semi-aqueous cleaners (also known as emulsion cleaners) that incorporate hydrocarbon solvents and water into the
cleaning and rinsing process
Aliphatic hydrocarbon solvents, including petroleum fraction hydrocarbons, such as mineral spirits, naphtha, kerosene,
and synthetic paraffinic hydrocarbons (especially appropriate in processes when contact with water must be avoided).
Miscellaneous organic solvents such as alcohols, ketones, and vegetable oils, that are less toxic solvents.
Catalytic wet oxidizers provide oxidation of organic contaminants in the presence of water.
Absorbent medium cleaners, such as cleaning wipes composed of specialty fibers designed to remove oil and other
contaminants.
Several solvent substitutes are found in the General Services Administration (GSA) is 1994 Environmental Products
Guide or DOE's Hazardous Solvent Substitution Data System.
Operational Modifications
To reduce emissions caused by drag-out, withdraw parts from the degreaser when they stop dripping; hold parts in the
freeboard zone until all parts are completely dry.
To hold parts, use fixtures that promote better draining.
Keep an idling degreaser covered.
Slow the speed at which pans are moved; keep large cross-sections of parts 50 percent smaller than the corresponding
degreaser section; and use sliding covers to reduce drafts and turbulence.
Minimize the use of sprays; when necessary, use high pressure low volume spray heads; keep the spray nozzle below the
cooling coils; and use short bursts of spray.
Consider superheating the vapor to allow pans to dry quickly.
Extend life of solvents through filtering and settling.
There also are several opportunities for implementing P2 activities to reduce or eliminate waste
generated during paint shop operations. Such opportunities include substitution of products and
modifications of equipment or operations. Table 5-3 provides some of the currently available P2
options in painting operations.
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TABLE 5-3
P2 OPPORTUNITIES FOR PAINTING OPERATIONS
Surface Preparation
* Minimize use of stripper.
Use spent stripper as a rough pre-stripper on die next item.
Consider ifae use of the following methods of stripping paint: dry ice pellets, abrasive media, plastic media bead-blasting', cryogenic,
thermal, wheat starch media, and laser or flash lamp.
Operational Modifications
Train spray pin operators in proper spray techniques to minimize generation of waste coating.
Pre-inspect parts to ensure it is dry, clean and dust-free, and to prevent painting of obvious rejects.
Schedule coatings to minimize color changes, or paint with lighter colors before darker colors to minimize the need for equipment cleanouts.
Mix only as much coating as is needed for a job. Train employees to estimate amounts and mix paints correctly.
Save off-color paint for other jobs.
Apply extra coats to use excess paint.
Avoid the need for re-coating by first inspecting the area to be painted
Waste Segregation
Segregate nonhazardous paint solids from hazardous paint solvents and thinner.
Segregate solvent waste streams and avoid dilution with water.
Separate solvents and foreign substances for recycling and reuse.
Separate thinners from paint sludges by gravity separation and reuse them.
Material Snbstiratiaos
Use powder crating; to eliminate VOC emissions and obtain high transfer efficiency.
Use water-based coating to reduce solvent emissions.
Eqnpmeot Mi
Modify the spray booth to allow recovery and reuse of overspray solids.
Size the paint cup on spray guns appropriately.
Automate spray and dip operations when possible.
Isolate spray booths for solvent-based coalings from spray booths for water-based coatings.
Keep solvent soak tanks away from heat sources.
Use high volume low pressure (HVLP) spray apparatus to increase transfer efficiency
Equipment Cleaning
Train employees to use only small amounts of solvents for cleaning.
Flush equipment first with dirty solvent before final cleaning with virgin solvent, or preclean items with rags before cleaning with solvents.
Use virgin solvents for final equipment cleaning, then reuse it as paint thinner.
Consolidate solvent cleaning operations and use a multipurpose solvent.
Reuse cleaning solvents for a resin system by allowing solids to settle out of solution.
Use pressurized air mixed with a mist of solvent to clean equipment.
Keep the washoff tank covered when it is not in use,
Minimize dripping by tilting or rotating parts to drain as much solvent as possible and by allowing sufficient dry time.
Use rags rather than disposable wipes whenever possible. Launder the rags in-house or locate a commercial laundry in the area that can
provide the service.
If disposable wipes are used, remove as much solvent from them as possible before disposing of them. Keep the used wipes and the spent
solvent in separate containers.
Use low-volume water cleaning systems.
If possible, return coatings with expired shelf life to the manufacturer, sell them, use them as primer.
5.2 EXAMPLES OF P2 OPPORTUNITIES IN FUEL STORAGE AND REFUELING
Fuel storage facilities present a number of opportunities for P2. These opportunities involve equipment
modifications, material substitution, and changes in operational practices. They are presented in Table
5-4 on the next page.
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TABLE 5-4
P2 OPPORTUNITIES FOR FUEL STORAGE OPERATIONS
Material Substitutions
Substitute JP-8 jet fuel for JP-4
Operational Modifications
Sell fuels no longer useabie under military specifications to civilian users
Maintain covers of above ground storage tanks to minimize infiltration by rainwater
Use non-lead based paints to paint above-ground storage tanks
Use high pressure low volume sprays for tank cleanout work
Process Modifications
Install recycling systems in environmental and runoff controls to remove waste fuel from wastewaters
53 EXAMPLES OF P2 OPPORTUNITIES IN ELECTROPLATING
There are several P2 opportunities at each stage of the plating process, including minimizing generation
of cleaning solutions and maximizing the lifetime of the plating solution. P2 techniques include
substitution of materials, statistical process control, and modification of processes. Table 5-5 on the
next page illustrates some common P2 techniques for these processes.
5.4 EXAMPLES OF P2 OPPORTUNITIES IN PRINTING AND PHOTOPROCESSING
Process modification and materials substitution are two P2 methods that can be used in printing and
photoprocessing. Table 5-6 provides a list of some of the more common P2 options used in printing
and photoprocessing.
5.5 Version 1.2
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TABLE 5-5
P2 OPPORTUNITIES FOR ELECTROPLATING
Material Substitutions
Use water treated by deionization, distillation, or reverse osmosis instead of tap water.
Consider hexavalent chromium alternatives and use of nonchelated process chemicals.
Switch to noncyanide plating solution.
Process Modifications
Extend the bath life through filtration, replenishment, electrolytic dumping, precipitation, monitoring, housekeeping,
reduction of drag-in, purer anodes, and bags and ventilation and exhaust systems.
Reduce process chemical drag-out by: minimizing concentrations of bath chemicals by maintaining chemistry at the
lower end of the operating range; maximizing operating temperature of the baths to reduce viscosity; using setting
agents to reduce surface tension of solution; maintaining racking orientations to maximize draining; withdrawing work
pieces at slower rates to allow draining before rinsing; using air knives above process tanks; avoiding plating bath
contamination of the plating bath; using drain boards between process and rinse tanks to route dripping fluids to
process tanks; and using drag-out tanks to recover chemicals for reuse.
Improve rinse efficiency of the rinse process through use of spray rinses and agitation of the rinse water, increased
contact time; and counter-current rinse systems, or flow controls. Reduce drag-in through better rinsing.
Reuse bath or rinse water from one process in another, if compatible.
Consider using spent process baths Ph adjusters.
Equipment Modifications
Use purer anodes.
Properly design and maintain racks.
Install a bath filter to remove impurities.
Replace cyanide-based plating solutions with cyanide-free solutions.
Metals Recovery Techniques
Evaporate rinse water by heating it and reuse concentrated solution.
Use reverse osmosis at high pressure, which allows water to pass through a membrane that retains metals, allowing
return of the metal solution and use of the water as rinse water.
Use ion exchange to recover metal ions in solution.
Consider electrolytic recovery and electrowinning or electrodialysis.
5-6 Version 1.2
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TABLE 5-6
P2 OPPORTUNITIES FOR PRINTING
AND PHOTOPROCESSING OPERATIONS
Plate Making
Use a coumercurrenl rinsing process during plate making.
Reduce drag-in of contaminants and reduce drag-out of solution by adding clapboards and extending drip time.
Monitor pH, temperature, and the strength of the solution frequently, to extend bath life.
Uie direct-to-plate technologies whenever passible; these allow preparation of plate from computer images without intermediate steps.
Eliminate metal etching or plating processes by substituting nonhazardous alternatives like prcsensmzed lithographic plates.
Use floating lids on bleach and developer tanks.
Use washless processing systems.
iSyrtem
Use waterless or dry printing whenever possible; it eliminates alcohol and fountain solutions altogether.
Ink System
Prepare and use the precise quantity of ink needed for a press run.
Cover all ink reservoirs or consider use of special non-drying aerosols that can be sprayed onto the ink system co prevent the ink from
drying overnight or during shutdown, thus preventing the ink from becoming unusable.
* Purchase inks in containers that can be returned to the supplier for refining or order ink in small containers to avoid storage of large.
partially-used containers.
Choose water-based inks, radiation curing, soy-based inks, or inks that contain low levels of toxic metals.
Use an automatic ink leveler.
Recycle inks, either on-lite or off-site. A common technique is the blending of various leftover color inks to produce black ink.
Cleaning System
Use a separate container of solvent for cleaning each color unit; collect the solvent and use it again for that color.
Adopt a standard ink sequence; doing so will eliminate the need to clean out the fountain solutions to change the ink rotation. Schedule
light colors first to reduce equipment cleaning frequency.
Clean the fountain solutions only when changing colors or when the ink may dry out between runs.
Replace conventional hazardous cleaning solvents with less hazardous alternatives.
Purchase solvents from a company that will pick up and recycle the spent solvent, whenever possible.
Reuse press wipes as long as possible. Use a dirty wipe for the first pass and a clean one for the second pass.
« Use rags rather than disposable wipes, whenever possible. Use a commercial rag cleaning business in the area that can provide the
service.
Photographic Processing
Extend Jives of photo and film developing baths by adding replenishers and regenerators.
Reduce the amount of waste containing silver by using films that do not contain silver.
Reclaim and recycle silver from photochemical wastewater.
Recycle photographic film and paper.
S3 EXAMPLES OF P2 OPPORTUNITIES IN HOSPITAL OPERATIONS
P2 opportunities at hospitals are somewhat limited by the practice of using disposables to prevent
transmission of diseases and bacteria. However, many hospitals can benefit from the adoption of good
management practices aimed at reducing or eliminating generation of waste. In addition to the
suggestions illustrated in Table 5-1, there are a number of general P2 practices that hospitals can
follow. These include:
5.7 Version 1.2
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Keep individual waste streams segregated.
Centralize purchasing and dispensing of drugs and other chemicals.
Test all new materials in small quantities before making bulk purchases.
Provide spill cleanup kits and train staff appropriately.
Inspect and maintain equipment to avoid leaks.
Neutralize acid waste with basic waste.
Use mechanical handling aids for drums to reduce spills.
Use automated metering systems for laundry chemicals.
TABLE 5-7
P2 OPPORTUNITIES FOR HOSPITALS
CTifmollieiapy
Optimize drag container sizes when purchasing.
Centralize chemotherapy compounding in a single location.
Minimize waste from cleaning of the compounding hood.
Formaldehyde
Minimize wastes from cleaning of dialysis machines and reverse osmosis (RO) units.
Use reverse osmosis water treatment to reduce demands for cleaning of dialysis.
Capture waste formaldehyde and consider its reuse in pathology or autopsy laboratories
Photographic I
Return off-specification developer to the manufacturer.
Cover developer and fixer tanks to reduce evaporation and oxidation.
Recover silver, waste film, and paper.
Use squeegees to reduce bath losses.
Use countercurrent washing.
Radionuclides
Use less hazardous isotopes when possible.
Segregate and label radioactive wastes, and store short-lived wastes on site until decay permits disposal.
Solvents
Consider solvent substitutes.
Reduce requirements for analytes.
Use premixed kits for tests involving solvent fixation.
Use calibrated solvent dispensers for routine tests.
Recover or reuse solvents through distillation.
Mercury
Substitute electronic sensing devices for devices that contain mercury.
Recycle uncontaminaied mercury wastes, using proper controls.
Wan* Anesthetic Gases
Employ low-leakage work practices
Purchase low-leakage equipment
5-8 Version 1.2
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5.6 EXAMPLES OF P2 OPPORTUNITIES IN RESEARCH LABORATORY OPERATIONS
P2 suggestions for laboratories include better operating and material management practices. P2
practices for laboratories are illustrated in Table 5-8.
TABLE 5-8
P2 OPPORTUNITIES FOR LABORATORIES
AND RESEARCH INSTITUTIONS
Material Management
Establish a centralized purchasing program.
Order reagent chemicals in conservative but realistic amounts.
Encourage suppliers of chemicals to become responsible partners (such as by accepting return of outdated supplies).
Establish an inventory control program that traces chemicals from cradle to grave.
Rotate chemical stock, using chemicals before expiration of shelf life.
Develop a running inventory or unused chemicals for use by other departments, if possible.
Perform routine self-audits.
Improved Laboratory Practices
Segregate solvents and recycle them.
When cleaning with solvents, reuse the spent solvent for the initial cleaning and use fresh solvent only for the final
rinsing.
Platinum, palladium, and rhodium contained in catalysts can be recovered through chemical procedures specific to
certain metals. Segregation of these waste for off-site recycling may be preferable.
Investigate whether unused reagent chemicals and their containers can be returned to the manufacturer. The supplier
may be able to resell sealed bottles of stable chemicals.
Designate a facility or area for storage, segregation, and treatment of waste.
Increase use of segregation of waste streams.
Ensure that all chemicals and waste are identified clearly on containers.
Other Suggestions
Design P2 into proposals for research activities, and build in funding for proper waste management.
Contact other labs before ordering chemicals and supplies to determine local availability, if possible.
Determine sample quantities needed and alternatives to sample analysis.
Expand use of microanalytical techniques.
Educate procurement personnel to identify opportunities for material substitution.
Explore the possibility of other uses for expired chemicals.
5.9 Version 1.2
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5.7 EXAMPLES OF P2 OPPORTUNITIES IN WASTEWATER TREATMENT PLANT
OPERATIONS
Many P2 techniques for wastewater treatment strive to reduce the amount of wastewater being
discharged from the source. Techniques related to source reduction were discussed earlier.
Improvement of wastewater treatment systems can be an effective P2 opportunity that often does not
require significant modifications of processes or equipment. Many wastewater streams can be treated
more effectively and economically if they are segregated from other streams that do not require the
same degree of treatment. Highly contaminated wastewater streams, oily wastewater streams, and
wastewater streams that contain contaminants that require specific treatment (for example, removal of
metals) can be segregated to reduce the volumes of wastewater undergoing certain treatment steps.
Treatment of wastewater also can be improved by adding stages, such as biological treatment, chemical
precipitation, filtration, ion exchange, and sludge dewatering, to improve the effectiveness of the
system and reduce treatment costs through reduction in the amount of sludge generated, recovery of
metal for resale, and replacement of more costly treatment stages. Table 5-9 lists some P2 options for
reducing generation of wastewater.
5-10 Version 1.2
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TABLE 5-9
P2 OPPORTUNITIES FOR WASTEWATER TREATMENT
Process Modifications
Reuse process water, if possible.
Prevent process water from leaking into noncontact cooling water or storm water. Test storm sewer piping for leaks.
Operate machinery at correct temperature and flow levels. Consider the use of automatic control and lock-out valves.
Segregate wastewater streams that require different levels of treatment.
Rinse Water Conservation
Install automatic flow controls or multiple rinse tanks in a counter-current series system (the latter can reduce generation of
wastewater by at least 90 percent).
Use drag-out recovery techniques.
Use sprays or mist to rinse off excess process solution, and agitate the rinse bath to increase its efficiency.
Cleaning System Modifications
Schedule the use of similar chemicals together to reduce the need for cleaning.
Maximize dedication of process equipment.
Attempt to remove residue remaining in equipment to avoid the need for cleaning.
Use process fluids to clean equipment, then recycle or blend them into the process stream.
Use steam to yield a smaller volume of wastewater, and recycle the steam.
Filter cleaning water to remove paniculate and reuse water.
Use compressed air to clean equipment or parts.
Treatment Alternatives
Use treatment technologies that do not generate heavy metal sludges.
Use different precipitating agents that can generate less sludge, such as caustic soda instead of lime.
Maximize recovery of materials from wastewaters.
Identify beneficial uses for sludge.
5.8 EXAMPLES OF P2 OPPORTUNITIES IN OFFICE OPERATIONS
The major opportunity for P2 activities in government offices, beyond the familiar recycling of paper
and photocopy machine and laser jet cartridges, is the paperless office. The concept of the paperless
office involves the use of computers, local area networks, and even the Internet, rather than paper, to
transmit information. Typically, officewide memoranda are sent to the e-mail addresses of all office
staff. Memoranda and work products also can be shared among individuals or small groups by this
method.
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APPENDIX A: KEY STATUTES AND EXECUTIVE ORDERS
THAT AFFECT FEDERAL FACILITIES
Version 1.2
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SUMMARY OF KEY STATUTES THAT AFFECT FEDERAL FACILITIES
Statute
Description
Relevance to Federal Facilities
Implementing Regulations
Clean Air Act
(CAA)
Title I requires EPA to identify "air
pollutants," adopt National Ambient Air
Quality Standards (NAAQS), and establish
technology-based New Source Performance
Standards (NSPS) and National Emission
Standards For Hazardous Air Pollutants
(NESHAP)
Title I also requires states to develop state
implementation plans (SIP)
Title II requires establishment of nationally
uniform emissions standards for automobiles
Title III authorizes citizen suits against
violators and judicial review of EPA actions
Title IV creates a system of marketable
allowances for sulfur dioxide emissions
Title V requires permits for all major sources
of air pollutants
Title VI contains provisions to phase out the
use of ozone-depleting chemicals, such as
chlorofluorocarbons, halons, carbon
tetrachloride, and methyl chloroform, as
required by the Montreal Protocol on
Substances That Deplete the Ozone Layer.
Federal facilities have been and will continue
to be significantly affected by provisions of
the CAA.
The NESHAP program also affects
federal facilities
Title III activities can affect federal
facilities extensively
Title VI requirements are particularly
important because of the need for many
ozone-depleting substances in weapons
systems. In addition, many of these
chemicals are used extensively by
federal facilities as refrigerants on ships
and airplanes.
Federal facilities are bound to adhere to
regulations that implement the CAA.
Those regulations are found in the Code of
Federal Regulations (CFR) parts 50-99.
Some key provisions include:
State-by-state implementation plans
are found at 40 CFR part 52
Standards of performance and
NESHAPs are found at 40 CFR part
60
Penalty assessment requirements are
found at 40 CFR part 66 and 67
Mobile source requirements are found
at 40 CFR pans 81 through 89
Clean Water Act
(CWA)
The CWA, first passed in 1972 and amended in
1977 and 1978, is the most comprehensive source
of federal regulatory authority to control water
pollution. In relation to federal facilities, it
specifically:
Establishes limits on effluents that prohibit
discharge of pollutants
Requires states to adopt water quality criteria
Requires EPA to adopt water quality
guidelines
Requires source performance standards based
on best demonstrated control technology
Requires dischargers of toxic pollutants to
meet limits on effluents
Establishes the national pollution discharge
elimination system (NPDES) permit program
Requires permits from the U.S. Army Corps
of Engineers (USAGE) for disposal of dredged
material into navigable waters
Authorizes citizen suits
Many federal facilities own and operate
permitted wastewater treatment systems that
treat industrial and domestic sewage
generated at the facilities.
Also, some stormwater runoff discharges at
federal facilities are subject to permitting
under NPDES.
Regulations under the CWA are
found at 40 CFR pan 100 through
140. Those regulations set forth
instructions for the NPDES program
and related wastewater treatment
activities
The guidelines for standards of
performance for new sources are
found at 40 CFR parts 400-699.
Those guidelines prescribe minimum
standards for treatment of a variety of
industrial sources, such as metal
finishing and explosives
manufacturing operations, and
hospitals
Regulations governing dredge-and-fill
operations are found at both 40 CFR
and 33 CFR
A-l
Versioh 1.2
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SUMMARY OF KEY STATUTES THAT AFFECT FEDERAL FACILITIES
Statute
Description
Relevance to Federal Facilities
Implementing Regulations
The
Comprehensive
Environmental
Response,
Compensation, and
Liability Act
(CERCLA or
Superfund)
Provides the basic legal framework for the
federal "Superfund" program to clean up old
hazardous waste sites.
Title in of the 1986 Superfund Amendments
and Reauthortzation Act (SARA) (also known
as the Emergency Planning and Community
Right-to-Know Act (EPCRA]) requires all
manufacturing facilities to report annually to
the public information about stored toxic
substances, as well as about release of such
substances, into the environment. The report
is known as the Toxic Release Inventory
(TRI).
Provides framework and guidance for
federal facilities to conduct installation
restoration, environmental restoration,
and similar programs.
Executive Order (EO) 12856 made the
TRI reporting requirement applicable lo
alt federal facilities. Consequently,
federal facilities were required to submit
their first set of TRI data to EPA on
July I, 1995.
The regulations governing Superfund
are found in 40 CFR part 300. They
are called the National Contingency
Plan (NCP). Although they do not
set forth any standards, they do
establish procedures and practices for
cleaning up a contaminated site.
The regulations governing
implementation of EPCRA are found
at 40 CFR parts 350-399
Toxic Substances
Control Act
(TSCA)
Gives the EPA comprehensive authority to
regulate any chemical substance whose
manufacture, processing, distribution in
commerce, use, or disposal may present an
unreasonable risk of injury to health or the
environment.
Regulates asbestos and radon inside buildings.
Federal facilities are affected by
regulations under TSCA because they
address both the handling and disposal
of substances regulated under TSCA
plus the remediation of asbestos and
radon.
Federal facilities handle many
substances regulated under TSCA, such
as polychlornated biphenyls (PCB).
Asbestos and radon problems are found
in many buildings owned by federal
agencies.
Regulations implementing TSCA are found
at 40 CFR parts, 700-799
Resource
Conservation and
Recovery Act
(RCRA)
Establishes standards and regulations
applicable to generators, transporters, and
owners or operators of hazardous waste
treatment, storage, and disposal facilities
(Subtitle C) and management of solid waste
(Subtitle D).
Contains provisions regulating underground
storage tanks (UST) that store petroleum and
chemical products.
Federal facilities are regulated stringently
under RCRA and subject to its corrective
action authority:
Almost all federal facilities generate
solid waste that requires disposal
Many also generate hazardous waste
through maintenance or manufacturing
activities
Some also are treatment, storage, or
disposal facilities.
Many store petroleum products in USTs
Regulations under the RCRA program,
which are found at 40 CFR parts 240-299,
govern waste management practices at
federal facilities.
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SUMMARY OF KEY STATUTES THAT AFFECT FEDERAL FACILITIES
Statute
Description
Relevance to Federal Facilities
Implementing Regulations
Pollution
Prevention Act
(PPA)
The PPA makes it a national policy of the United
States to reduce or eliminate the generation of
waste at the source whenever feasible. The EPA is
directed to undertake a multimedia program of
information collection, technology transfer, and
financial assistance to enable the states to
implement this policy and to promote the use of
source reduction techniques.
Federal facilities are implementing the PPA
through changes in policies and procedures
(hat govern acquisition and procurement.
The PPA is not implemented by federal
regulations.
federal
Insecticide,
Fungicide, and
Rodenticide Act
(FIFRA)
FIFRA provides a comprehensive framework for
regulating the sale and distribution of pesticides
within the United States. Under the statute, EPA
registers pesticides for either "general" or
"restricted" use. Once a pesticide has been
registered, its handling and distribution are
addressed. However, once a pesticide is in or on a
raw agricultural commodity, the pesticide is
regulated under the Federal Food, Drug, and
Cosmetic Act.
Federal facilities are affected by FIFRA
because pesticide application occurs at those
facilities.
The regulations, which are found at 40
CFR parts 152-186, govern federal
facilities' use of pesticides and worker
protection for their application.
National
Environmental
Policy Act (NEPA)
NEPA imposes environmental responsibilities on all
agencies of the federal government. NEPA makes
it the policy of the federal government to use all
practicable means (o administer federal programs in
the most environmentally sound fashion. NEPA
requires that decision-making processes of federal
agencies take into account environmental factors.
The agencies do so through the conduct of an
environmental assessment (EA) that often is
followed by an environmental impact statement
(EIS).
Federal facilities are affected by NEPA
every time a decision is made to expend a
"significant" amount of federal dollars.
Before that money can be spent, an EA or an
EIS must be conducted at the facility. Thus,
every time they build a road, bridge, or
building, federal facilities must assess the
environmental effects and make a finding of
no significant impact.
The regulations governing NEPA are
found at 40 CFR part 1500 et. seq.
federal Facilities
Compliance Act
(FFCA)
The FFCA was passed in 1992 to enable the EPA
and states to bring civil action against federal
agencies for violations of certain actions relating to
RCRA. Before the FFCA, the doctrine of
sovereign immunity prevented civil actions against
federal agencies. However, the FFCA states that it
is admissible to initiate civil action against a federal
agency. Criminal actions always have been
possible, under the criminal provisions of individual
statues.
Any civil action that may be brought against
a federal facility falls under the authority of
the FFCA.
The FFCA is not implemented by federal
regulations.
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EXECUTIVE ORDERS THAT IMPACT FEDERAL FACILITIES
Executive Order
Title
Requirements
Date Signed
12580
Superfund Implementation
Requires all federal agencies to
carry out the requirements of the
Superfund statutes
January 22, 1987
12856
Right-to-Know and Pollution
Prevention Requirements
Requires agencies to develop
pollution prevention (P2) strategies
and facility -specific plans for
eliminating acquisition,
manufacturing, and processing or
use of toxic chemicals or extremely
hazardous substances
August 3, 1993
12873
Acquisition, Recycling, and Waste
Prevention
Requires agencies to review and
revise specifications, product
descriptions, and standards and set
goals for waste prevention and
acquisition of recycled products
October 20, 1993
12902
Energy Efficiency and Water
Conservation
Requires agencies to undertake a
prioritization survey of all
facilities, leading to a 10-year plan
to conduct comprehensive energy
and water audits
March 8, 1994
12843, 12844, 12845
Ozone-Depleting Substances,
Alternative-Fuel Vehicles, and
Energy Efficient Computers
Directs agencies to change
procurement policies to reduce the
use of ozone-depleting substances;
asks each agency to adopt plans to
purchase and use alternative-fueled
motor vehicles; and requests that
agencies agree to buy energy-
efficient computers, monitors and
printers to the extent practicable.
April 21, 1993
12088
Federal Compliance with Pollution
Control Standards
Agencies must take all necessary
actions for the prevention, control,
and abatement of environmental
pollution with respect to their
facilities.
October 13, 1978
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APPENDIX B: SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
During the rulemaking process, federal facilities, like other members of the regulated community,
provide comments to the U.S. Environmental Protection Agency (EPA) on regulations as they are
proposed. Occasionally, EPA will invite one or two federal agencies to participate in the rulemaking
process. However, for the most part, EPA treats federal facilities in the same manner as other
regulated entities. Several forthcoming regulations may have a direct affect on the ability of federal
facilities to achieve compliance. Those identified in the Federal Register (FR) at the initial drafting
of this notebook (Spring 1995) are outlined hi the following pages. This summary may be updated in
future versions of this notebook.
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
Spent Solvents Listing
Determinations
40 CFR 261,271, and 302
Action will propose to list or not to list as
Resource Conservation and Recovery Act
(RCRA) hazardous wastes 14 spent
solvents and still bottoms, including:
limone, phenol, sophorine, acetonitrile,
furfurl, epichlorohydrin, methyl chloride,
ethylene dibromide, benzyl chloride, p-
dichlorobenzene, 2-methoxyethanol, 2-
methoxyethanol acetate, 2-ethoxyethanol,
acetate, and cyclohexanol.
Proposed Rule expected March 1995.
Final Rule expected May 1996.
Military Munitions:
Hazardous Waste Rule
Identification and
Management; Explosives
Emergencies; Redefinition
of On-Site
40 CFR 260, 261,262,
263, 264, 265, and 270
Proposed rule identifies when conventional
and chemical military munitions become
hazardous wastes subject to federal
hazardous waste transportation, storage,
treatment, and disposal rules. The rule
also amends existing regulations regarding
emergency responses as well as the
definition of "on-site," which applies to
generators of hazardous waste.
Proposed Rule November 8, 1995.
(60 FR 56467).
Final Rule expected July 1996.
Universal Waste Rule
(Hazardous Waste
Management System;
Modification of the
Hazardous Waste Recycling
Program)
40 CFR 260, 261,262,
264, 265, 266, 268, 270,
and 273
EPA promulgated streamlined hazardous
waste management regulations governing
the collection and management of certain
widely generated wastes (batteries,
pesticides, and thermostats) known as
universal wastes.
Proposed Rule February 11, 1993
(58 FR 8102).
Proposed Rule/Notice of Data Availability
June 20, 1994 (59 FR 31568).
Final Rule May 11, 1995
(60 FR 25492).
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
Hazardous Waste
Treatment, Storage, and
Disposal Facilities and
Hazardous Waste
Generators; Organic Air
Emission Standards for
Tanks, Surface
Impoundments, and
Containers
40 CFR 264 and 265
Investigating the health and environmental
impacts of non-combustion source air
emissions from hazardous waste treatment,
storage, and disposal facilities and to
develop standards for monitoring and
control as needed. Pollutants to be
considered include volatile organic
compounds, paniculate matter, specific
toxic substances, or a combination of these.
EPA has adopted a three phase approach:
Phase I regulates organic emission from
equipment leaks and process vents; Phase
II will address tanks, containers, surface
impoundments, and miscellaneous units;
and Phase HI will address residual risk
associated with particular hazardous
organic constituents.
Phase I: Proposed Rule February 5, 1987
(52 FR 3748); Final Rule June 21, 1990
(55 FR 25454).
Phase II: Proposed Rule July 22, 1991
(56 FR 33490); Final Rule December 6,
1994 (59 FR 62896).
Notice of postponed effective date, May
19, 1995 (60 FR 26828).
Proposed Rule data availability, August
14, 1995 (60 FR 41870).
Federal Facility
Compliance With RCRA
3004(i)/42 U.S.C. 6924(i)
With Respect to Mixed
Waste
N/A
Three years after passage of the Federal
Facility Compliance Act, the waiver of
sovereign immunity contained in RCRA
6001(a) becomes applicable to agencies of
the federal government fo> violations of
RCRA 3004(j) involving the storage of
mixed waste that is not subject to an
existing agreement, permit, or
administrative or judicial order.
Sovereign immunity protection for
violations of RCRA 3004(j) with respect
to storage of mixed waste expired October
6, 1995.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
Effluent Limitations
Guidelines, Pretreatment
Standards, and New Source
Performance Standards:
Metal Products and
Machinery
40 CFR 433, 438, and 464
EPA will establish technology-based limits
for the discharge of pollutants by existing
and new facilities that manufacture,
maintain or rebuild finished metal parts,
products or machines. The Phase I
regulation covers the following industrial
sectors: aircraft, aerospace, hardware,
ordnance, stationary industrial equipment,
mobile industrial equipment, and electronic
equipment. The Phase II rule will cover
eight industrial sectors: bus and truck,
household equipment, instruments, motor
vehicle, office machine, precious and
nonprecious metals, railroads, and ships
and boats.
Phase I: Proposed Rule May 30, 1995
(60 PR 28210); Final Rule expected
September 1996.
Phase II: Information Needed
Effluent Limitations
Guidelines, Pretreatment
Standards, and New Source
Performance Standards;
Centralized Waste
Treatment Category
40 CFR 437
EPA proposed technology-based, effluent
limitations, new source performance
standards, pretreatment standards for
existing sources, and pretreatment
standards for new sources for centralized
waste treatment facilities that receive
hazardous and non-hazardous industrial
waste from offsite for treatment or
recovery.
Proposed Rule January 27, 1995
(60 FR 5464).
Final Rule expected September 1996.
Effluent Guidelines and
Standards for the Industrial
Laundries Category
40 CFR 441
EPA will propose effluent limitations
guidelines for industrial laundries, which
supply laundered and dry-cleaned work
uniforms, wiping towels, safety equipment
(such as gloves and flame-resistant
clothing), dust covers and cloths, and
similar items to industrial and commercial
users.
Proposed Rule expected December 1996.
Final Rule expected December 1998.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
Effluent Guidelines and
Standards for the
Transportation Equipment
Cleaning Category
40 CFR 442
EPA will propose effluent limitations
guidelines for transportation equipment
cleaning facilities, which service tank
trucks, railroad tank cars, tank barges, and
aircraft exteriors (cleaning and de-icing).
Proposed Rule expected December 1996.
Final Rule expected December 1998.
Effluent Guidelines and
Standards for Pesticide
Formulation, Packaging,
and Repackaging
40 CFR 455
EPA will propose effluent guidelines and
standards for facilities that formulate,
package, or repackage registered pesticide
products, excluding the active ingredient
sodium hypochlorite (bleach).
Proposed Rule April 14, 1994
(59 FR 17850).
Final Rule expected September 1995.
Effluent Guidelines and
Standards for Landfills and
Incinerators
40 CFR 437
EPA will propose effluent guidelines and
standards for (1) industrial incinerators and
thermal destruction units; and (b) all
landfills with leachate collection systems.
Proposed Rule expected March 1997.
Final Rule expected March 1999.
Lesser Quantity Emission
Rates
40 CFR 63
Regulation would establish lesser quantity
emission rates (LQER) (that is, less than
10 tons per year) applicable to specific
pollutants, which will be used to define
which facilities are major sources subject to
national emissions standards for hazardous
air pollutants (NESHAP). Facilities
emitting pollutants subject to an LQER
may be subject to NESHAP requirements
when emitting below 10 tons per year of
the target pollutant.
Proposed Rule expected February 1996.
Final Rule undetermined.
Leaded Gas Prohibition
40 CFR 80
Regulation would prohibit selling, offering
for sale, supplying, offering for supply,
dispensing, transporting, r r introducing
into commerce gasoline that contain lead or
lead additives for use as fuel in any
highway motor vehicle.
Proposed Rule expected April 1995.
Final Rule expected December 1995.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
Standard of Performance
for New Stationary
Sources: Volatile Organic
Compound Emissions From
the Synthetic Organic
Chemical Manufacturing
Industry Wastewater
40 CFR 60
New source performance standards (NSPS)
to control air emissions of volatile organic
compounds (VOC) from secondary sources
(for example, wastewater treatment) at
synthetic chemical manufacturing facilities.
Proposed Rule September 12, 1994
(59 FR 46780).
Proposed Rule November 28, 1994
(59 FR 60751).
Final Rule was expected September 1995.
Standards of Performance
for New Stationary Sources
and Emission Guidelines
for Existing Source's:
Medical Waste Incinerators
40 CFR 60
NSPSs and Emission Guidelines (EG),
applicable to existing sources, applicable to
medical waste incinerators. Standards must
address paniculate matter, sulfur dioxide,
hydrogen chloride, oxides of nitrogen,
carbon monoxide, lead, cadmium,
mercury, and dioxins and dibenzofurans.
Proposed Rule March 15, 1995
(60 FR 13937)
Final Rule expected April 1996.
Standards of Performance
for New Stationary
Sources: Municipal Waste
Combustors
Emission Guidelines:
Municipal Waste
Combustors
40 CFR 60
NSPSs and EGs, applicable to existing
sources, applicable to municipal waste
combustors. Standards must address
paniculate matter, sulfur dioxide, hydrogen
chloride, oxides of nitrogen, carbon
monoxide, lead, cadmium, mercury, and
dioxins and dibenzofurans.
NSPS: Proposed Rule September 20,
1994 (59 FR 48198); Final Rule was
expected September 1995.
EG: Proposed Rule September 20, 1994
(59 FR 48228); Final Rule undetermined.
NSPS: Steam Generating
Electric Utilities
40 CFR 60
Revision of NSPSs for sulfur dioxide
emissions from large electric utility steam
generating facilities.
Proposed Rule expected May 1996.
Final Rule undetermined.
Standards of Performance
for New Stationary
Sources: Cold Cleaning
Machine Operations
40 CFR 60
NSPSs to control fugitive VOC solvent
emissions from cold cleaning operations.
Impacts automotive repair shops, gas
stations, and miscellaneous industries.
Proposed Rule September 9, 1994
(59 FR 46602).
Final Rule was expected August 1995.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
NESHAP For Source
Category: Pulp and Paper
Production
40 CFR 63
NESHAPs for pulp and paper mills
(integrated with effluent guideline). Areas
affected may include: pulping, byproduct
recovery, pulp washing, pre-bleaching,
bleaching evaporation, liquor recovery,
acid plants, and paper making. Emissions
from process vents, open process
equipment, tanks, furnaces, kilns, spills,
and wastewater collection and treatment.
Standards being integrated with effluent
guidelines being developed under the Clean
Water Act (CWA).
Proposed Rule: Non-Combustion Sources
(kraft, sulfite, soda, semichemical mills)
December 17, 1993 (58 FR 66078)
Proposed Rule was Expected:
Combustion Sources (kraft, sulfite, soda,
semichemical mills) June 1995.
Proposed Rule Expected: Other Processes
(mechanical pulping, non-wood chemical,
purchased pulp, secondary fiber pulp,
drinking) November 1996.
Final Action: All Sources November
1997.
NESHAP; Proposed
Standards for Hazardous
Air Pollutant Emissions
From Wood Furniture
Manufacturing Operations
40 CFR 63
NESHAPs for wood furniture
manufacturing. Focus on hazardous air
pollutants (HAP) and VOCs.
Proposed Rule December 6, 1994
(59 FR 62652).
Final Rule was expected November 1995.
NESHAP; Proposed
Standards for Hazardous
Air Pollutant Emissions
From the Printing and
Publishing Industry
40 CFR 63
NESHAPs for the printing and publishing
industry. May address rotogravure,
fexography, offset lithography, screen
printing, letter press, and other parts of the
printing and publishing industry.
Proposed Rule March 14, 1995
(60 FR 13664).
Final Rule expected March 1996.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
NESHAP for Polymers and
Group 1 Resins
40 CFR 63
NESHAPs for emissions from process
vents, equipment leaks, wastewater, and
storage at facilities that manufacture butyl
rubber, epichlorohydrin elastomer, ethylene
propylene rubber, Hypalon (TM),
neoprene, nitrite butadiene rubber,
polybuiadiene rubber, polysulfide rubber,
and styrene butadiene rubber and latex.
Proposed Rule June 12, 1995
(60 FR 30801).
Final Rule expected May 1995.
NESHAP: Polymers and
Resins/Group II
40 CFR 63
NESHAPs for emissions from process
vents, equipment leaks, wastewater, and
storage at facilities engaged in epoxy resin
production and non-nylong polyamide resin
production processes.
Proposed Rule May 16, 1994
(59 FR 25387).
Final Rule was expected February 1995.
NESHAP: Surface Coating
Operations in Shipbuilding
and Ship Repair
40 CFR 63
NESHAPs to control emissions from
painting. Also proposed limits for VOCs.
Proposed Rule expected January 1995.
Final Rule was expected November 1995.
NESHAP: Aerospace
Industry
40 CFR 63
NESHAPs from facilities that manufacture
or rework military and commercial aircraft,
subassemblies, and aircraft parts. Most
HAPs come from solvent usage (for
example, methyl ethyl ketone, methyl
isobutyl ketone, toluene, and methylene
chloride).
Proposed Rule June 9, 1994
(59 FR 29216)
Final Rule was expected July 1995.
NESHAP: Off-Site
Operations
40 CFR 63
NESHAPs for facilities that treat, store,
dispose, recycle, recover, or re-refine solid
waste received from off-site. Would
include commercial waste treatment
facilities, used oil re-refining, solvent
recovery plants, transfer stations, and
industrial landfills.
Proposed Rule October 13, 1994 (59 FR
51913; also see 59 FR 65744).
Final Rule was expected November 1995.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
NESHAP: Polymers and
Resins/Group III
40 CFR 63
NESHAPs for atnino, acetal, and phenolic
resin production, based on emissions of
phenol or formaldehyde.
Proposed Rule undetermined.
Final Rule undetermined.
(Statutory deadline November 1997).
NESHAP: Polymers and
Resins/Group IV
40 CFR 63
NESHAPs for manufacturers of
polyethylene, terephthalate,
methymethacrylate-butodine-styrene, and
styrene-acrylonitrile polymers. Emissions
from process vents, equipment leaks,
wastewater, and storage at facilities will be
addressed.
Proposed Rule expected March 1995.
Final Rule expected March 1996.
NESHAP: Reinforces
Plastic Composites
Production
40 CFR 63
NESHAPs for plants engaged in the
manufacturing of homopolymers or
copolymers that contain materials designed
to enhance the chemical, physical, or
thermal properties of the polymer (for
example, hand and spray layup of gelcoats
that incorporate styrene).
Proposed Rule expected December 1996.
Final Rule expected November 1997.
NESHAP: Manufacturers
of Acrylic/Modacrylic
Fibers
40 CFR 63
NESHAPs for plants engaged in the
manufacturing of acrylic or modacrylic
fibers, targeting emissions from the
polymerization reaction. Primary
emissions of concern are vinyl acetate and
acrylonitrile.
Proposed Rule undetermined.
Final Rale undetermined.
(Statutory deadline November 1997).
Standards for Tank Vessel
Loading Operations
40 CFR 90
Regulation to control VOCs and HAPs
from tank vessel loading operations.
Proposed Rule May 13, 1994
(59 FR 25004).
Final Rule was expected April 1995.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
VOC Regulation for
Architectural and Industrial
Maintenance Coatings
40 CFR [Not determined]
Regulation to control VOC emissions from
architectural and industrial maintenance
coatings applied to stationary structures,
portable buildings, pavements, or curbs.
Proposed Rule expected May 1995.
Final Rule undetermined.
NSPS for Nitrogen Oxides
(NOx)
40 CFR 60.40
Revision to current NSPSs for electric
utility and industrial steam generating units.
Proposed Rule expected October 1994.
Final Rule was expected April 1995.
Emission Standards for
Clean Fuel Vehicles and
Engines, Requirements for
Clean Fueled Vehicle
Conversions, California
Pilot Test Program
40 CFR 88
Will establish state program standards to
require centrally fueled fleets to include
some clean fuel vehicles in their new
purchases; establish clean fuel vehicle
standards, including conversion standards;
and California pilot test program.
Proposed Rule Vehicle
Conversion/Standards June 10, 1993 (58
FR 32474); CA Pilot June 29, 1993 (58
FR 34727).
Final Rule: Clean Fuel Definition
December 9, 1993 (58 FR 64679);
Vehicle Conversion/Standards were
expected October 1994.
NESHAP: Chromium
Electroplating
40 CFR 63
Rule will impose standards for chromium
emissions from electroplating operations.
Hard decorative and anodizing operations
may be affected.
Proposed Rule December 16, 1993
(58 FR 65767.
Final Rule was expected January 1995.
NESHAP: Halogenated
Solvent Cleaning
40 CFR 63
Emission standards would apply to new and
existing organic halogenated solvent
cleaners (degreasers) using any of the 189
HAPs referenced in Section 112 of the
Clean Air Act (CAA).
Proposed Rule November 29, 1993
(58 FR 62566).
Final Rule December 2, 1994
(59 FR 61801).
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status1
NESHAP: Chromium
Industrial Process Cooling
Towers (1PCT)
40 CFR 63
Rule imposes work practice standard that
prohibits the use of chromium-based water
treatment chemicals in new and existing
industrial process cooling towers (IPCT)
that are major sources.
Final Rule September 8, 1994
(59 FR 46339).
Effective date: Existing IPCTs March 8,
1996; New IPCTs initial date of use after
September 8, 1994.
NESHAP: Hazardous
Organic
40 CFR 63
Rule establishes emission limits for 112
organic chemicals emitted at both new and
existing synthetic organic chemical
manufacturing industries that are major
sources.
Final Rule April 22, 1994
(59 FR 19402).
Effective Date April 22, 1994.
Designation Under
CERCLA and Reportable
Quality Adjustments for
CAA HAPs and RCRA
Hazardous Wastes
40 CFR 117,302, and 355
List and specify reponable quantities for
non-Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA) CAA HAPs and specified
RCRA wastes (F037 and F038). Makes
release of reporlable quantity of such
wastes a reportable event.
Proposed Rule October 22, 1994
(58 FR 54836).
Final Rule was expected February 1995.
Release Prevention and
Risk Management
40 CFR 68
Regulation and guidance requiring
stationary sources where a regulated
substance is present to implement a risk
management plan for the detection and
prevention of accidental releases.
Proposed Rule October 22, 1993 (58 FR
54190; Supplement expected February
1995.
Final Rule expected May 1996.
Dates maybe updated for future revisions of this notebook
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SUMMARY AND STATUS OF PENDING REGULATIONS
THAT MAY AFFECT FEDERAL FACILITIES
Regulation Title
CFR Section
Summary of Content
Status*
Pesticides and Groundwater
State Management Plan
Regulation
40 CFR 152.170
The regulation will designate certain
individual pesticides to be subject to EPA
approved state management plans (SMP) as
a condition of legal sale and use. This
regulation will establish SMPs as a new
regulatory requirement for those pesticides;
absent an EPA-approved state plan
specifying risk reduction measures, use of
the chemical would be prohibited. The
rule would specify procedures and
deadlines for development, approval and
implementation of SMPs.
Proposed Rule was expected April 1995.
Final Rule undetermined.
Pesticide Management and
Disposal: Standards for
Pesticide Containers and
Containment
40 CFR 156 and 165
The 1988 amendments to the Federal
Insecticide, Fungicide, and Rodenticide Act
(FIFRA) significantly expanded EPA
authority to regulate the management of
pesticides and their containers, including
storage, transportation, and disposal. EPA
may exercise this authority through labeling
provisions, and other regulations for
storage, transport, and disposal of
pesticides.
Proposed Rule:
Container design, residue removal, bulk
containment February 11, 1994
(59 FR 6712);
Storage, disposal, mixer/loader,
transportation undetermined.
Final Rule undetermined.
Classification of Certain
Pesticides for Restricted
Use Due to Groundwater
Concerns
40 CFR 152.170
This rule will apply groundwater
contamination criteria to select pesticides
for restricted use (RU) classification due to
groundwater concerns. Once promulgated,
classified pesticides will be restricted to use
by trained and certified operators.
Proposed Rule expected May 31, 1991
(56 FR 22076).
Final Rule was expected May 1995.
Dates maybe updated for future revisions of this notebook
B 12
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APPENDIX C
OVERVIEW OF AGENCY POLLUTION PREVENTION STRATEGIES
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OVERVIEW OF AGENCY POLLUTION PREVENTION STRATEGIES
This table reviews the general compliance status of selected Federal entities with various key
provisions of Executive Order 12856. This table has been photocopied from EPA document number
300-R-95-014 "Meeting the challenge: A Summary of Federal Agency Pollution Prevention
Strategies." Its content is limited to the information that was available at the time of that document's
publication.
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Overview of
Agency
Pollution
Prevention
vjuaicyico
Strategy includes a commitment to
utilize pollution prevention (through
source reduction, where practicable)
as a primary means to achieve and
maintain environmental compliance
Strategy contains a commitment to
incorporate pollution prevention
(through source reduction, where
practicable) In facility management
and acquisition
Strategy identifies indlvidual(s)
responsible for coordinating Agency
E01 2856 efforts
Strategy Includes a Pollution
Prevention Policy Statement
Strategy Includes a commitment to
involve the public In monitoring
progress*
Section 3-301- Federal Agency Strategy
'Denotes an Executive Order recommendation
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Overview of
Agency
Pollution
Prevention
v-m ciiuyiuo
Strategy: (1) commits to voluntary
goal or reducing total releases of toxic
chemicals and off-site transfers lor
treatment or disposal, through source
reduction whenever practicable, by
50% by December 31. 1999, or( 2)
50% reduction goal for toxic pollutants
Strategy Includes a commitment to
develop a written pollution prevention
plan for each covered facility
Strategy directs facilities to conduct
assessments as necessary to develop
pollution prevention plans and facility
pollution prevention programs
Strategy establishes or calls tor a plan
and goals for eliminating or reducing
unnecessary acquisition of products
containing extremely hazardous
substances or toxic chemicals
Strategy establishes or calls lor a plan
and goals for voluntary reductions In
manufacturing, processing, and use of
txlremely hazardous substances and
toxic chemicals
Section 3-302- Toxic Chemical Reduction Goal
Section 3-303- Acquisition and Procurement Goals
'Denotes an Executive Order recommendation
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Overview of
Agency
Pollution
Prevention
WWW
w//''"'
Ull UlliVJIUO
Strategy includes a commitment to
review standardized documents to
identify opportunities to eliminate or
reduce the use ol extremely hazardous
substances and toxic chemicals
Strategy Includes a commitment to
make all appropriate revisions to
specifications
Strategy includes a commitment to
develop and test innovative pollution
prevention technologies to encourage
the development ol strong markets for
such technologies'
Strategy calls lor the creation of
partnerships with others to assess and
deploy innovative environmental
technologies for domestic use and
markets abroad*
Strategy includes a commitment to
comply with EPCRA Section 313, PPA
Section 6607, and all implementing
regulations and future amendments
Section 3-303- Acquisition and Procurement Goals (Cont.)
-
Section 3-304- Toxics Releases Inventory/Pollution Prevention Act Reporting
'Denotes an Executive Order recommendation
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Overview of
Agency
Pollution
Prevention
ouaicyico
Strategy Indicates agency compliance
with EPCRA Section 302 (Substances
and Facilities Covered and Notification)
Strategy indicates agency compliance
with EPCRA Section 303
(Comprehensive Emergency Response
Plans)
Strategy indicates agency compliance
with provisions ol EPCRA Section 304
(Emergency Notification)
Strategy Indicates agency compliance
with EPCRA Section 31 1 (MSDS)
Reporting)
Strategy Includes a commitment to
comply with EPCRA Section 312
(Emergency and Hazardous Chemical
Inventory Forms)
Section 3-305- Emergency Planning and Right-to- Know Responsibilities
'Denotes an Executive Order recommendation
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APPENDIX D
ACTIVITIES SPONSORED BY TRADE ASSOCIATIONS
AND FEDERAL FACILITIES
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ACTIVITIES SPONSORED BY TRADE ASSOCIATIONS
AND FEDERAL FACILITIES
A large number of associations interact with various federal facilities. Because of the diverse nature
of the federal facility sector and the diverse skill mixes of its employees, a number of the associations
listed below conduct activities and share information with the various federal agencies.
Presented on the following pages is a list of trade associations that are involved with federal facilities.
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Trade Associations
DEPARTMENT OF DEFENSE
American Institute of Hydrology
3416 University Avenue, SE
Minneapolis, MN 55414-3328
(612) 379-1030
Federal Facility Environmental Program Involvement:
This professional, educational organization registers
and certifies hydrologists and hydrogeologists. The
organization provides a forum for the discussion of
national and international hydrology issues and
provides continuing education for its members.
American Society of Naval Engineers
1452 Duke Street
Alexandria, VA 22314-3458
(703) 836-6727
Federal Facility Environmental Program Involvement:
This organization is a professional engineering society
that represents the areas of naval and marine
engineering, naval aviation, combat systems, the
environment, and other professions engaged in naval
construction, operation, and maintenance. The
organization offers opportunities for information
transfer, provides continuing education, and bestows
honors and awards.
Association of Naval Aviation
5205 Leesburg Pike, Suite 200
Falls Church, VA 22041-3863
(703) 998-7733
Federal Facility Environmental Program Involvement:
This organization is a professional, nonprofit,
educational society of naval aviation, whose purpose is
to educate the public and national leaders on the roles
of the Navy, Marine Corps, and Coast Guard aviation
as key elements of the national defense posture. The
association works actively at high-level deliberations
on national security, recognizes outstanding
achievements in the field, supports the interaction
between military and other federal organizations, and
serves as a repository of historical data.
Marine Technology Society
1828 L Street, NW, Suite 906
Washington, DC 20036-5108
(202) 775-5966
Federal Facility Environmental Program Involvement:
This professional society provides technical support
and education to improve humans' ability to work at
ocean depths. This international, multidisciplinary
society publishes a technical journal, conducts naval
research, and provides education in oceanography and
marine sciences.
Military Operations Research Society
101 S. Whiting Street, Suite 202
Alexandria, VA 22304
(703) 751-7290
Federal Facility Environmental Program Involvement:
This professional society provides research analysts in
the area of management science. The society consists
of 33 working groups, one of which focuses on
environmental issues, and its members are 50 percent
military personnel and 50 percent contracting
personnel.
National Association of Superintendents of
U.S. Naval Shore Establishments
5301 Etheridge Circle
Virginia Beach, VA 23464
(804) 479^635
Federal Facility Environmental Program Involvement:
This labor organization is made up of top-level
management personnel working primarily at national
shipyards. The members of the organization resolve
various issues associated with activities taking place at
the nation's shipyards.
Society of American Military Engineers
607 Prince Street
P.O. Box 21289
Alexandria, VA 22314-3117
(703) 549-3800
Federal Facility Environmental Program Involvement:
This organization exists in the interest of national
defense, bringing together all phases of U.S.
engineering, civil sector, and military, for the
advancement of the knowledge of the science of
military engineering and the rapid mobilization of
engineering capabilities. Members include military
personnel and civilians who interact with one another
through meetings and work together to publish books
and articles in periodicals.
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DEPARTMENT OF ENERGY
American Association of Blacks in Energy
927 15th Street, NW, Suite 200
Washington, DC 20005-2304
(202) 371-9530
Federal Facility Environmental Program Involvement:
TBD
American Nuclear Society
555 N. Kensington Avenue
LaGrange Park, IL 60525
(708)352-6611
Federal Facility Environmental Program Involvement:
This is a nonprofit, international, scientific, and
educational organization with a focus on the diverse
fields of nuclear science and technology. The society
promotes the advancement of engineering and science
related to the atomic nucleus, integrates the many
nuclear science and technology disciplines, encourages
research, establishes scholarships, develops
cooperative relationships with government agencies,
and disseminates technical information through
meetings and technical papers.
Association of Energy Engineers
4025 Pleasantdale Road, Suite 420
Atlanta, GA 30340-4264
(404) 447-5083
Federal Facility Environmental Program Involvement:
This nonprofit professional society is made up of
8,200 members in the U.S. and throughout the world.
The society provides a forum for the exchange of
technical and managerial information on all aspects of
energy and the environment. The society, which
publishes several journals, consists of three divisions:
the Cogeneration & Competitive Power Institute, the
Environmental Engineers & Managers Institute, and
the Demand-Side Management Society.
Federal Energy Bar Association
1350 Connecticut Avenue, NW
Suite 300
Washington, DC 20036
(202) 223-5625
Federal Facility Environmental Program Involvement:
TBD
Institute of Nuclear Materials Management
60 Revere Drive, Suite 500
Northbrook, IL 60062
(708) 480-9573
Federal Facility Environmental Program Involvement:
This international educational society consists of 750
members who meet annually and work together to
provide seminars and other forms of continuing
education on the topic of nuclear materials
management. The society is made up of six divisions
and includes members from diverse fields, such as
nuclear physicists and waste management specialists.
Institute of Nuclear Power Operations
700 Galleria Parkway
Atlanta, GA 30339-5957
(404) 644-8000
Federal Facility Environmental Program Involvement:
This organization works directly with power utilities
that pay a membership fee to it. The organization
evaluates the operations of power plants, providing
consultation on their better operation.
Integrated Waste Services Association
1401 H Street, NW, Suite 220
Washington, DC 20005
This association was formed in 1991 to promote
integrated solutions to solid waste management
problems. The organization encourages the use of
waste-to-energy technology as a key component of
community solid waste management programs. This
nonprofit organization consists of 65 companies
throughout the nation, 58 of which are waste-to-energy
facilities.
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APPENDIX E
RELATED EPA DOCUMENTS
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FFEO Resources
Following is a list of recent documents and resources available from the Federal Facilities Enforcement Office. To order,
check off the documents desired and fax to (202) 260-9437 or mail this page to FFEO U.S. EPA (2261), 401 M Street. SW,
Washington, DC 20460.
Q Guidance for Implementing Executive Order
12856: Federal Compliance with Right-to-Know
Laws and Pollution Prevention Requirements -
March 28, 1995. (EPA 300-B-95-005, April 1995, 55
pp.) Provides section-by-section interpretive guidance on
E.O. 12856, explains how federal agencies should
comply with EPCRA reporting requirements, and offers
"leadership options" for federal agencies in meeting the
goals of the executive order.
O Executive Order 12856: Federal Compliance with
Right-to-Know Laws and Pollution Prevention
Requirements: Questions and Answers. (EPA 745-
R-95-011, March 1995, 40 pp.) Provides detailed
questions and answers to assist federal facilities in
determining their EPCRA reporting requirements and
complying with E.O. 12S56.
fj Environmental Management System Benchmark
Report: A Review of Federal Agencies and Selected
Private Corporations. (EPA 3QQ-R-94-Q09,
December 1994, 121 pp.) A comparison of performance
in six environmental management areas of civilian
federal agencies, the Department of Energy, the Army.
Navy, and Air Force, and three private sector
corporations (Chevron. Xerox, and 3M).
Q Federal Facilities Multi-Media Enforcement/
Compliance Initiative. (EPA 300-R-94-007,
November 1994, 85 pp.) National highlights of the
initiative in FY 1993-94, plus reports from each EPA
region.
Q| Federal Facility Pollution Prevention Planning
Guide. (EPA 300-B-94-O12, November 1994, 29
pp.) Designed to help federal agencies prepare facility
prevention plans under E.O. 12856. Outlines steps to
follow in developing plans and provides lists of contacts.
01 Federal Agency Environmental Management
Program Planning Guidance. (EPA 300-B-95-001,
October 1994, 66 pp. plus 17 appendices) Guidance to
federal manager on preparing A-106 plans. Includes
overview of the A-106 process, descriptions of each
element, and an instruction kit for competing new
program plans and updating existing plans.
£J Catalogue of Federal Agency Environmental
Compliance/Management Documents. (EPA 300-B-
94-011, June 1994, 79 pp.) Annotated listing of over
200 federal agency environmental compliance and
management documents published by EPA and other
agencies on compliance with specific environmental laws,
policies, and environmental management programs.
Q Pollution Prevention in the Federal Government:
Guide for Developing Pollution Prevention
Strategies for Executive Order 12856 and Beyond.
(EPA 300-B-94-007), April 1994, 44 pp. plus 7
appendices with texts of executive orders.) Provides
background on executive orders requirements and EPA
activities in pollution prevention, focusing on the
government's roles in setting policies and regulations,
making acquisitions, generating hazardous waste and
managing facilities, and facilitating R&D and tech
transfer.
Q The State of Federal Facilities: A Comprehensive
Overview of the Environmental Compliance Status
of Federal Facilities through the End of FY 1992
("Keystone Report"). (EPA 300-R-94-001, February
1994) Includes briefing charts, graphs, tables, and bar
charts with statistics on federal compliance with
CERCLA, RCRA. NPDES, TSCA, Public Water Supply
Supervision, TRI. and the status of ihe base closure
program
Q Pollution Prevention and Right-to-Know in the
Government: Executive Order I2&56. (EPA 100-
K-93-001. October 1993, 15 pp.) Briefly reviews the
importance of the executive order, lists key deadlines,
and includes text of E.O. 12856.
(jP Generic Protocol for Conducting Environmental
Audits of Federal Facilities. (February 1995)
Available on-line through EnviroSense, on diskette from
FFEO, and in hardcopy from NTIS. Material is intended
lo assist in conducting environmental audits and
environmental management assessments. Protocols can
be customized to agency requirements.
£5 EnviroSense, EPA's free, public, integrated
environmental information system, offers
information exchange and documents relating to pollution
prevention and federal facilities. To access via modem,
dial 703-908-2092 (baud 2400 to 14,400, 8, N, 1,
emulation: ANSI, BBS, or VT-IOO). Access via the
Internet and the World Wide Web is at:
hop: //wastenot. go v /en virosense.
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APPENDIX F
LIST OF ACRONYMS
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List of Acronyms
AFS
AIRS
BIF
BLM
BOD
BRAC
CAA
CAAA
CERCLA
CERCLIS
CERFA
CFA
CFC
CO
COD
CSA
CSI
CWA
CZMA
D&B
DOA
DOC
DoD
DOE
DOI
DOJ
DOL
DOT
DUSD(ES)
ELP
EM
EPA
EPCRA
FCC
FFCA
FEMA
FFEO
FFTS
FHLB
FIFRA
FINDS
FMECI
FWPCA
FY
COCO
GSA
HAP
HHS
HSDB
HUD
AIRS Facility Subsystem (CAA database)
Aerometric Infonnation Retrieval System (CAA database)
Boilers and Industrial Furnaces (RCRA)
Bureau of Land Management
Biochemical Oxygen Demand
Base Realignment and Closure Act
Clean Air Act
Clean Air Act Amendments of 1990
Comprehensive Environmental Response, Compensation, and Liability Act
CERCLA Infonnation System
Community Environmental Response Facilitation Act
Civilian Federal Agency
Chlorofluorocarbon
Carbon Monoxide
Chemical Oxygen Demand
Community Service Association
Common Sense Initiative
Clean Water Act
Coastal Zone Management Act
Dun & Bradstreet Marketing Index
Department of Agriculture
Department of Commerce
Department of Defense
Department of Energy
Department of the Interior
Department of Justice
Department of Labor
Department of Transportation
Deputy Undersecretary of Defense (Environmental Security)
Environmental Leadership Program
Environmental Management
United States Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Federal Communication Commission
Federal Facility Compliance Act
Federal Emergency Management Agency
Federal Facilities Enforcement Office
Federal Facility Tracking System
Federal Home Loan Bank Board
Federal Insecticide, Fungicide, and Rodenticide Act
Facility Indexing System
Federal Facility Multimedia Enforcement Initiative
Federal Water Pollution Control Air
Fiscal Year
Government-Owned, Contractor-Operated
General Services Administration
Hazardous Air Pollutants (CAA)
Department of Health and Human Services
Hazardous Substances Data Bank
Department of Housing and Urban Development
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IDEA
ICA
INS
LDR
LEPC
MACT
MCLG
MCL
MEK
MSDS
NAAQS
NAFTA
NASA
NCDB
NCP
NEIC
NEPA
NESHAP
NOAA
NO2
NOV
NO,
NPDES
NPL
NRC
NSF
NSPS
OAR
OECA
OPA
OPPTS
OSHA
OSW
OSWER
OW
P2
PCS
POTW
PPA
RCRA
RCRIS
SARA
SDWA
SEP
SERC
SI
SIC
S02
sox
TOC
TRI
TRIS
TCRIS
Integrated Data for Enforcement Analysis
International and Community Association
Immigration and Naturalization Service
Land Disposal Restrictions (RCRA)
Local Emergency Planning Committees
Maximum Achievable Control Technology (CAA)
Maximum Contaminant Level Goals
Maximum Contaminant Levels
Methyl Ethyl Ketone
Material Safety Data Sheets
National Ambient Air Quality Standards (CAA)
North American Free Trade Agreement
National Aeronautics and Space Administration
National Compliance Database (for TSCA, FIFRA, EPCRA)
National Oil and Hazardous Substances Pollution Contingency Plan
National Enforcement Investigation Center
National Environmental Policy Act
National Emission Standards for Hazardous Air Pollutants
National Oceanic and Atmospheric Administration
Nitrogen Dioxide
Notice of Violation
Nitrogen Oxide
National Pollution Discharge Elimination System (CWA)
National Priorities List
National Response Center
National Science Foundation
New Source Performance Standards (CAA)
Office of Air and Radiation
Office of Enforcement and Compliance Assurance
Oil Pollution Act
Office of Prevention, Pesticides, and Toxic Substances
Occupational Safety and Health Administration
Office of Solid Waste
Office of Solid Waste and Emergency Response
Office of Water
Pollution Prevention
Permit Compliance System (CWA Database)
Publicly Owned Treatment Works
Pollution Prevention Act
Resource Conservation and Recovery Act
RCRA Information System
Superfund Amendments and Reauthorization Act
Safe Drinking Water Act
Supplementary Environmental Projects
State Emergency Response Commissions
Smithsonian Institution
Standard Industrial Classification
Sulfur Dioxide
Sulfur Oxides
Total Organic Carbon
Toxic Release Inventory
Toxic Release Inventory System
Toxic Chemical Release Inventory System
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TSCA - Toxic Substances Control Act
TSDF - Treatment Storage and Disposal Facility
TSS - Total Suspended Solids
TVA - Tennessee Valley Authority
UIC - Underground Injection Control (SDWA)
USPS - U.S. Postal Service
UST - Underground Storage Tanks (RCRA)
VA - Department of Veterans Affairs
VOC - Volatile Organic Compounds
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APPENDIX G
SECTOR MANUALS
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Contacts for Available Sector Notebooks
The Sector Notebooks were developed by the EPA Office of Compliance. Particular questions
regarding the Sector Notebook Project in general can be directed to the EPA Work Assignment
Managers:
Michael Barrette
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7019
Gregory Waldrip
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7024
Questions and comments regarding the individual documents can be directed to the appropriate
specialists listed below.
Document Number
EPA/3 10-R-95-001
EPA/310-R-95-002
EPA/3 10-R-95-003
EPA/3 10-R-95-004
EPA/310-R-95-005
EPA/310-R-95-006
EPA/310-R-95-007
EPA/3 10-R-95-008
EPA/310-R-95-009
EPA/3 10-R-95-0 10
EPA/3 10-R-95-0 11
EPA/3 10-R-95-0 12
EPA/3 10-R-95-0 13
EPA/3 10-R-95-0 14
EPA/3 JO-R-95-015
EPA/3 10-R-95-016
EPA/310-R-95-017
EPA/3 10-R-95-018
Industry
Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay , Glass and Concrete Industry
Transportation Equipment Cleaning Industry
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Se:h Heminway
Greg Waldrip
Keith Brown
Suzanne Childress
Jane Engen
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7024
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
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APPENDIX H
LIST OF REFERENCES
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List of References
Environmental Quality- Twenty-Fourth Annual Report; The Council on Environmental Quality
Guidance for Implementing Executive OrHt».r I2KS6; EPA Document Number 300-B-95-005
Federal Agenry Environmental Management Program Planning Giiirianpp/ EPA Document Number 300-
B-95-001
Meeting thft Challenge- A Summary of Federal Age.ncy Pnllntinn Pre.ve.ntinn Stratpgip.s; EPA Document
Number 300-R-95-014
Draft Strategy fnr Imprnving F.nvirnnmp.ntal Management Program?; at Civilian Ferie.ral Age.ncie.s;
November 1995
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