vvEPA
VOLUME 1, ISSUE
United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
(2261)
EPA300-N-95-001B
Fall 1995
An environmental bulletin for federal facilities
AGENCIES PLEDGE TO POLLUTION
PREVENTION, ENERGY EFFICIENCY
GOALS AT WHITE HOUSE CEREMONY
5
6
7
8
Gufcst Spot: Fran McPoland,
the Federal Environmental
"Executive < h r
\ ' ' '
BRAC Cleanup... at Naval
.^Charleston
EPA Receives a Favorable
Ruling on Military Monitions
as Hazardous Wastes
New Executive Order Issued
Civilian Federal Agency
Strategy for Improving
Environmental Management
Regional Round-up,., ,; >.-,*
' "
Generic Audit Protoctoix
Available for Customizing -
Meet EPAa Office of Federal
Activities "~>v
12 ~~~ Calendar of Events
In a White House ceremony on Septem-
ber 12, top environmental and energy
officials highlighted outstanding exam-
ples of individual leadership and accom-
plishments under the President's
executive orders to increase federal recy-
cling, energy efficiency, and pollution pre-
vention. Hosted by Council on
Environmental Quality Chair Kathleen
McGinty, the event, called "Environmen-
tal Excellence in Government," also fea-
tured Energy Secretary Hazel O'Leary,
EPA Administrator Carol Browner, OMB
Office of Federal Procurement Policy
Administrator Steven Kelman, Federal
Environmental Executive Fran
McPoland, and North Carolina Assistant
Secretary for the Environment Linda
Rimer.
During the ceremony, fifteen federal
agencies signed a formal charter under
Executive Order 12856, "Federal Compli-
ance with Right-to-Know and Pollution Pre-
vention Requirements." Signed by federal
agency members of the Executive Order
Interagency Pollution Prevention Task
Force, the Charter reaffirms the federal
commitment to demonstrate leadership in
pollution prevention and community right-
to-know and to achieve the goals established
in the Executive Order.
The first annual White House "Closing
the Circle" awards were given to 23 indi-
viduals and groups from federal commu-
nities across the nation who have
demonstrated a commitment to environ-
mental excellence in the areas of recy-
cling, waste prevention, model
demonstration projects, procurement,
environmental innovation, and lifetime
achievement (See list on page 12.)
At the awards ceremony: EPA Administrator
Carol Browner (left) with Shem Goodman, DOD
Deputy Under Secretary for Environmental
Security, and Steven Herman, EPA Assistant
Administrator for Enforcement and Compliance
Assurance.
In addition, 22 federal agencies signed
the "Energy Efficiency and Resource Con-
servation Challenge," pledging to pur-
chase "best practice" products which are
practicable, cost-effective, and in the
upper 25 percent of energy and water effi-
ciency.
BARRY BREEN
Dear Reader:
Many readers ofFedFacs work on feder-
al facilities issues full time. Some of us
are regulators at agencies such as EPA,
and some are program managers and
implementers at agencies that operate
federal facilities. Virtually all of us feel a
deep commitment to a common goal:
improving the federal facility environ-
ment Why do we feel our work is so
important?
Continued on page 9
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Thai/I vi ii
Case Highlights:
• Region 2 Assesses $190,700 in
RCRA Penalties against USDA’s
Plum IMLind Facility — EPA Region
2 has issued two complaints against
the Department of Agriculture’s Plum
Island Animal Disease Center at
Greenport., NY and against a USDA
contractor for illegal storage and din-
posal of hazardous waste. The orders
carry proposed civil penalties of
$111,100 and $79,600, respectively
• Region 2 Orders Seneca Army
Depot to Comply with SDWA— On
Feb. 3, 1*95, EPA Region 2 issued a
— dnilninfrative order reqth
ing a Ne4YorkArmy facility to comply
with rul under the Safe Drinking
Water Ast (SDWA) for installing filtra-
tion systems. The unsigned ordei
issued to Seneca Anny Depot in Ronm
lus, NY, finds the facility is a public
water supplier and is in violation of 40
CFR Part 141, Subpart K The facility
failed to install filtration by Dec. 25,
1994, the deadline set by anL EPA deter-
mination, which found, with state
input, that auch filtration was required
under the regulations.
• State of Wnsihington Depart.
mont of Ecology Fines National
Oceanic and Atmospheric Mmhi .
isfration for Illegally ‘ fransportlng
and Storing Dangerous Mixture of
Chemical Wastes — NOAA has been
fined $120,000 for illegally transport-
ing hazardous wastes and storing them
improperly The wastes, which hiclud
ed reactive and potentially explosive
materials from— NOAA’B laboratories,
were transported through residential
neighborhoods and commercial areas
near the University of Washington in
Seattle. The Department of Ecology
also cited violations for improper segre-
gation of over 3,000 containers of waste
chemicals and lack of identification of
wastes.
Having recently
celebrated the
i.. 25th anniversary of
the first Earth Day,
I thought it would
be appropriate in
this space to reflect
on the Federal Gov-
ernment’s role in promoting recycling and
related activities during the past quarter
century.
Despite our success in recycling, the
policies of the last 25 years must be
viewed against a backdrop of overarching
government policies promoting the
extraction and use of virgin materials. As
you may recall, within six months of the
first Earth Day in 1970, some 3000 Com-
munity Recycling Centers had been
established. But by the time of the eco-
nomic slowdown in the mid-1970s, most
of these had failed. These programs failed
for a number of reasons, not the least of
which is the fact that both federal policy
and human inclination has long favored
“new and improved” over “recycled and
old.” We did very little to educate con-
sumers about buying recycling products.
We forgot basic economics. We created the
‘supply’ of collected products—but there
wasn’t enough ‘demand’ to keep the pro-
grams working.
In 1976 Congress realized that it had a
role to play and directed EPA to develop
guidelines on recycled content products
that the Federal Government itself would
purchase. However, as a result of budget
cuts, various controversies, and the
urgency of the hazardous waste and
Superfund programs, very little was done
by EPA to actually develop this guidance
until the mid to late 1980s.
By 1989, EPA had finally issued guide-
lines for five items: retread tires: paper
and paper products: re-refined lubricat-
ing oil; cement and concrete containing fly
ash; and building insulation. As of June
1989, all federal agencies (as well as state
and.locaL governments receiving federal
funds) were obligated, if they purchased
more than $10,000 of any of these items,
to procure products which conformed to
the EPA Guidelines.
However, the law gave the agencies an
“our—and they took it! The law allowed
agencies to avoid purchasing these prod-
ucts if the products (1) were not cost com-
petitive; (2) were not readily available; or
(3) did not meet their requirements.
Thus, for the past six years we have seen
agencies create lube oil specifications that
effectively mandated use of virgin lube
oil, and tire tread specifications that
retread tires couldn’t meet. While corn-
piflining that recycled content products
were too costly or unavailable, these same
agencies were taking steps to cut these
recycled products off from being dove!-
oped. Some agencies, such as GSA, had
even written manuals prohibiting the use
of re-refined oil and retread tires. And,
since GSA manages most of the faderal
civilian fleet of vehicles, its guidelines are
generally followed by other agencies.
With barriers like these, it has been
almost impossible for federal purchasers
who wanted to do the right thing, to get
their agencies to purchase those products.
Let me tell you what the President has
directed me to do and what our overall
plan is to turn around the federal recy-
cling record. On October 20, 1993, Presi-
dent Clinton signed Executive Order
#12873 on Federal Acquisition., Recycling
and Waste Prevention— a unique and
historically significant commitment to
dramatically increase federal action on
source reduction, pollution prevenbon,
recycling, and procurement of recycled
and energy efficient materials. As the first
Federal Environmental Executive, I have
Continued on page 11
Gi s
FRAN McPOLAND
Federal Enuimnmental Erecutiue
PAGE 2
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BRAC CLEANUP TEAM...
SETTING A PRECEDENT AT
NAVAL BASE CHARLESTON
by WT1 Linda L Helmig
Editor, The Bow Hook
They came together with one common
goal. to quickly and safely manage the
environmental cleanup of Naval Base
Charleston. They are the BRAC Cleanup
Team (BCT) and they are comprised of
representatives from the Department of
Defense, U.S. Environmental Protection
Agency, and South Carolina’s environ-
mental agency. But what they do is far
from routine.
Thgether, the environmental agencies
are breaking new ground by creating a
partnershi with the U.S. Navy to solve
environmejital problems at the Naval
Base “I think that we have gotten more
actual environmental work done here in
the last two years than in the ten years
before the BRAC Cleanup Team was
established,” stated Doyle Brittain,
Senior Remedial Project Manager for
EPA.
What is taking place is unprecedented
and a sharp departure from business as
usual. Teamwork among the BCT mem-
bers is the key to this process that began
over two years ago. Since its establish-
ment in 1993, the BCT has identified all
potential hazardous waste sites at Naval
Base Charleston and developed a five-vol.
ume master work plan to investigate
those sites. Because Naval Base
Charleston is large and spread out over
several square miles, the BC’F divided the
base property into 12 zones, to allow for
the environmental investigation of the
base in an efficient and timely manner.
At this point, investigation of one full
zone has been completed and two other
zones are in the final stage of investiga-
tion.
Once each zone investigation is com-
pleted and reviewed, a Corrective Mea-
sures Study will be performed to
determine the most efficient method of
cleanup. Public hearings will be held to
give community members the opportuni-
ty to be part of the
decision-making
process.
Another issue
being dealt with by
the BCT is how
future reuse of the
base would affect
the environment.
The Navy, through
the BCT, has
drawn up an Envi-
ronmental Impact
Statement which
considers the clo-
sure of the Naval
Base and imple-
mentation of the
c o m m U n i ty ‘8
Reuse Plan. The
Reuse Plan out-
lines the communi-
ty’s concept of how the property at the
base would be reused.
While the base property cannot be
turned over to the area’s Redevelopment
Authority (RDA) until full environmental
remediation has been accomplished,
property can be temporarily turned over
to the RDA for leasing to other groups.
The BCT conducts smaller investigations
to ensure the property is suitable for leas-
ing.
The good news is that most of the prop-
erty at the Naval Base can be leased
today without significant environmental
concerns. Two pieces of property that
have already been leased to the commu-
nity are the marina complex and the new
building by McMillan Gate. There is no
part of the base that presents an immedi-
ate health hazard and there are no sites
so contaminated that they cannot eventu-
ally be reused.
The roots of the BCT come from Presi-
dent Clinton’s Five Part Program for revi-
talizing communities affected by the Base
Realignment and Closure Acts (BRAC).
One of those parts involved Fast Track
Cleanup to speed the reuse of environ-
mentally contaminated sites. From that
has come the BRAC Cleanup Team and a
proactive, cooperative approach to man-
aging cleanup efforts.
Aenal vww of Naval Base Charleston
Environmental Invest igators collect sod samples
for lab analysia
PAGE 3 ;&D ’
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Net.
FAVORABLE RUUNG
FOR EPA ON MIUTARY
MUN ONS AS
HAZARDOUS WASTES
A significant ruling was handed down
earlier this year in a test case involving
enforcement of the Federal Facility Com-
pliance Act (FFCA). The FFCA ends the
immunity to penalties that had been pre-
viously been available to federal facilities
violating the provisions of RCRA. On
May 12, 1995, Mministrative Law Judge
Spencer Nissen ruled on motions in the
Lackland Training Annex case (Docket
No. RCRA VI-3 11-H.) EPA Region 6 had
initiated an administrative enforcement
action ag inst Lacidand for unautho-
rized disposal of military ordnance by
open bur ting and open detonation
(OB/OD). The RCRA violations were: (1)
failure to obtain interim status for oper-
ating the Site 7 thermal treatment unit
for OB/OD, and (2) operating a haz-
ardous waste management unit without
interim statuS or a permit
In his rulings on prehearing motions,
Judge Nissen analyzed earlier decisions
and the law. He ruled that military ord-
nance is considered hazardous waste
under RCRA. Furthermore, he ruled that
EPA was not estopped from enforcing
because Lackland had relied on a letter
from the state regulator incorrectly
advising the installation that it had
interim status. Judge Nissen also ruled
that even though Lackland had not dis-
posed of additional hazardous waste at
the Site 7 disposal facility after the effec-
tive date of FFCA, the failure to obtain a
permit was a continuing violation. Site 7
remained in active status and Lackland
was liable for penalties for operation of
the unpermitted unit until Lackland
completed the RCRA hazardous waste
unit closure procedure. EPA could assess
a penalty for each day of violation after
the enactment of the FFCA for failure to
close an unauthorized hazardous waste
management unit.
The case is expected to be appealed.
For more information, coniact Patrick
Larkin, Office of Regional Counse4 Do!-
las, 7X, 214-665-2156.
USING EPA’S FEDERAL
FACIL ES TRACKING
SYSTEM
The Federal Facilities Tracking Sys-
tem, or FF1 5 , is an EPA database main-
tained by FFEO that offers a
multi-media view of compliance activities
at over 15,000 federal facilities. EPA
Headquarters and Regional Offices are
currently using DOS version 2.01 of
FFI’S. The Windows version of FYIS is
in the final stages of development and
should be in use in early fall. The Win-
dows version, with new programming
features, will allow for easier retrieval of
data and provide more sophisticated
graphics capabilities.
F?l’S data includes relevant federal
facility information from seven existing
EPA databases. They are:
• NCDB, the National Compliance
DataBase, run by the Office of Pollu-
tion Prevention and Toxic Substances
• PCS, the Permit Compliance System,
run by the Office of Water Enforce-
ment and Compliance
• RCRIS, the RCRA Information Sys-
tem, run by the Office of Solid Waste
• CERCLIS, the CERCLA Information
System, run by the Office of Emer-
gency and Remedial Response
• FFIS, the Federal Facility Informa-
tion System, run by the Office of Fed-
eral Activities
•. FINDS, the Facility Index System,
run by the Office of Information
Resources Management
FVFS links information for a single
facility that is stored in various program
and media-specific offices. This informa-
tion includes:
Continued on page 5
ENVVEST GETS UNDERWAY
In one of the 25111gb Priority Actions unveiled In the Clinton Mminisb ation’s
Reiu*nling Environmental Regulation Initiative EPA will work with other fed-
eral agencies to ensure that their programs achieve environmental -results in the
most cost eftèctive manner, while eliminating needless bureau ratic procedures.
The initial pilot for this project called ENVVES1 , is a joint EPAiDepartment of
Defense initiative which will test new approaches to environmental mans ig ment
at three to five DOD installations. ENVVEST falls under the framework of Pro-
ject XL, part ofa package of initiatives unveiled by the President for reinventing
environmental regulation. The goals are to produce overall environmental results
beyond wb$ would be achieved with existing regulations, and to impiuve the cost-
eff e±venees of DOD environmental invest nenta. The initiative will serve as a
natiOnAl model for performance-based envirnnn,ental management systems. EPA
and DOD are currently negotiating an umbrella Memorandum of Agreement to
help guide development of site-specific agreements.
DOD’s Deputy Under Secretary for Environmental Security Sherri Goodman,
baa tentatively identified Florida, California, and Alaqkn (in EPARegions 4,9. and
10, respectively) as states that have expressed interest in supporting pilot projects
at federal facilities within their borders. Once proposals are reviewed and pilot
installations selected, EPA and DOD will develop performance standards, iniple-
mentation plans, and site-specific compliance agreements for each participating
pilot facility
PAGE 4 , &a s°
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FEDERAL TRACKING SYSTEM
Continued from page 4
• facility location
• points-of-contact
• status information
• permits
• cleanup activities
• inspections
• enforcement activities.
Other facility linking and data
cleanup activities are needed before
FVFS development is completed. Some
civilian federal agencies will be asked to
participate in facility identification exer-
cises to assess the need for further data
cleanup. When data linking and cleanup
are concluded, FVFS reports for federal
agencies and federal facilities will be
made ava4able. Federal agency reports
will be designed by EPA Headquarters
and packaged for release to individual
agencies. Reports for individual federal
facilities will be prepared and distributed
by EPA’S Regional Offices. These reports
are expected to be available by mid-F’Y
1996.
NEW EXECU11VE ORDER
ISSUED ON POLLU11ON
DISCLOSURE
On August 8, 1995, President Clinton
issued Executive Order 12969, “Federal
Acquisition and Community Right-to-
Know,” which requires manufacturing
facilities doing business with the federal
government to comply with TRI report-
ing requirements, i.e., to disclose to the
public information on their emissions of
651 chenucals (including the 286 recently
added to the Tifi list). The Executive
Order does not apply to contracts below
$100,000 and uses the simplified right-to-
know reporting requirements recently
adopted for small businesses.
Also announced at the same time was
the President’s directive to EPA to
expand the right-to-know program to
include mforrnation on chemical use, and
to expand the number and types of facili-
P2/FINANCE SOFTWARE AVAILABLE
P2/FINANCE is a spreadsheet software tool that helps organizations collect and
analyze data essential to a dearer financial evaluation of product/process costs and
pollution prevention costa P2/FiNANCE is available free of charge for any feder-
al, state or local government employee. The software offers a valuable starting
point for introducing a Thtal Coat Assessment (TCA) approach to cost exunmting.
The TCA approach-differs from- conventional practices in four key ways: a
broader inventory of costs and savings; allocation of all coats and savings to spe-
cific process and product lines rather than to overhead a unts; expanded time
horizons for the capture of long term benefits; and the use of profitability indica-
tors which incorporate the time value of money. Users input capital and operat-
ing costs for product/process and an alternative product/process, and the program
outputs a fifteen year cash flow analysis and a profitability analysis. The analy-
sis calculates three financial factors: net present value; internal rate of return;
and simple payback. P2/FINANCE comes with a user manual and free access to
a user hotline.
For ir fonnation on how to obtain P2/FINANCE, contact EPA’S Poll ution Pre-
vention Information Clearinghouse at 202-260-1023.
ties required to report. The President
also took aim at Republican proposals to
severely limit EPA’S ability to expand the
TRI reporting requirements beyond
those initially enacted, threatening to
issue a second executive order that would
secure the public’s right-to-know through
executive action.
APPLYING UFE CYCLE
AND TOTAL COST
ASSESSMENT CONCEPTS
In order to assist federal facilities in
complying with Executive Order 12856,
FFEO recently published Federal Facili-
ty Pollution Prevention Project Analysis:
A Primer for Applying Li/i Cycle and
Thtal Cost Assessment Concepts. Section
4-404 of the Executive Order requires
that federal agencies apply total cost
a unting (TCA) and life cycle analysis
(LCA), to the greatest extent practicable,
when evaluating pollution prevention
opportunities.
The manual is written to help deci-
sion-makers and those who evaluate and
recommend projects understand and
implement life cycle and total cost assess-
merit In addition to explaining the pri-
mary concepts of LCA and TCA, the
guide provides step-by-step worksheets
for performing cost assessments and life
cycle assessments. The guide also pro-
vides references for those needing addi-
tional information.
Contact: Rick Brenizei 202-260.6177.
7b obtain a copy of the giude, contact EPA S
Pollution Prevention Information Clear-
uighouse at 202-2&)-10’23. Electronic for-
mats of the guide and worksheets are also
available on EPA S Envzm$en$e bulletin
PAGE 5
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A STRATEGY FOR IMPROVING CIVILIAN FEDERAL
AGENCY ENVIRONMENTAL PERFORMANCE
active partnership with EPA.
Civilian federal agencies often lack the
infrastructure, budget, and technical
expertise to effectively manage environ-
mental problems. In a survey of 28 CFAs
conducted in January 1993, for example,
over 80% of the CFAS reported having no
formal compliance training program at
either the regional or installation level for
employees charged with ensuring agency
compliance. Only one agency reported
having an agency-wide system or data-
base to ensure that proper records are
maintained and updated.
SIX AREAS OF NEED
The CFA Task Force identified six areas
of need for CFA environmental manage-
ment:
1. Inadequate or duplicative environ-
mental management training.
EPA has prepared a Strategy for
Improving Environmental Management
Programs at Civilian Federal Agencies
(EPA 300-B-95-006) which is scheduled
for release in September 1995. The strat-
egy is a product of the Task Force of Civil-
ian Federal Agencies (CFAs) convened by
EPA in October 1992 to address the
unique environmental compliance/man-
agement problems of non-military agen-
cies. (CFAs include all federal
departments and offices other than the
Departments of Defense and Ener )
The Task Forc&s goals were to identify
deficiencies in CFA environmental man-
agement and compliance programs,
determine their causes, and make recom-
mendatio i for improvements. The effort
is directecE at assisting CFA compliance
and management programs in evolving to
higher levels of performance by providing
increased a sato resources and a more
Enviro$en$e UPDATE
Help Is on the w*j 4 Enviro$en$e is EPA new full- ervice
computerized environmental information system. ‘HeIp”
instructions are now available frcxn the Federal Facilities
Enforcement Office, for modem users of the electronic bulletin
board system (BBS) plali Irm of Enviro$en$e. The in truction
address how to nect to the system, registezr search and view
documents, compress, uncompress convert to ASCII ter and
download and upload documents. When tlw EPA HQ LAN
“ALS Communication” is upgraded, a4mitsir inaiructions will be
completed for EPA LAN users. FFEO will also psi&age Envi-
rc$en$e help instructions in an Enviro$en$e BBS User’s
Guide, to be completed this Fall. For information, call Isabella
Lacayo (202-260-3035) or download the instructions fiom the
BBS Utilities Directory
Calls and Customerar In its first five n,ri fl a of operation,
Enviro$en$e has already received over 2,000 documents, and
routinely gets 150-200 calls per da
FFLEL The Federal Facilities Environmental Leadership
Exchange system is now a saible as a directory on the Envi-
ro$en syatenL
Access Informatiom Following is the a a information
for reaching Enviro$en$e
Via modenu Use a personal computer with a modem (up to
2. Difficulty in finding timely and reli-
able information on regulations, tech-
nologies, and management strategies.
3. Absence of centralized data manage-
ment systems to alert federal agencies
to changes in facility compliance sta-
tus.
4. Need for EPA assistance on specific
compliance issues and needs, such as
environmental auditing.
5. Insufficient staffing to provide ade-
quate technical services and support.
6. Poor communications among EPA
headquarters and regions, and
between EPA and other federal agen-
cies.
Recommendations were made in each area
indicating where improvements can be
accomplished through technical assistance
Continued on page 7
address from last issue of FedFaca)
WWW Hotliner 208-528-8958
For more in/brmation, contact Isabdlle Lacayo, 202-260-
3025, or Louis Paley, 202-2604640.
14,400) and communications software set to the following spec-
iflcalions 8, N, 1, Emulation ANSI, BBS, or ‘VT-lOO.
‘iblephone Number 703-908-2092
BBS Hotilner 908-2007
Via the jnternet You need to have access to the Interact
and use World Wide Web ac software such as Mosaic. Use
tire following address:
. !lwastenotJneLgovfenviroseflsaf (Note: Corrected
PAGE 6 k Y
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In theLWMi
EPA-NEW ENGLAND “STEPS UP,,
ENFORCEMENT OF PUBLIC AGENCIES
On July 5, EPA-New England unveiled
its overhaul of the region’s enforcement
policy bringing another round of enforce-
ment actions against two federal facili-
ties, nine municipalities, two state
facilities, and one municipal airport for
violations of federal environmental laws,
totaling $184,000 in penalties. The new
enforcement policy, called STEP-UP, the
Strong, Targeted Enforcement Program
targets public agencies, the urban envi-
ronment, sensitive coastal resources, and
high-risk sources of pollution. Up to 80
percent of EPA-New England’s enforce-
ment res irces are being dedicated to
the target areas. Since the initiative
began last fall, the region has brought 52
cases against public agencies.
The two cases brought in July against
federal facilities were as follows:
The Vermont Air National Guard
in South Burlington, VT faces a
fine of $81,300 for numerous viola-
tions of federal waste management
laws. The facility was cited for failing
to properly mark, inspect, and store
hazardous wastes, and failing to
maintain adequate records of haz-
ardous wastes generated at the site.
The U.S. Army Natick Research,
Development and Engineering
Center Facility in Natick, MA,
which was recently listed on the
National Priorities List, will pay a
$49,700 penalty for violations of haz-
ardous waste management laws.
EPA inspectors found the Army had
failed to properly identify hazardous
wastes at its facility failed to label
and mark accumulated containers of
wastes, failed to keep containers
closed in storage, and failed to clearly
mark hazardous waste storage areas.
In the next stage of STEP-U} EPA-New
England will target specific geographic
areas for inspection, such as Nan-a-
gansett Bay (R.I.) and Casco Bay
(Maine).
For nwre information, contact Alice
Kaufman, 617-565-4592.
ENVIRONMENTAL PERFOffi 1ANCE
Continued from page 6
from EPA or other outside sources. The
recommendations are a result of a collab-
orative effort of EPA and federal agencies
to establish a greater sense of partnership
and to further the common goal of improv-
mg environmental performance.
FUTURE TASK FORCE
ACT1VJ11ES
The CFA Task Force is expected to
become a permanent partnership group
and serve as the primary conduit of com-
munication between EPA and CFAS.
Periodic informal meetings will be held
to review the progress of CFAs and EPA
m implementing the actions called for in
the CFA Strate document and to iden-
tify and resolve new issues as they arise.
For more information, contact Rich
Satterfield, 202-260-9759. For a copy of
the strategy document, see ordering infor-
matzon on p. 11.
RegionaIf w
• In May 1995, EPA Region 1 and
the Army signed a Federal Facili-
ty Agreement (FFA) for the Army
Materials Ththnalo Lab (AMTL)
in Watertown, MA. AMTh is a
BRAC 1, fast track base, slated for
closure in September 1995. AMTL
was placed on the National Priori-
ties List in May 1994. The Army
and EPA agreed to language in the
FFA that addresses EPA s concern
with protecting the ongoing
cleanup and ensuring that activi-
ties of subsequent franthrees do
not interfere with the cleanup
efforts. The FFAIS accompanied by
a side lettei- from the Army rein-
forcing the Army’S coninnbiient to
ensure that the substance of protec-
tive language worked out with EPA
is actually included in the appropri-
ate land transfer documents.
• During April and May 1995, EPA
Region 3 conducted a number of
Inspections of ISderal facilities in
Washington, D.C. as pelt of the
Region’s Anacostia River cleanup
initiative. EPA and District of
Columbia representatives inspect-
ed the Bureau of Eiigraving and
Printing, Wnshingtou Naval
- Shipyard, and the Southeast
Federal Center The primaxy
focus of these inspections was to
determine the facilities’ compliance
history while ex niining whether
their operations have had any
impact on environmental problems
in southern Washington, D.C.
Region 3 anticipates receiving
drafts of the inspection reports by
the end of the fiscal year and will
decide whether additional facilities
in D.C. may need tobe inspected.
PAGE 7
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GENERIC PROTOCOL AVAILABLE IN
ELECTRONIC FORMAT FOR CUSTOMIZING
A revised Generic Protocol for Conduct-
ing Enuironmental Audits of Federal
Facilities (released in February 1995) is
available for use by federal agencies. Pre-
pared as a collaborative effort by the
member agencies of the Federal Audit
Protocol Workgroup for the Federal Com-
munity (EPA, DOE, DOD, USPS, NASA,
DO!, USDA, and FAA), the protocol is
meant to assist in the conduct of environ-
mental audits and environmental man-
agement assessments. The protocol
focuses on determining compliance with
environmental requirements and adher-
ence to good management practices.
Because o its size — over 1,800 pages —
the proto l is being made available to
federal agencies on computer diskette as
well as online.
The Generic Protocol contains three
separate auditing sections or “phases”
intended to provide both a micro and
macro view of environmental manage-
ment and help identilSr root causes for
problems found.
• Phase I provides for a review of facil-
ity conditions in regard to specific
media areas (e.g. au water, and solid
and hazardous waste) with a focus on
compliance with Federal environmen-
tal requirements. Phase I may be
used as a starting point for agencies
that have just begun new programs.
• Phase II of the protocol examines
cross-cutting issues, provides an
assessment of pollution prevention
initiatives for each environmental dis-
cipline, and evaluates seven manage-
ment systems that are relevant to
each environmental area. These are:
organizational structure, environ-
mental commitment; formality of
environmental programs; internal
and external communications; staff,
resources, training, and development;
program evaluation, reporting, and
corrective action; and environmental
planning and risk management
• Phase III examines the facility’s
management of all environmental
programs to help establish compli-
ance as the starting point rather than
the endpoint of environmental perfor-
mance.
A companion document to the protocol,
Enuironmental Audit Program Design
Guidelines for Federal Agencies, is cur-
rently undergoing revision. The guide-
lines are tailored to federal agency
organizational and budgetary contexts,
and will help federal agencies design
environmental audit programs for facili-
ties that they own or operate.
CUSTOMIZING THE PROTOCOL
Federal agencies are encouraged to cus-
tomize the protocol to their own needs
before issuing it to auditors. ‘lb facilitate
that customizing, the protocol is available
in a packet of seven diskettes (Diskettes
1-5 cover Phase 1; Diskette 6 covers
Phase 2; and Diskette 7 covers Phase ifi)
in IBM compatible, Wordperfect format
Call 202260.9801 to obtain a packet.
Accessing the Generic Protocol on EnviroSenSe
To download the document from Enviro$en$e nith g a
modem, follow these directions.
1. Using a modem, cali 703-908-2092.
2. Set the modem and onmmnnicRtions software at 2400,8,
N, 1, and VT .100 orANSI emulation. Consult your com-
munications software manual for specific details, includ
lug how to set up a path and directory. For setup
questions, you may call the BBS Hotline (703-908-2007)
for help.
3. Follow insthictions to registan You may immediately use
the BBS after registering, for up to 2 hours per day
4. From the Enviro$en$e System Menu, search for the
Generic Protocol by typing “5;” press ENTER; type “fl” to
search by directories (this searches abstracts and titles of
documents; text searches will search text only). 1 rpe
1 ’generic’ press ENTER; type “A” (for ALL) press
ENTER; scroll through the documents until you find the
three files (representing Phases 1,11, and 111) of the Pro-
tocol.
5. Once the search results are displayed on-screen, select
each docwnentby ypj g (to flag it for later download)
‘and follow the prompts . You must also download a utili-
ty program called PK22040.EXE to uncempress the
Generic Protocol files foruse on your PC. This utility file
can be found in the Utilities Director3
6. When you are ready to download, go to Enviro$en$e’a
System Menu, select “fl” and follow the prumpts. After
the download is completed, use the PKUNZIP file from
the PKZ2O4G.EXE Me to uncompress your document.
For more injbrmation, contact Iwbelle La xmyo, 202-260-
3025, or Lou Pale 202-260-4640.
PAGE 8 ? 1 ’
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MEET... EPA’S OFFICE OF
FEDERAL ACTIVITIES
EPA’S Office of Federal Activities (OFA) is a “sister office” to
the Federal Facilities Enforcement Office within OECA. OFA
houses three major national programs:
Review of federal agencies’ environmental impact state-
ments (EISs) and other major action under the authority of
the National Environmental Pohcy Act (NEPA) and Section
309 of the Clean Air Act;
• Review of EPA’S own compliance with NEPA and related
laws, directives, and Executive Orders concerning special
environmental areas and cultural resources; and
• Coordination of OECA’s international enforcement and com-
pliance, and environmental impact assessment programs.
OFA provides a central point of information for EPA, other
government agencies, and the public on environmental impact
assessmen techniques and methodologies. OFA works with the
Council on-Environmental Quality on NEPA program adminis-
tration, an administers the filing and information system for
all federal EISs under agreement with CEQ. For the interna-
tional community, OFA is EPA’s focal point on the conduct of
environmental enforcement and compliance assurance.
OFA is organized into the NEPA Compliance Division and
the International Enforcement and Compliance Division.
NEPA Compliance Division. Last year over 500 EISs were
filed with OFA under delegation from CEQ. EPA commented on
about 200 draft EISs and 200 final EISs, and a number of pro-
posed regulations, legislation, environmental assessments, and
scoping notices. In addition to coordinating EIS reviews, this
division is active in a number of areas ranging from DOD base
closure to endangered species management. The NEPA Com-
pliance Division is currently working closely with EPA’S region-
al offices and other agencies to implement Section 2001 of Public
Law 104-19; this section, Emergency Salvage ‘flmber Sales, was
enacted on July 27, 1995. On August 1, 1995, the White House
issued a letter implementing timber-related provisions of the
law. A Memorandum of Agreement was signed by EPA and the
Departments of Agriculture, Commerce, and Interior to coordi-
nate the sale of 1.6 billion board feet of salvage timber.
International Enforcement and Compliance Division. This
division has ongoing coordination responsibilities with Mexico,
Canada, Russia, the United Nations Conference on Environ-
ment and Development, and other international concerns. In
Mexican relations, for example, OFA, in conjunction with EPA
Regions 6 and 9, has begun efforts to encourage U.S. parent
companies to take leadership roles in promoting compliance and
pollution prevention among their Mexican operations. “léchni-
cal assistance in targeting enforcement efforts, and a training
video have been made available to Mexico as well.
DIRECTOR’S WORD
Continued from page 1
I can think of at least three reasons.
First, federal facilities have a dramatic,
direct physical effect on the environment.
The federal judge handling the Army’s
Rocky Mountain Arsenal case called it
“the worst hazardous and toxic waste site
in America.” The Energy Department
observes that DOE “faces one of the
largest environmental challenges in the
world.” The General Accounting Office
concluded that “with close to 730 million
acres of land, federal civilian agencies’
inventory of possible hazardous waste
sites could be enormous.” Both the
breadth of the federal government’s activ-
ities and the inherent danger in many of
them lead to an enterprise that requires
direction to ensure its harmony with the
environment.
The second reason our work is so
important is that it sets an example for the
rest of the nation. President Lôrndon John-
son summarized it when he wrote ‘ Fhe
Federal Government is rightly expected
to provide an example to the nation in
pollution controL We cannot make new
demands on State and local governments
or on private industry without putting
the federal house in order.” President
Clinton carried forward this thought
when he called on federal facilities to “set
the example for the rest of the country
and become the leader in applying pollu-
tion prevention.” Federal facility compli-
ance isn’t a side event in environmental
policy it’s a demonstration of federal com-
mitment
The third reason we work so hard on
federal facilities environmental issues is
that they are a matter of trust between the
American people and the federal govern-
ment. “Public officers are servants and
agents of the people,” President Grover
Cleveland said. As public servants,
whether as regulators or federal facility
personnel, we are trustees for this gener-
ation and America’s future generations.
Our part of the public trust is the federal
environment, and when we manage it
well we set the example not only for envi-
ronmental polic but for all of govern-
ment
Our work is of the highest importance,
and given the magnitude of it, we need
help from all quarters. We look forward to
working with you.
Dzrector FFEO
Bany
PAGE 9 1 ’
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16 FEDERAL AGENCIES COMMIT TO
POLLUTION PREVENTION STRATEGIES
Sixteen federal agencies have sub-
mitted pollution prevention strategies to
implement Executive Order 12856. The
16 strategies cover implementation
activities at over 2,500 covered federal
facilities. Executive Order 12856 was
signed by President Clinton in August
1993, directing federal agencies to com-
ply with the Emergency Planning and
Community Right-to-Know Act of 1986
(EPCRA) and Pollution Prevention Act of
1990. The Order sets a new standard for
federal environmental excellence by
extending this compliance requirement
to many activities not cunently mom-
tored in j,vate mdustiy
Agencies submitting strategies
include tl e Central Intelligence Agency,
the De artments of Agriculture,
Defense, ‘Ener Health and Human
Services, Interior, Justice, Transporta-
tion, Treasury, and Veterans Affairs,
Environmental Protection Agency, Gen-
eral Services Administration, National
Aeronautics and Space Administration,
Smithsonian Institution, Tennessee Val-
ley Authority and U.S. Postal Service.
(The Smithsonian, VA, and Postal Ser-
vice were not strictly required to submit
strategies, but did so nonetheless.)
POLLUTiON PREVENTiON
GOALS
The Executive Order directs that each
federal agency develop voluntary goals to
reduce the agency’s total releases and
transfers of toxic chemicals by 50 percent
by the end of calendar year 1999. A
majority of federal agencies explicitly
committed in their pollution prevention
strategies to the 50% reduction goal by
the end of 1999.
Some federal agencies went beyond
the chemicals covered by EPCRA. For
example, USDA’S strategy allows the
various USDA services to set their 50
percent reduction goal for toxic pollu-
tants rather than toxic chemicals, there-
by expanding the number of chemicals
that will be reported as well as identify-
mg opportunities for source and release
reductions at USDA facilities.
The CLA s pollution prevention strate-
gy mcludes a commitment expanding the
50 percent reduction goal to include
releases of extremely hazardous sub-
stances.
ACQLJIS ON AND
PROCUREMENT
All of the federal agency pollution pre-
vention strategies contain a commitment
to pollution prevention in both facility
management and acquisition. For exam-
ple:
• DOD’s strategy requires the integra-
tion of pollution prevention and other
environmental concerns into the
entire life-cycle of acquisition pro-
grams.
• The General Services Administration
commits to reduce or eliminate prod-
ucts that contain hazardous chemi-
cals from the inventory of products
purchased for the federal supply sys-
tem.
• The pollution prevention strategy for
the Department of Health and
Human Services commits to revisions
of standard internal administrative
and policy manuals to ensure those
documents embrace pollution preven-
tion and reflect the Executive Order.
• The Tennessee Valley Authority strat-
egy calls for a review of agency stan-
dardized documents to identify
opportunities to eliminate or reduce
use of extremely hazardous sub-
stances or toxic chemicals and ulti-
mate revision of those documents to
reflect goals of the Executive Order.
FACILITY SPECIHC PLANS
The Executive Order directs that the
head of each agency will ensure that its
covered facilities develop a written pollu-
tion plan that sets forth the facility’s con-
tribution toward the agency 50 percent
reduction goal. Nearly all of the federal
agency pollution prevention strategies
include an agency commitment to ensure
development of facility specific pollution
prevention plans for covered facilities.
Most of the strategies direct facilities to
conduct formal facility pollution preven-
tion opportunity assessments to enhance
the effectiveness of the plan .
Each of the federal agency strategies
also includes a specific commitment to
pollution prevention as the primary
means of achieving and maintaining
compliance with environmental require-
ments. Over half of the federal pollution
prevention strategies contain specific
commitments endorsing the develop-
ment, testing and support of innovative
pollution prevention technologies and
programs.
EPA’s Federal Facilities Enforcement
Office has prepared a document outlining
the collective federal commitment to pol-
lution prevention and community right-
to-know, with summaries and full text of
each federal agency strategy. For a copy
of the document, “Meeting the Challenge”,
see ordering information on p. 11.
-
Meeting the Challenge.
A Sunvn ,y 04 Fe a Age 1 ,
Poll t 0 , Prevent,n , , Straiogc
4 ‘ . 0
—. —.-— . — -- -
PAGE 10 ;& k
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To Receive FedFacs in the Mail or to Order Documents
Mentioned in the Newsletter
L Please include me on the FedFacs mailing list (no charge).
C Please send one copy of the following documents (no charge):
C i Strategy for Improving Environmental Management Programs
at Civilian Federal Agencies (EPA 300-B-95-006, September 1995).
Ci Meeting the Challenge A Sumni ry of Federal Agency Pollution
Prevention Strategies (EPA 300-R.95-014, September, 1995).
Federal Facility Pollution Prevention Project Analysis: A Primer
for Applying Life Cycle and Total Cost Assessment Concepts
(EPA 300-B-95-008, July 1995).
Complete the following:
Name
AMrpqqj
Mail to: FedFacs (for newsletter)
I Federal Facilities Enforcement Office (for documents)
U.S. EPA (2261), 401 M Street, SVt Washington, DC 20460
or J’. to: 20 - 0-
L J
GUESTSPOT
Cordmued from page 2
been tasked by the President to come up
with ways to make that happen—quickly.
Each Department has named an
Agency Environmental Executive to work
with both me and their own Departments
to assure complete and rapid implemen-
tation. Over the past year we have made
important strides.
One of the first things we did was to
look at barriers in the federal government
that limit demand for, or prevent pro-
curement of, recycled items. For example,
we have worked to convince GSA to allow
the use of re-refined oil in government
vehicles. We have also worked with EPA
to identilS’ 19 more items subject to affir-
mative procurement by federal agencies
and governments receiving federal-fund-
ing. The leadership challenge we face will
be to purchase and track an expanded
number of items better than we did for
the first five. My office has brought
together members from several large
agencies to look at new ways of compiling
purchase information using the upcom-
ing electronic commerce system that will
significantly ease the burden of tracking
and reporting by the agencies.
There is more positive change on the
horizon. A recent law (PL 103-329) allows
the proceeds from recycling efforts to go to
federal agencies, rather than the U.S.
‘freasury; to offset at least some operating
costs of recycling and pollution preven-
tion programs.
EPA s Office of Pollution Prevention has
been developing guidance for environinen-
tally preferable products which will begin
to move the Federal Government towards
purchases of less environmentally harmflul
and more environmentally friendly prod-
ucts, through a series of pilot prqjects in
various sectors of the government. The
first pilot project is already underway an
EPA/GSA Cleaners Project.
In closing, I want to assure you that
the President and Vice President are as
committed to the success of the govern-
ment’s recycling challenge as I am. But
while the Agency Environmental Execu-
tives and I help to establish the overall
battle plan, it is the front line troops in
acquisitions offices, the people using
those materials, and the people charged
with final disposition who, by thinking
“outside the box” of narrow responsibility,
will make this process a success. We
know what happens when facility man-
agers and staff take on this responsibility
wholeheartedly—we saw the outstanding
record of results compiled by the recent
winners of the “Closing the Circle”
awards for federal facilities. It is their
efforts—and yours—that will make the
Federal Government a leader, not a fol-
lower, in the recycling arena.
is published by EPA s Federal
Facilitice Enforcement 0 ee.
Jim Edward, Joyce Johnson, Editors
Gilah Iangn Wüer
Robin Fostei La cu
I I
I I
I I
I I
I I
I I
I I
I I
Ci
UST OF ACRONYMS
BRAC Base Realignment and
Closure Act
CFA Civilian Federal Agency
DOD Department of Defense
EPA Environmental Protection
Agency
FFCA Federal Fadlity
Compliance Act
FFEO Federal Facilities
- Enforcement Office (EPA)
FFLEX Federal Facilities
Environmental Leadership
GSA General Services
Administration
OECA Office of Enforcement and
Compliance Assurance (EPA)
0MB Office of Management and
Th got
RCRA Resource Conservation and
Reaweiy Act
‘I ic Subatan s Control Act
SDWA Safe Drinking Water Act
PAGE 11
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CALENDAR
October 30-November 3,1995
GOVERNMENT &S11TUTES - ThE DEFENSE ENVIRONMENML
MANAGEMENT INSTTTIJIE
Alexandria, VA
Five days of intensive compliance training sessions for DOD
environmental professionals. A team of experts from the armed
services and the civilian community conduct lectures and work-
shops on special issues of concern to DOD environmental per-
sonnel, including NEPA, BRAC, and other laws and regulations.
$1,899, 40 credits, Level 1. Contact: Government Institutes,
Inc., Suite 200,4 Research Place, Rockville, MD 20850, Tel: 301-
921-2345, Fax: 301-921-0373.
December 6-8
NATiONAL POLLUTION PREVENTION ROUNDTABLE
Miami Beach, FL
Thpics for f deral facilities include painting, depainting, clean-
ing, and d 7 reasing and voluntary and innovative initiatives.
Co-sponsored with the Florida DEP and Dade County Pollution
Prevention Program. Contact NPPR at 202-466-P2P2.
January 16-18, 1996
1996 HAZARDOUS MATERIALS AND WASTE MANAGEMENT
CONFERENCE & EXH18 ON
Alexandria, VA
Sponsored by the Defense Logistics Agency and the Military
Services, the theme of this year’s conference is “Resource Con-
servation and Recovery into the 21st Century” Contact: Ameri-
can Defense Preparedness Assn. at 703-247-2557.
March 18-21, 1996
2 D ENVIRONMENTAL SYMPOSIUM & E)(HIBITION
Orlando, FL-
Sponsored by the American Defense Preparedness Association,
this year’s event is titled: “Investing in Our Future: Reinventing
Environmental Protection for Improved Readiness.” For more
information, fax ADPA at 703-522-1885.
CONGRATIJLA11ONS TO ThIS YEAR’S CLOSINGTHE CIRCLE AWARD WiNNERS!
Lge-Time Achievement John
Stanberr, GSA.
Aff ve ocurement Beth
Law, National Naval Medical
Center, Bethesda, MD. Paula
Ure, GSA and Paul Ruesch,
EPA, Region V. U.S. Postal
Service Headquarters,
Washington, D.C.
Model Facility Demonsfratlon:
U.S. Coast Guard Support
tion, Cherry Point, NC. Depart-
ment of Housing and Urban
Development Headquarters.
BulM1ng Washington, D.C.
lake City Army Ammunition
Recycling: Scott J. Ammon, Plant, Independence, MO.
Whiteman Air Form Base, MO.
Brent Glezentanner, Aransas Waste Preventloit U.S. Postal
National Wildlife fuge,iX ServiCe, Vehicle Maintenance
Chip Britting, Blue River Facilities in New Orleans, LA
Ranger station, Edison, NJ; Anchorage, AK
National Forest, OR. Fort th Houston, I X and other sites in .-’
OK. Marine Corps Mr Sta- - , C1 ’ RI. NY. MA. ME, NH.
Kennecy Space Center FL
Y-12 Site Management
Services, Oak Ridge; TN
nmn
Captain Gordon Matthews,
Washington Army National
Guard, Thanna, WA. Army -
National Guard, Arlington, VA.
Savneirnih River Site, Aiken,
SC.. - -
FedF
United States Enviromnental
Protection Agency (2261)
Washington, DC 20460
Official Business
Penalty for Pnvate Use $300
Center, Governors’ Island, NY
U.S. Postal Service Hartford
Vehicle Maintenance FaciIIt
Hartford, CT.
- , j
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT NO. G-35
Forwarding & Return Postage Guaranteed
Address Correction Requested
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