&EPA
United States
Environmental Protection
Agency
January 2004
The State of Federal
Facilities
An Overview of Environmental
Compliance at Federal Facilities
FY 2001-2002
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EPA Document No: EPA 300-R-04-001
This document was prepared by EPA's Federal Facilities Enforcement
Office in the Office of Enforcement and Compliance Assurance.
For additional copies of this document, please contact:
U.S. Environmental Protection Agency
Federal Facilities Enforcement Office (2261 A)
1200 Pennsylvania Ave, NW
Washington, D.C. 20460
Phone:(202)564-2510
Fax:(202) 501-0069
This document, as well as additional information on EPA's
compliance and enforcement programs, can be found at
www.epa.gov/compliance/civil/federal/crossmedia.html
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Federal Facilities Enforcement Office
TABLE OF CONTENTS
Section Page
I. Executive Summary 1
II. Introduction 5
III. Federal Facility Compliance Rates 9
IV. Inspections and Enforcement Actions 27
V. Federal Facilities Universe and Toxic Release Inventory Data 35
Appendix A - Acronyms 47
LIST OF EXHIBITS
Exhibit Page
Federal Facility Compliance Rates
1. Definitions of Compliance Indicators for Federal Facilities 9
2. Federal Facility Compliance Rates for Selected Indicators 13
3. Federal Facility Compliance Rates 14
4. RCRA TSDF Compliance Rates by Federal Agency Category 15
5. Percentage of Inspected TSDFs not in SNC 16
6. RCRA LQG Compliance Rates at Federal Facilities 17
7. Percentage of Inspected LQGs not in SNC 17
8. RCRA SQG Compliance Rates at Federal Facilities 18
9. Percentage of Inspected SQGs not in SNC 19
10. CWA/NPDES Compliance Rates by Federal Agency Category 20
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Federal Facilities Enforcement Office
11. Percentage of Major CWA/NPDES Facilities not in SNC 21
12. CAA Compliance Rates by Federal Agency Category 22
13. Percentage of CAA Major Sources not Cited for HPVs 23
14. SDWA/PWSS Noncompliance at Federally-Owned Systems 24
15. Percentage of SDWA/PWSS Public Water Supply Systems not in SNC 25
Inspections and Enforcement Actions
16. EPA and State Inspections at Federal Facilities 28
17. Enforcement Actions at Federal Facilities 29
18. RCRA Inspections and Enforcement Actions 30
19. RCRA Inspections and Enforcement Actions by Facility Type 31
20. CWA/NPDES Inspections and Enforcement Actions at Major Federal Facilities 32
21. CAA Inspections and Enforcement Actions at Major Federal Sources 33
22. SDWA/PWSS Enforcement Actions at Federal Facilities 34
Federal Facilities Universe
23. Federal Government's Owned and Leased Real Property 35
24. Federal Facilities by Agency Category 36
25. Distribution of CFA Facilities by Agency 37
26. RCRA Regulated Facilities by Agency Category 39
27. Universe of RCRA Regulated Federal Facilities 40
28. Universe of Major Federal CWA/NPDES Facilities 41
29. Universe of Major Federal CAA Sources 42
30. Universe of Federal Public Water Supply Systems 43
31. TRI Releases at Federal Facilities 45
ii State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
I. EXECUTIVE SUMMARY
EPA's Federal Facilities Enforcement Office within the Office of Enforcement and
Compliance Assurance periodically assesses federal facility performance with respect to
environmental statutes and programs. The purpose of this report is to provide an overview of the
federal facility environmental compliance program for fiscal years 2001 and 2002 (FY 2001, FY
2002). In some parts of this report, where appropriate and where data are comparable, data prior
to FY 2001 is examined to identify long term trends. This overview is presented in terms of
compliance assessment (inspections), compliance assurance (enforcement actions), and
performance (compliance rates). The report also provides information on the size and
composition of the federal facility universe.
Compliance Rates'
From FY 1993 to FY 2002, the federal facility RCRA compliance rate increased steadily
from 55 percent to 94 percent. In contrast, the compliance rate for CWA/NPDES decreased from
94 percent to 52 percent in FY 2001. Although the CWA/NPDES compliance rate in FY 2002
increased from the prior year, it remained nearly 30 percent below FY 1993 levels. The
compliance rate for the CAA fluctuated at a level slightly below 90 percent for most of the period
before increasing to approximately 93 percent in FY 2002. Similarly, the compliance rate for
SDWA/PWSS remained above 90 percent for the entire period, although it has declined slightly
from 99 percent in FY 1993 to 96 percent in FY 2002.
Federal Facility Compliance Rates
50.O%
1 I I I I I I 1
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
RCRA/TSDF
CWA/NPDES
SDWA/PWSS
Compliance rates for federal facilities regulated under RCRA include only the percentage of inspected TSDFs that are
not in significant noncompliance. Compliance rates under the CWA/NPDES include only the percentage of NPDES majors that
are not in significant noncompliance. Compliance rates under the CAA include only the percentage of CAA major sources that
are not high priority violators. See Chapter 3 of this report for an explanation of compliance indicators.
State of Federal Facilities Report, FY 2001-2002
1
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Federal Facilities Enforcement Office
Inspections and Enforcement Actions
The total number of federal facility inspections conducted by EPA and the states under
RCRA, CWA/NPDES, and CAA decreased by roughly four percent from FY 1993 (1,284) to
FY 2002 (1,228). CWA/NPDES inspections declined by approximately 36 percent, while RCRA
inspections declined by 18 percent; although the decrease in RCRA inspections was much larger
in numerical terms. CAA inspections actually increased by approximately 59 percent relative to
FY 1993, however, the level of CAA inspection activity peaked in FY 1999 and has since
declined. A portion of this decline is due to a FY 2002 programmatic change to the definition of
what constitutes an inspection under the CAA, yet even in FY 2001, prior to the change, CAA
inspections were decreasing. The number of SDWA/PWSS inspections is not reported in the
federal SDWIS database and therefore is not presented in this report.
EPA and State Inspections at Federal Facilities
1000
800-
600-
400
200-
1993
1994 1995 1996
ITl RCRA
1997 1998 1999 2000 2001 2002
H CAA SD CWA/NPDES
EPA and states took just under 300 enforcement actions against federal facilities in
FY 2001 (293 actions) and FY 2002 (279 actions). Both totals represent declines of more than
34 percent relative to FY 1993. RCRA enforcement actions remained the most common,
comprising 63 percent of all enforcement actions at federal facilities in FY 2001, and 56 percent
of all actions in FY 2002. CWA/NPDES actions accounted for approximately 19 percent in
FY 2001 and 15 percent in FY 2002 of all enforcement actions. CAA actions accounted for
roughly 16 percent of the total enforcement actions in FY 2001 and 26 percent in FY 2002.
SDWA/PWSS actions accounted for less than three percent of the total enforcement actions at
federal facilities.
State of Federal Facilities Report, FY 2001-2002
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Enforcement Actions at Federal Facilities
1993 1994 1995 1996 1997 1998
O RCRA E3 CWA/NPDES
1999 2000 2001 2002
CAA £3 SDWA/PWSS
Federal Facility Universe
The federal government owns and leases vast amounts of real property in the United
States. According to the General Services Administration (GSA), as of September 30, 2002, the
total amount of federally owned or leased property is approximately 670 million acres, which
represents approximately 30 percent of all land in the United States. The total area of federally-
owned or leased buildings amounts to approximately 3 billion square feet. Although all federal
facilities are potentially subject to environmental regulations, many are not involved in activities
that would normally trigger federal environmental compliance requirements. According to the
Federal Registry System, as of April 1, 2003, there were 7,853 federal facilities that engaged in
some type of activity directly affected by environmental requirements under RCRA, CAA,
CWA/NPDES, or TSCA/FIFRA/EPCRA §313.2 These facilities can be grouped into four broad
categories - Department of Defense (DOD), Department of Energy (DOE), Civilian Federal
Agencies (CFAs), and unidentified federal facilities3. CFAs account for nearly 59 percent of
federal facilities, while DOD facilities account for roughly 30 percent. DOE facilities comprise
approximately four percent of all federal facilities while seven percent of the total universe is not
identified with any particular federal agency.
A total of 283 federal facilities reported under the Toxic Release Inventory. Of these, 172
facilities were DOD, 23 DOE and 88 were CFAs. DOD reported 13.8 million pounds of total
releases representing 17.4 percent of all releases by all federal facilities. Federal facilities, as a
whole, reported a total of 79 million pounds of both on-site and off-site releases.
' These totals do not include approximately 4,300 federally-owned public water supply systems tracked in SDWIS.
3,,
Unidentified" federal facilities have not been assigned a GSA code or named within their relevant data systems in
such a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
State of Federal Facilities Report, FY 2001-2002 3
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State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
II. INTRODUCTION
EPA's Federal Facilities Enforcement Office (FFEO), within the Office of Enforcement
and Compliance Assurance (OECA), periodically assesses federal facility performance with
respect to environmental statutes and programs. The last assessment, The State of Federal
Facilities: An Overview of Environmental Compliance at Federal Facilities, FY1999-2000, was
published in September 2001. This State of Federal Facilities report examines federal facility
environmental performance during FY 2001 and FY 2002.
Purpose
The purpose of this report is to provide an overview of the federal facility environmental
compliance program, both in terms of compliance assessment (inspections and reports from
regulated facilities), compliance assurance (enforcement actions), and performance (compliance
rates). The principal period of analysis is FY 2001-2002, although where appropriate and when
data are comparable, this report also examines pre-FY 2001 data in order to identify long term
trends. In addition, the report provides data on non-federal entities to provide a point of
comparison for the federal sector.
FFEO Mission and Program
EPA, in conjunction with the states, has oversight responsibility for federal facility
environmental programs. To fulfill its oversight responsibility, EPA conducts a broad range of
activities, including compliance oversight and smart enforcement and training, compliance, and
stewardship assistance. In addition, FFEO is directly involved in enforcement negotiations,
including interagency agreements, administrative penalty and/or compliance orders, and in
litigation and enforcement support at federal facilities. Through its network of EPA Regional
Federal Facilities Program Managers (FFPMs) and other regional and state contacts, FFEO works
with appropriate facility personnel to ensure that they take the necessary actions to prevent,
control, and abate environmental pollution. It is EPA's goal that all federal agencies reach a
level of compliance with environmental requirements that equals or surpasses the rest of the
regulated community. EPA believes that federal facilities should lead the way in minimizing
environmental contamination and impacts to public health.
Environmental Requirements
Federal facilities are generally subject to the same environmental statutes and regulations
as commercial entities and facilities operated by other levels of government such as cities,
counties and states. Environmental requirements potentially affecting federal facilities range
from Executive Orders and federal statutes and their implementing regulations to state and local
laws and ordinances. This report summarizes federal facility data during FY 2001 and FY 2002
with respect to the following environmental statutes and programs:
State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
• Resource Conservation and Recovery Act (RCRA) - RCRA Subtitle C and its
associated amendments regulate the generation, transport, storage, treatment, and
final disposal of hazardous waste.
• Clean Water Act (CWA) - Under the CWA, EPA or approved states issue
National Pollutant Discharge Elimination System (NPDES) permits that establish
effluent limits for municipal and industrial wastewater discharges.
• Clean Air Act (CAA) - The CAA authorizes EPA to establish emission control
standards to achieve the air quality goals set forth in the National Ambient Air
Quality Standards.
• Safe Drinking Water Act (SDWA) - The Public Water System Supervision
(PWSS) program authorized by the SDWA enables EPA to set standards to
control both man-made and naturally occurring contaminants. In most cases,
states have primary responsibility for oversight and enforcement under the
SDWA.
Sources and Suitability of Environmental Information
The information contained in this report is drawn from EPA's Integrated Database for
Enforcement Analysis (IDEA). IDEA is EPA's main information management system that
draws upon several program specific databases compiled and maintained by various EPA
environmental program offices, including the Office of Air, the Office of Water and the Office of
Solid Waste. These offices have primary responsibility for compiling and maintaining data
pertaining to EPA and state enforcement and compliance activities. These EPA program specific
databases include:
• RCRAInfo - Allows cradle-to-grave waste tracking of many types of information
about the regulated universe of RCRA hazardous waste handlers.
• PCS - The Permit Compliance System tracks EPA regional and state compliance
and enforcement data for the NPDES program under the CWA.
AIRS/AFS - The Aerometric Information Retrieval System/AIRS Facility
Subsystem manages aerometric compliance data on point sources tracked by EPA,
state, and local governments in accordance with the CAA.
• SDWIS - The Safe Drinking Water Information System is a national database that
tracks public water supply system compliance and enforcement data collected by
EPA Regions and states under the PWSS program of the SDWA.
The IDEA system is operated by EPA's Office of Enforcement and Compliance
Assurance and integrates facility data from these disparate program specific databases. Since the
purpose of this report is to provide an overview of federal facility compliance and performance
6 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
information and a description of the federal facility universe, the IDEA data system was
determined by FFEO to provide the most practicable and suitable source of information to meet
this goal. Limitations on the use and interpretation of this data are detailed in the specific
chapters of this report.
Agency-wide Information and Users Access
In addition to the program specific sources of data, EPA has developed several database
search systems that interface with the public and other government agencies to access
environmental enforcement and compliance information via the internet. These systems include:
• The Facility Registry System (FRS) - FRS is a centrally managed linking
database that identifies facilities, sites or places subject to environmental
regulations or of environmental interest. FRS creates authoritative facility
identification records that incorporate information from diverse program national
systems (e.g., RCRAInfo, PCS, AIRS/AFS), state master facility records, data
collected from EPA's Central Data Exchange registrations, and data management
personnel.
• The Online Tracking Information System (OTIS) - OTIS enables federal, state,
local and tribal government agencies to tap into IDEA data to evaluate compliance
information, generate customized reports, and improve data quality. Information
includes detailed facility reports that specify environmental permits, inspection
activities, violations and enforcement actions at a given facility.
• Environmental Compliance History Online (ECHO) - Similar to OTIS, ECHO
provides public access to core EPA data systems. ECHO focuses on facility
compliance and EPA/State enforcement of environmental regulations. Unlike
OTIS, the data included within ECHO have been in the public domain through
Freedom of Information Act (FOIA) requests. ECHO provides this information
for the first time in a searchable Web format.
• Envirofacts - This website provides the public with a single point of access to
several EPA databases containing information about environmental activities that
may affect air, water, and land anywhere in the United States. Envirofacts
provides access to more databases than ECHO, however, the system does not
allow users to conduct searches based on facility compliance status.
• Sector Facility Indexing Project (SFIP) - SFIP brings together environmental
and other information from a number of data systems to produce facility-level
profiles for a subset of major federal facilities, as well as five industry sectors.
SFIP information relates to compliance and inspection history, chemical releases
and spills, demographics of the surrounding population, and production (industrial
sectors only). To be included in SFIP, federal facilities must be classified as a
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Federal Facilities Enforcement Office
"major" facility under at least two of the following three statutes: CAA, CWA,
and RCRA.
• Federal Agency Compliance Tracking System (FACTS) - FACTS is a Windows
based search engine that allows users to obtain both summary and detailed multi-
media compliance and enforcement information about individual federal facilities
(e.g., military bases, federal government research laboratories). FACTS reports
regulatory activities occurring at over 7,800 specific installations belonging to
over 30 different federal agencies, bureaus, and operating units for each quarter of
the fiscal year. Users can get information on facility characteristics, permits,
inspection and compliance history, and formal enforcement actions and penalties
issued by EPA or states. FACTS is accessible to everyone in EPA as well as other
federal, state and tribal regulatory agencies.
Organization of the Report
This report is organized according to a multi-media approach in which the data are
intended to address the following basic questions:
• What are the current trends in compliance? (Section III - Federal Facility
Compliance Rates)
• What is the level of inspection activity at federal facilities and what actions are
taken to address noncompliance? (Section IV - Inspections and Enforcement
Actions)
• What is the universe of federal facilities that are regulated/affected under each of
the environmental programs? (Section V - Federal Facility Universe and Toxic
Release Inventory Data)
State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
III. FEDERAL FACILITY COMPLIANCE RATES
Compliance Indicators
Federal facility compliance with environmental requirements can be measured in many
ways, ranging from the percentage of facilities cited for any violations, regardless of their
severity, to the percentage of facilities repeatedly cited for significant noncompliance. EPA has
traditionally focused on the latter, particularly at large and more prominent facilities. The
reasons underlying this tradition include the availability of data, as well as programmatic factors
(see below). Exhibit 1 provides the definitions of the compliance indicators used by this State of
Federal Facilities report to calculate compliance rates.
Exhibit 1
Definitions of Compliance Indicators for Federal Facilities
Statute Compliance Indicator
RCRA/TSDF Percent of inspected federal treatment, storage, and disposal facilities
(TSDFs) not in significant noncompliance (SNC)
RCRA/LQG Percent of inspected large quantity generators (LQGs) not in SNC
RCRA/SQG Percent of inspected small quantity generators (SQGs) not in SNC
CWA Percent of NPDES major federal facilities not in SNC
CAA Percent of major federal sources not cited for high priority violations (HPV)
SDWA Percent of federal public water systems not in SNC
The compliance indicator for CAA and CWA is measured only at major facilities
primarily because of data quality issues. For both programs, states are not required to provide
data on minor facilities to their respective national data systems, and many do not. Thus,
national compliance data for minor CAA and CWA facilities is incomplete. In the case of
RCRA, compliance determinations are based on inspection data. Only a portion of the RCRA
universe of facilities are inspected in any given year. This is especially true for transporters,
small quantity generators, and even large quantity generators. A significant percentage of small
quantity generators have never been inspected. In contrast, most federal TSDFs are inspected
annually, and in some cases, more than once a year. Of the federal TSDFs in existence in
FY 2002, approximately 74 percent were inspected, while 27 percent of LQGs and only 1 percent
of SQGs were inspected. Compliance statistics for TSCA, FIFRA, and EPCRA are no longer
included in this State of Federal Facilities report for two reasons: 1) the relevant data fields
within the National Compliance Database are not reliably populated and are subject to other data
quality issues, and 2) even if the data fields were complete, the universe of facilities is too small
to yield meaningful results.
State of Federal Facilities Report, FY 2001-2002 9
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Federal Facilities Enforcement Office
A brief summary of each program's data system definition of SNC is shown below.
However, these summaries are not meant to substitute for the complete definition, which can be
found in the following relevant guidance documents:
• Hazardous Waste Civil Enforcement Response Policy; March 15, 1996 -
www.epa. gov/Compliance/resources/policies/civil/federal/hwcerp 1996.pdf:
• Revision of NPDES Significant Noncompliance (SNC) Criteria to Address
Violations of Non-Monthly Average Limits, Memo from Steven A. Herman,
September 21, 1995-
www.epa.gov/compliance/resources/poHcies/civil/federal/revisnpdessnc.pdf:
• Office of Enforcement and Compliance Assurance Workbook - The Timely and
Appropriate (T&A) Enforcement Response to High Priority Violations (HPVs),
June 23, 1999-
www.epa.gov/compliance/resources/publications/civil/federal/airsnc.pdf:
• Public Water System Supervision Program Water Supply Guidance Manual,
January 2000; Nos. 57, 63, 65, & 67 - www.epa.gov/safewater/wsg/newindex.pdf.
These documents are available from the EPA Website at the URLs listed above or can be
obtained by contacting the relevant program office in the EPA Region or at EPA Headquarters.
RCRA
EPA groups RCRA violators into two different categories - SNCs and Secondary
Violators (SVs). If the violator is a SNC, then EPA considers formal enforcement appropriate,
and the violator will be subject to administrative/civil actions and penalties. SVs are corrected
through informal actions; however, SVs that do not return to compliance may be re-classified as
SNC, with the corresponding expectation of a formal enforcement response by EPA. The initial
decision to classify a violator as SNC is based on the following criteria:
• Exposure or threatened exposure of a sensitive environment (such as wetlands or
groundwater) or workers to hazardous waste (HW) or HW constituents;
• Minor release of a HW or HW constituent in a populated area or a publicly
accessible location;
• Release or threatened release of a highly mobile HW;
• Any release that suggests a continuing threat of future releases;
• A pattern of similar violations or multiple violations at the same site; or
• A substantial violation that defeats RCRA's regulatory purpose or procedures.
10 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
If these factors do not provide a clear answer to how to classify the violator, EPA will
evaluate the following: any steps the violator took to expeditiously come into compliance or to
mitigate any risks caused by the violation before EPA became involved; similar prior violations
or multiple violations (including other environmental statutes) by the violator, especially at the
same facility; or previous violations by the same person at other locations, especially when
identical to the present violation.
This second group of factors is used to determine the effectiveness of the informal
enforcement process. Violations within the past three years are weighed more heavily, however
older violations are assessed to determine if a pattern of non-compliance exists. When
examining historical trends, EPA does not consider minor deviations from RCRA requirements,
even if there are past similar violations. Although these factors are the most commonly used to
determine the violator's category, a particular site might have unique circumstances that EPA
will consider. EPA does not consider whether there was actual damage to human health or the
environment or the size or financial viability of the violator.
CWA/NPDES
Most CWA/NPDES SNC designations are based on an automated analysis of Discharge
Monitoring Reports (DMRs) that facilities with NPDES permits are required to submit on a
monthly basis. The compliance designation of a facility in the PCS database is done using a
mathematical formula that takes into account the amount, duration, and frequency of discharges
in comparison with permit levels. In some instances facilities may be manually designated as
SNC, even if the PCS data system does not automatically designate them as such. Examples of
events that could result in the manual generation of a SNC code for a facility include:
unauthorized discharges; failure of a facility to enforce its approved pretreatment program;
failure to meet a construction deadline; failure to file a DMR; filing a DMR more than 30 days
late; or violating any judicial or administrative order. Manually entered compliance data, if
present, override machine-generated compliance data.
A facility may have multiple discharge points and different designations for each point. If
any of these points show a SNC type code, then the overall facility status is listed as SNC, even if
other discharge points are in compliance. Removal of the SNC designation occurs once the
facility's DMR reports show a consistent pattern of compliance with permit limits, or if EPA or a
state agency issues a formal enforcement order to address the violations that resulted in the SNC
designation.
State of Federal Facilities Report, FY 2001-2002 \ 1
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Federal Facilities Enforcement Office
CAA
The following criteria can trigger high priority violator (HPV) status under the CAA:
• Failure to obtain a Prevention of Significant Deterioration permit;
• Violation of an air toxics requirement;
• Violation by a synthetic minor of an emission limit that affects the source's
regulatory status;
• Violation of an administrative or judicial order;
• Substantial violations of a sources Title V obligations;
• Failure to submit a Title V permit application within 60 days of the deadline;
• Testing, monitoring, record keeping or reporting violations that substantially
interfere with enforcement or determination of a facility's compliance
requirements;
• Violation of an allowable emission limit detected during a source test;
• Chronic or recalcitrant violations; or
• Substantial violations of 112 (r) requirements.
Under the CAA, the HPV designation is removed once a facility demonstrates it has
resolved the violation that led to the HPV listing. The HPV flag is reported in AIRS/AFS. A
'YES' appears in the column to indicate that the facility has HPV status.
SDWA/PWSS
Under SDWA/PWSS, facilities in SNC have more serious, frequent, or persistent
violations. The criteria which designate a system as a SNC vary by contaminant. Different SNC
definitions exist for total coliform, turbidity, nitrates, chemical and radiological, surface water,
and lead and copper. (See the guidance manuals cited above for specific definitions). Once a
system is designated as a SNC, it is subject to EPA's timely and appropriate response policy.
SNCs that have not returned to compliance or are not addressed timely and appropriately are
called Exceptions. Timeliness for SNCs is eight months after the system became a SNC. (Two
months for the state to determine, and become aware of, the system's SNC status and six months
in which to complete the follow-up/enforcement action). The types of actions considered
appropriate include the issuance of a formal state or federal administrative or compliance order, a
civil or criminal referral to a state attorney general or the Department of Justice, or state bilateral
compliance agreement signed by both the state and the violator.
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Federal Facilities Enforcement Office
Multimedia Compliance Rates
Exhibit 2 presents compliance rates for four statutes (RCRA, CWA/NPDES, CAA, and
SDWA/PWSS) based on the definitions of the indicators taken from Exhibit 1 above.
Compliance rates for years prior to 2001 were taken directly from previous State of Federal
Facilities reports. These compliance rates are also presented graphically in Exhibit 3.
Exhibit 2
Federal Facility Compliance Rates for Selected Indicators
Fiscal Year
Statute 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
RCRA/TSDF* 55.4% 61.6% 73.8% 75.1% 81.2% 88.2% 88.6% 93.6% 92.3% 94.0%
RCRA/LQG** ________ 96.7% 98.5%
RCRA/SQG** ________ 96.9% 96.4%
CWA/NPDES 94.2% 88.5% 76.2% 73.0% 70.4% 61.5% 64.9% 67.5% 51.9% 67.3%
CAA*** 87.0% 87.9% 88.8% 87.4% 84.2% 88.9% 90.0% 87.9% 91.7% 92.5%
SDWA/PWSS 99.2% 98.7% 93.0% 96.4% 97.1% 98.1% 98.2% 97.7% 95.3% 95.9%
Source: IDEA - various dates
*The RCRA TSDF compliance indicator used prior to FY 1999 was "inspected TSDFs without Class I violations." For
FY 1999 and beyond, the compliance indicator is "inspected TSDFs not in SNC."
** The RCRA LQG and SQG compliance indicator is inspected LQGs and SQGs not in SNC. FFEO did not collect
data on these RCRA facility types in SOFF reports prior to 2001.
***Prior to FY 2001, the CAA compliance indicator used was "major sources in compliance." For FY 2001 and
beyond the compliance indicator is "major sources not cited for HPVs."
State of Federal Facilities Report, FY 2001-2002 13
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Federal Facilities Enforcement Office
Exhibit 3
Federal Facility Compliance Rates
60.0% -
50.0%
i i r
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
d] RCRA/TSDF Q CWA/NPDES
?7\ CAA E3 SDWA/PWSS
Source: IDEA - various dates
As shown in Exhibits 2 and 3, from FY 1993 to FY 2002, the compliance rate for RCRA
increased steadily from 55 percent to 94 percent. In contrast, the compliance rate for
CWA/NPDES decreased from 94 percent to 52 percent in FY 2001. The CWA/NPDES
compliance rate in FY 2002 did increase by approximately 15 percent; however, it remained
nearly 30 percent below FY 1993 levels. The compliance rates for the CAA fluctuated at a level
slightly below 90 percent for most of the period before increasing to approximately 93 percent in
FY 2002. Similarly, the compliance rate for SDWA/PWSS remained above 90 percent for the
entire period, although it has declined slightly from 99 percent in FY 1993 to 96 percent in FY
2002.
Because definitions vary across programs, it is important not to place too much
significance in comparisons of the nominal compliance rates for a particular year (e.g., 96
percent for SDWA/PWSS in FY 2002 vs. 94 percent for RCRA); however, comparisons of
historical compliance trends can be highly significant. For example, among these four programs,
RCRA compliance has exhibited a fairly steady and substantial increase, while CWA/NPDES
compliance has generally declined (except for relative increases in FY 1999, FY 2000 and
FY 2002).
14 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
RCRA TSDF Compliance Rates
In FY 2001 and FY 2002, 181 and 166 federal TSDFs, respectively, were inspected. Of
these, approximately eight percent (14 of 181) and six percent (10 of 166) were determined to be
in SNC. Therefore, the RCRA TSDF compliance rates (percentage of inspected TSDFs not in
SNC) for FY 2001 and FY 2002 were 92 percent and 94 percent, respectively (see Exhibit 4).
Exhibit 4
RCRA TSDF Compliance Rates by Federal Agency Category
Agency
DOD*
Army
Navy
Air Force
CFAs
DOE
Unidentified**
Total
Inspected
TSDFs
139
62
32
41
12
29
1
181
FY 2001
TSDFs in
SNC
7
2
2
3
1
5
1
14
TSDFs not
in SNC
132 (95.0%)
60 (96.8%)
30 (93.8%)
38 (92.7%)
11(91.7%)
24 (82.8%)
-
167(92.3%)
FY 2002
Inspected
TSDFs
131
54
35
39
13
22
-
166
TSDFs in
SNC
4
3
0
1
1
5
-
10
TSDFs not
in SNC
127 (96.9%)
51 (94.4%)
35 (100.0%)
38 (97.4%)
12 ( 92.3%)
17(77.3%)
-
156(94.0%)
Source: IDEA - 3/6/02 & 1/27/03
* Other DOD facilities (e.g., DLA, Defense Mapping Agency) are included in the overall DOD compliance rates, but
are not broken out separately in this table because they represent such a small portion of the DOD universe.
** Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in
such a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
According to Exhibit 4 compliance rates at DOD TSDFs were 95 percent in FY 2001
and 97 percent in FY 2002. These rates were higher than the overall compliance rate for other
federal TSDFs. In FY 2001 and FY 2002, the TSDF compliance rate for CFAs remained at
about 92 percent for both years, while the same compliance rates at DOE facilities were lower
(roughly 83 percent and 77 percent) than the overall federal facility rate for both years. Among
the major DOD services, there was no clear trend in terms of which had the highest (or lowest)
TSDF compliance rates. Exhibit 5 shows the federal sector TSDFs, in general, had a higher
compliance rate than those in the non-federal (i.e., private) sector.
State of Federal Facilities Report, FY 2001-2002 15
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Federal Facilities Enforcement Office
Exhibit 5
Percentage of Inspected TSDFs not in SNC
(Federal vs. Non-Federal TSDFs)
100.0% -r
90.0%
80.0% -
70.0% -
60.0% -
50.0%
| | Inspected Federal TSDFs
Inspected Non-Federal TSDFs
FY2001
FY 2002
Source: IDEA - 3/6/02 & 1/27/03
Note that the term "non-federal" refers to those facilities listed within the IDEA database that are not flagged as federal
(e.g., industrial, commercial facilities, etc.).
RCRA Generator Compliance Rates
Exhibits 6 and 7 provide compliance rates for inspected LQGs. EPA and states
inspected 152 federal LQGs FY 2001 and 136 federal LQGs in FY 2002. Of these facilities, five
were found to be in SNC in FY 2001 and two in FY 2002. Because there are fewer RCRA
requirements that potentially apply to these facilities (in comparison to TSDFs), one would
expect that their compliance rates would be higher, and indeed, this is the case. For both FY
2001 and FY 2002, LQG compliance rates were between three and four percent higher than
corresponding rates for TSDFs. Exhibit 7 compares compliance rates for federal LQGs with
their non-federal counterparts. For FY 2001 and FY 2002, the federal LQG compliance rate was
between four and six percent higher than for non-federal LQGs.
16 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
Exhibit 6
RCRA LQG Compliance Rates at Federal Facilities
FY 2001
FY 2002
Agency
DOD
CFAs
DOE
Unidentified*
Total
Inspected
LQGs
92
46
3
11
152
LQGs in
SNC
4
1
0
0
5
LQGs not
in SNC
88 (95.7%)
45(91.7%)
3 (100.0%)
11(100.0%)
147 (96.7%)
Inspected
LQGs
88
43
3
2
136
LQGs in
SNC
1
1
0
0
2
LQGs not in
SNC
87 (96.9%)
42 ( 92.3%)
3 (100.0%)
2 (100.0%)
134(98.5%)
Source: IDEA-7/31/03
* Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in such
a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
Exhibit 7
Percentage of Inspected LQGs not in SNC
(Federal vs. Non-Federal)
100.0%
90.0% -
80.0% -
70.0%
Source: IDEA-7/31/03
Inspected Federal LQGs
Inspected Non-Federal LQGs
FY2001
FY 2002
State of Federal FacUities Report, FY 2001-2002
17
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Federal Facilities Enforcement Office
Exhibits 8 and 9 provide compliance rates for inspected SQGs. EPA and states
inspected 64 federal SQGs in FY 2001 and 56 federal SQGs in FY 2002. Of these facilities, two
were found to be in SNC in both FY 2001 and FY 2002, resulting in compliance rates of
approximately 97 percent and 96 percent. As was the case with LQGs, these compliance rates
for SQGs were higher than for TSDFs. It should be noted, however, that the number of
generators inspected comprises a much smaller portion of the generator universe, particularly for
SQGs. For example, in FY 2002, only 27 percent and 1 percent, respectively, of federal LQGs
and SQGs were inspected, compared to 74 percent of federal TSDFs. The corresponding figures
for non-federal LQGs and SQGs were!3 percent and two percent. Therefore, these compliance
rates may not be as representative of the entire generator universe as are the compliance rates for
TSDFs.
Exhibit 8
RCRA SQG Compliance Rates at Federal Facilities
Agency
DOD
CFAs
DOE
Unidentified*
Total
Inspected
SQGs
23
32
1
8
64
FY 2001
SQGs in
SNC
0
1
0
1
2
SQGs not
in SNC
23 (100.0%)
31(96.9%)
1 (100.0%)
7 (87.5%)
62 (96.9%)
FY 2002
Inspected
SQGs
17
31
2
6
56
SQGs in
SNC
1
1
0
0
2
SQGs not in
SNC
16(94.1%)
30 (96.8%)
2(100.0%)
6(100.0%)
54 (96.4%)
Source: IDE A-7/31/03
* Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in such
a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
18
State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
Exhibit 9
Percentage of Inspected SQGs not in SNC
(Federal vs. Non-Federal)
100.0%
90.0% -
80.0% -
70.0%
| I Inspected Federal SQGs
L> Inspected Non-Federal SQGs
FY2001
FY 2002
Source: IDEA-7/31/03
State of Federal Facilities Report, FY 2001-2002 19
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Federal Facilities Enforcement Office
CWA/NPDES Compliance Rates
Exhibit 10 presents CWA/NPDES compliance rates by agency category for FY 2001 and
FY 2002. DOD compliance increased by more than 20 percent while the compliance rates for
CFA facilities decreased by more than 8 percent. The DOE compliance rate nearly doubled over
the same period, from approximately 39 percent in FY 2001 to 75 percent in FY 2002. The
overall compliance rate for federal facilities increased by more than 15 percent, most of which
was attributable to improvements at DOD facilities, which comprise roughly two-thirds of the
federal NPDES universe. As far as the compliance rates for the major DOD services, the Air
Force consistently had the highest rates (71.4 and 91.7 percent, respectively), while the Navy
continued to experience the lowest rates (31.8 and 52.2 percent). It should be noted, however,
that all three branches experienced increases of more than 20 percent between FY 2001 and FY
2002.
Exhibit 10
CWA/NPDES Compliance Rates by Federal Agency Category
Agency
DOD
Army
Navy
Air Force
CFAs
DOE
Total
Major
Facilities
67
31
22
14
24
13
104
FY 2001
Majors in
SNC
33
14
15
4
9
8
50
Majors Not
in SNC
34 (50.7%)
17 (54.8%)
7 (31.8%)
10(71.4%)
15 (62.5%)
5 (38.5%)
54(51.9%)
FY 2002
Major
Facilities
65
30
23
12
24
12
101
Majors in
SNC
19
7
11
1
11
3
33
Majors Not
in SNC
46 (70.8%)
23 (76.7%)
12 (52.2%)
11(91.7%)
13 (54.2%)
9 (75.0%)
68 (67.3%)
Source: IDEA- 3/2/02 & 1/27/03
20
State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
Exhibit 11
Percentage of Major CWA/NPDES Facilities not in SNC
(Federal vs. Non-Federal Majors)
Major Federal Facilities
Major Non-Federal Facilities
100.0%
90.0% -
80.0% -
70.0% -
60.0% -
50.0% -
40.0%
FY2001
Source: IDEA-3/2/02 & 1/27/03
I
FY 2002
Exhibit 11 compares the compliance rate of major federal CWA/NPDES facilities
against the corresponding compliance rate for the universe of major non-federal CWA/NPDES
facilities. In FY 2001, the compliance rate for federal facilities was almost 52 percent (54 of
104), roughly 18 percent lower than for major non-federal facilities. In FY 2002, compliance
rates for federal facilities increased by nearly 15 percent (68 of 101), while major non-federal
facilities experienced a slight increase from just under 70 percent to slightly more than 75
percent.
State of Federal Facilities Report, FY 2001-2002 21
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Federal Facilities Enforcement Office
CAA Compliance Rates
As shown in Exhibit 12, during FY 2001 and 2002 the DOD compliance rates increased
from 93 percent to a little more than 95 percent. The compliance rate for CFAs decreased by
nearly two percent over the same period. DOE compliance essentially remained constant between
FY 2001 and FY 2002. Among the DOD services, the Air Force had the highest compliance
rates and the Army had the lowest for both years, although the differential between these two
services narrowed from roughly seven percent in FY 2001 to three percent in FY 2002. All three
services experienced compliance rates near or exceeding 90 percent for both years.
Exhibit 12
CAA Compliance Rates by Federal Agency Category
Agency
DOD*
Army
Navy
Air Force
CFAs
DOE
Unidentified**
Total
Major
Sources
300
103
98
89
191
33
15
539
FY 2001
Majors in
HPV
21
12
4
4
22
1
1
45
Majors Not
in HPV
279 (93.0%)
91 (88.3%)
94 (95.9%)
85 (95.5%)
169(88.5%)
32 (97.0%)
14 (93.3%)
494(91.7%)
FY 2002
Major
Sources
305
101
99
90
186
32
24
547
Majors in
HPV
15
7
5
3
25
1
-
41
Majors Not
in HPV
290(95.1%)
94(93.1%)
94 (94.9%)
87(96.7%)
161 (86.6%)
31(96.9%)
24 (100.0%)
506 (92.5%)
Source: IDEA- 3/5/02 & 1/28/03
* Other DOD facilities (e.g., DLA, Defense Mapping Agency) are included in the overall DOD compliance rates, but
are not broken out separately because they represent such a small portion of the DOD universe.
** Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in
such a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
22
State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
As shown in Exhibit 13, during FY 2001 and FY 2002, major CAA sources at federal
facilities experienced nearly the same compliance rates (roughly 92 for FY 2001 and 93 percent
for FY 2002) than the non-federal regulated community. CAA compliance rates at major non-
federal sources remained constant at nearly 94 percent for the same two-year period.
Exhibit 13
Percentage of CAA Major Sources not cited for HPVs
(Federal vs. Non-Federal Sources)
100.0% -<
90.0% -
80.0%
70.0%
I | Major Federal Sources
Major Non-Federal Sources
FY 2001
FY 2002
Source: IDEA- 3/5/02 & 1/28/03
State of Federal Facilities Report, FY 2001-2002 23
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Federal Facilities Enforcement Office
SDWA/PWSS Compliance Rates
Exhibit 14 shows the number of federally-owned public water systems cited for
violations under SDWA, as well as the number of systems classified as SNC for more serious
violations. The number of systems cited for violations increased slightly from approximately 17
percent in FY 2001 to nearly 18 percent FY 2002. The number of systems in SNC increased
from 4.1 percent in FY 2001 to 4.7 percent in FY 2002. The database used to track SDWA
compliance does not contain information on agency affiliation, thus it is not possible to provide
these compliance rates by agency category.
Because the compliance indicator used for SDWA is the percentage of systems not in
SNC, the compliance rate for federal systems overall remained nearly unchanged from 95.9
percent in FY 2001 to 95.3 percent in FY 2002. As shown in Exhibit 15, the overall federal
facility compliance rate has remained above the compliance rate for non-federal systems.
Exhibit 14
SDWA/PWSS Noncompliance at Federally-Owned Systems
6,000
I | Federally-Owned Systems
f J Systems with Violations
Significant Noncompliers
FY2001
FY2002
Source: SDWIS - 7/9/03
24 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
Exhibit 15
Percentage of SDWA Public Water Supply Systems not in SNC
(Federal vs. Non-Federal Systems)
100.0% -\
90.0%
80.0% -
70.0%
Source: SDWIS - 7/9/03
Federal Systems
Non-Federal Systems
FY2001
FY 2002
State of Federal Faculties Report, FY 2001-2002 25
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Federal Facilities Enforcement Office
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26 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
IV. INSPECTIONS AND ENFORCEMENT ACTIONS
EPA and states monitor activities at federal facilities to determine whether they are in
compliance with environmental laws and regulations. Compliance monitoring also enables EPA
to measure and track performance over time and to identify potential problem areas and
compliance assistance opportunities. EPA obtains information regarding environmental
performance from reports submitted to states, and EPA by the regulated facilities. Information
on performance is also provided by inspections and other assessments conducted by regulatory
agencies. Most environmental programs rely on some form of inspection as the principal tool for
determining compliance. The level of effort associated with these inspections varies, depending
on the specific requirements addressed, the size and complexity of the facility's operations, and
the type and amount of data required to assess compliance.
Increasingly, EPA has found it necessary to more sharply focus the resources of its
enforcement program, including those associated with federal facilities, on issues and problems
that matter most. This "smart enforcement" approach launched in April 2003, embodies a
common sense approach to problem solving and decision making. Simply put, smart
enforcement is the use of the most appropriate enforcement or compliance tools to address the
most significant environmental problems and achieve that best outcomes that will help increase
the effectiveness and efficiency of the Agency's federal facilities program.
Exhibit 16 shows the total number of EPA and state inspections at federal facilities for
RCRA, CWA/NPDES, and CAA since FY 1993. The number of inspections conducted under all
three programs decreased by roughly four percent from 1,284 in FY 1993 to 1,228 in FY 2002.
CWA/NPDES inspections declined by 36 percent, while RCRA inspections declined by roughly
18 percent; although the decrease in RCRA inspections was much larger in numerical terms.
CAA inspections actually increased by approximately 59 percent relative to FY 1993; however,
the level of CAA inspection activity peaked in FY 1999 and has since declined. A portion of this
decline is due to a FY 2002 programmatic change to the definition of what constitutes an
inspection under the CAA, yet even in FY 2001, prior to the change, CAA inspections were
decreasing. The number of SDWA/PWSS inspections is not reported in the federal SDWIS
database and therefore is not presented in this report.
State of Federal Facilities Report, FY 2001-2002 27
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Federal Facilities Enforcement Office
Exhibit 16
EPA and State Inspections at Federal Facilities
1000
800-
600-
400-
200-
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
QD RCRA E3 CAA \Z\ CWA/NPDES
Source: IDEA various dates
Federal facilities, like all other regulated facilities, are responsible for complying with
environmental requirements. EPA and the states work with federal agencies to help them comply
with environmental requirements and take all necessary actions to prevent, control, and abate
environmental pollution. Any federal facility that fails to comply with environmental
requirements may be subject to enforcement. EPA and most states have explicit authority to
issue orders to require compliance by federal facilities in violation of most environmental statues,
as well as the authority to assess noncompliance penalties under some of these laws. EPA and
the states respond to the discovery of violations at federal facilities by issuing formal or informal
enforcement actions. The type of enforcement action (i.e., formal vs. informal) depends upon a
variety of factors, including, but not limited to the severity of the violation, the compliance
history of the facility, and the actual or potential threat to human health and the environment.
Exhibit 17 presents the number of EPA and state enforcement actions at federal facilities
for RCRA, CWA/NPDES, CAA, and SDWA/PWSS since FY 1993. EPA and states issued 293
and 279 enforcement actions against federal facilities in FY 2001 and FY 2002, respectively.
The 279 actions issued in FY 2002 represents a decline of approximately 37 percent relative to
FY 1993. RCRA enforcement actions remained the most common, comprising 63 percent of
total enforcement actions in FY 2001 and 56 percent of total actions in FY 2002. CWA/NPDES
actions accounted for approximately 19 and 15 percent of the total actions respectively, while
CAA actions accounted for roughly 16 (FY 2001) and 26 (FY 2002) percent of total
enforcement actions during the same two year period. SDWA/PWSS actions accounted for less
than three percent of federal facility enforcement. Since enforcement actions may lag behind the
28
State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
event that triggered it (such as an inspection), enforcement actions in one year are not necessarily
related to inspections conducted in a prior year.
Exhibit 17
Enforcement Actions at Federal Facilities
(Formal and Informal Actions)
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
O RCRA Q CWA/NPDES Q CAA [2 SDWA/PWSS
Source: IDEA - various dates
State of Federal Facilities Report, FY 2001-2002
29
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Federal Facilities Enforcement Office
RCRA Inspections and Enforcement Actions
To assess compliance with RCRA requirements, EPA inspectors conducted 99 (FY 2001)
and 102 (FY 2002) inspections at federal facilities, including TSDFs, LQGs, SQGs,
conditionally-exempt SQGs (CESQGs), and transporters. Because RCRA is generally a state-
delegated program, state totals were much higher (634 and 551). As shown in Exhibit 18, The
total number of RCRA inspections declined by approximately 9 percent from FY 2001 to FY
2002. DOD facilities received approximately 61 percent of all inspections in FY 2001 and FY
2002, while CFA facilities received between 21 and 26 percent for both years. The inspection
totals for DOE facilities over the same period were between 10 and 14 percent.
Exhibit 18
RCRA Inspections and Enforcement Actions
By Agency
EPA-Lead
State-Lead
By Agency
DOD
CFA
DOE
Inspections
FY 2001
Lead
99(13.5%)
634 (86.5%)
Category
444 (60.6%)
158(21.6%)
100 (13.6%)
Unidentified* 3 1 (4.2%)
Total
733
FY 2002
Enforcement Actions
FY 2001
102(15.6%)
551 (84.4%)
31 (16.7%)
155 (83.3%)
403 (61.7%)
169 (25.9%)
68 (10.4%)
13 (2.0%)
653
114(61.3%)
33 (17.7%)
28(15.1%)
11(5.9%)
186
FY 2002
28 (17.8%)
129 (82.2%)
109 (69.4%)
33 (21.0%)
11(7.0%)
4 (2.5%)
157
Source: IDEA-5/16/02 & 1/27/03
* Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in such
a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
The federal share of both inspections and enforcement actions increased between FY
2001 and FY 2002. This percentage increase is primarily due to a decrease in state-led activity,
rather than an increase in the number of EPA-led inspections and enforcement actions. The
distribution of enforcement actions among the federal agency categories was generally consistent
with that for inspections. DOD facilities received approximately 61 percent, CFAs around 20
percent, and DOE facilities between seven and 15 percent of enforcement actions.
3 0 State of Federal Faculties Report, FY 2001-2002
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Federal Facilities Enforcement Office
Exhibit 19
RCRA Inspections and Enforcement Actions by Facility Type
Inspections and
DOD
CFA
DOE
Unidentified*
Inspections and
DOD
CFA
DOE
Unidentified*
Inspections and
DOD
CFA
DOE
Unidentified*
Total**
Inspections
FY 2001 FY 2002
Enforcement Actions
FY 2001
Enforcement Actions at TSDFs
243 (37.3%) 261 (43.9%)
22 (3.4%) 26 (4.4%)
89 (13.6%) 64 (10.8%)
..
63 (40.1%)
4 (2.5%)
27(17.2%)
--
Enforcement Actions at LQGs
144(22.1%) 105(17.6%)
76(11.7%) 66(11.1%)
7(1.1%) 2(0.3%)
4 (0.6%) 3 (0.5%)
30(19.1%)
12 (7.6%)
1 (0.6%)
1 (0.6%)
Enforcement Actions at SQGs
25 (3.8%) 22 (3.7%)
35 (5.4%) 39 (6.6%)
2 (0.3%)
7(1.1%) 5(0.8%)
652 595
9 (5.7%)
7 (4.5%)
--
3(1.9%)
157
FY 2002
72 (50.0%)
8 (5.6%)
1 1 (7.6%)
-
24 (16.7%)
12 (8.3%)
--
1 (0.7%)
6 (4.2%)
9 (6.3%)
--
1 (0.7%)
144
Source: IDEA-5/16/02 & 1/27/03
* Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in such
a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
** Totals do not include inspections or enforcement actions conducted at CESQGs, transporters, or non-notifiers.
Exhibit 19 demonstrates that among RCRA TSDFs, LQGs, and SQGs, most inspections
and enforcement actions occurred at TSDFs. For both FY 2001 and FY 2002, more than 50
percent of inspections took place at TSDFs. This concentration was more pronounced for
enforcement actions. Approximately 60 percent of enforcement actions were issued at TSDFs in
FY 2001, and in FY 2002, the figure was approximately 63 percent.
State of Federal Facilities Report, FY 2001-2002 31
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Federal Facilities Enforcement Office
CWA/NPDES Inspections and Enforcement
Implementation responsibility for the CWA/NPDES program lies primarily with the
states. As a consequence, roughly 90 percent of CWA/NPDES inspections conducted at major
federal facilities during FY 2001 and FY 2002 were led by states. As shown in Exhibit 20,
CWA/NPDES inspections increased by approximately 27 percent between FY 2001 and FY
2002. DOD facilities received between two-thirds and three-quarters of these inspections in FY
2001 and FY 2002, while CFA and DOE facilities received roughly equivalent shares of the
remaining inspections over the same period.
The number of enforcement actions taken to address NPDES noncompliance at major
federal facilities decreased by 26 percent between FY 2001 and FY 2002. EPA-led enforcement
actions decreased by more than half to 4.8 percent. Enforcement actions at DOE declined from
approximately 40 percent of the total CWA/NPDES actions in FY 2001 to only 14 percent of the
total actions taken in FY 2002.
Exhibit 20
CWA/NPDES Inspections and Enforcement Actions at Major Federal Facilities
Inspections
FY 2001 FY 2002
By Agency
EPA-Lead
State-Lead
By Agency
DOD
CFA
DOE
Lead
11 (10.5%)
94 (89.5%)
Category
69 (65.7%)
17(16.2%)
19(18.1%)
Unidentified*
Total
105
Enforcement Actions
FY 2001 FY 2002
11 (8.3%)
122 (91.7%)
6 (10.5%)
51 (89.5%)
98 (73.7%)
17 (12.8%)
17(12.8%)
1 (.8%)
133
32 (56.1%)
2 (3.5%)
23 (40.4%)
-
57
2 (4.8%)
40 (95.2%)
33 (78.6%)
2 (4.8%)
6 (14.3%)
1 (2.4%)
42
Source: IDEA- 1/31/02 & 1/27/03
* Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in such
a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
3 2 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
CAA Inspections and Enforcement Actions
Exhibit 21 shows that EPA and state inspectors conducted 559 CAA inspections of
major federal sources during FY 2001 and 442 in FY 2002. This represents a decrease of nearly
21 percent. A portion of this decline is due to a FY 2002 programmatic change to the definition
of what constitutes an inspection, although the number of CAA inspections has been falling since
FY 1999. As is the case with RCRA and CWA/NPDES, states continued to take a lead role on
the majority of CAA inspections (526 state-led inspections versus 33 by EPA in FY 2001 and
421 state-led inspections versus 21 by EPA in FY 2002). DOD facilities received more than 60
percent of CAA inspections in both FY 2001 and FY 2002. CFA facilities received between 20
and 30 percent of inspections over the same period, while DOE facilities received less than 10
percent for both years.
Exhibit 21
CAA Inspections and Enforcement Actions at Major Federal Sources
Inspections
FY 2001 FY 2002
Enforcement Actions
FY 2001 FY 2002
By Agency Lead
EPA-Lead
State-Lead
33 (5.9%)
526 (94.1%)
21 (4.8%)
421 (95.2%)
2 (4.2%)
46 (95.8%)
1 (1.4%)
72 (98.6%)
By Agency Category
DOD
CFA
DOE
Unidentified*
Total
376 (67.3%)
116 (20.8%)
54 (9.7%)
13 (2.3%)
559
273 (61.8%)
128 (29.0%)
34 (7.7%)
7 (1.6%)
442
32 (66.7%)
14 (29.2%)
2 (4.2%)
-
48
47 (64.4%)
23 (31.5%)
1 (1.4%)
2 (2.7%)
73
Source: IDEA- 1/30/02 & 1/27/03
* Unidentified federal facilities have not been assigned a GSA code or named within their relevant data systems in such
a way as to identify them as belonging to a particular federal agency, however, they have been flagged as federal.
EPA and states issued 48 and 73 enforcement actions against federal sources during FY
2001 and FY 2002, respectively, for failure to comply with provisions of the CAA. As shown in
Exhibit 21, states took the lead on approximately 96 percent of these enforcement actions. DOD
sources received approximately 62 percent, while CFA sources received roughly 30 percent of
the total enforcement actions. DOE and other sources each received less than five 5 percent of
total actions during FY 2001 and FY 2002.
State of Federal Facilities Report, FY 2001-2002
33
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Federal Facilities Enforcement Office
SDWA/PWSS Inspections and Enforcement
The number of SDWA/PWSS inspections is not reported in the federal SDWIS database
and therefore is not presented in this report. Similarly SDWIS does not provide information on
agency affiliation with public water systems and, therefore, and a summary of affected federal
agencies is also not provided for this report. Exhibit 22 shows that the total number of formal
enforcement actions issued against federal facilities increased from two in FY 2001 to seven in
FY 2002. EPA took the lead on none of the SDWA actions during FY 2001 and 14.3 percent (1
of 7) during FY 2002.
Exhibit 22
SDWA/PWSS Enforcement Actions at Federal Facilities
„ - , T . Number of Actions in Number of Actions in
Enforcement Lead FY 2001 FY2002
EPA 0 (0%) 1 (14.3%)
State 2(100.0%) 6(85.7%)
TOTAL 2 7
Source: SDWIS - 7/9/03
34 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
V. FEDERAL FACILITIES UNIVERSE AND
Toxic RELEASE INVENTORY DATA
The federal government owns and leases vast amounts of real property in the United
States. According to the General Services Administration, as of September 30, 2002, the total
amount of federally owned or leased property is approximately 670 million acres. This
represents approximately 30 percent of all land in the United States. The total area of federally-
owned or leased buildings amounts to approximately 3.3 billion square feet. The vast majority of
this real property is owned, rather than leased, although as a percentage of the total square
footage, leased buildings comprise a much larger share of federal property than leased land (10
percent versus 0.1 percent). Exhibit 23 below presents a more detailed breakdown of these
property holdings.
Exhibit 23
Federal Government's Owned and Leased Real Property (FY 2002)
_ ,. Number of Percent ... , ,. _ .,.. . Percent
Type of Number of Building Area -„ , ,
nj , Installations Acreage of Total „ .... . =.. of Total
Property . T e Buildings (sq. ft.)
/ Leases acreage Area
Owned
Leased
Total
32,019
59,262
--
674,099,756
842,242
674,941,998
99.9%
0.1%
-
441,213
46,029
487,242
2,974,885,045
339,520,657
3,314,405,702
89.8%
10.2%
-
Source: GSA, Federal Real Property Profile, Sept 30, 2002. Totals do not include property outside of the U.S.
Although all federal facilities are potentially subject to environmental regulations, most
are not involved in activities that would normally trigger compliance requirements. According to
the Federal Registry System (FRS), as of April 1, 2003, there were 7,853 federal facilities. The
data pulled for this facility count includes any NPDES permitted facility in PCS, any facility
with a CAA permit in AIRS/AFS, and any facility that either has a RCRA permit or is a Part A
notifier as a generator of hazardous waste. Facility types left out of the total include:
• Non-permitted small quantity and conditionally exempt small quantity generators
under RCRA. This probably includes a major portion of the RCRA universe in
the federal facility sector. (Some transporters require all generators, regardless
of their size, to notify EPA or obtain a permit, as a condition for accepting
shipments of hazardous waste);
• Minor facilities under NPDES that states have elected not to report since they are
not required to forward this information to EPA as long as they track these
facilities;
State of Federal Facilities Report, FY 2001-2002 3 5
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Federal Facilities Enforcement Office
• SDWA public water supply systems (This universe of data is not fully integrated
with the IDEA system);
• Minor CAA sources;
• Facilities regulated under FIFRA, TSCA, or EPCRA 313, unless they are tracked
under another program (e.g., RCRA). (FIFRA permitees do not necessarily
represent facilities and TSCA notifiers may be coincidentally reported to EPA or
the states by some other means (e.g., RCRA)); and
• CERCLA regulated sites, unless they are also tracked under another program.
Federal facilities can be grouped into four broad categories - Department of Defense (DOD),
Department of Energy (DOE), Civilian Federal Agencies (CFAs), and unidentified federal
facilities (Exhibit 24).
Exhibit 24
Federal Facilities by Agency Category (FY 2002)
DOE (3.7%) 289
Unidentified (7.1%) 561
DOD (30.4%) 2,391
CFAs (58.7%) 4,612
N = 7,853 Facilities
Source: FRS - 4/1/03
The FY 1999-2000 State of Federal Facilities report indicated that the number of federal
facilities regulated under these programs was considerably higher (i.e., 11,670). This decrease is
primarily due to EPA's on-going data cleanup efforts, as well as database maintenance. EPA
removed several thousand inactive or obsolete NPDES identification numbers (IDs) from PCS.
A considerably smaller number of inactive facility IDs were also removed from RCRAInfo and
AIRS/AFS. In addition, several hundred facilities were archived from FRS until their federal
3 6 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
status can be determined. Lastly, EPA removed the A-106 database, which resulted in the
elimination of the majority of Formerly Utilized Defense Sites (FUDS).4
Exhibit 25 shows the distribution of CFA facilities according to individual agencies. The
overall number of CFA facilities has declined relative to FY 2000 for the reasons discussed
above; however, both the percentage of the total accounted for by individual agencies, as well as
their relative ranking, has remained fairly consistent.
Exhibit 25
Distribution of CFA Facilities by Agency (FY 2002)
Postal Service -
Transportation -
300
400
500
600
700
800
Source: FRS-4/1703
FUDS are still tracked within the remaining systems, however, their numbers are so small as to not warrant a separate
categorization within Exhibit 20. These facilities are instead included in the overall DOD numbers.
State of Federal Facilities Report, FY 2001-2002 3 7
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Federal Facilities Enforcement Office
Federal Facility Activities
Federal facilities engage in a range of activities similar to the other non-federal sectors of
the regulated community. Below is a list of North American Industry Classifications (NAICS)
that covers the vast majority of activities carried out at federal facilities. More information on
NAICS Codes can be found at the website: http://www.census.govepcd/www/naicstab.htm.
• 113 - forestry and logging
• 211-utilities
• 491 - postal service
• 531 - real estate
• 562 - waste management and remediation services
• 621 - ambulatory health care services
• 622 - hospitals
• 623 - nursing and residential care services
• 712 - museums, historical sites, and similar institutions
• 811 - repair and maintenance
• 812 - laundry and personal care services
• 921 - executive, legislative and other general government
• 922 - justice, public order and safety activities
• 923 - administration of human resource program
• 926 - administration of economic programs
• 927 - space research and technology
• 928 - national security and international affairs
3 8 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
RCRA Universe
RCRA regulated federal facilities can be divided into three types: generators, transporters,
and treatment, storage, and disposal facilities (TSDFs). Generators of RCRA-regulated waste
must obtain an EPA ID number; prepare hazardous waste for transport; and comply with the
accumulation and storage, record keeping, and reporting requirements. They are also responsible
for tracking waste through a manifest system. The manifest system creates a written record of
the chain-of-custody from the time a waste leaves a generator until it reaches its final disposal
site. Transporters must obtain an EPA ID number, comply with the manifest system, and
address any hazardous waste releases. TSDFs are subject to record keeping and reporting
requirements and technical standards covering treatment and disposal methods, as well as the
location, construction, and operation of disposal sites. Finally, both generators and TSDFs may
be subject to land disposal restrictions requiring treatment of the waste before it is land-disposed.
In addition, a small number of facilities are classified as non-notifiers. Non-notifiers are RCRA
facilities that have been identified through sources other than regular reporting and are suspected
of engaging in RCRA-regulated activities without proper authority.
At the end of FY 2002, there were 5,290 federal RCRA regulated facilities. As shown in
Exhibit 26, in FY 2002, 34.4 percent of the federal RCRA facilities were DOD facilities (Army
- 19.0 percent, Navy - 7.6 percent, USAF - 6.2 percent, and other DOD -1.6 percent). The
majority of federal RCRA facilities are CFAs (55.5 percent), while DOE facilities and facilities
that are unidentifiable by agency category comprise 2.4 percent and 7.7 percent, respectively.
Exhibit 26
RCRA Regulated Facilities by Agency Category (FY 2002)
^ <«*>
Army (19.0%) 1,003
CFAs (55.5%) 2,938
N = 5,290 Facilities
Source: IDEA-1/27/03
State of Federal Facilities Report, FY 2001-2002 3 9
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Federal Facilities Enforcement Office
As shown in Exhibit 27, large and small quantity generators5 (LQGs and SQGs) make up
the largest share of RCRA regulated federal facilities (94.2 percent), followed by TSDFs and
transporters (4.2 percent and 1.1 percent respectively). Non-notifiers (at least those that have
been identified through other means) comprise less than one percent of the universe of RCRA
regulated federal facilities.
Exhibit 27
Universe of RCRA Regulated Federal Facilities (FY 2002)
SQG(84.8%)4,486
LQG(9.4%)498
Non-Notifier (0.4%) 23
TSDF (4.2%) 223
r Transporter (1.1%) 60
N = 5,290 Facilities
Source: IDEA-1/27/03
' This total also includes conditionally exempt small quantity generators.
40 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
CWA/NPDES Universe
Under the CWA, all point source dischargers of wastewater, including federal facilities,
must submit an application for a NPDES permit. NPDES permits may contain water quality-
based and/or technology-based standards for effluent discharges, compliance schedules, and
monitoring/reporting requirements.
At the end of FY 2002, there were 101 major federal facilities regulated under the
NPDES program. As shown in Exhibit 28, of these 101 facilities, 64.4 percent were DOD
(Army - 29.7 percent, Navy - 22.8 percent, and USAF - 11.9 percent, while 23.8 percent were
CFA facilities and 11.9 percent were DOE facilities.
Exhibit 28
Universe of Major Federal CWA/NPDES Facilities (FY 2002)
DOE (11.9%) 12
USAF (11.9%) 12
CFAs(23.8%) 24
Army (29.7%) 30
Navy (22.8%) 23
N= 101 Major Facilities
Source: IDEA-1/27/03
State of Federal Facilities Report, FY 2001-2002 41
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Federal Facilities Enforcement Office
CAA Universe
To meet EPA's National Ambient Air Quality Standards (NAAQS), states typically
require new sources to obtain preconstruction permits. Permit requirements depend on the
attainment status of the area, which is based on air quality with respect to six criteria pollutants
(CO, SO2, NOX, VOCs, particulates, and lead). Areas meeting the NAAQS are considered in
"attainment," while areas that do not are in "nonattainment." New sources in nonattainment
areas must go through the permit review process under the New Source Review, which allows
for new sources if stringent requirements are met, including emissions offsets, state-wide
compliance for all sources, public notification, and installation of equipment to meet the Lowest
Achievable Emission Rate. If the source is to be located within an attainment area, the permit
review process falls under Prevention of Significant Deterioration requirements, which require
installation of the Best Available Control Technology, establishment of maximum allowable
emissions increases, performance of impact analyses by source, and public notice.
Federal sources, depending on the nature and size of their operations, also maybe subject
to technology-based New Source Performance Standards for new, modified, or reconstructed
sources; health-based National Emissions Standards for Hazardous Air Pollutants for new and
existing sources within specific categories; and/or Title V requirements for all sources of
emissions at a facility under a single permit. In FY 2002, there were 547 major federal sources
(i.e., exceeding federally reportable thresholds) regulated under all programs within the CAA.
As shown in Exhibit 29, 55.8 percent of these federal sources were DOD (Army - 18.5 percent,
Navy- 18.1 percent, USAF - 16.5 percent, and other DOD - 2.7 percent), 34 percent were
CFAs, 5.9 percent were DOE, and 4.4 percent were unidentifiable by agency category.
Exhibit 29
Universe of Major Federal CAA Sources (FY 2002)
Other DOD (2.7%) 15
DOE (5.9%) 32
Other (4.4%) 24
USAF (16.5%) 90
CFAs (34.0%) 186
N = 547 Major Sources
Army (18.5%) 101
Navy (18.1%) 99
Source: IDEA-1/28/03
42 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
SDWA/PWSS Program Universe
Under the SDWA/PWSS program, the definition of a public water system is "a water
system providing water for human consumption through constructed conveyances to at least 15
service connections or an average of 25 individuals daily at least 60 days per year." EPA has
interpreted the term human consumption to include drinking, bathing, showering, cooking,
dishwashing, and maintaining oral hygiene. There are three types of public water systems:
• Community Water Systems serve at least 15 service connections used by year-
round residents of an area or regularly serves at least 25 year-round residents for
60 days or more per year. The remaining two types of systems are considered
non-community water systems because they do not provide water to more than 15
residences year-round.
• Transient Non-Community Water Systems serve transient or seasonal customers
in locations such as campgrounds, motels, and gasoline stations.
• Non-Transient Non-Community Water Systems regularly serve at least 25 of the
same non-resident people per day for at least six months of the year. Examples
include schools, factories, hospitals, and other facilities with their own supplies.
Exhibit 30
Universe of Federal Public Water Supply Systems (FY 2002)
Non-Transient Non-Community (8.3%) 356
Community (10.1%) 434
N = 4,276 Federal Systems Transient Non-Community (81.5%) 3,486
Source: SDWIS - 7/9/03
State of Federal Facilities Report, FY 2001-2002 43
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Federal Facilities Enforcement Office
As shown in Exhibit 30, the most common system is the Transient Non-Community,
which comprise 81.5 percent of all federal PWSS, while Community and Non-Transient Non-
Community systems make up 10.1 percent and 8.3 percent, respectively of the federal universe.
There is no agency identifier within SDWIS, so it is not possible to identify the PWSS universe
by agency category. A review of system names indicates that most PWSS in the federal
government are operated by CFAs, particularly public land agencies such as the U.S. Forest
Service within the Department of Agriculture and the National Park Service within the
Department of Interior.
EPCRA TRI Data for Federal Facilities
The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986
established the authority for EPA to create the Toxic Release Inventory (TRI). TRI is a publicly
available database that contains information on toxic chemical releases and other waste
management activities reported annually by certain covered industries as well as by federal
facilities.
Executive Order 13148 requires federal facilities to report to TRI if certain reporting
criteria are met. Exhibit 31 shows the TRI on-site and off-site releases at federal agencies for
calendar year 2001. In summary, a total of 283 federal facilities reported under TRI. Of these,
172 facilities were DOD, 23 DOE and 88 were CFAs. DOD reported 13.8 million pounds of
total releases representing 17.4 percent of all releases by all federal facilities. Federal facilities,
as a whole, reported a total of 79 million pounds of both on-site and off-site releases.
Between 2000 and 2001, total on- and off-site releases from federal facilities declined 7.6
percent, a decrease of 6.3 million pounds, primarily due to the net decrease reported by the
Tennessee Valley Authority (TVA). TVA facilities reported a decrease of 10.3 million pounds
from 2000 to 2001, which represented a decrease of 14.5 percent. DOE facilities reported the
second largest decrease with almost 266,700 pounds or 35.7 percent. Defense Logistics, an
agency of DOD, reported a decrease of 79.1 percent from 2000 to 2001.
Most other federal agencies reported increases. U.S. Army facilities reported the largest
increase with 2.2 million pounds, or a 37 percent increase. EPA Fund-lead Superfund Sites also
reported a net increase from 2000 to 2001. These releases are related to clean-up activities at
hazardous waste sites. U.S. Air Force facilities reported the third largest increase with 637,400
pounds, a 45.8 percent increase.
More information or TRI releases at federal agencies can be found in an EPA report, 2001
Toxics Release Inventory Public Data Release. The report can be found at the EPA website:
http://www.epa.gov/tri/tridata/triQl
44 State of Federal Facilities Report, FY 2001-2002
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Federal Facilities Enforcement Office
Exhibit 31
TRI Releases at Federal Facilities (2001)
Federal Agency
Department of Defense
Air Force
Army
Army Corps of Engineers
Defense Logistics
Defense Stockpile
Marines
Military Academy
Navy
Department of Energy
Department of Interior
Department of State
Department of Transportation
Department of Treasury
Department of Veterans Affairs
Environmental Protection Agency
Environmental Protection Agency
EPA Fund-Lead Superfund Sites
NASA
Tennessee Valley Authority
US Department of Agriculture
US Enrichment Corporation
US General Services Administration
Total for Federal Facilities
Total
Facilities
Number
172
35
78
2
1
3
21
2
30
23
13
1
9
14
3
7
3
4
8
26
5
1
1
283
Total Air
Emissions
Pounds
2,964,552
910,939
1,596,769
0
869
0
132,814
254
322,907
215,239
751
0
227
148
3,686
5,900
0
5,900
73,334
41,275,091
1
497,743
0
45,036,673
Surface Water
Discharges
Pounds
4,024,363
110,405
3,527,879
13,287
0
0
338,784
0
34,008
86,425
5,225
250
2
0
750
64,911
0
64,911
0
909,336
0
73
0
5,091,334
On-site Releases
On-site Land Releases
Underground
Injection RCRA Subtitle Other On-site
C Landfills Land Releases
Pounds Pounds Pounds
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3,880
0
0
0
0
0
0
0
0
4
0
0
0
0
3,884
5,869,743
1,014,977
3,767,221
4,600
0
0
675,534
32,914
374,497
227,470
23,508
0
6,222
142,796
0
1,750,613
0
1,750,613
4,632
18,652,015
450,768
570
0
27,128,337
Total On-
site
Releases
Pounds
12,858,658
2,036,321
8,891,869
17,887
869
0
1,147,131
33,168
731,412
533,013
29,484
250
6,451
142,944
4,436
1,821,424
0
1,821,424
77,969
60,836,442
450,769
498,386
0
77,260,228
Off-site
Releases
Transfers
Off-site to
Disposal
Pounds
928,474
109,065
438,393
0
0
0
3,059
0
377,957
258,872
0
0
2,527
29,016
0
1
0
1
1,825
545,953
250
0
3
1,766,920
Total On-
and Off-site
Releases
Pounds
13,787,132
2,145,387
9,330,262
17,887
869
0
1,150,190
33,168
1,109,369
791,886
29,484
250
8,978
171,960
4,436
1,821,425
0
1,821,425
79,794
61,382,396
451,019
498,386
3
79,027,148
Source: 2007 Toxic Release Inventory Public Data Release - 6/30/03
Note: On-site Releases are from Section 5 of Form R. Off-site Releases are from Section 6 (transfers off-site to disposal) of
Form R. Off-site Releases include metals and metal compounds transferred off-site for solidification/stabilization and for
wastewater treatment, including to POTWs. Off-site releases do not include transfers to disposal sent to other TRI facilities that
reported the amount as an on-site release.
State of Federal Facilities Report, FY 2001-2002 45
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46 State of Federal Facilities Report, FY 2001-2002
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Acronym
AIRS/AFS
CAA
CESQG
CFA
CWA
DMR
DOD
DOE
ECHO
FFEO
FRS
FUDS
IDEA
HPV
LQG
NAAQS
NOV
NPDES
OTIS
OECA
PCS
PWSS
RCRA
RCRAInfo
APPENDIX A - ACRONYMS
Definition
Aerometric Information Retrieval System/AIRS Facility
Subsystem
Clean Air Act
Conditionally-Exempt Small Quantity Generator
Civilian Federal Agency
Clean Water Act
Discharge Monitoring Report
Department of Defense
Department of Energy
Enforcement and Compliance History Online
Federal Facilities Enforcement Office
Federal Registry System
Formerly Used Defense Site
Integrated Database for Enforcement Analysis
High Priority Violator (Violation)
Large Quantity Generator
National Ambient Air Quality Standards
Notice of Violation
National Pollutant Discharge Elimination System
Online Tracking Information System
Office of Enforcement and Compliance Assurance
Permit Compliance System
Public Water System Supervision
Resource Conservation and Recovery Act
RCRA Information System
State of Federal Facilities Report, FY 2001-2002 47
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Federal Facilities Enforcement Office
Acronym Definition
SDWA Safe Drinking Water Act
SDWIS Safe Drinking Water Information System
SNC Significant Noncompliance (Noncomplier)
SQG Small Quantity Generator
TSDF Treatment, Storage, and Disposal Facility
48 State of Federal Facilities Report, FY 2001-2002
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