&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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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.
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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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                                                            Federal Facilities Enforcement Office
                         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.
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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."
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                                      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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                                                    Federal Facilities Enforcement Office
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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