nooui cii i
ISSUE #4
Agency
(2261 A)
an environmental bulletin for federal facilities
EPA ORDERS CEASE-FIRE
ON CAPE COD BASE
2 Guest Spot: Sherri W. Goodman
3 TRI Drops for Feds Second
Year of Reporting
4 In the Field: Groundwater
Testing in Nebraska,
Washington Navy Yard
6 The Hammer
7 Congratulations to Pollution
Prevention Environmental
Challenge Winners!
8 Reports and Regulations
10 Conferences
12 Calendar
EPA Ordered a cease-fire, effective May
19, 1997, at one of the largest National
Guard training areas in the Northeast in
an effort to protect Cape Cods drinking
water from contamination. On April 10,
1997, EPA Region 1 ordered Army Nation-
al Guard to suspend all training activities
at Camp Edwards on the Massachusetts
Military Reservation (MMR) that could
release contaminants to the air, soil, and
water on Upper Cape Cod. This is the first
time that EPA has ever stopped military
training to protect human health. EPA
also ordered the National Guard to imme-
diately begin cleanup of lead and unex-
ploded ordnance from firing ranges and
impact areas on base.
"This is a home run day for EPA, but
more especially for the citizens of the
Cape," said EPA Regional Administrator
John DeVillars. "Their air will be cleaner,
their drinking water more secure, and
their health better protected as a result of
this action." Continued on page 10
Contractors search for buried unexploded ord-
nance in the impact area at Camp Edwards
on Cape Cod using a magnometer device.
Director^
CRAIG HOOKS
The United States Government has
embarked on a long and costly voyage in
coming to grips with its own environmen-
tal legacy. The federal government repre-
sents the single largest environmental
program in the world, with the largest set
of problems and challenges in the west-
ern hemisphere.
For some time the federal government
has claimed that it intends to be a leader
in environmental protection. At the same
time, the federal government historically
has resisted attempts to hold itself
accountable to environmental laws to the
same extent that municipalities, state
governments, and the private sector are
held accountable. These two messages
are inconsistent. Until the federal gov-
ernment accepts voluntarily the concept
of a "level playing field" for all environ-
mental laws, it will only be a pretender to
the leadership throne.
One step towards achieving this lead-
ership and reestablishing faith in the gov-
ernment is to assure the public that the
federal government is accountable to the
citizens, states, and the Congress for its
environmental record. In a previous col-
umn, I talked about trust and whether
Continued on page 11
Printed on Recycled Paper
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SHERRI W. GOODMAN
Deputy Under Secretary of Defense for Environmental Security
It has become increas-
ingly clear to me that pre-
serving our Nations nat-
ural heritage requires a
commitment, and team-
work. A commitment to
conducting business in an
environmentally sustainable manner, and
teamwork to make that vision a reality.
To protect people and environment,
and to promote economic development
across the globe, all sectors of society
must integrate environmental considera-
tions into their activities. The Depart-
ment of Defense (DOD) is making an
extremely important contribution to what
has become a global effort to balance envi-
ronmental protection and development.
This global effort, often framed in the con-
text of "sustainable development" empha-
sizes managing growth, developing tech-
nologies to prevent pollution from the
outset, protecting air and water quality,
as well as historic sites and natural areas,
and strengthening communities.
These same underpinnings form the
basis for DODs environmental program.
The Office of Environmental Security is
responsible for protecting and maintaining
our access to land, sea and air so that we
can sustain the military mission. This
involves managing the natural and cultur-
al resources under our stewardship, clean-
ing up sites that have been contaminated
in the past, developing programs and tech-
nologies to prevent pollution from the out-
set, protecting the safety and health of our
troops, and complying with the law.
DOD manages over 25 million acres, is
subject to environmental laws and regu-
lations, and invests nearly 2% of its bud-
get in environmental security. Our 435
installations operate like small cities, fac-
ing many of the same challenges. Base
commanders play a leadership role in
their community, setting policy in every
area, from infrastructure development
and maintenance (roads, schools, hous-
ing, etc.), to waste management, environ-
mental protection and community devel-
opment.
Our environmental commitment was
well expressed by the Secretary of Defense
William Cohen who issued an Earth Day
Proclamation which stated, "Environmen-
tal protection is our responsibility as good
citizens, neighbors, and managers." He
proclaimed that "...environmental protec-
tion is critical to the Defense Department
mission and environmental considerations
shall be integrated into all defense activi-
ties." That is an excellent summary of
what we are trying to achieve with DoDs
environmental program. Today, environ-
mental factors are in the mainstream of
DoD activities.
Environment, safety and health activ-
ities now enhance, rather than burden,
productivity and competitiveness. Our
strategy is to reduce operational costs,
increase operational flexibility, and
reduce liabilities. Efforts have focused on
looking for ways to substitute existing
materials or processes with environmen-
tally sound alternatives, or to treat and
dispose of contaminated emissions and
effluents in a safe and environmentally
sound manner. About 80% of the haz-
ardous materials used by DOD is attrib-
utable to the acquisition process. So it's
the acquisition process, from the research
and development, to production, to actual
operations and support, that can benefit
the most from eliminating pollutants. It's
a simple concept: pollution is waste, and
waste is wasted money. Below is a snap-
shot of our progress to date:
(1) The number of enforcement actions
are down 80% even though the number of
inspections by regulators has remained
the same. (2) This year DOD made sub-
stantial progress toward meeting its goal
to reduce disposal of hazardous waste by
50% by 1999 from a 1992 baseline. DOD
already reduced hazardous waste 50%
between 1985 and 1992. (3) DOD com-
pleted its second Toxic Release Inventory
public data report and toxic release
reductions are down 30% in the first
reporting year (1994/95). (4) Environmen-
tal considerations and costs have been
integrated into the design of new
weapons systems. For example, the
Navy's New Attack Submarine is reduc-
ing its future hazardous waste generation
90% below levels currently generated by
submarines. (5) DOD now purchases only
recycled content copier paper as long as
the cost is below that of virgin paper.
DOD use of recycled paper will save
150,000 trees each year, and 60 million
gallons of water—the amount one million
Americans use in a day. (6) DOD has com-
pleted 62% of all biological inventories of
plants and animals found on lands under
DOD jurisdiction.
These successes are the result of sys-
tematic efforts to integrate environmen-
tal education and training at every level
of the work force and throughout our mil-
itary academic institutions, by establish-
ing policy for aggressive self-assessment
programs, and by creating incentives for
environmental stewardship.
A common thread runs through our
best programs. That common thread is
partnership. We have strong programs to
jointly develop constructive solutions to
common challenges — both environmen-
tally and economically. Meaningful com-
munication and cooperation with Federal,
State and local agencies, tribal nations and
communities near our installations is key
to ensuring that we are operating efficient
installations, promoting effective military
training and protecting the environment.
Achieving sustainablity requires all
individuals and organizations to adopt a
new view toward the environment and
the way we live and do business. We have
found that making these changes is help-
ing us to fulfill the military mission while
improving the quality of life for our Ser-
vice men and women.
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FEDERAL FACILITIES REPORT SIGNIFICANT
DROP IN TRI RELEASES
Federal facilities reported to EPA's
Toxics Release Inventory (TRI) for the sec-
ond time in 1995, and the data show near-
ly a 25% decline in total amounts of toxic
chemicals released in 1995, and nearly a
35% decline in transfers, compared to
1994. However, the source of the decreas-
es is not yet clear. It may be due to the
adoption of pollution prevention mea-
sures or to the fact that fewer facilities
reported in 1995 (144 rather than 193).
The most recent TRI data for federal
agencies are summarized in the accompa-
nying table. Half of the 2-million-pound
reduction in releases is due to the Air
Force s efforts, while nearly 80% of the 3.4-
million-pound reduction in transfers
comes from the Army. Note that the per-
centage changes between 1994 and 1995
shown in the table relate only to chemicals
reported in both those years, not to the
actual 1995 release and transfer numbers.
Information on obtaining TRI data is
available from EPA's EPCRA hotline at 1-
800-535- 0202 (703-412-9810 in the Wash-
ington, D.C. area) or online from the TRI
home page at http://WWW.epa.gOV/
opptintr/tri. TRI data can also be
accessed through the Right-to-Know
Computer Network (http://www.rtk.net).
1995 TRI DATA FOR FEDERAL FACILITIES
Federal Agency
Agriculture
Defense
Air Force
Army
Army Corps of Engineers
Defense Logistics Agency
Marines
Navy
Energy
Health & Human Services
Interior
Justice
Transportation
Treasury
Veterans Affairs
EPA
NASA
Tennessee Valley Authority
U.S. Knrichment Corp.
Total
1995 Releases
474.9
5,615.3
3,651.8
917.6
22.4
5.3
375.0
643.1
581.9
0
4.8
32.5
16.5
37.6
0
0
474.0
13.6
675.7
7,927.0
1994-1995
Change (%)
-26.7
-25.5
-29.1
0.2
-83.1
-26.5
-28.9
-7.7
-100.0
316.5
-64.8
-30.7
493.3
-45.0
-13.7
-100.0
-11.7
-23.6
Releases and transfers reported in millions of pounds.
1995 Transfers
0
5,694.1
1,065.0
3,672.7
0.3
2.8
560.6
392.7
103.1
55.1
25.8
0
6.3
441.7
91.0
0
78.1
0
0
1994-1995
Change (%)
-
-38.9
-23.3
-42.3
-
-82.3
-28.4
-48.1
22.8
-60.6
-100.0
-
0.0
119.4
-
-
-25.2
-100.0
_
6,495.3
-34.7
Source: EPA, 1995 Toxics Release Inventory: Public Data Release (EPA 745-R-97-005,
April 1997).
ENVIRONMENTAL JUSTICE AT FEDERAL
FACILITIES: A NEW INITIATIVE
Over the past few years, FFEO has
been attempting to integrate considera-
tions of environmental justice into poli-
cies and guidance governing federal facil-
ities, in particular linking voluntary
pollution prevention activities with envi-
ronmental justice. "Environmental jus-
tice" is a response to the disproportionate
environmental impacts faced by many
communities made up predominantly of
people of color and/or low income. A new
report discusses the preliminary results
of FFEO's Federal Facilities Environ-
mental Justice Enforcement Initiative
which is aimed at identifying federal
facilities that may pose environmental
justice concerns and emphasizing
enforcement efforts at such facilities.
The initiative highlighted 44 facilities
as potential environmental justice sites.
The majority of them are located in
Regions 4, 6, and 9. Of the 44 sites, 77%
belong to DOD, 18% to DOE, and 5% to
civilian federal agencies. Twelve of the
sites have recent violations, 13 are in sig-
nificant noncompliance, and 17 are listed
on the National Priorities List (Super-
fund). FFEO used four criteria for tar-
geting sites: relative health risks posed by
the facility to populations in the immedi-
ate vicinity (using the TRI Indicator
Model); compliance history; community
and other reports of EJ concerns; and
geographic distribution. To determine
whether the 44 facilities listed in the
report are in fact EJ sites, further inves-
tigation is needed. FFEO is encouraging
each EPA Region to include at least one
targeted facility in its annual multi-
media inspections and to engage regional
E J coordinators and federal facility coor-
dinators in joint targeting efforts.
For more information or a copy of the
report, contact Darlene Boerlage, FFEO,
202- 564-2593.
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lathe
THE WASHINGTON NAVY
YARD: ERA'S MULTI-
MEDIA ENFORCEMENT
IN THE DISTRICT OF
COLUMBIA
by Darlene Boerlage
The Washington Navy Yard, a 66
acre facility in Southeast Washington on
the banks of the Anacostia River, has
been working with EPA for the expedient
cleanup and return to compliance of the
facility. Due to its 150 years of naval
industrial activities the Navy Yard is on
track to be listed on the Superfund
National Priorities List within the next
several years.
EPA Region 3 issued four significant
enforcement actions on September 30,
1996, two at the Washington Navy Yard
and two at the Anacostia Naval Station.
Multi-media inspections had previously
been conducted at the facilities as part of
the Regions Anacostia River Initiative.
Two of the complaints were the first ever
issued under the Underground Storage
Tank program (RCRA Section 9006)
against a federal agency for violations of
federal underground storage tank regu-
lations. The Navy answered the com-
plaints and requested a hearing on Janu-
Washington Navy Yard
ary 7, 1997. Negotiations are ongoing to
resolve these complaints. The other two
actions were for violations of RCRA Sub-
title C (hazardous waste) involving sites
that were contaminated,which assessed
penalties in the amount of $302,000 for
the Washington Navy Yard and $310,000
at the Anacostia Naval Station. The
Region and the Navy are working togeth-
er as a team to resolve these counts.
On March 6, 1997, EPA Region 3 and
the Department of Navy signed a RCRA
7003 cleanup order. This order requires
comprehensive hazardous and solid
waste cleanup at the installation. As part
of a team effort, EPA Region 3 has
assigned both a Superfund and RCRA
(hazardous waste) project manager to the
facility to fully integrate the cleanup of
the site once it becomes final on the
National Priorities List. Meanwhile, the
Navy has been conducting cleanup activ-
ities at the installation.
Under the Clean Water Act, the Navy
has applied for a National Pollution Dis-
charge Elimination System (NPDES)
permit for management of its stormwater
and discharges into the Anacostia River.
At last check, the District of Columbia
has not concurred on the NPDES permit.
Under requirements of the National
Environmental Policy Act, the Navy held
a public meeting on Janu-
ary 23, 1997, to discuss the
draft Environmental
Impact Statement for the
relocation activities pro-
posed at the facility. The
Washington Navy Yard
will be receiving approxi-
mately 4,100 new person-
nel transferring from a
location in Arlington, Vir-
ginia. Reportedly, commu-
nity members and the
Sierra Club Legal Defense
Fund focused on the ongo-
ing cleanup at the Navy
Yard as well as the need
for more accessible infor-
mation from the Navy on the progress of
cleanup. The Navy has responded to the
community by forming a Restoration
Advisory Board comprised of community
members and other stakeholders to
advise the Navy on the cleanup process.
The Navy Yard remediation is part of a
broader community-based approach by
EPA Region 3 and the Navy to conduct
cleanup under the Anacostia River Initia-
tive.
Darlene Boerlage can be reached at
202-564-2593.
EPA REGION 2 REVIEW OF
DOE BROOKHAVEN
NATIONAL LABORATORY
EPA Region 2 conducted a major multi-
media inspection of DOEs Brookhaven
National Laboratory (BNL) in Upton, NY.
The inspection took place May 5-14, 1997,
with assistance from EPAs National
Enforcement Investigation Center. Twen-
ty-five inspectors representing eleven
programs participated in the inspection.
BNL was identified as an inspection
candidate because of its size and complex
and variable operations. Of particular
interest to EPA was the controversy sur-
rounding the waste management prac-
tices at the site, and the fact that numer-
ous violations had been found during
EPAs earlier multi-media inspection of
BNL in 1991.
To complement the multi-media
inspection, Region 2 will be conducting
two additional reviews of the facility.
First, an evaluation of BNL's major
processes (both operational and research)
will be conducted to provide EPA and
BNL with a comprehensive understand-
ing of all waste generation at the facility.
And second, an Environmental Manage-
ment Review (EMR) will be conducted to
determine whether the facility s manage-
ment system is adequately designed to
sustain a viable environmental compli-
ance program. Both reviews will begin
this summer with NEIC assistance.
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GROUNDWATER
SAMPLING UNDERWAY
IN NEBRASKA AND
KANSAS
EPA Region 7, the Kansas Department
of Health and Environment, and Nebras-
ka Health and Human Services have
begun testing private wells and ground-
water near USDA-operated grain storage
sites to identify possible carbon tetrachlo-
ride (CCl4) contamination. A history of
finding CCl4-contaminated groundwater
near former grain storage facilities in
Nebraska and Kansas has compelled
EPA to push for testing of approximately
400 still untested sites in these two
states. EPA has committed over half a
million dollars to support sampling at
these sites in order to ensure that private
well users nearby are not using contami-
nated water. The money is being con-
tributed by the Federal Facilities
Enforcement Office, Region 7s Super-
fund Program, the Office of Water, and
the Office of Emergency and Remedial
Response.
Sampling will take place over a period
of approximately 15 months, with the
states conducting much of the work. EPA
estimates that this effort will address the
approximately 400 sites that currently
need to be sampled in Kansas and
Nebraska, with about $200,000 needed to
complete sampling in these states. Grain
bin sites in Iowa, which appear to have a
significantly lower detection rate, may be
addressed in future sampling projects.
No sites have been sampled in Missouri.
The Commodity Credit Corporation,
an agency of USDA, operated approxi-
mately 4,500 grain storage sites national-
ly from the 1940s until 1970. Of these,
about 1,800 known sites are located in
Region 7 (Nebraska, Kansas, Missouri
and Iowa). USDA fumigated stored grain
at these sites with CCl4, a probable
human carcinogen. For some time, EPA
has sought to have USDA perform wide-
spread sampling in order to identify
potential users of CCl4-contaminated
groundwater. Recently, USDA has
expressed interest in sampling activities
and a willingness to contriubte $110,000
of its FY97 funds toward a sampling
ON THE INTERNET: ENVIRO$EN$E AND BEYOND...
A wide variety of information on federal facilities is available through EPA
sites on the Internet:
^ To reach Enviro$en$e, EPA's environmental electronic information system:
• Through EPA's server, go to http://www.epa.gov/envirosense
(No dollar signs!!)
• Through the INEL server, go to http://es.inel.gOV
^ To go directly to Federal Facilities Information on Enviro$en$e, go to
http://es.inel.gov/oeca/fedfac/fedfac_info.html
^ To reach FFEO's home page (also the Federal Facilities Environmental Lead-
ership Exchange home page), go to http://es.inel.gov/oeca/fedfac/fflex.html
>• To reach EPA's home page, go to http://WWW.epa.gOV
^ To read this or past issues of FedFacs on the Internet, go to http://es.inel.
gov/oeca/fedfac/ann/index.html
For information on FFLEX/Enviro$en$e, contact Isabella Lacayo, FFEO,
202-564-2578.
See you on the Internet!
effort of its own. Also, in 1997, USDA
completed a survey of its field offices in
Kansas and Nebraska and located 75
sites not previously identified.
For additional information contact
Lance Elson at202-564-2577.
REGION 6 REPORTS FIRST
TRANSFER OF BASE CLO-
SURE TO CIVILIAN USE
On May 23, 1997, EPA Region 6
approved final transfer of NAS Chase
Field to the Beeville/Bee County Redevel-
opment Authority. This is the first base
closure in Region 6 that has been com-
pletely converted to civilian use.
NAS Chase Field was placed on the
Base Closure list in 1991 (BRAC II). To
speed the economic recovery of communi-
ties impacted by the closing of the base,
an innovative partnership was created
among EPA, the State of Texas, and Navy
environmental personnel. A goal-oriented
process was established to fast-track
environmental cleanup and to ensure
that cleanup of old hazardous waste sites
at the base does not interfere with rede-
velopment of this property. Significant
amount of solid waste management units
were identified and investigated at the
base. Major sites investigated and reme-
diated include landfills, firefighting train-
ing areas, waste oil tanks, solvent tanks,
waste storage areas, and oil-water sepa-
rators.
The success of environmental cleanup
and reuse at NAS Chase Field is attrib-
uted to team work among staff from EPA,
the Texas Natural Resource Conserva-
tion Commission, and the Navy, as well
as the direct involvement of the Base
Commander in promoting reuse of the
facility and a close working relationship
with the local Redevelopment Authority.
For further information, contact Mr.
Sing Chia, EPA Region 6, 214-665-8301.
is published by EPA's Federal Facilities
Enforcement Office.
Joyce Johnson, Editor
Gilah Langner, Writer
Robin Foster, Layout
To receive FedFacs in the mail, contact:
Federal Facilities Enforcement Office
U. S. EPA (2261), 401 M Street SW,
Washington, DC 20460
or Fax =202-501-0069
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REGION 1:
Actions Against Veterans Affairs
Facility. On March 31, 1997, Region I
reached a settlement with the Depart-
ment of Veterans Affairs (VA) Medical
Center in Westhaven, CT on a complaint
and compliance order under RCRA Sec-
tion 3008(a). The penalty assessed in the
complaint was $82,375 with a settlement
penalty of $61,550. The VA will pay
$15,388 (25%) in cash and will perform
SEPs costing some $48,000. The VA will
install and operate, as part of the x-ray
film processing operations, a closed-loop
silver recovery system and automatic
batch system for four x-ray developer
units. In addition, the VA will purchase
necessary computer hardware and haz-
ardous materials software to be used by
the VA Safety Office personnel for haz-
ardous materials and waste manage-
ment information.
The VA also will hire a consultant to
conduct an environmental compliance
audit at the facility. The audit will identify
opportunities to maintain compliance with
RCRA regulations, ways in which the
RCRA program at the VA can be improved,
efficient ways to manage hazardous waste
generated at the VA, and opportunities to
reduce the use, production, and generation
of hazardous materials and waste. The
audit will require a detailed inspection of
all chemical use areas, satellite accumula-
tion areas, and the hazardous waste accu-
mulation shed. Finally, the VA will provide
eight-hour RCRA hazardous waste man-
agement training to all members of the
Fire & Safety Office, appropriate members
of the Facilities Management Service, and
research laboratory principle investiga-
tors.
Among the violations outlined in the
complaint was the failure to make haz-
ardous waste determinations. EPA
inspectors found that the facility had
sent hazardous wastes off-site designat-
ed as nonhazardous wastes. The facility
also failed to operate so as to minimize
the possibility of a fire, explosion, or any
unplanned release of hazardous waste
constituents. EPA inspectors found con-
tainers holding acids and caustics that
could result in heat generation and vio-
lent reaction if mixed together or thrown
out in a trash barrel. A similar action was
settled earlier in the year against VA
medical facilities in Boston, MA.
In September 1996 the Veterans
Administration agreed to spend $16,800
to design and implement an environmen-
tal training program for all nine VA med-
ical facilities throughout New England.
The training included instruction on
management of hazardous waste and rec-
ognizing opportunities for pollution pre-
vention. The VA also agreed to pay a cash
penalty of $47,725 to settle an EPA com-
plaint regarding violations of federal and
state hazardous waste management laws
at the VAs medical center on South Hunt-
ington Ave. in Boston, MA.
REGION 4:
Agreement with DOE on Paducah
Plant. Region 4 reached agreement with
DOE to clean up the NPL-listed Paducah
Gaseous Diffusion Plant. The intera-
gency agreement (IAG) reflects an expec-
tation that the groundwater at the site
will be cleaned up by 2010. The IAG was
issued for public comment in Spring 1997
and is expected to be finalized in the fall.
Final agreement on a major modification
to the IAG covering cleanup at the DOE s
Oak Ridge Reservation NPL site was also
reached. The modification provides for
milestones which are more enforceable
than those of the original agreement.
RCRA Cases. Region 4 continues to
work toward resolution of administrative
complaints issued late in 1996 against
the Army's Fort Campbell in Kentucky,
where a $48,700 penalty was proposed,
and the Defense Logistics Agency s (DLA)
Memphis Depot, which was assessed a
$20, 000 penalty.
The Fort Campbell violations includ-
ed: failure to make hazardous waste
determinations, failure to correctly label
containers, failure to remove hazardous
waste from satellite accumulation areas
in a timely manner, and failure to main-
tain emergency equipment.
The DLA Memphis, Tennessee facility
violated the conditions of its permit by
improperly storing incompatible wastes,
creating potentially dangerous conditions.
Region 4 also took a RCRA enforce-
ment action against Lockheed Martin
Energy Systems in late 1996, for failure
to adequately inspect hazardous waste
tank systems at DOEs Oak Ridge, Ten-
nessee facility. The RCRA Consent Agree-
ment and Consent Order imposed a
$22,500.00 penalty for improper inspec-
tion procedures. The tank inspections are
now being properly performed.
REGION 9:
Air Force Agreement to Pay Stipu-
lated Penalty at McClellan Air
Force Base in California. On April
25, 1997, the Air Force agreed to pay a
$15,000 fine and accepted full responsi-
bility for exceeding effluent limitations
for its groundwater treatment system for
a three-day period, and discharging
groundwater contaminated with TCE,
1,1 -dichloroethane, 1,1 ,-dichloroethylene
in greater concentrations than allowed in
the interim record of decision. In addi-
tion, the Air Force failed to sample the
effluent on a weekly basis (which would
have indicated that the carbon filters
needed replacing).
REGION 10:
RCRA Consent Agreement and
Consent Order Signed for Fort
Richardson and Fort Wainwright.
On April 29, 1994, EPA issued two com-
plaints and compliance orders under
RCRA Section 3008(a) to the Army for
hazardous waste violations at Fort
Richardson and Fort Wainwright in Alas-
ka assessing $1.34 million and $650,000,
respectively. On November 21, 1996, a
consent agreement and consent order
Continued on page 7
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CONGRATULATIONS!!
AWARD WINNERS MEET THE CHALLENGE OF POLLUTION PREVENTION
On May 5, 1997,
the second annual
Closing the Circle
award ceremony
was held, honoring
super environmen-
tal achievers in the
federal govern-
ment. This years
award ceremony
included the Envi-
ronmental Pollu-
tion Prevention Challenge Awards which
were presented to individuals in federal
agencies for outstanding achievements in
implementing the provisions of the 1993
Executive Order 12856 on Federal Com-
pliance with Pvight-to-Know Laws and
Pollution Prevention. The winners of
these awards were:
Cathy Andrews, Department of the
Navy, Naval Surface Warfare Center,
Crane, IN, for effective outreach to facil-
ity stakeholders and team-building
efforts, including a pollution prevention
stand down where over 3,000 Navy
employees learned about the environ-
mental benefits of pollution prevention.
Mary Jo Bieberich, Department of
the Navy, Carderock Naval Surface
Warfare Center, Carderock, MD, for
leadership in the Navy's Pollution Pre-
vention Afloat Program which integrates
pollution prevention activities into ship-
board activities at sea. Her at sea
opportunity assessments identified over
40 pollution prevention opportunities
while ships were deployed.
Edward Cooper, Department of the
Army, Corpus Christ! Army Depot,
Corpus Christi, TX, for designing a
broad range of process changes and mod-
ifications, some of which include design
criteria requiring virtually zero pollution
from various chemical processes.
Ronald Barnett, Department
of the Army, United States
Field Artillery Center and
Fort Sill, Fort Sill, OK. As
Director of Environmental Quali-
ty for Fort Sill, Mr. Barnett pro-
vided unique pollution prevention
outreach and training materials
to facility personnel, the Fort Sill
community, and the public at
large.
Ronald Robbins, U.S. Postal
Service Northeast Area Office,
Windsor, CT. As Chair of the U.S.
Postal Service Pollution Preven-
tion Task Force, Mr. Robbins guided the
development of pollution prevention pro-
grams affecting the Postal Service
nationwide; at postal facilities in the
Northeast, his efforts resulted in a reduc-
tion of hazardous waste by over 90 per-
cent.
Russell P. Schaefer, U.S. Postal Ser-
vice, Portland, ME, for establishing
effective pollution prevention programs
at District of Maine facilities and for
implementation of a highly effective haz-
ardous waste amnesty plan.
Continued on page 11
Sherri Goodman, Cathy Andrews, R. Adm.
Totusher (DOD), Fran McPoland (Federal Envi-
ronmental Executive), Mike Stahl (EPA)
THE HAMMER
Continued from page 6
was signed to settle the two complaints.
The settlement calls for the Army to pay
a penalty of $200,000 and to perform two
supplemental environmental projects
worth over $1.0 million. Under the SEPs,
the Army will obtain hazardous waste
storage lockers for use at US Army
installations in Alaska and establish a
Joint Regional Environmental Training
Center making environmental training
available to federal and state agencies in
Alaska.
RCRA Consent Agreement and
Consent Order Signed for Coast
Guard's Kodiak Facility. A Consent
Agreement and Consent Order was
signed by the Region 10 Administrator on
January 23, 1997, for this Alaska facility,
settling a complaint and compliance
order issued on July 12, 1994. The com-
plaint sought over $ 1 million in penalties
for violations of RCRA, including the fail-
ure to monitor groundwater and illegally
burning waste piles of debris. A penalty of
$602,260 has been agreed to for the spe-
cific violations alleged in the complaint.
INEEL Settlement for CERCLA
Agreement Violations. On March 18,
1997, a settlement was signed for viola-
tions of the CERCLA 120 Federal Facili-
ty Agreement/Consent Order for DOEs
Idaho National Engineering & Environ-
mental Laboratory. The violations involve
the cleanup of Pit 9 and groundwater in
the Test Area North of INEEL. Both sites
had remediation activities that DOE had
privatized, and significant delays in
remediation occurred because of manage-
ment and other difficulties associated
with the contracting mechanisms and
cleanup. EPA and Idaho have worked
with DOE and the contractors to get the
projects in question back on track and to
minimize further delays. EPA and the
state have assessed DOE a total of
$970,000 in penalties of which $100,000
will be monetary and the remainder will
be a SEP involving the conservation of
environmentally sensitive land.
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Reports and
EXECUTIVE ORDER 12856
ANNUAL REPORT
SUMMARY
FFEO is currently preparing the first
report on federal agency performance
under Executive Order 12856, Federal
Compliance with Right-To-Know Laws
and Pollution Prevention Requirements.
The report will cover the efforts of 13
agencies on community right-to-know
and pollution prevention activities.
Executive Order 12856 affirmed and
strengthened the federal governments
obligation as a responsible neighbor in
communities where federal facilities are
located by requiring federal agencies and
facilities to comply with chemical report-
ing and emergency planning provisions
of the Emergency Planning and Commu-
nity Right-To-Know Act of 1986 (EPCRA)
and the Pollution Prevention Act of 1990.
The Order set a new standard for federal
environmental excellence by extending
this compliance requirement to many
activities not currently monitored in pri-
vate industry.
Executive Order 12856 also estab-
lished the Administration s vision for fed-
eral government leadership in pollution
prevention. The order directed that fed-
eral agencies and facilities take steps to
embrace pollution prevention as a gov-
ernment-wide ethic in the day-to-day
management of federal facilities. In par-
ticular, E.O. 12856 set ambitious goals
for reducing or eliminating the release of
toxic and hazardous pollutants from fed-
eral facilities into the environment. Fed-
eral agencies were required to modify
their acquisition and procurement prac-
tices and adopt pollution prevention as
standard practice for government pur-
chase of goods and services. Finally, E.O.
12856 supported the continuing federal
commitment to work with the private
sector in the development, testing, and
implementation of innovative pollution
prevention technologies.
Section 402 of Executive Order 12856
directs federal agencies to report annual-
ly to EPA on the progress made in fulfill-
ing each of the provisions of the order. In
1995, EPA published Meeting the Chal-
lenge: A Summary of Federal Agency Pol-
lution Prevention Strategies, which docu-
mented the first 18 months of activity by
federal agencies and facilities under the
executive order. EPA is now preparing a
second document which will summarize
progress reports provided by 13 federal
agencies. The document will be available
in late summer.
For more information, contact Will
Garvey, 202-564-2458.
HAZARDOUS WASTE
COMPLIANCE DOCKET
UPDATED WITH SECTION
3016 INVENTORY
The Federal Agency Hazardous
Waste Compliance Docket has been
recently updated. Update 10, published
on June 27, 1997, added 102 federal facil-
ities, bringing the total number of facili-
ties on the docket to 2,104. Four of the
new additions to the docket are facilities
that have reported to the National
Response Center the release of a
reportable quantity of a hazardous sub-
stance. Since the dockets inception in
1988, the number of federal facilities list-
ed has increased by nearly 80 percent,
from 1,094 to 2,104.
The docket includes the 1996 invento-
ry of hazardous waste facilities mandated
by Section 3016 of RCRA. Section 3016
requires all federal agencies to compile,
publish, and submit to EPA an inventory
of all facilities they currently own or oper-
ate, or have previously owned or operat-
ed, at which hazardous waste is stored,
treated, or disposed of, or was disposed of
at any time. The inventory must be sub-
mitted every two years. ERA s Office of
Solid Waste conducted an initial invento-
ry in 1986, and subsequently in 1988,
1990, 1992, and 1994. In 1996, responsi-
bility for conducting the inventory was
transferred to FFEO. FFEO requested
inventory submissions from federal agen-
cies in April 1997, and held a half-day
interagency training to help federal agen-
cies respond to the request.
For more information, contact Augus-
ta Wills, FFEO, 202-564-2468.
ERA/DOE COLLABORA-
TIVE DECISION-MAKING
GUIDANCE FINALIZED
EPA's Office of Enforcement and Com-
pliance Assurance, Office of Solid Waste
and Emergency Response, and DOEs
Environmental Management Office
recently issued the final joint Guidance
on Improving Communication to Achieve
Collaborative Decision-Making at DOE
cleanup sites. The guidance places a
great deal of emphasis on greater use of
interagency project teams to improve and
expedite cleanup and regulator involve-
ment in annual budget development.
The DOE/EPA communications guid-
ance was approved as Interim Final by
Steve Herman, Elliott Laws, and Al Aim
at a joint signing ceremony in November,
1996, and finalized in June, 1997. The
four-page document focuses on improving
communication to: (1) further the EPA
and state regulator role in establishing
project priorities at DOE sites; (2) encour-
age greater use of collaborative decision-
making to improve and expedite cleanup
and compliance at DOE facilities; and (3)
improve the informal dispute/ issue reso-
lution process to facilitate cleanup and
compliance.
A variety of factors led to the develop-
ment of this guidance. First, independent
observers highlighted the need for
improved communications both within,
and between, EPA and DOE. Second,
increasing fiscal constraints make it
important to have greater regulator
involvement in DOE budget planning.
Lastly, EPA and DOE saw the need to
jointly identify the steps to be taken to
-------
achieve the most suitable remedies. This
will save money, focus effort on appropri-
ate actions, and accelerate cleanup.
The guidance describes a communica-
tion framework that should
improve compliance, acceler-
ate environmental work, and
increase efficiencies. Improv-
ing communications is criti-
cal to achieving DOEs goal
of completing cleanup at
most sites with a decade.
Several Regions have suc-
cessfully participated on
interagency teams and docu-
mented success in using col-
laborative decision-making
approaches to reduce costs at
federal cleanup sites. The
concepts outlined in the guidance can
strengthen EPA and state positions in
establishing priorities at DOE sites while
assisting DOE in accomplishing its expe-
dited cleanup goals contained in DOEs
site-specific Ten Year Plans.
A copy of the Guidance may be down-
loaded from FFEO's Web site at
http://es.inel/beca/fedfac/policy/policy.html
For more information, contact David Lev-
enstein at 202-564-2591.
REIMBURSABLE
INSPECTIONS
Section 104 of the Federal Facilities
Compliance Act (FFCA) requires EPA
Regions and delegated states be reim-
bursed for the costs of conducting certain
annual RCRA inspections at federal
transfer, storage, and disposal (TSD)
facilities. Since 1994 EPA has had intera-
gency agreements (lAGs) in place with
DOD and DOE (and more recently with
NASA in 1996) to enable reimbursement
for the cost for these inspections.
FY97 agreements for DOE and NASA
are approved and in place. The DOD ser-
vices are reviewing their FY97 packages
and it is expected that with some lan-
guage changes, the agreements will be
INDEPENDENT
OBSERVERS
HIGHLIGHTED THE
NEED FOR IMPROVED
COMMUNICATIONS
BOTH WITHIN,
AND BETWEEN,
EPA AND DOE
signed and processed through the Head-
quarters grants office by the end of July.
DOD services have agreed that the lAGs
will be effective for a five-year period
(FY97-FY02) instead of
one to two years to help
speed up the IAG
process. This will avoid
using resources at the
end of a fiscal year to re-
charge appropriate
accounts for eligible
RCRA inspections costs.
Having the accounts
available at the begin-
ning of a fiscal year will
allow the Regions to
charge eligible RCRA
inspection costs to the
applicable accounts as costs are incurred
during a fiscal year.
FFEO is responsible for coordination
of reimbursement to both EPA Regions
and the individual states for RCRA TSD
inspections required by the FFCA. EPA
has completed a management review
study of the first three years of program
implementation.
For a copy of this study or for more
information, contact Susan Weiner,
FFEO, 202-564-2471.
IMPLEMENTATION
GUIDANCE AVAILABLE
FOR CEMP
EPA recently published an Impie
mentation Guide for the Code of Environ-
mental Management Principles (CEMP)
for Federal Agencies. The guide presents
specific actions that agencies can take in
implementing CEMP, and encourages
agencies to consider other steps or to
adopt an environmental management
system (EMS) standard (such as ISO
14000) as the vehicle for implementing
CEMP. The guide also includes a "Self-
Assessment Matrix that describes the
stages an organization may go through in
implementing CEMP.
ERA's CEMP, published on October 16,
1996 (61 FR 54062), is a collection of five
broad principles and performance objec-
tives that can assist agencies in develop-
ing the necessary management infra-
structure to support a proactive, flexible,
cost-effective, and integrated environ-
mental performance. Sixteen federal
agencies have endorsed CEMP and are at
various stages in implementing it at the
facility level.
For more information, contact Andrew
Cherry, FFEO, at 202-564-5011. For
copies of the guide, fax a request to Priscil-
la Harrington, FFEO, 202-501-0069, or
download a copy from the Enviro$en$e
Web site at http://es.inel.gov/oeca/
cemp/cemptoc.html.
REPORT ISSUED ON
RCRA ADMINISTRATIVE
ORDERS
A report analyzing RCRAadministra-
tive orders issued at federal facilities
between 1992 and 1995 is available from
EPA. The report analyzes data obtained
from EPA Regions and their counterpart
offices at the state level. Among the find-
ings:
• Federal orders took longer to settle
than orders issued by states. The aver-
age settlement time was 369 days for
federal orders and 196 days for state
orders. The average proposed federal
penalty was $321,921, while the aver-
age proposed state penalty was
$54,664.
• Of the 701 violations cited in 105
administrative orders, 135 related to
storage and accumulation issues,
another 133 represented general oper-
ations and maintenance failures, 87
were labeling deficiencies, 68 were
safety violations, and 58 were deficien-
cies in records submissions.
To order copies of the report, contact
Kelly Conrad, 202-564-2459.
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REGION 4 FEDERAL FACILITY
CONFERENCE
Some 225 people attended the llth
Annual Environmental Conference spon-
sored by EPA Region 4 (Environmental
Accountability Division, Federal Facili-
ties) with the Department of Defense
(Joint Interservice Regional Support
Group) and several civilian federal agen-
cies, held on May 11-14, 1997. The theme
was Progress Through Partnering.
Keynote speakers were John Hankinson
(Regional Administrator for EPA Region
4), Phyllis Harris (EPA Regional Coun-
sel) , Curtis Bowling (Deputy to the Assis-
tant Deputy Under Secretary of Defense,
Environmental Quality), Denzel Fisher
(Assistant to the Deputy Assistant Secre-
tary of the Army, Environment Safety &
Occupational Health) and Elsie Munsell
(Deputy Assistant Secretary of the Navy,
Environment & Safety).
Topics covered included state presen-
tations and workshops, EPA/DOD Part-
nering, North Carolina/DOD Partnering,
Project XL & ELP, Risk Management,
Safe Drinking Water Act, Underground
Tanks & Underground Injection Control,
Munitions Rule, Range Rule, ISO 14000,
and the Coastal America Partnership
Program.
For more information, contact David
Holroyd, EPA Region 4, 404-562-9625.
Information will be posted on the EPA
Region 4 EAD/AMB home page.
ATTENTION FEDERAL FAdUTIES:
EMR PILOTS AVAILABLE
Environmental Management Reviews (EMRs) are evaluations of an indi
vidual facility s program and management systems to determine the extent to
which a facility has programs and plans in place that can ensure compliance and
progress toward environmental excellence. As described in the last issue of Fed-
Facs, EMRs are not inspections, audits, or pollution prevention opportunity
assessments. Instead, they offer federal facilities an understanding of the under-
lying causes of current or potential compliance problems and develop sugges-
tions for correcting them. EPA is offering to conduct EMRs at federal facilities as
part of a pilot program. For information on EMRs or to sign up for one, contact
your EPA Regional Federal Facility Coordinator:
Region 1, Anne H. Fenn, 617-565-3927
Region 2, Jeanette Dadusc, 212-637-3492
Region 3, Eric D. Ashton, 215-566-2713
Region 4, David F. Holroyd, 404-562-9625
Region 5, Lee J. Regner, 312-353-6478
Region 6, Joyce F. Stubblefield, 214-665-6430
Region 7, Jamie Bernard-Drakey 913-551-7400
Region 8, Dianne Thiel, 303-312-6389 or Connally Mears, 303-312-6217
Region 9, Sara Segal, 415-744-1569
Region 10, David Tetta, 206-553-1327
CEASE-FIRE ON CAPE COD
Continued from page 1
The National Guard asked EPA Head-
quarters to overturn DeVillars original
cease-fire order on April 10, warning that
it could "jeopardize the readiness of
National Guard units on the East Coast
and the lives of our soldiers on the battle-
field." Late on May 16, however, EPA
Deputy Administrator Fred Hansen
rejected the appeal, calling the firing
ranges "an imminent and substantial
endangerment." He said that only troops
that needed to be ready for deployment to
Bosnia or other hot spots should be
exempted from the cease-fire.
The Cape Cod aquifer is the sole drink-
ing water source for approximately
200,000 permanent and 520,000 seasonal
residents of Cape Cod. The MMR training
range and impact area is directly above
the most productive groundwater
recharge area of the aquifer, the Sag-
amore Lens. Groundwater flows radially
in all directions from the training range
and impact area. Four towns look to this
region in the northern part of MMR to
find new water supplies to replace those
already lost to groundwater pollution and
to fill the gap between supply and
demand (estimated at 11 million gallons
per day by 2020).
The Superfund cleanup at MMR has
identified plumes that have polluted
roughly 66 billion gallons of water — an
amount that could supply the drinking
water needs of all Cape Cod residents for
7.5 years. It is estimated that each day
another 6-8 million gallons of groundwa-
ter are contaminated because of rapid
movement of plumes through subsurface
soils. The unusually high cancer rate in
Upper Cape communities surrounding
MMR — 24% higher than the statewide
average — has heightened the publics
concern about MMR. However, because
the impact area and training range are
active range and training sites, study and
remediation of these areas were not
required under the Superfund federal
facilities agreement.
On Feb. 27, 1997, EPA Region 1 issued
an Administrative Order pursuant to the
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emergency powers authority of Section
1431 of the Safe Drinking Water Act,
requiring the National Guard to (1)
undertake a comprehensive study of
groundwater related to the training
range and impact area; (2) provide infor-
mation to EPA about possible contamina-
tion in the impact area; (3) develop a pro-
posal for pollution control measures; and
(4) coordinate with a community- based
oversight group.
National Guard officials in February
agreed to suspend the use of live ammu-
nition until completion of a groundwater
study, expected to take 1-2 years. Howev-
er, EPA, the communities, and elected
officials remained concerned about poten-
tial impacts to the aquifer from activities
which the National Guard proposed to
continue, given the widespread ground-
water contamination already emanating
from MMR. No study provided to EPA
evaluated possible migration of contami-
nants to groundwater from soil contami-
nation associated with the use of propel-
lants and "pyrotechnics" such as smoke
grenades. EPA called for a broader cease-
fire on April 10, including live ammuni-
tion, but also the chemical propellants
used to fire dummy artillery and mortar
shells as well as pyrotechnics. EPA said
that high levels of toxins in these devices
also had been found in base soil.
For more information, contact Bill
Frank, FFEO, 202-564-2584.
DIRECTOR'S WORD
Continued from page 1
the federal government had earned the
publics trust. The public needs to know
that it will be protected through vigorous,
forceful enforcement by EPA and the
states for violations of environmental
laws and situations that put public health
and our natural resources at risk. This
type of accountability is the only way for
the federal government to gain the credi-
bility it needs to effectively manage its
environmental programs.
EPA has strengthened the principle
that one federal agency can fine or penal-
ize another agency. On numerous occa-
sions EPA has had to defend EPAs taking
penalty actions against other federal
agencies. Some view that as merely rob-
bing Peter to pay Paul. Or, isn t a penalty
action irrelevant since the federal govern-
ment is not motivated by profits? This
debate should be over, though, because
the facts are straightforward and unas-
sailable — penalties deter non-compli-
ance. They create a powerful incentive for
agencies to comply — the incentive of not
getting caught and not being exposed to
the public and to one s superiors as a vio-
lator. Congress charged EPA with provid-
ing that incentive and we have demon-
strated our intention to do so and to
continue doing so in the future.
The 1992 Federal Facility Compliance
Act (FFCA) clearly established our RCRA
order authority against federal facilities
and placed it on a par with EPAs author-
ity against private companies and indi-
viduals. In enacting FFCA, Congress
sought to ensure that the incentives to
comply brought about by strong enforce-
ment and penalties would apply equally
to federal facilities and those in the pri-
vate sector. This level playing field is nec-
essary to restore the faith of the American
people that the protection of human
health and the environment on federal
facilities is a priority. The message is
clear. Environmental enforcement is a
necessary incentive to ensure compliance
and must be applied with equal force to
the federal government.
The trend toward equality among all
members of the regulated community is
growing. Congress amended the Safe
Drinking Water Act (SDWA) this fall and,
similar to FFCA, clarified EPAs and the
states enforcement authorities under
SDWA against other agencies of the feder-
al government. As a result of these amend-
ments, there can be no doubt that federal
agencies are liable for penalties just like
private parties. In addition, although the
Clean Water Act did not pass recently,
there was bipartisan support for placing
the federal government on a level playing
field with the private sector with regard to
enforcement actions and penalties.
Enforcement actions and penalties are
a deterrent to noncompliance. Citizens
expect EPA to act as an "honest broker"
within the federal government—an agency
that will oversee other agencies environ-
mental compliance and take enforcement
when necessary. EPA will continue to serve
as such a broker.
CLOSING THE CIRCLE AWARDS
Continued from page 7
Richard Peri, Department of Trans-
portation, Aeronautical Engineering
Division at U.S. Coast Guard Head-
quarters, Washington, D.C., for inte
grating pollution prevention goals
throughout the Coast Guard aeronautical
community through such efforts as devel-
oping a pollution prevention chapter for
the Aeronautical Engineering Mainte-
nance Manual and establishing aircraft
maintenance working groups.
Jane Powers, Department of Energy,
Office of Environmental Policy and
Assistance,Washington, DC, for her
efforts to include DOE in EPA's 33/50 tox-
ics reduction program and to develop
clear and concise pollution prevention
guidance, training courses and work-
shops for DOE facility personnel.
Arthur Benson, U.S. Department of
Agriculture, Beltsville Agricultural
Research Center, Beltsville, MD, for
establishing ten pollution prevention
goals to ensure that the Research Center
meets and exceeds the pollution preven-
tion goals of Executive Order 12856.
Congratulations to all who contributed
their talents and energies towards
demonstrating federal leadership in pre-
venting pollution!
Note: The Closing the Circle Award nom-
ination form for this coming year will
include nominations for the individual
Pollution Prevention Environmental
Challenge Award.
Director, FFEO
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CALENDAR
SEPT. 3-4,1997
REGIONAL FEDERAL FACILITIES/
MULTI-MEDIA POLLUTION
PREVENTION CONFERENCE
Dallas, TX
Free conference for environmental man-
agers at federal facilities. Contact: Joyce
Stubblefield, 214-665-6430
SEPT. 15 -18,1997
POLLUTION PREVENTION FAIR
Aberdeen PG, MD
Contact: American Defense Preparedness
Association, tel: 703-522-1820, fax: 703-
522-1855.
SEPT. 23 - 25,1997
7TH SOUTHERN STATES ANNUAL ENVI-
RONMENTAL CONFERENCE AND EXHIBI-
TION: A CONFERENCE ON HOW-TO'S
Biloxi, MS
Sponsored by Mississippi Dept. of Envi-
ronmental Quality; MISSTAP; DOD
Joint Interservice Regional Support
Group South 2 Area) Tennessee Valley
Authority; USAE Waterways Experiment
Station; U.S. EPA 4 and 6. Contact:
http://www.de.msstate.edu/misstap/index
2.html.
FIRST "AMERICA RECYCLES DAY"
NOVEMBER 15,1997
The first "America Recycles Day" — based on the highly successful "Texas Recycles
Day" held in recent years — is being organized by a group of private and public
organizations and government representatives. The goal of "America Recycles
Day" is to ask the American public to continue recycling and to purchase recycled
and recycled content products. A federal steering committee will support "Ameri-
ca Recycles Day" activities at government facilities. For more information, contact
George Mohr at 410-965-4387.
NOV. 18-20,1997
THE NATIONAL MARKETPLACE FOR THE
ENVIRONMENT
Washington, DC
Conference and trade show devoted to the
marketing of environmental products,
programs, and services to federal, state,
and local governments. Contact: 800-334-
3976.
DEC. 3-5,1997
3RD ANNUAL SERDP SYMPOSIUM
Washington, D.C.
Technical sessions and information on
FY99 solicitation process and funding
opportunities, for Strategic Environmen-
tal Research and Development Program.
Contact: SERDP Support Office, 703-736-
4548.
LIST OF ACRONYMS
CERCLA Comprehensive Emergency
Response, Compensation, and
Liability Act
DOD Department of Defense
DOE Department of Energy
EPA Environmental Protection
Agency
EPCRA Emergency Planning and
Community Right-To-Know
Act of 1986
FFCA Federal Facilities
Compliance Act
FFEO Federal Facilities
Enforcement Office (EPA)
NASA National Aeronautics and
Space Administration
NPL National Priorities List
RCRA Resource Conservation and
Recovery Act
SDWA Safe Drinking Water Act
SEP Supplemental
Environmental Project
TRI Toxics Release Inventory
USDA U.S. Department of
Agriculture
United States Environmental
Protection Agency (2261)
Washington, DC 20460
Official Business
Penalty for Private Use $300
BULK RATE
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EPA
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