SEPA
ISSUE #12
United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
(2261 A)
an environmental bulletin for federal facilities
EPA300-N-01-011
Fall 2001
VA's Self-Disclosure of UST Violations Results in Significant
Waiver of Potential Penalties and an Innovative Settlement
The Department of Veterans Affairs
(VA) and EPA have resolved multiple
underground storage tank (UST) viola-
tions at more than a dozen VA facilities
that VA had self-disclosed to EPA under
the Agency's "Audit Policy" (see related
article below). The vast majority of the
UST violations qualified for complete
penalty mitigation because VA's self-dis-
closure for these tanks satisfied the nine
criteria of the Audit Policy. Twelve tanks
could not meet the nine criteria and
thus failed to qualify for such a waiver.
Two other tanks met the criteria for
penalty mitigation but EPA found that
significant cost savings had accrued
from the delayed compliance. VA has
agreed to pay a penalty of $17,578 for
the 14 tanks. Had EPA inspected and
discovered the violations at the nearly
50 UST systems that VA self-disclosed,
thereby eliminating the benefits of the
Audit Policy, the maximum penalty that
could have been assessed would have
been dramatically higher.
At issue was VA's compliance with the
December 1998 federal tank upgrade and
closure requirements. By letter dated
January 22, 1999, VA self-disclosed that
approximately 50 tanks at its facilities
located in nine different states had poten-
tially violated these requirements. EPA's
review of the self-disclosure, along with
subsequent information VA supplied,
demonstrated that VA had self-identified,
disclosed, and corrected many of the com-
pliance problems in a timely fashon.
Accordingly, the vast majority of the
tanks qualified for complete penalty miti-
gation under the Audit Policy. Only 14
tanks were assessed a penalty.
"VA self-disclosed these violations in a
manner which maximized the benefits of
the Audit Policy. Further, VA's coopera-
tion during our review of the information
demonstrates how federal facilities and
EPA can work together to achieve full
compliance and increase protection for
human health and the environment with-
out costly and adversarial litigation,"
stated Craig Hooks, Director of EPA's
Federal Facilities Enforcement Office.
Another innovative part of the settle-
ment was EPA's use of a compliance
agreement to simultaneously initiate and
conclude the enforcement action. This
approach eliminated the need for multi-
ple successive administrative filings that
significantly expedited the settlement,
thereby keeping transaction costs to a
minimum.
For more information, contact Dan
Drazan at 202-564-2328.
Inside
2 Building Environmental
Leadership
3 Management of FUDS
4 Park Service EMRs
5 Army Officer Exchange Program
6 Conferences
7 TXP3 GBOF Initiative
8 Hazardous Waste Docket
9 ENERGY STAR
10 Technical Work
11 The Hammer
EPA's Efforts to Encourage Voluntary
Self Disclosure and Compliance
Often when EPA investigates a viola-
tion, it discovers facility staff were
aware of the problem - or should have
been - and in some cases were in the
process of developing an appropriate rem-
edy when a regulator discovered it during
an inspection. Discovery of serious viola-
tions during an inspection can mean sub-
stantial penalties and, in some cases,
harm to careers. There is a better way.
EPA has in place a program, utilized by
few federal facilities, which can help.
Effective facility audit systems are criti-
cal to maintaining compliance and allow
for self disclosure of violations to take
advantage of EPA's Audit Policy. The
prompt self-disclosure and correction of
violations is in the interest of EPA, the
regulated facility, and the environment.
On April 11, 2000, EPA's revised final
policy on Incentives for Self-Policing: Dis-
covery, Disclosure, Correction and Pre-
vention of Violations (the Audit Policy)
was published in the Federal Register.
This final Audit Policy was developed
with input from states, public interest
groups, U.S. Department of Justice, and
the regulated community. In drafting the
revisions, the Agency benefitted from five
Continued on page 5
Printed on Recycled Paper
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Building Environmental Leadership in Region X
EPA Region X, Washington State
Department of Ecology, and the Fed-
eral Network for Sustainability hosted a
workshop entitled, "Federal Environ-
mental Leadership: Environmental
Management Systems" on August 23-24,
2001, in Seattle, Washington.
The workshop was attended by 92 fed-
eral, state, and local personnel interested
in environmental management systems
and environment leadership. Topics
ranged from Sustainability to ISO 14001,
and included cases studies from many of
the federal agencies in Region X.
In addition, the "Greening the Govern-
ment" Executive Orders were discussed,
including: E.O. 13148: Leadership
Through Environmental Management,
E.O. 13101: Greening the Government
Through Waste Prevention, Recycling,
and Federal Acquisition, E.O. 13123: Effi-
cient Energy Management, E.O. 13149:
Fleet Fuel, and E.O. 13150: Federal Wor-
force Transportation.
The keynote speaker was Admiral Bill
Center (retired). Mr. Center gave a talk
on "Building Environmental Leadership,"
including a top ten list on getting your
boss to be an environmental leader, which
was extremely well-received by partici-
pants. Region X again thanks Mr. Center
for taking the time to participate and
share his valuable knowledge and insight.
It was one of the highlights of this two-
day workshop.
UpcomingEvents
December 11,2001
Environmental Management for
the 21st Century
Kansas City, KS
Contact: Diana Jackson, EPA, 913-551-7744
December 12,2001
Military Environmental
Working Group Meeting
Kansas City, KS
Contact: Steve Scanlon, Army Region
816-983-3445
Building Environmental Leadership
By Bill Center
Why leaders, not managers?
Managers: Plan & budget, organize &
staff, control & problem solve.
Managers produce predictability &
order.
Leaders: Establish direction (vision),
align people & communicate, motivate
& inspire.
Leaders produce change.
Clearly we need BOTH leaders and
managers.
How do we "embed change in the culture?"
By how these questions are answered:
Why do we... ?
What do we reward?
What do we punish?
Who do we promote?
How do we handle bad news?
To effectively lead an organization
through change you need:
1. To overcome inertia and complacency
with sense of urgency.
2. A clear vision of where you're headed.
No vision = no direction.
3. A guiding coalition of senior leaders.
No stagnation at the top.
4. Collect some easy and early victories.
Consolidate gains, evaluate, move
forward.
5. Work to embed the change in your
corporate culture.
Reasons we fail at implementing
change:
1. No vision or sense of urgency.
2. Senior leaders don't buy in.
3. Under-communicating.
We under-communicate by a factor of
10... or even 100.
Figure out how to get the message from
top to bottom in the organization.
Remember: "Perception IS reality."
4. Allowing obstacles to block progress.
You anticipated obstacles at the out-
set... when you bump into one,
remember, you knew it was coming...
don't allow it to become an excuse for
not achieving your vision.
REC,
Ten things you can do to get your boss directly involved as an
environmental leader:
1. Set up a meeting for your boss with top regulators (to review plans, issues of mutual concern,
etc.).
2. Arrange a tour or visit by dignitaries, especially members of Congress, Senators.
3. Win an environmental award ... get the boss's picture in the paper.
4. Bad press. A good motivator to get the boss directly involved. May be worth taking a little heat
to focus boss's attention.
5. Good press ... not as painful as bad press ... may not be as effective either. But if the boss
gets the credit, he/she will likely want to learn more about how they did it.
6. Make a direct appeal. Don't bring problems to the boss ... bring solutions. Know your stuff. Do
your homework.
7. Use the budget process. Show the boss how to achieve "cost avoidance" by making " invest-
ments" in environmental programs.
8. Pressure from above is sometimes a good thing ... maybe you can arrange for your boss to get
some pressure from his/her boss.
9. Present a comprehensive plan to the boss for approval ... then turn it into the "boss's plan."
It's amazing what you can accomplish when you don't worry about who gets credit.
10. Sign up your boss to give a speech!
You learn to be a leader by being one.
2 FEDFACS
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News
Successful Partnering on
Management of Formerly
Used Defense Sites
The Kansas Department of Health and
Environment, the Kansas City District of
the U.S. Army Corps of Engineers (KC
COE), and EPA Region VII improved com-
munications and developed working rela-
tionships during an intensive effort to
develop a Management Action Plan
(MAP) for Formerly Used Defense Sites
(FUDS). This pilot project was initiated
as a result of a finding by the FUDS
Improvement Work Group, a national
multi-agency work group organized to
address problems with the Army's FUDS
program, which indicated that regulatory
coordination was lacking in program
implementation.
Kansas was one of four states chosen
for the pilot and to date is the only state
to have successfully completed the MAP
process with full participation. The work
began in March 2001, with very little
structure or guidance regarding the prod-
uct to be developed. All three parties met
extensively to communicate each agency's
requirements for the MAP. Through their
cooperation and industry collaboration, a
MAP document has been developed that
will be a great reference tool and future
planning tool for coordinating work at
FUDS in Kansas.
The MAP is a living document, and
will be updated annually as part of the
ongoing efforts to improve the FUDS
process. The agencies celebrated the first
year of the MAP's completion on Novem-
ber 2, 2001 at the Region VII office.
EPA Region II Outdoor
Shooting Range Initiative
Outdoor shooting ranges provide recre-
ational facilities for millions of shooting
sports enthusiasts in the United States as
well as provide an area for training of law
enforcement officers. Recently, there has
been a growing concern about the poten-
tial negative environmental and health
effects of range operations. In particular,
there is concern about potential risks
associated with the historical and contin-
ued use of lead shot and bullets at out-
door ranges.
This concern is not unfounded. An esti-
mated 9,000 non-military outdoor ranges
exist in the United States, collectively
shooting millions of pounds of lead annu-
ally. Many are owned by state, county,
and municipal governments.
Since the mid-1980s, citizen groups
have brought several lawsuits against
range owners and have urged federal and
state agencies to take action against own-
ers/operators of outdoor shooting ranges.
The citizen groups argued that range
owners improperly managed discharged
lead bullets and shot. Federal courts have
supported parts of these suits, requiring
range owners/operators to clean up lead-
contaminated areas. Concurrent with the
increased citizen suit activity, EPA, the
Centers for Disease Control and Preven-
tion, and a large number of states have
identified human exposure to all forms of
lead as a major health concern in the
United States.
To manage lead, many owners and
operators have successfully implemented
Best Management Practices (BMPs) at
their ranges. These range owners and
operators have realized many benefits
from sound lead management including:
• stewardship of the environment, nat-
ural resources and wildlife,
• improved community relations,
• improved aesthetics of the range/good
business practices,
• increased profitability through recov-
ery/recycling lead, a valuable and
finite resource, and
• reduced public scrutiny.
Shooting sport organizations (e.g.,
National Rifle Association (NRA), the
National Shooting Sports Foundation
(NSSF)) promote lead management
throughout the United States. These
organizations have researched different
methods to effectively address potential
and actual lead mobility and exposure
without detracting from the enjoyment of
the sport. The NRA and NSSF strongly
encourage range owners/operators to
develop and implement a BMP program
as recommended by EPA's Best Manage-
ment Practices for Lead at Outdoor Shoot-
ing Ranges. By implementing appropri-
ate lead management at outdoor shooting
ranges, range owners and operators may
reduce the environmental and health
risks associated with lead deposition,
meet legal requirements, and realize
quantifiable benefits.
The Best Management Practices for
Lead at Outdoor Shooting Ranges man-
ual provides owners/operators of outdoor
rifle, pistol, trap, skeet, and sporting clay
ranges with information on lead manage-
ment at their ranges. This manual serves
as a reference guide and presents BMPs
available to shooting ranges. The prac-
tices have been demonstrated to reduce
lead contamination and may be economi-
cally beneficial to the range owner/opera-
tor. Since each range is unique in both the
type of shooting activity and its environ-
mental setting, site-specific solutions are
not provided in the manual. Rather, a
range owner/operator may use this man-
ual to identify and select the most appro-
priate BMP(s) for his facility. Other infor-
mation on environmental aspects of
management at outdoor shooting ranges
can be found in the NSSF's Environmen-
tal Aspects of Construction and Manage-
ment of Outdoor Shooting Ranges.
The BMP manual may be viewed or
downloaded at http://www.epa.gov/
region2/waste/leadshot. If you would like
a free hard copy of the BMP manual,
please e-mail Leadshot.Region2@epa.gov.
For more information, please contact
George Meyer or Edward Guster at 212-
637-4145.
Continued on page 4
FEDFACS 3
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NEWS
Continued from page 3
Greening the Supply Chain
at Federal Facilities
A report recently presented to Congress
by the General Accounting Office (GAO),
investigated the compliance of federal
facilities with Section 6002 of the
Resource Conservation and Recovery
Act (RCRA). Federal facilities are
required by RCRA §6002 and Executive
Order 13101 to establish programs to
purchase environmentally preferable
and biobased materials. Also, the Fed-
eral Acquisition Regulations, or FARs,
were amended in 2000 to require agen-
cies to demonstrate compliance within
their contracts by requiring the procure-
ment and use of recycled products desig-
nated by EPA and the consideration of
environmentally preferable products.
The GAO report centered on the four
largest purchasers, the Departments of
Defense and Energy, the General Services
Administration (GSA), and the National
Aeronautics and Space Administration.
These agencies account for 85 percent of
the $200 billion spent each year on prod-
ucts and services. These agencies
reported that their procurement practices
had not changed to increase the purchas-
ing of recycled content and biobased prod-
ucts. Obstacles to compliance include lack
of purchasing tracking by facilities, fail-
ure to inform and educate all staff of
requirements, and deterioration of cen-
tral purchasing due to the proliferation of
government credit cards.
EPA representatives encountered all
these issues while checking for compli-
ance at federal facilities. EPA Region III
conducted close to 20 inspections for com-
pliance with RCRA §6002 and found that
most of the facilities are not complying.
One additional obstacle is the confusion
concerning the relationship between the
facilities and GSA. Although GSA pro-
vides many varieties of an item for pur-
chase, it is up to the facility to choose the
compliant item. EPA and the White
House Task Force on Recycling are
presently evaluating new strategies to
increase compliance and the purchasing
of these recycled products.
Information on all products required
for compliance, including definitions,
specifications, and suppliers, can be
found on EPA's Comprehensive Pro-
curement Guidelines page at http://
www.epa.gov/cpg/.
For more information, contact Mike
Giuranna, EPA Region III, at 215-814-
3298, or Diane Dolson at 215-814-3304.
National Park Service
EMRs in Region VI
In 1998, EPA conducted an environmen-
tal management review (EMR) within
the National Park Service (NFS). This
EMR was part of a comprehensive tech-
nical assistance effort by EPA to
enhance regulatory compliance within
the Department of the Interior (DOI).
In August 2000, a final EMR report
was published by EPA, which described
the EMR process, explained the scope of
the EMR, and provided EPA's findings and
recommendations. This report, titled "An
Environmental Management System
Review of the National Park Service:
Based on the Code of Environmental Man-
agement Principles" gave EPA Region VI
the incentive to conduct a National Park
Service Initiative as a follow up to the ini-
tial EMR conducted in 1998.
During January 2001, letters were
sent to several national parks located in
the states within the jurisdiction of
Region VI inviting
them to participate
in the EMR
process. Three NFS
facilities responded
positively and an
agreement was
reached for Region
VI to conduct
EMRs during the
year. The EMR
team consisted of
Joyce Stubblefield
(Federal Facilities
Program Man-
ager), Bob Clark,
Jana Harvill, and
Gary Chiles (SAIC
contractor).
The first NFS EMR was conducted at
the Lyndon B. Johnson National Histor-
ical Park. The second NFS EMR was
conducted at the San Antonio Missions
National Historical Park, located in San
Antonio, Texas. The third NFS EMR was
conducted at the Padre Island National
Seashore.
The environment is one of the pri-
mary strengths of the NFS culture,
which promotes the protection of natural
resources, historical sites, and endan-
gered species. This characteristic will
serve NFS well in its efforts to develop
and implement environmental manage-
ment systems to enhance the NPS's
environmental performance both as a
whole and at specific parks.
EPA Region VI EMR
Recognitions
FAA, Oklahoma City, OK
USPS, Houston, TX
BIA, Albuquerque, NM
DOE, SPR, TX and LA
EPA Laboratory, Houston, TX
FDA, NCTR , Jefferson, AR
USD A, ARS, College Station and
Kerrville, TX
Bureau of Engraving and Printing, TX
Corps of Engineers, Fort Worth and Lake
Whitney, TX
NFS, LBJ, Johnson City, TX
FEMA, TX
EPA Region VI EMR Recognition Ceremony
Left to right, back to front: Colonel Freeman, USAF, Phil
Smith, USDA-ARS, Doug Lipka, EPA Lab, Cody Partridge,
FDA, Keith Eddins, FAA, Bill Bozzo, DOE-SPR, Colleen
McKinney, BEP, Sam Coleman, EPA, and Joyce Stubblefield,
EPA.
4 FEDFACS
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Region VII: Army Officer
Exchange Program
In the Army's Training with Industry Pro-
gram, officers develop higher level man-
agerial techniques, interact with environ-
mental matters that affect the military,
and gain an understanding of the rela-
tionship of industry to specific functions
of the Army. Once an officer is integrated
back into the Army organization, he/she
uses this information to improve the
Army's ability to interact and conduct
business with industry.
Captain Daniel Laurelli is assigned
to EPA Region VII through August 2002,
beginning with a rotation in the Federal
Facilities Program. Captain Laurelli
has been in the Army for seven years
with the Chemical Corps (Nuclear, Bio-
logical, and Chemical Officer). He has
served as the Chemical Officer of the
55th Medical Group (Ft. Bragg) and the
Aviation Brigade of the 3rd Infantry
Division (Mech) (Hunter AAF). Addi-
tionally, he served as a platoon leader
and executive officer in the 101st Chem-
ical Company (Ft. Bragg) and comman-
der of Headquarters and Headquarters
Company Aviation Brigade, which
included a six month rotation in Bosnia
in support of peacekeeping operations.
Captain Laurelli's special duties
included Team Leader of the 1st and
2nd Patient Decontamination Support
Team and Aviation Brigade Unit Move-
ment Officer.
Captain Laurelli can be reached at
laurelli.daniel@epa.gov.
Region VI Federal Facilities
Compliance Status Report
The primary goal of the EPA Federal
Facilities Compliance Program is to
ensure that federal agencies achieve com-
pliance rates that meet or exceed those of
industrial and major municipal facilities.
To help ensure this goal, FFEO distrib-
utes quarterly Environmental Compli-
ance Status Reports to twenty-eight fed-
eral agencies.
To further this effort, EPA Region VI
is developing a report to communicate
more detailed federal facility environ-
mental compliance data within Region
VI. The 2000-2001 Region VI Federal
Facilities Compliance Status Report is
expected to be distributed by the end of
October 2001. This report is based on
data received from each of the major
EPA program areas. Major sections of
the report include: listings of facilities
in significant noncompliance, 1999
major federal facilities multi-media
inspections, inspections and enforce-
ment actions, base closure updates, and
a status summary of federal facilities on
the National Priorities List. A com-
ments/concerns page is also included to
provide the federal facilities an opportu-
nity to voice any inaccuracies or dis-
crepancies with the report. EPA Region
VI is distributing these data as a means
of fostering communication among EPA,
states, and other federal entities in
Region VI.
For more information please contact
Gabe Gruta at 214-665-2174.
AUDIT POUCY
Continued from page 1
years of experience implementing the pol-
icy. The policy was designed to encourage
compliance by providing greater incen-
tives for facilities to self-police and correct
any violations discovered during volun-
tary facility audits.
Facilities that self-report violations dis-
covered through an environmental audit
or a compliance management system that
reflects the entity's "due diligence in pre-
venting, detecting, and correcting viola-
tions" may have the gravity-based penalty
waived. The cost savings component of the
penalty is not affected. If the cost savings
is "insignificant" this portion of the penalty
may also be waived. Facilities where the
"disclosing entity does not detect the viola-
tion through systemic discovery" but
which meet the other eight policy condi-
tions will have the gravity-based compo-
nent of the penalty reduced by 75%. The
Audit Policy describes procedures the dis-
closing entity must follow.
As noted above, to be eligible for the
full waiver of the gravity component of
the penalty the facility must have discov-
ered the self-reported violation through
an environmental audit or a compliance
management system. However, EPA can
still provide substantial penalty reduc-
tion for those able to meet the following
requirements.
• Discovery must have been "volun-
tary" and not discovered because of
an activity required by a regulation or
permit.
• Disclosure of the violation must be
made within 21 days of discovery,
unless a regulation requires disclo-
sure sooner.
• Discovery and disclosure must be
made independent of EPA, state, or
third party plaintiff.
• The disclosing entity must expedi-
tiously correct the violation and rem-
edy any harm caused by it.
• Steps must be taken to prevent recur-
rence of the violation. The same or
similar violations must not have
occurred within the past three years.
• The facility must fully cooperate with
EPA by providing required informa-
tion.
Some violations, such as those that
present an imminent and substantial
endangerment to public health or the
environment or result in serious harm,
are not eligible. EPA can use the Audit
Policy to provide flexibility in working
with regulated entities to reach impor-
tant environmental and public health
goals.
While encouraging voluntary compli-
ance and offering incentives to self-
report, the compliance monitoring and
enforcement program will remain an
important option. The expeditious dis-
covery and correction of violations has
always been in the interest of EPA and
regulated federal facilities. The Audit
Policy provides strong incentives for
EPA and federal facilities to work
closely in correcting violations and
improving management systems to help
prevent future problems.
For more information, visit http://es/
epa.gov/oeca/ore/apolguid/html, see Fed-
eral Register 65, 19618 (April 11, 2000),
or contact David Levenstein at 202-564-
2591.
FEDFACS 5
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Conferences
Third Annual Alaska Forum
on the Environment Held
The third annual Alaska Forum on the
Environment was held in Anchorage on
February 5-8, 2001. Over 1,000 people
from all around Alaska and the lower 48
states participated. The Forum provided
over 100 educational breakout sessions
and meetings.
The Alaska Forum on the Environment
greatly depends on the generosity of its
sponsors. The 2001 Forum was a success
thanks to several platinum level sponsors,
including the Environmental Protection
Agency, Federal Aviation Administration,
Alaska Inter-tribal Council, and nine other
government and private organizations.
Speaker Highlights
A wide variety of topics were covered dur-
ing the forum, including subsistence issues,
public health and epidemiology, environ-
mental justice, fish and wildlife manage-
ment issues, hazardous waste manage-
ment, and many more. Keynote speakers
for the event included Robert F Kennedy,
Jr., Jean-Michel Cousteau, Robert Pojasek,
John Nance, and Andrea Carmen.
Robert F. Kennedy, Jr. spoke passion-
ately of the value of environmental protec-
tion as a critical element of assuring true
long-term community development. "We
have an obligation to the next generation.
Human beings have other appetites
besides money," he said during his speech.
"If we don't feed them. We won't grow.
Everyone has to wake up and say, 'Is today
going to be about community, or is it going
to be about me?'"
Kennedy, an attorney for Hudson
Riverkeeper and the Natural Resources
Defense Council, spoke about the environ-
ment and the economy. He said restric-
tions to protect the environment are an
investment in the future while environ-
mental pollution is deficit spending. "It
makes a few people rich while making
everyone else poor," he said.
Jean-Michel Cousteau, son of the late
Jacques Cousteau, emphasized the inter-
connectedness of all things as well as his
love and concern for the water planet.
Robert Pojasek discussed the methods for
communities to reduce waste and setting
a goal of zero waste. John Nance related
his organizational and team building
experiences to how environmental success
can be achieved by working together.
Andrea Carmen, Executive Director of
the International Indian Treaty Council,
spoke of the contributions indigenous peo-
ple have made to the national and inter-
national policies addressing human
responsibilities and environmental pro-
tection.
Native Elders Walter Austin and
Howard Luke also presented at the forum.
Austin outlined his concerns for timber har-
vesting in the Tongass, development of the
Arctic National Wildlife Refuge, and the
declining fish returns. Luke spoke of his
concerns and hopes that we continue to
work together as one people, both young
and old.
Alaska Forum 2002
The fourth annual Alaska Forum on the
Environment will be held February 4-8,
2002. The Planning Board is interested in
hearing ideas to help improve this major
event. Please send your suggestions by e-
mail to info@akforum.com. The forum
agenda, registration, and hotel informa-
tion will be available online at www.
akforum.com.
Pollution Prevention
Bonanza @ Region VI
Region VI P2 Conference
EPA Region VI's Regional Pollution Pre-
vention Conference was held May 24-25,
2001. The theme was "Don't Permit Pollu-
tion: Prevent It! Tools and Techniques for
Compliance Assistance Through Pollution
Prevention." The conference was sponsored
by EPA Region VI and co-sponsored by the
National Pollution Prevention Roundtable,
University of Texas at Arlington, Arkansas
Department of Environmental Quality,
Louisiana Department of Environmental
Quality, New Mexico Environmental
Department, Oklahoma Department of
Environmental Quality, and Texas Natural
Resource Conservation Commission.
This southwest regional conference
focused on how pollution prevention (or
reduction of waste at the source) can be
used to help companies and facilities meet
environmental standards and regulations
and often exceed those requirements. The
conference breakout sessions were inter-
active and participants were encouraged
to share ideas, needs, and concerns with
panelists and fellow participants. Break-
out session presenters were from EPA
Headquarters, EPA Region VI, federal,
state, and local agencies, and industry.
The event gave facilities access to pollu-
tion prevention professionals and
resources to assist them in achieving and
exceeding environmental compliance
standards, and promoted pollution pre-
vention as the best environmental and
corporate strategy. The conference ended
on a high note with music, fun, and enter-
tainment, including twists on "Survivor,"
"Jeopardy," and the "Weakest Link."
MVP P2 Award Winners:
Equistar Chemicals, L.P. Plant Reliability
Improvement Program
City of Fort Worth Pretreatment Program:
Pretreatment P2
Dyess Air Force Base: Clean Dyess 2000
P2 Roundtable Individual
Recognitions:
Eli Martinez, U.S. EPA Region VI
Jeff Voorhis, Texas, TNRCC
6 FEDFACS
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National P2RX Meeting
EPA Region VI hosted the National Pol-
lution Prevention Information Resource
Exchange (P2RX) Meeting on May 21-
23, 2001. The P2RX Regional Centers
provide access to pollution prevention
information, research, and expertise.
The regional centers offer specialized
expertise and are independent from reg-
ulatory agencies. Information on the
Regional Centers can be found at
www.p2rx.org.
Texas P3 Spring Meeting
EPA Region VI hosted the Texas Pollu-
tion Prevention Partnership (P3) meet-
ing on May 23, 2001. The partnership
meeting was held in Dallas to take
advantage of the EPA Pollution Preven-
tion Conference being held during the
same week.
The Texas Pollution Prevention Part-
nership members are: Department of
Defense, Texas Natural Resource Con-
servation Commission, Texas National
Guard, NASA - Johnson Space Center,
the U.S. Coast Guard, and DOE Strate-
gic Petroleum Reserve. The highlight of
this meeting was the participation of
Region VI states and the attendance of
special guests, Chris Cambell, New
Mexico State University, Bill Hayen,
USPS Southwest Area, Phil Smith,
USD A Agricultural Research Service,
and Jim Edward and Karin Leff, EPA
Headquarters.
National P2 Crossfeed Forum
On August 23, 2001, Dr. Thomas Rennie,
U.S. Air Force, Regional Environmental
Office, Dallas, Texas, hosted the
National Pollution Prevention (P2)
Crossfeed Forum in San Antonio, Texas.
Attendees at the meeting were represen-
tatives from Department of Defense P2
partnerships nationwide, EPA Region
VI, and a National Park Service visitor.
These meetings are timed with the
Annual Joint Service P2 Conference and
Exhibition and the National P2 Round-
table meeting.
Texas P3 Summer Meeting
The Texas Pollution Prevention Partner-
ship met on August 24, 2001. The Texas
TXP3 GBOF Initiative
The Green Base of the Future (GBOF) is an initiative under the Texas Pollution Prevention Part-
nership (TXP3). When completed, the GBOF will be a multi-service guide that enhances mis-
sion readiness and achieves significant cost savings by fully integrating best operating practices
and operational requirements. The GBOF attempts to measure an installation's "greenness" quo-
tient.
The TXP3 has approached the military service environmental centers to help cultivate ser-
vice headquarters-level interest in the development of this tool. TXP3 expects to export the final
GBOF product to service leadership for use throughout the nation.
The fully developed GBOF product will include several internet-accessible components,
including self-assessment checklists known as the Green Assessment Tool (GAT). Future addi-
tions will include supporting resources and success stories.
The GAT has undergone preliminary testing and was modified accordingly. TXP3 is currently
determining which partners can offer an installation and funds to test the revised tool. Currently,
Ft. Sam Houston is testing the GAT within their Environmental Resource Management Office. If
the trial results are favorable, they may be willing to run an installation-wide trial.
TXP3 members see the potential for GBOF to be linked with environmental management sys-
tem (EMS) initiatives. The GAT will show how well environmental and pollution prevention issues
are integrated into base operations, revealing where an EMS needs strengthening. GBOF does
not duplicate internal environmental compliance audit protocols, which assess environmental
compliance. A well developed EMS and GBOF will point the way beyond compliance, through a
fully implemented pollution prevention program that reduces costs and liabilities.
Discussions early in GBOF development showed that TNRCC may be willing to reduce an
installation's environmental compliance requirements if they could demonstrate a commitment
to pollution prevention. More recently, S.B. 2997 has directed the TNRCC to implement a regula-
tion by December 2001 that would provide incentives to facilities that implement an EMS.
For more information, visit www.3di.com/gbof or contact Barton Ives, USAEC Central
Regional Environmental Office, at bart.o.ives@usace.army.mil.
P3 meeting was hosted by Fort Sam
Houston with representatives from
EPA, the Texas Natural Resource Con-
servation Commission, and other fed-
eral agencies. The Partnership is plan-
ning a retreat in November 2001.
P2 at Federal Facility
Hospitals
Region IX Federal Facilities and Pollu-
tion Prevention (P2) staff hosted a work-
shop on September llth, focused on pol-
lution prevention for federal facility
hospitals. With the day's tragic events,
attendance was extremely limited. A few
speakers and attendees, whose return
flights were canceled, decided to stay and
meet for a half-day session.
Tom Murray from EPA Headquarters,
Office of Pollution Prevention and Toxic
Substances provided updates on Hospi-
tals for a Healthy Environment efforts
targeting persistent, bio-accumulative,
and toxic chemicals. Ann Melamed of the
American Nurses Association discussed
environmentally preferable purchasing.
Claire Yee of Tripler Army Medical Cen-
ter in Hawaii highlighted their facility's
efforts to implement P2, especially tar-
geting mercury, food waste, solid waste,
and xylene. Stephanie Davis of Waste
Reduction Remedies and Sutter Antioch
Hospital provided information on oppor-
tunities to reduce medical or "red bag"
waste.
Larry Woods, Region IX's Federal
Facilities Coordinator, presented infor-
mation on environmental management
reviews and Eileen Sheehan, P2 Team,
highlighted P2 opportunities and dis-
tributed information on environmental
requirements for federal healthcare
facilities.
FEDFACS 7
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Hazardous Waste Docket
Federal Agency Hazardous
Waste Compliance Docket
Updated: The Region VI
Approach
In accordance with Section 120 (c) of
the Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA), EPA is required to take
steps to ensure that it receives informa-
tion necessary to assess the threat to
human health and the environment. Fur-
thermore, Executive Order 12580 dele-
gates the responsibility for the prepara-
tion of this information to federal
agencies. The Federal Agency Hazardous
Waste Compliance Docket contains infor-
mation about federal facilities engaged in
hazardous waste activity or facilities from
which hazardous substances may have
been or may be released.
EPA Regional Docket Coordinators
work with EPA Headquarters and federal
facilities in their regions on Docket report-
ing and follow-up. For example, EPA
Region VI has informed federal facilities
in their region about the Federal Agency
Hazardous Waste Compliance Docket and
has reiterated the importance of federal
facilities reporting to the Docket. The pre-
ambles and letters were mailed to thirty
facilities on the Docket throughout the
Region. Region VI asked the facilities to
provide currently available information
EPA can use to assess the disposition of
the facilities under CERCLA.
The Docket contains information sub-
mitted to EPA by federal facilities under
Sections 3005, 3010, and 3016 of the
Resource Conservation and Recovery Act
(RCRA) and Section 103 of CERCLA.
• Section 3005 of RCRA establishes a
permitting system for hazardous
waste Treatment, Storage, and Dis-
posal (TSD) facilities.
• RCRA Section 3010 requires waste
generators, transporters, and TSD
facilities to report hazardous waste
activities.
• RCRA Section 3016 requires federal
facilities to submit to EPA biennially
an inventory of owned or operated haz-
ardous waste sites.
• Section 103(a) of CERCLA requires
that the National Response Center be
notified of a release.
• Section 103(c) of CERCLA requires
reporting to EPA the existence of
known or suspected releases of haz-
ardous substances at facilities.
If a federal facility submits one of
these documents or submits this type of
information to EPA, the facility will be
added to the Docket.
All facilities listed on the Docket will
undergo site evaluation activities, such as
preparing a Preliminary Assessment (PA)
report and, when appropriate, a Site
Inspection report. EPA has determined
that a PA should provide the required
information to assess the disposition of the
facility in reference to CERCLA.
The Docket will be available for public
inspection at reasonable times. Every six
months, the EPA Administrator will pub-
lish in the Federal Register a list of the
federal facilities which have been added
to, deleted from, or corrected in the
Docket. This publication will also indicate
where in the appropriate regional EPA
office additional information may be
obtained with respect to any facility on
the Docket. The fourteenth update of the
Federal Agency Hazardous Waste Com-
pliance Docket was released in the Fed-
eral Register on October 2, 2001, and
details additions, deletions, and correc-
tions to the previous Docket update. The
current number of facilities on the Docket
is 2,214.
For more information, contact the
National Docket Coordinator at 202-564-
2468. In Region VI, contact Philip Ofosu
at 214-665-178 or visit the FAHWCD
website at www.access.gpo.gov/su_docs/
fedreg/aOOl 229c.html.
Region X Moves Docket
Sites Forward
The Office of Environmental Cleanup's
(ECL) Federal Facility Site Assessment
Program began an initiative to ensure
adequate assessment and cleanup of
federal facilities listed on the Federal
Agency Hazardous Waste Compliance
Docket. Currently, there are numerous
sites on the Docket for which federal
agencies have failed to submit required
Preliminary Assessment (PA) or Site
Inspection (SI) reports for Hazard Rank-
ing System scoring. These sites, some of
which may be high risk or NPL-caliber,
have not been evaluated by EPA, nor
addressed by the responsible federal
agency. In some cases, sites have
remained on the Docket with an unre-
solved status and no EPA oversight for
years. Agencies have not submitted
reports due to limited funding, compet-
ing priorities, or lack of interest.
Region X is conducting the "Moving
Docket Sites Forward" initiative by
working directly with federal agencies
in all Region X states to gain firm com-
mitments for PA and SI report submis-
sion. Staff will emphasize the impor-
tance of report submission and work to
establish mutual agreements. With
reports in hand, ECL will evaluate
whether each site requires further site
assessment, cleanup, or other actions.
The end result of this initiative is
that Region X will resolve the status of
all federal facility Docket sites and
make progress in moving high-risk sites
forward. When Congress, the public, or
other stakeholders use the Docket to
track progress at individual sites or the
entire universe of federal facilities, they
will access accurate information that
shows Region X sites are being
addressed.
For more information, contact Debo-
rah Leblang at 206-553-0115.
8 FEDFACS
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Energy
New Energy Programs in
Region VI
Energy efficiency, energy conservation,
and renewable energy are important to
federal facilities not only because they
must all attempt to comply with Execu-
tive Orders. The waste creates air pollu-
tion as well as water pollution. EPA
Region VI is pleased to announce several
new Department of Energy and EPA pro-
grams. These are:
• Energy Star for Industry,
• Combined Heat and Power, which
addresses co-generation and tri-gener-
ation at both large and small scale sys-
tems, and
• Green Power Partnerships, which pro-
motes renewable energy resources by
creating partnerships between federal
facilities, state and local government,
public institutions, private industry,
public utilities, and private residences.
Becoming a steward of the environ-
ment is easy even when resources are lim-
ited. As deregulation begins and renew-
able energy becomes available, new
opportunities open up for federal facili-
ties. Region VI supports these efforts
through a wide variety of outreach efforts,
including assistance in obtaining the
Energy Star Plaque, the highest award
for excellence in energy performance. EPA
Region VI has already assisted the Gen-
eral Services Administration Region VI to
become number one in the United States
in Energy Star Plaques on federal facili-
ties in CY 2000 and will continue its push
for energy excellence.
A recent highlight of Region VI's
efforts include working with the Region
VI states, Arkansas, Louisiana, New
Mexico, Oklahoma, and Texas, to
develop renewable energy support
groups that create new partnerships,
provide technical assistance, and
develop important renewable energy
resources and guidance in creating a
portfolio standard. Region VI continues
to work with Energy Star Buildings and
Green Lights, Energy Star Homes,
Energy Star for Public Institutions, and
Energy Star Purchasing to name a few
programs. For more information on how
to be included in these efforts, contact
the regional support number at 1-800-
887-6063 and visit the website
www.energystar.gov.
For more information, contact Patrick
Kelly, EPA Region VI, at 214-665-7316.
ENERGY STAR, Executive
Order 13123, and You: Tips
for Federal Managers
ENERGY STAR fig-
ures prominently in
Executive Order
13123, Greening the
Government through Efficient Energy
Management. ENERGY STAR can help
federal agencies meet the requirements of
the Executive Order, while saving money.
EPA and the Department of Energy
(DOE) have established ENERGY STAR
for office buildings, homes, K-12 schools,
and over 30 categories of products. The
ENERGY STAR label will be available for
other building types and products in the
coming year.
Become an ENERGY STAR
Executive Order Section 403 (c) requires
agencies to:
• Strive to meet ENERGY STAR criteria
where cost effective for energy perfor-
mance and indoor environmental
quality by the end of 2002.
• Use the ENERGY STAR perfor-
mance rating system for buildings in
general facility audits.
How To Comply: Use EPA's online rating sys-
tem, available at www.energystar.gov, to
evaluate your buildings' energy perfor-
mance using data that you input on each
building's physical attributes, operating
characteristics, and monthly energy con-
sumption. The rating system allows you to
benchmark your buildings on a 1 to 100
scale. The results will help you set energy
performance targets and plan building
upgrades. Buildings that score a 75 or
higher and maintain an indoor air environ-
ment that meets or exceeds industry stan-
dards are eligible to receive the ENERGY
STAR label, the nationally recognized sym-
bol of superior energy performance.
Specific Steps You Can Take
• Benchmark all office buildings and
schools over 5,000 square feet.
• Apply for ENERGY STAR labels for all
buildings that score 75 or better.
• For buildings that score below 75,
develop a plan to upgrade these facili-
ties and improve their performance
rating.
• After upgrades, re-benchmark each
building to measure yearly progress.
Reminder: The Office of Management
and Budget (OMB) requires that agen-
cies report in 2001 the number and per-
centage of buildings that are expected to
meet ENERGY STAR levels and receive
the ENERGY STAR label in FY 2002.
Look for ENERGY STAR When
Leasing Buildings
Executive Order Section 403 (e) directs
agencies to:
• Include a preference for buildings with
the ENERGY STAR label in selection
criteria for acquiring leased buildings.
• Encourage lessors to apply for the
ENERGY STAR label.
• Require new building offers to include
projected energy use data.
• Stipulate the purchase of facility man-
agement systems or energy manage-
Continued on page 11
FEDFACS 9
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TechnicalWork
TNRCC's New Action Levels
for Perchlorate
Texas Natural Resource Conservation
Commission (TNRCC) recently changed
their interim action levels for ammonium
perchlorate. Ammonium perchlorate is
manufactured almost exclusively as the
oxidizer component and primary ingredi-
ent in solid propellant for rockets, mis-
siles, and fireworks. Nationally, perchlo-
rate detections have been confirmed in 17
states. Only three other states, Califor-
nia, New York, and Arizona, have formal
action levels. Last month TNRCC set new
interim action water levels for perchlo-
rate at 4 parts per billion (ppb). The new
ground water cleanup number replaces
the former Texas standard of 22 ppb.
Under the Texas Risk Reduction Pro-
gram (TRRP), which is the new 1998
cleanup rule, the new residential
groundwater cleanup standard is 4 ppb
and the commercial/industrial ground-
water cleanup standard is 7 ppb.
Under TNRCC's old cleanup rule, the
Risk Reduction Rule (RRR), the residen-
tial groundwater cleanup standard is 4
ppb and the commercial/industrial
groundwater cleanup standard is 10 ppb.
Sites already under the RRR had the
option of staying under that rule or
switching to the TRRP.
Longhorn Army Ammunition Plant
has identified perchlorate contamination
in soil, groundwater, and surface water
and is under the RRR. Naval Weapons
Industrial Reserve Plant, McGregor has
identified perchlorate contamination in
on-site groundwater and surface soils and
is under the TRRP.
Region VI Participates in
Development of New Test
Method
Have you ever seen a nasty thick black
cloud of pollution billowing from a smoke-
stack? Of course you have. But, unless
you're familiar with the air enforcement
program, you may not know that there is
a way to determine how opaque that
plume is. There is a test method that EPA
developed many years ago to measure
opacity. Known as Method 9, and found in
Appendix A of 40 CFR Part 60, it is used
to measure how much opacity is associ-
ated with a plume of smoke.
What Is Opacity?
Opacity is a measurement of the amount
of light that is blocked by a medium, such
as smoke or a tinted window. Opacity is
usually stated as a percentage. An opac-
ity of 0% means that all light passes
through, and an opacity of 100% means
that no light passes through. Opacity is
important because it gives an indication
of the concentration of pollutants leaving
a smokestack. The more particles that
are emitted from a stack, the more light
will be blocked, resulting in a higher
opacity percentage.
How Is Opacity Measured?
At present, there are several ways to
measure opacity. The simplest method is
visual observation. Anyone can be trained
and certified to become a Visible Emis-
sion Observer. Federal, state, and local
inspectors, as well as government and
industry staff, have been trained to con-
duct opacity readings to determine if a
source is meeting its federal and/or state
opacity requirements. These people have
been trained to estimate the percentage
of opacity for black and white smoke com-
ing from smokestacks.
EPA adopted standardized training
and certification procedures in Method 9.
"Smoke School" involves a one-day lecture
on the principles and history of opacity
and certification using these procedures.
For certification, black and white smoke is
generated at different opacities for a total
of 50 separate visible emission readings.
Opacities must be within a certain per-
centage of accuracy, for both types of
smoke, for certification to be obtained.
Certification expires after six months.
Is There an Easier Way?
The Environmental Security Technology
Certification Program (ESTCP) is a
Department of Defense (DoD) program
that promotes innovative, cost-effective
environmental technologies through
demonstration and validation at DoD
sites. The ESTCP has approved and
begun work on a project to test a digital
recording and analysis method for opac-
ity determination. This digital opacity
method would be used as an alternate
method to Method 9.
EPA's Emissions Measurement Cen-
ter requested the formation of a scien-
tific advisory group to review and pro-
vide comments during the development
and testing of this new method. The
members are from EPA, the Air Force,
and outside contractors and are consid-
ered to be experts in either digital imag-
ing and/or Method 9. This group will
review test plans to ensure that key
variables are covered in the field work,
define project success, and agree what
conditions must be met to achieve it by
the end of the project.
The kickoff meeting for this group was
held on Monday, April 2, 2001, at Hill
AFB, Utah. The meeting included an
overall project briefing, a review of the
advisory group members and purposes,
and a detailed briefing and demonstration
of the proposed new technology. Represen-
tatives from RTF, NEIC, and Region VI
attended and participated in this meet-
ing. Upcoming meetings will cover the
software used by the digital camera as
well as the development and implementa-
tion of field tests of the camera. Field tests
are currently scheduled for Salt Lake
City, Utah, in early October 2001, and
Augusta, Georgia, in late October 2001.
For more information, contact Ray-
mond Magyar, EPA Region VI, at 214-
665-7288.
1O FEDFACS
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The Hammer
Economic Benefit and Size
of Business Issues in CAA
Enforcement
On October 4, 2001, oral argument was
presented before Chief Administra-
tive Law Judge (ALJ) Susan Biro in the
Clean Air Act (CAA) administrative
enforcement action against the United
States Army, Alaska Garrison, Ft. Wain-
wright. The EPA Complaint alleged vari-
ous CAA violations at Ft. Wainwright's
Central Heating and Power Plant. In
January 2001, EPA filed a Motion for
Accelerated Decision on Liability for the
nine counts contained in the Complaint.
The Army filed its Opposition to the
Motion in February 2001, and EPA filed
its Reply in March 2001.
On July 3, 2001, the Chief ALJ issued
an Order on Complainant's Motion for
Accelerated Decision and on other
motions. The Chief ALJ's Order found no
issue of material fact with respect to liabil-
ity for eight of the nine counts contained in
the Complaint. Thus, while issues remain
regarding the appropriate penalty amount
in the case, at hearing only one count will
be litigated in terms of liability. The Order
also dismissed six of the Army's Affirma-
tive Defenses as they pertain to liability,
but left open the possibility that some of
the Army's Affirmative Defenses may bear
on the amount of the appropriate penalty.
On October 4, 2001, oral argument
was presented on the main issue in this
case, namely whether EPA has the
authority to consider CAA Section 113(e)
penalty factors of "size of business" and
"economic benefit of noncompliance" in
determining an appropriate penalty for a
federal facility violation. EPA's position is
that CAA provides the Administrator
with the authority to consider these
statutorily-mandated penalty factors,
while the Army's position is that the
Administrator has no such authority.
Much of the Army's presentation focused
on the underlying assumptions of the
BEN Model, and also emphasized what it
considers the unique attributes of federal
agencies that make application of the
"size of business" and "economic benefit of
noncompliance" penalty factors inappro-
priate. EPA reiterated that the legal
question currently before the Chief ALJ is
the authority to consider the statutorily-
mandated penalty factors in determining
an appropriate penalty, and that the BEN
Model is not at issue in the case. EPA
acknowledged that federal agencies have
unique characteristics, but argued that
these characteristics could be considered
in determining the appropriate amount of
any penalty and had no bearing on the
underlying legal authority issue before
the court at oral argument. The Chief
ALJ posed difficult questions to counsel
for both EPA and the Army. EPA Region
X and FFEO are jointly managing this
case, and both represented EPA at oral
argument. A decision from the Chief ALJ
is expected in the next few months.
For more information, contact Jeff
Kopf, Region X, at 206-553-1477, or
Andrew Cherry, FFEO, at 202-564-2589.
ENERGY STAR
Continued from page 9
ment services to comply with the
ENERGY STAR requirements of Sec-
tion 403 through GSA schedules 63 I
and 871 II at www.fss.gsa.gov/
environ/h2o-energy-prod.cfm#Office.
ENERGY STAR Products
The Executive Order states that use of
ENERGY STAR labeled products will be
part of the scoring criteria in the OMB
energy scorecard [Sec. 306(1)]. The Order
directs federal agencies to:
• Purchase ENERGY STAR labeled
products, when found life-cycle cost
effective. For products not covered by
ENERGY STAR, purchase products
that are in the upper 25th percent of
energy efficiency as designated by the
Federal Energy Management Pro-
gram (FEMP). [Sec. 403 (b.l)]
• Incorporate ENERGY STAR energy
efficiency levels into guide and project
specifications, as well as into product
specification language developed for
Basic Ordering Agreements, Blanket
Purchasing Agreements, Government
Wide Acquisition Contracts, and all
other purchasing procedures. [Sec.
403 (b.3)]
• Purchase ENERGY STAR and
FEMP designated products from
your federal supply sources. The
Executive Order states that GSA
and the Defense Logistics Agency
(DLA) shall create clear catalogue
listings that designate energy-effi-
cient products in both print and elec-
tronic formats. [Sec. 403 (b)(2)]
GSA and DLA are federal supply sources
of ENERGY STAR and FEMP designated
products. Energy-efficient products can
be purchased through GSA's online pro-
curement system, Advantage!
The Energy Solutions Services and
Products Guide from GSA/FSS is avail-
able at www.fss.gsa.gov/environ.
Other Energy-Efficient Products
ENERGY STAR and FEMP have estab-
lished efficiency levels for other products
not sold through federal supply sources.
Check out Buying Energy Efficient
Products, DOE's federal purchasing
buying guide issued by FEMP. This
binder has a series of product efficiency
recommendations to identify the upper
25th percent in energy efficiency. To
obtain a free copy, contact 1-800-363-
3732 or go to www.eren.doe.gov/femp/
procurement/.
For more information, contact 1-888-
STAR-YES or visit www.energystar.gov.
FEDFACS 11
-------
United States Environmental
Protection Agency (2261 A)
Washington, DC 20460
Official Business
Penalty for Private Use $300
Address Service Requested
LIST OF ACRONYMS
ALJ Administrative Law Judge GBOF
BIA Bureau of Indian Affairs GSA
BMP Best Management Practices KC COE
CAA Clean Air Act LMA
CEMP Code of Environmental MAP
Management Principles NFS
CERCLA Comprehensive Environmental NSSF
Response, Compensation, and
Liability Act OMB
DoD Department of Defense P3
DOE U.S. Department of Energy PA
DOI Department of Interior RCRA
EMR Environmental Management
Review RRR
ESPCs Energy Savings Performance SDWA
Contracts SI
ESTCP Environmental Security TNRCC
Technology Certification Program
FDA Food and Drug Administration TSD
FEMA Federal Emergency Management TRPP
Agency USPS
FUDS Formerly Used Defense Sites VA
GAT Green Assessment Tool
Green Base of the Future
General Services Administration
Kansas City Corps of Engineers
Land Management Agency
Management Action Plan
National Park Service
National Shooting Sports
Foundation
Office of Management and Budget
Pollution Prevention Partnership
Preliminary Assessment
Resource Conservation and
Recovery Act
Risk Reduction Rule
Safe Drinking Water Act
Site Inspection
Texas Natural Resource
Conservation Commission
Treatment, Storage, and Disposal
Texas Risk Reduction Plan
U.S. Postal Service
Department of Veterans Affairs
is published by EPAs Federal Facilities
Enforcement Office.
Joyce Johnson, FFEO, Editor
SciComm, Inc., Layout
To receive FedFacs in the mail, contact:
Federal Facilities Enforcement Office
U.S. EPA (2261A), 1200 Pennsylvania
Avenue, NW, Washington, DC 20044
or Fax: 202-501-0069
Read FedFacs on the Internet
http://www.epa.gov/oeca/fedfac/ann/index.html
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