ISSUE #1
United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
(5305)
EPA300-N-95-001A
April 1995
an environmental bulletin for federal facilities
2 Guest Spot: Steve Herman,
EPA Assistant Administrator
for Enforcement and
Compliance Assurance
3 Pollution Prevention Facility
Planning Guide Aims at
Meeting December Deadline
4-5 Introducing FFEO and
FFRRO
6 EPA Issues New A-106
Guidance
7 Log On, Sign Up, Join In!
9 Multi-Media Inspection
Initiative Yields Multiple
Benefits
12 Calendar of Events
TWO FEDERAL
INSTALLATIONS CHOSEN AS
ENVIRONMENTAL LEADERS
EPA has announced the first selection
of 12 pilot projects for the Agency's
Environmental Leadership Program.
Among the pilots are two federal installa-
tions that have volunteered to test the
design of specific elements of the pro-
gram. They are McClellan Air Force Base
in Sacramento and the Puget Sound
Naval Shipyard in Bremerton, Washing-
ton. Pilot participants receive public
recognition as environmental leaders and
the opportunity to inform and directly
participate in EPA's effort to reassess its
environmental auditing policy.
The Environmental Leadership
Program is aimed at exploring ways that
EPA and States might encourage indus-
trial and federal facilities to develop inno-
vative auditing and compliance programs
and reduce the risk of non-compliance
through pollution prevention practices.
Each pilot project will work toward
achieving one or more of the following
key principles or goals:
• Environmental management systems.
EPA is interested in encouraging
facilities to adopt management sys-
tems that both prevent violations and
assure continuous environmental
improvement.
• Multi-media compliance assurance.
EPA is interested in developing and
sharing inspection protocols with
industry which can be integrated into
corporate environmental manage-
ment systems.
• Third party certification. EPA wants
to explore the use of an independent
verification of compliance audits to
enhance compliance assurance and
the credibility of facility-generated
data.
Public accountability. EPA is commit-
ted to developing performance mea-
sures which are accurate and mean-
ingful to the public, and which allow
comparisons of one facility's perfor-
mance with others.
Community involvement. EPA is com-
mitted to "place-based" solutions to
Continued on page 8
Director's^
BARRY BREEN
Dear Reader:
Welcome to the first issue of FedFacs!
Depending on how useful you and others
tell us it is, we plan for FedFacs to be a
regular update on our work and to offer
you an avenue for sharing progress on
your own work.
Elsewhere in these pages you will find
specific coverage of our work on a wide
variety of projects. Those of you who
know FFEO already realize this is a tal-
ented, high energy group. What's more,
much of what we accomplish is in part-
nership with others. For example, EPA
Regions and the National Enforcement
Investigations Center deserve much of
the credit for the Multi-Media
Compliance and Enforcement Initiative.
The Guidance on Accelerating CERCLA
Environmental Restoration at Federal
Continued on page 9
Printed on Recycled Paptr
-------
EPA State
30
P-
Penalties $5,722,978 $791,311 $6,514,289
Actions under CERCLA, FT 1994:
Interagency Agreements
Stipulated Penalties Assessed
Proposed Supplemental
Environmental Projects
CASE HIGHUGHTS:
2
$1,270,000
$2,150,000
US. Mr Force, Myrtle Beach AFB, South
Carolina, September 19, 1994. Region 4
issued a unilateral RCRA section 3008(h) cor-
rective action order following months of unsuc-
cessful attempts to negotiate an order on con-
sent for timely cleanup of the dosing base.
• Fort Dix, New Jersey, July 15, 1994. Region
2 issued a Notice of Violation for a Clean Water
Act violation for interim limits on biological
oxygen demand.
• US. Coast Guard Kodiak Support Center,
Kodiak, AL, July 14, 1994. EPA Region 10
sought $1,018,552 in penalties for two RCRA
violations: failure to properly monitor ground-
water m an area where cleaning solvents had
been dumped on the ground, and illegal storage
of hazardous waste without a proper permit.
• US. Navy; Naval Construction Battalion
Center (NCBC), Rhode Island, June 6,
1994. Region 1 settled a RCRA penalty order
against the Navy. The Navy agreed to pay a
penalty of $57,223 for violations including
falure to provide training, failure to label haz-
ardous waste containers, and failure to conduct
weekly container inspections.
Guesté /yz i?
STEVE HERMAN
It is a plea-
sure for me
to have
been invit-
ed to pro-
vide the
first guest
column in
this inau-
gural issue of FedFacs. I am
encouraged by the increasing
attention that many federal agen-
cies are giving to environmental
issues. I do not have to tell you
that this has not always been the
case. In many respects we are
playing catchup and are paying
for the sins — of omission and
commission — of those who came
before us. Today, however, we
have no choice but to confront the
legacy of past abuse and neglect of
our environment. The public
demands it, and our laws requir-
ing federal cleanup and compli-
ance with environmental stan-
dards reflect these demands.
We have seen the federal envi-
ronmental restoration and com-
pliance budget increase to over
$12 billion in FY 1995. And the
greatest challenges are yet to
come, as we move from studying
sites to remediating them. Annual
needs in the years ahead could go
up to $16 billion per year. And
these budget demands come at a
time when downsizing, streamlin-
ing, and reinventing government
have placed
demands on
resources.
In my past life, I had the honor
of defending the President and
the Secretary of Defense in legal
disputes involving the deploy-
ment of the MIX missile system
and the Navy’s ELF submarine
system. Now, I find myself in a
somewhat different position. I
was honored to have been chosen
by President Clinton and
Administrator Browner to be the
EPA Assistant Administrator for
Enforcement and Compliance
Assurance. As such, my office is
responsible for ensuring that our
environmental laws are complied
with by the regulated communi-
ty.., and that includes the federal
government.
Now, what is EPA’S perspective
on all this? By enhancing EPA’S
enforcement authorities — most
recently in the 1992 Federal
Facility Compliance Act —
Congress sought to ensure that
EPA would provide an indepen-
dent force to keep environmental
compliance and cleanup a high
federal government priority. The
general public also looks to EPA to
play a distinct and independent
role in federal facilities compli-
ance. In various forums and meet-
ings, citizens have repeatedly
stressed to us that they expect
EPA to act as an “honest broker”
within the federal government,
both to oversee other agencies’
compliance actions and to take
enforcement action when neces-
sary. And we have been doing so.
In the first two years of imple-
menting the Federal Facility
Compliance Act, for example, EPA
and the states have issued over
even greater 100 administrative orders and
limited agency assessed $12 million in penalties
against federal facilities.
Sometimes federal agency staff
are outraged or mystified at the
notion of one federal agency fining
or penalizing another federal
agency. They ask: “Why are you
Continued on page 3
The r
Federal Facilities Enforcement Actions under
FFCA and RCRA, VY 1994:
Administrative
Orders 10
40
PAGE 2
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Facility Planning Guide Aims at
Meeting December Deadline
To help federal agencies meet the
requirements of a number of recent
Executive Orders, EPA’s Federal
Facilities Enforcement Office has devel-
oped a Federal Facility Pollution
Prevention Planning Guide. The guide
provides detailed, step-by-step assistance
in developing facility-specific pollution
prevention plans.
Under E.O. 12856, each covered facili-
ty must develop a written pollution pre-
vention plan by December 31, 1995. The
plan should define how the facility will
contribute to the agency’s overall pollu-
tion prevention reduction goals.
The guide includes a review of rele-
vant Executive Orders and federal and
state legislation; steps in the develop-
ment of plans; guidance on public partic-
ipation, developing a measurement
process; and lists of publications, pro-
grams, and contacts.
For copies of the guide, see the order-
ing information on p. 11 below.
FEDERAL FACIUTY
POLW11ON PREVEN11ON PLANNING WORKSHOPS
FFEO is sponsoring workshops at six different locations on how to develop a facility-specific pollution prevention plan.
Small group sessions will offer hands-on experience.
Date
March 21-22
April 25-26
May 9-10
May 16-17
June 13-14
June 26-27
Location
New York, NY
Gulfport, MS
Lakewood, CO
Alameda, CA
Potomac, Ml)
Norman, OK
Co-Sponsor
USCG
NASA
EPA NETI
USOG
USPS
USPS
Th obtain a registration form or more information, fax a request to 202-260-9437 or call 703-821-4630.
GUEST SPOT
Continued from page 2
fining us?” “Why are you embarrassing
us?” “Why don’t you just help us?” “Show
us how to do it right.” The simple, truth-
ful answer is that the enforcement action
and penalty are a deterrent to noncompli-
ance. Congress has charged EPA with the
means to swing the “hammer” and we
will continue to use it in appropriate cir-
cumstances.
While our enforcement efforts provide
a strong incentive for compliance, this is
not the only set of responses being used
by EPA for achieving this goal. By provid-
ing compliance assistance tools which
promote pollution prevention, EPA is
helping to build the capacity of federal
facilities to move toward cleaner, cheaper
and smarter methods of environmental
management.
One primary area we are targeting our
compliance assurance efforts is pollution
prevention, much of it related to imple-
mentation of the President’s Pollution
Prevention Executive Order (#12856).
Appropriate federal implementation of
E.O. 12856 is key to changing the central
premise of environmental protection from
treatment and disposal to pollution pre-
vention.
In closing, I would like to stress again
that EPA’s role in federal facilities
cleanups and compliance is a unique and
sometimes difficult one. On the one hand,
we are committed to working with our
sister agencies to address the enormous
environmental challenges confronting
the federal government. On the other, we
are charged by law with being the federal
government’s principal environmental
regulator and enforcer. Although EPA’s
role is sometimes misunderstood, we
intend to persevere because it is in all of
our mutual interests to do so. I look for-
ward to continue working with those of
you in the federal sector and thank you
for the opportunity to share my thoughts
in FedFacs.
Steven A Herman is EPXs Assistant
Administrator for Enforcement and
Compliance Assurance.
Federal Facility
Prevention
PAGE3 .‘i;
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INTRODUCING
FFEO S EPA’S front-line office for
ensuring that federal facilities take all
necessary actions to prevent, control, and
abate environmental pollution. FFEO
participates in enforcement negotiations,
oversees enforcement activities under-
taken by the Regions, and is responsible
for resolving enforcement disputes
between EPA and other agencies. On
nationally significant cases, FFEO coor-
dinates with the Regions on issuing com-
pliance orders and agreements. Actions
against federal agencies include notices
of violation, lAGs, orders, and agree-
ments under all relevant environmental
statutes.
FFEO is divided into two groups:
The Site Remediation and
Enforcement Staff (SRES) primarily
works with federal agencies and other
offices in EPA (including FFRRO) to
streamline enforcement and cleanup at
federal facilities. Specific SRES responsi-
bffities include:
• Reviewing, coordinating and partici-
pating in the negotiation and imple-
mentation of CERCLA lAGs and
Memoranda of Understanding.
• Coordinating development of CER-
CIA enforcement policy with EPA
Regions through the Federal Facility
Leadership Council.
• Developing regulations, policies, guid-
ance, and strategies for federal facili-
ties enforcement under the Resource
Conservation and Recovery Act
(RCRA) and other environmental
statutes.
The Planning, Prevention and
Compliance Staff (PPCS) is responsible
for initiatives to prevent noncompliance
at federal facilities and overseeing com-
pliance and enforcement activities.
Activities include:
FFEO, EPA’s Federal
Facilities Enforcement Office
• Developing, coordinating, and track-
ing federal facility compliance assur-
ance and assistance efforts; improv-
ing environmental management and
auditing programs; and managing
FFTS and other enforcement and
compliance databases.
• Promoting pollution prevention and
environmental justice goals through
implementation of E.O. 12856 and
other Executive Orders.
• Managing the Federal Facilities
Multi-Media EnforcementiCompli-
ance Program, the “A-106” environ-
mental management program that
oversees federal agencies’ environ-
mental compliance budget requests.
• Facilitating the use of innovative
environmental technologies to attain
prevention, compliance, and cleanup
goals.
Office of
Enforcement
Compliance
A ance
Steven A.
Herman,
44 s sL tant
Administrator
Michael Stahl,
Depui yAsst.
Administrator
Fedemi
Facilities
Enforcement
Office (FFEO)
Barry Breen,
Director
Craig Hooks,
Associate Director
(Acting)
Site Remediation
and Enforcement
- Staff
Joyce Olin, Director
(Acting)
PlRnning ,
- Prevention and
Compliance Staff
Jim Edward, Director
MOW1HLY ROUNDTABLE KEEPS
COMMUNICATiONS FLOWING
FFEO’s monthly roundtable meetings offer federal agency staff a steady
stream of fresh information to keep them up-to-date with EPA policy, existing and
pending standards and regulations, and the latest in environmental research.
Fifty federal departments and agencies participate in the EPA 1 Federal Agency
Environmental Roundtable.
The Roundtahle also provides a forum for the exchange of information on pol-
lution prevention and control techniques as well as innovative cleanup technolo-
gies. Other topics include: in rmalion needed to prepare the annual federal
agency pollution abatement and prevention plans required by E.0. 12088,0MB
Circular A-106, and 0MB Circular A-li; the hazardous waste docket; technical
information systems; and high profile topics such as the National Priorities List
and base closure.
The Roundtable was established under authority of Executive Order 12088, to
fulfill the consultative and teclniical assistance mandate envisioned between EPA
and other federal agencies. The Roundtable has been in continuous operation at
EPA for over 10 years.
Contact: Don Franklin, EPA FKEO, 202-260-5908.
PAGE 4
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EPA’s Federal Facilities Restoration
and Reuse Office is the primary office
charged with responsibilities toward
restoration and reuse of closing and
decommissioned federal facilities.
Military base closures, cleanup stream-
lining, and stakeholder involvement are
the primary focus of the FFRRO’s efforts.
Highlights of projects in these areas are
described below.
Military Base Closure. President
Clinton’s Five Point Plan to speed the
economic recovery of communities
where military bases are slated for
closure is built on a partnership
between EPA, DOD, and the States.
The Fast Track Cleanup program
focuses on cleanup efforts to facilitate
reuse of closing bases. The program
includes identifying clean parcels,
accelerating cleanup, facilitating leas-
ing agreements, encouraging removal
actions, technical assistance at non-
NPL bases, enhanced community
involvement, and integration of
cleanup with economic development.
In conjunction with DOD and EPA’s
regional offices, the FFRRO develops
long-range environmental policies,
plans and programs to expedite the
cleanup and transfer of closing mili-
tary installations.
Cleanup Streamlining. FFRRO
has several projects underway to
improve the cleanup process at feder-
al facilities. Working with the goal of
enhancing the cleanup process to
restore sites and facilities to produc-
tive use, FFRRO has built strong
partnerships with DOD and DOE to
improve cleanup guidance, stream-
line oversight, and promote innova-
tive technologies
Stakeholder Involvement. FFRRO
manages the Federal Facilities
Environmental Restoration Dialogue
Committee, which provides the
Federal government advice on how to
improve stakeholder involvement at
federal facilities, priority setting, and
management of the cleanup pro-
grams. In conjunction with FFEO,
FFRRO provides major contributions
to the national debate on Superfund
Reform and efforts to improve the fed-
eral government’s overall approach to
environmental management. FFRRO
has teamed with DOD and DOE as
they build community advisory
boards at their sites. FFRRO also
works with states, local governments,
Native American tribes and commu-
nity representatives to ensure that
social and economic factors are con-
sidered in cleanup priority-setting
arid decision-making at federal facili-
ties.
EPA REGIONAL
FEDERAL FACLif V
COORDINATORS
FFC’s are responsible for coordi-
nating the implementation of FFEO
policies and programs at the Regional
level. Regional FFCs coordinate with
EPA Regional media program staff to
implement federal facilities enforce-
ment programs; manage tracking,
oversight, and compliance planning
activities; coordinate and train feder-
al facilities in developing environmen-
tal management program plans; pro-
vide program assistance, training,
and outreach for federal facilities; and
encourage pollution prevention at fed-
eral facilities.
GION 4 I GlON 9
(AL, FL, GA. KY,
MS, NC, SC, TN)
Arthur Unton,
404-347-3776
FEG1ON 5
(IL, IN, MI, MN,
OH W1)
Lae Regner,
312.353-6478
and FFRRO, EPA’s Federal
Facilities Restoration &
Reuse Office
Office of Solid
Waste &
Emergency
Responce
Elliott LaWS,
Assistant
Administrator
Timothy Fields,
Deputy Asst.
Administrator
Federal
Facilities
Restoration
— and Reuse
Office (FFRRO)
Jim Woollord,
Director
- Base Uo
1 am
Federal
- Facilities
Policy T am
Stakeholder
- Enhancement
Tham
FEGION 1 FEGION 6
(Ce, M MA,
NH, RI, Wi ’)
Aane Fenn,
617-565.3927
(AK, L N
OK, TX)
Joyce Stubblefield
214-665-6430
lEGION 2 lEGION 7
(NJ, NY PR, Vi)
Laura livingston,
212-637-3494
(IA , KS,MO, NE)
Craig Bernatem,
913-551-7688
REGION 3 lEGION 8
(DE, DC, MD,
PA, VA, WV
cMhton,
215-597-9857
(CO, MT. ND,
SD, UT, WY)
Dinnne Th
303-294.1059
(A4 C HA, N
Amer. Samoa,
Guan ‘l F)
Sara Seg
415-744-1483
lEGION 10
.AL, ID, OR, WA)
David Tetta,
206-553-1327
PAGE 5
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EPA ISSUES NEW
A-106 GUIDANCE
Federal Agency Environmental
Planning Process Revitalized
An Interagency Advisory Committee
formed by EPA to examine the 0MB
Circular A-lOG pollution abatement and
prevention planning process has com-
pleted its work and made recommenda-
tions for revitalizing the system. The
committee included members from EPA,
0MB, DOl, DOE, FAA, DOT, DOD,
Army, Navy, Air Force, USMC, DLA,
USACE, NASA, USDA, and Treasury.
The recommendations in the commit-
tee’s final draft report (issued in August
1994) proposed the largest changes in the
A-lOG process in the last 15 years. The
committee recommended that EPA issue
more detailed guidance on the A-106 sys-
tem to other federal agencies, include
pollution prevention project information
in the system, change both the timing
and type of EPA review of federal agency
pollution abatement and prevention
plans, and change the timing of the sub-
mission of the annual report to 0MB.
Following up on these recommenda-
tions, Steve Herman, EPA Assistant
Administrator for Enforcement and
Compliance Assurance, authorized the
distribution of new guidance to other fed-
eral agencies, entitled Federal Agency
Environmental Management Program
Number of buildings owned by the
Federal Government:
over 450,000
Number of installations owned or
operated by the Federal
Government:
31,500
Number of acres in the United States
owned or managed by the Feds:
over 662 million
Planning, issued under authority of
Executive Order 12088 and 0MB
Circular A-106. This new guidance out-
lines the major procedures to be followed
by all federal agencies in planning and
budgeting for environmental compliance.
The purpose of this planning process,
now called FEDPLAN, is to ensure that
federal agencies identify all environmen-
tal requirements and target adequate
resources to address them.
EPA’s FFEO, which manages the
FEDPLAN process, has developed a new
PC-based management information
database, called FEDPLAN-PC, that con-
tains all federal agency environmental
project information that supports the
review process. FEDPLAN-PC will be
fully implemented during this fiscal year.
The database provides a powerful data
analysis capability to regional media pro-
gram review personnel and regional
Federal Facility Coordinators. EPA staff
will be able to perform relational analy-
ses between the project level compliance
and budget information contained in
FEDPLAN-PC and the inspection and
compliance information contained in the
new Federal Facility Tracking System
coming on-line.
Contact: Don Franklin, EPA FFEO, 202-
260-5908. For a copy of the new A-106
Guidance, fax your request to Vicki
Nelson at 202-260-9437.
Number of federal facilities listed on
the National Priorities List
of hazardous waste sites:
154 final, 8 proposed
Number of military installations
scheduled to be closed that are
listed on the NPL:
23
Source: U.S. EP Office of Enforcement, “The
State of Federal Facilities” (EPA 300-R-94-0O1,
Februa y 1994 ,1.
ENViRONMENTAL
JUS11CE PROJECTS
Final environmental justice strate-
gies are due to the President from all fed-
eral agencies on April 11, 1995. FFEO is
reviewing draft EJ strategies of other
agencies pertinent to F’FEO’s mission, as
required by Executive Order 12898.
EPA’s Office of Enforcement and
Compliance Assurance has developed a
detailed series of workplans outlining EJ
projects underway and planned in OECA,
which were presented to the National
Environmental Justice Advisory
Council’s Enforcement and Compliance
Subcommittee in January 1995. FFEO
also is developing GIS (geographic infor-
mation systems) Environmental Justice
Profile reports for 25 federal facilities in
all 10 EPA Regions which are due to be
issued in April.
For more information, contact Darlene
Boerl age, FFEO, 202-260-0413.
BENCHMARK STUDY
IDENTIFiES BEST IN
CLASS BEHAViORS
Study Shows Civilian Federal
Agencies Lagging Behind Private
Sector Leaders and Defense
Related Agencies
A new study released by EPA’s Office of
Enforcement and Compliance Assurance
evaluates the environmental manage-
ment systems in place in 17 civilian fed-
eral agencies, 3 private corporations, and
four defense-related agencies. The pur-
pose of the study was to evaluate how pri-
vate and government organizations per-
form against a benchmark considered to
be state-of-the-art environmental man-
agement performance.
The study compared CFA responses on
a 1993 survey questionnaire to private
sector and defense-related agency prac-
tices in six areas of evaluation: organiza-
Continued on page 7
Faci/i%
PAGE 6 ;J;
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BENCHMARK STUDY
Contlnw?d from page 6
tional structure; management commit-
ment; implementation of programs; infor-
mation collection, use, and follow-up;
internal and external communications;
and personnel management.
On most of the six areas and associat-
ed benchmark criteria, the civilian feder-
al agencies lagged significantly behind
industry leaders (Chevron, Xerox, and
3M) as well as their counterparts in
defense-related agencies (Departments of
Energy, Army, Navy, and Air Force). For
example:
• Only 5 of 17 CFAs report a manage-
ment conunitment to go beyond com-
pliance with environmental require-
ments, in terms of resource allocation,
training, and support;
• Only 3 CFAs report having well-pub-
licized channels for employees to raise
environmental concerns;
• Only 5 CFAs reported that facility
managers have environmental com-
pliance as part of their performance
evaluations;
• While a majority of CFAs report that
agency employees receive formal
guidance on environmental require-
ments associated with their jobs, only
5 CFAs report utilizing formal train-
ing programs for compliance staff
By contrast, the private and defense-
related respondents rated significantly
better on all key indicators of “Best in
Class” performance.
An EPA-led interagency Civilian
Federal Agency Task Force is scheduled
to release a strategy for improving CFA
environmental compliance within the
next few months. Also soon to be released
is a study of CFA environmental auditing
issues by the U.S. General Accounting
Office.
To order a copy of EPA Benchmark
Report, see ordering information on p. 11.
For more information, contact Richard
Satterfield, FFEO, 202-260-9759.
LOG ON, SIGN UP,
JOIN IN!
EPA Bulletin Boards Offer Full
Spectrum Services for Federal
Facilities
EPA has joined the information revo-
lution with electronic bulletin board sys-
tems (BBS) and databases to serve feder-
al facilities’ environmental needs.
Currently in operation is the FFLEX
(Federal Facilities Environmental
Leadership Exchange) system, which
features information on pollution preven-
tion and other innovative technologies,
contacts, case study documents, Federal
Register documents, training opportuni-
ties, laws, executive orders, regulations,
and guidelines.
Just waiting final approval is the
merger of FFLEX with Enviro$ense, a
new full-service EPA BBS just coming on
line in Spring 1995. Enviro$ense will con-
tain a series of directories exclusive to
federal facilities. Included will be all of
the FFLEX data, several on-line databas-
es, and on-line access to other agencies’
BBSs and databases. Enviro$ense also
includes information on:
• Recycling, controls and disposal
• Base closure and cleanup
• Alternate chemicals and solvents
• Other federal and state agencies
• Industry, universities, environmen-
talists
Showcase Your Achievements!
State, federal, and environmental organi-
zations: You are invited to establish your
own directories on Enviro$ense, at no
cost to you! FFEO is aware that a BBS
can only reach its full potential with a
large amount of high-quality data and
timely information. FFEO is committed
to providing a value-added service to help
agencies comply with environmental reg-
ulations at the lowest possible cost.
Th widen the electronic information
available to the federal community,
HOW TO ACCESS FFIEX
(Until June 1995)
Until June 1995, FFLEX is
accessible only by modem (4 lines).
Call 202-401-5930 and set your sys-
tem to:
Data Bits: 8
Parity: None
Stop Bits: 1
Emulation: VT-100 orANSIBBS
Speed: 2,400-14,400 baud
HOW TO ACCESS
ENV1ROSENSE:
Beginning April 15, 1995,
Enviro$ense is accessible both by
modem and via the World Wide
Web on the Internet.
By modem (28 lines):
Call 703-908-2092
Data Bits: 8
Parity: None
Stop Bits: 1
Emulation: VT-100 or ANSI
Speed: 2,400-14,400 baud
By Internet: (World Wide Web)
httpi/wastenot.intel.gov/
envirosense
FFEO invites you to showcase your orga-
nization’s successes and accomplish-
ments. This can be done in several ways:
either by starting your own directory and
placing your information directly into it,
or by uploading your data into one of the
existing directories.
Either way, FFEO staff will be happy
to help you make the best possible use of
BBS services to meet your needs.
Contact Louis Paley at 202-260-4640 or
via the Internet at:paley.louis@epamail.
epa.gov.
PAGE7 ‘i.
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ENVIRONMENTAL LEADERS
Continued from page 1
pollution problems, and to environ-
mental justice for all communities
regardless of race or income.
Mentoring. Large corporations or
agencies can help small ones under-
stand and comply with environmen-
tal regulations and new technologies.
The 12 projects selected were chosen
from a pool of 40 projects submitted, 10 of
which were federal facility applicants.
the selection process was a cooperative
effort of EPA Regional Offices, State envi-
ronmental agencies, and EPA OECA
offices.
For more information, contact Tai-Ming
Chang, ELP Project Director, Tel: 202-
260-6777, Fax: 202-260-8511; or Louis
Paley at 202-260-4640.
PUGET SOUND NAVAL
SHIPYARD
The Puget Sound Naval Shipyard
in Bremerton, Washington employs
about 18,000 military and civilian per-
sonneL The facility’s proposal is to con-
duct a pilot project that goes a step
beyond compliance audits by conduct-
ing pollution prevention opportunity
assessments through a partnership
with EPA and the Washington State
Department of Ecology The assess-
ments will be directed at identifying
and improving regulations whose
unanticipated consequence is to harm
human health or the environment. A
model program will be outhned on
computer disk that will encourage
other facilities to operate beyond com-
pliance in a similar fashion.
LEADERS IN ACT1ON
McClellan Air Force Base
Located on 3700 acres in
Sacramento, California, the
15,500 employees of
McClellan AFB are involved
in depot maintenance and 40
associated units. McClellan
has shown its leadership in
pollution prevention with
over 150 projects already
underway, managed through
a computerized tracking sys-
tem. McClellan’s other track-
ing systems provide daily accounting of the disposition of hazardous materials
and track hazardous waste containers from the time they are issued for use until
they are turned in for disposal. Since 1985, McClellan has reduced its hazardous
waste by 78 percent; an additional 14% reduction is planned by 1996.
Approximately 40% of Puget
Sound Shipyard’s current
workload involves fist! ship
recyding. Here, the sails of
several submarines are being
readied/br recycling in dry-
dock after removal from
their submarine hulls.
COMING UP
IN THE NEXT
ISSUE OF
USING EPA’s FEDERAL FACILITIES
TRACKING SYSTEM
• MORE ON THE NEW INTERAGENCY
ENVIRONMENTAL AUDIT PROTOCOL
The F-22 Advanced 7bctical Fighter; for the
first time, engineers and designers are working
together to build and maintain an aircraft
without using hazardous materials.
PAGE8
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Multi-Media Inspection Initiative
Yields Multiple Benefits
Enforcementl
With 41 multi-media inspections of
federal facilities under its belt, the Federal
Facilities Multi-Media
Compliance Initia-
tive has yielded a
snapshot of the sta-
tus of federal facili-
ties and prospects for
multi-media inspec-
tions in the future.
Analysis indicates
that EPA and state
utilization of multi-
media inspections
can be effective,
regardless of the size
of the federal facility
or its operating
agency.
Established in FY
1993, the initiative was designed to
assess compliance of federal facilities
with environmental laws, using multi-
media inspections and enforcement to
address areas of non-compliance.
Coordinated team inspections were con-
ducted by all ten EPA Regional Offices, in
concert with state officials. Federal facili-
ties were selected based on their compli-
ance records and potential risk. Most of
the facilities selected were DOD facilities
(33 out of 41); the remainder were DOE
installations (2), USDA facilities (2), and
facilities operated by DOT, DOJ, NASA,
and DOl (1 each). Pollution Prevention
Opportunity
RESULTS
Profiles were prepared for
— all targeted facili-
ties. These profiles
were used by
EPAlstate teams
during the process
and provided to the
inspected facilities.
Pollution Pre-
vention Opportunity
Profiles were pre-
pared for all target-
ed facilities. These
proffles were used
by EPA/state teams
during the process
and provided to the
inspected facilities.
Results of the first year of the initiative
were as follows:
• Just over half of the facilities inspect-
ed violated more than one statute.
• EPA and the States together issued
75 enforcement actions at 31 facili-
ties. The actions ranged from warning
letters (15) to formal administrative
orders (18) with proposed penalties of
$2.1 million.
• The average time to issue an enforce-
ment action ranged from 2 weeks for
a field citation to 14 months for a
Federal Facility Compliance
Agreement.
• Of the facilities inspected, 24 C
received no formal enforcement
action.
Regional Offices participating in the
initiative reported good coordination with
state officials and a strengthening of
EPA-state working relationships.
Facilities involved were considered pro-
fessional and cooperative in the inspec-
tion, even in cases where the “facilities
initially responded with shock to the
arrival of inspection teams!” Despite
some difficulties with allocating resources
and coordinating schedules, the Regions
found that multi-media inspecting pro-
vided multiple benefits, including the
desired comprehensive review of a facili-
ty’s environmental compliance status,
and the attention of top-level managers to
the facility’s compliance.
For a copy of the interim report, “Federal
Facilities Multi-Media Enforcement /
Compliance Initiative,” see p. 11. For
more information, contact Jim Edward
(202-260-8859) or Reggie Cheatham
(202-260-4641).
DIRECTOR’S WORD
Continued from page 1
Facilities was a joint project with DOD,
DOE, key EPA Regions, and the Office of
Solid Waste and Emergency Response’s
Federal Facilities Restoration and Reuse
Office. Implementing President Clinton’s
pollution prevention executive order is a
joint effort with the Office of Prevention,
Pesticides and Toxic Substances’
Environmental Assistance Division.
Indeed, this last project has participation
from over a dozen other agencies besides
EPA.. To our partners, thank you. I expect
we’ll be approaching you again soon.
These and other specific efforts grow
out of the mission the President has laid
out for us: help other agencies “ensure
their cost effective and timely compli-
ance” in meeting “the same substantive,
procedural, and other requirements that
would apply to a private person,” through
technical advice and assistance, reviews
and inspections, review of proposed bud-
gets, and, sometimes, direct enforcement.
Longtime friends of our program will
see that the specific tools we use have
evolved over the years. But one theme
remains constant: We help the govern-
ment earn the trust of its citizens by liv-
ing up to its environmental promises. As
you will read in the column from
Assistant Administrator Steve Herman,
our efforts parallel EPA’S larger themes.
For me, there is special meaning in apply-
ing these themes to the federal .,.vern-
ment itself.
Barry Breen, Director, FFEO
R A
3 5%
SpiN Pr.v.ntlon
Control and
Countsrmasurss
9 /
CWA.
12%
TSCA
15%
The four most frequently violated
statutes were RCRA, TSCA, CAA.
and CWA.
PAGE9 “t
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Federal Agency
H azWaste
Compliance
Docket
Section 120(c) of CERCLA, as amend-
ed by SARA, requires EPA to establish a
Federal Agency Hazardous Waste
Compliance Docket. The purpose of the
docket is to identify federal facilities that
manage hazardous waste or from which
hazardous substances may be or have
been released. The docket is updated
with new information every six months.
Agencies are notified that one or more of
their facilities has been considered for
inclusion on the docket, and upon verifi-
cation by the federal agencies, the facili-
ties are listed in the Federal Register.
The first docket published in 1988, listed
840 facilities. The latest update, pub-
lished in the Federal Register as Update
#9, lists 2,070 facilities.
For more information, contact Augusta
Wills, 202-260-1686.
Following months of negotiations
EPA’s FFEO and the Army have reached
agreement on establishing a pollution
prevention technical assistance pilot pro-
ject. The Memorandum of Agreement
was signed by EPA Assistant
Administrator Steven A. Herman and
Army Under Secretary Joe R. Reeder in
March 1995.
The Agreement sets up a partnership
effort under which EPA and the Army will
conduct pollution prevention assessments
at three Army installations: Rock Island
Arsenal, 1L Fort Benning, GA; and
White Sands Proving Ground, NM.
EPA’s Risk Reduction Engineering
Laboratory in Cincinnati will fund and
conduct a pollution prevention opportuni-
ty assessment at each facility to include
an on-site visit, consultation with Army
personnel, and a written report which
will be made public. The report will con-
tain a range of pollution prevention
options and recommendations, to which
the Army has agreed to respond within
four months of receipt of the assessment.
Draft pollution prevention assessments
will be completed by June 1, 1995 so that
the Army can use them in preparing poi-
lution prevention plans for these installa-
tions (as required by Executive Order
12856).
The Anny has agreed to share the
results of the pollution prevention oppor-
tunity assessments with other similar
Army installations as applicable. In addi-
tion, the Office of the Deputy Assistant
Secretary of the Army (Environment,
Safety, Occupational Health) will review
this pilot program, including the assess-
ments and the installations’ responses,
and will comment on the appropriateness
of adopting any of the assessment proce-
dures and recommendations Army-wide.
The review document will be made avail-
able to the public.
For more information, contact: Bill
Frank, 202-260-5074 or Reggie
Cheatham, 202-260-4641.
New Audit Protocol
Goes Online
A newly-released Generic Protocol for Conducting
Environmental Audits of Federal Facilities is available online on
Enviro$ense (see p. 7 for access information) for use by federal
agencies. Prepared as a collaborative effort by the member agen-
cies of the Federal Audit Protocol Workgroup for the Federal
Community (EPA, DOE, DOD, USPS, NASA, DO!, USDA, and
FAA), the protocol is meant to assist in the conduct of environ-
mental audits and environmental management assessments.
Because of its size — 920 pages! — the protocol is being made
available to federal agency staff on computer diskette and via
NTIS, as well as online. Federal agencies are encouraged to cus-
tomize the protocol to their own needs before issuing it to audi-
tors.
For more information, contact Richard Satterfield, 202-260-
9759. The next issue of FedFacs will have a detailed article
about the contents and uses of the audit protocol.
Six Committees Set Up
to Promote E.O. 12856
EPA’s Office of Enforcement and Compliance Assurance and
Office of Prevention, Pesticides and Toxic Substances are co-
chairing an Interagency Pollution Prevention Task Force. The
Task Force has just established six committees to help the
Federal Government comply with the Executive Order 12856
(TRI reporting & P2 compliance) requirements, and foster inno-
vative technological P2 solutions. The six committees are:
• P2 Language for Federal Acquisition Regulations;
• P2 R&D and Thchnology Diffusion;
• Information Transfer and Technical Assistance;
• Standardized Material Safety Data Sheet Reporting
• Outreach and Publicity for the Federal Government
Executive Order and P2 Progress; and
• Substitute Chemicals and Alternative Processes.
Contact: Louis R. Paley, 202-260-4640 or via Internet at:
paley.louis@eparnail.epa.gov.
EPA and Army Agree on
Pollution Prevention Technical
Assistance Project
PAGE 10
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- - - 1
I I
Mail to:
FedFacs (for newsletter)
To Read FedFacs Electronically:
Dial into FFLEX by modem (202-401-5930).
System settings are shown on p. 7.
To Receive FedFacs in the Mail or to Order Documents
Mentioned in the Newsletter:
J Please include me on the FedFacs mailing list (no charge).
I Please send one copy of the following documents (no charge):
_I “Federal Facilities Multi-Media Enforcement/Compliance
Initiative” (EPA 300-R-94-007, November 1994).
J “Federal Facility Pollution Prevention Planning Guide”
(EPA 300-B-94-012, November 1994)
‘J “Federal Agency Environmental Management Program
Planning Guidance” (EPA 300-B-95-001, October 1994)
J “Environmental Management System Benchmark Report”
(EPA 300-R-94-009, December 1994).
Complete the following:
Name __________________
Organization __________
Address ______________
LIST OF ACRONYMS
CAA Clean Air Act
CERCLA Comprehensive Emergency
Response, Compensation,
and Liability Act
CFA Civilian Federal Agency
CWA Clean Water Act
DLA Defense Logistics Agency
DOD Department of Defense
DOE Department of Energy
i DOl Department of the Interior
DOT Department of
Transportation
I EJ Environmental Justice
EO Executive Order
I EPA Environmental Protection
Agency
I FAA Federal Aviation
Administration
i FFC Federal Facility
Coordinator
FFCA Federal Facilities
Compliance Act
FFEO Federal Facilities
Enforcement Office (EPA)
FFLEX Federal Facilities
Environmental Leadership
Exchange
I FFRRO Federal Facilities
Restoration and Reuse
— Office (EPA)
lAG Interagency Agreement
NASA National Aeronautics and
Space Administration
NET! National Enforcement
Training Institute (EPA)
Federal Facilities Enforcement Office (for documents) I NPL National Priorities List
LT.S. EPA (2261) OECA Office of Enforcement and
401 M Street, SW Compliance Assurance
Washington, DC 20460 I (EPA)
or Fax this page to: 202-260-9437 Office of Management and
I Budget
L J P2 PollutionPrevention
RCRA Resource Conservation and
Recovery Act
TSCA Toxic Substances Control
is published by EPA’S Federal Facilities Enforcement Office. USMC U.S. Marine Corps
USACE U.S. Army Corps of
Jim Edward, Joyce Johnson, Editors Engineers
Gilah Langner, Writer USCG U.S. COast Guard
Paine Bluett Paine, Design USDA U.S. Depiutlflent of
Robin Foster, Layout Agricultui ’
USPS U.S. Postal Service
PAGE 11
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CALENDAR
ApñIl8-20
THE 21ST ENVIROf’tt.IENTAL
SYMPOSiUM AND EXHIBI11ON
OF THE AME CAN DEFENSE
PREPAREDNESS ASSOCIATiON
San Diego, CA
This year’s event is entitled:
Environmental Protection and a
Changing Defense Mission: A Mid-
Decade View. For more information, fax
ADPA at 703-522-1885.
Apiil 20-21
AN INNOVATiVE CONCEPTS
TECHNOLOGY & BUSINESS
OPPORTUNITiES FAIR
Denver, CO.
Contact: Jerry Holloway, Pacific
Northwest Laboratory 509-375-2007
May 15-19
FEDERAL FACIU11ES ENVIRONMENTAL
COMPUANCE INSTiTUTE
Knoxville, 7W
Run by Government Institutes, Inc.
Contact: 301-921-2345. (Will be run
again on August 21-25, in Keystone, CO.
See later listing)
May 16-18
DOE’S 11TH POLWT1ON PREVENTION
CONFERENCE
Knoxville, 7W
Contact: Linda Josie McDonald, DOE
Oak Ridge, 615-435-3415.
Aug 15-18
AIR FORCE WORLDWiDE POLLU11ON
PREVE ON CONFERENCE
San Antonio, IX
Over 1500 attendees are expected from
government and industry Contact: W.
Bruce Holt, American Defense
Preparedness Association, 703-247-2579.
August 21-25
FEDERAL FACILITiES ENViRONMENTAL
COMPUANCE INSTifUTE
Keystone, CO
Run by Government Institutes, Inc.
Contact: 301-921-2345.
EPA Regional Federal Facilities
Conferences:
Regions
1,2, and 3
April 11-13
Providence, RI
Region 4
April 4-6
Atlanta, GA
Region 5
June
Chicago, IL
Region 6
May 23-25
Dallas, TX
Region 7
June 13-14
Kansas City, KS
Region 8
June 29-30
Denver; CO
Region 9
TBA
San Francisco, CA
Region 10
September
Seattle, WA
Contacts: See Federal Facility
Coordinators listed on page 5.
Workshops on Executive
Order 12856:
Free EPA-sponsored workshops open to
federal facility staff responsible for imple-
menting E.O. 12856. To register, call 703-
218-2709.
Region 8
April 10-13
Denver; CO
Region 10
April 18-20
Seattle, WA
Region 7
April 25-57
Kansas City, KS
Region 1
May 2-4
Boston, MA
Region 9
May 8-10
San Francisco, CA
Region 2
May 16-18
Edison, NJ
Region 5
May 23-25
Chicago, IL
Fed r
United States Envionmental
Protection Agency (5305)
Washington, DC 20460
Official Business
Penalty for Private $300
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT NO. G-35
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