SEPA
ISSUE #8
United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
(2261 A)
EPA#300-N-99-015
Fall 1999
an environmental bulletin for federal facilities
Compliance Assistance Reviews at
Bureau of Indian Affairs Facilities
EPA recently conducted compliance
assistance reviews of two Bureau of
Indian Affairs (BIA) facilities. The first
occurred in Region 10 at the Wapato Irri-
gation Project in Yakima, Washington.
The second took place in Region 4 at the
Cherokee Agency in Cherokee, North
Carolina. The reviews, conducted under a
1998 Memorandum of Agreement
between EPA and BIA, included a diverse
group of participants, including EPA
Headquarters and Regional representa-
tives, BIA Area and Agency/Project staff,
tribal representatives, and U.S. Depart-
ment of Agriculture personnel.
The goal of the reviews is to identify
site-specific regulatory compliance con-
cerns and opportunities for compliance
assistance. In addition, EPA expects that
many of the specific issues and solutions
identified at these two BIA facilities will
be applicable to other BIA locations and
that the lessons learned can be trans-
ferred BIA-wide.
The project has been exciting and chal-
Inside
2 Guest Spot: Israel Anderson,
TNRCC
3 Two New Executive Orders
4 Compliance with UST
6 EMRs
8 Regional News and Notes
9 Conference Update
11 The Hammer
12 Upcoming Events
lenging for EPA
because it has
involved offering
assistance with tradi-
tional EPA compli-
ance-based issues,
such as hazardous
waste management
and spill planning, as
well as unique envi-
ronmental manage-
ment concerns of
importance to BIA
and tribes. For exam-
ple, at the Wapato
Irrigation Project, non-traditional issues
being addressed include agricultural and
irrigation drainage management prac-
tices that may lessen impacts on surface
water quality and wildlife habitat. At the
Cherokee Agency, these issues involve
oversight of activities where BIA is not
the operator, but faces potential liability
or owns property.
EPA will provide specific compliance
review findings and recommendations for
each facility. EPA will publish draft
reports in fall 1999. Their primary
emphasis will be the identification of
potential improvements and compliance
assistance tools available from EPA and
other sources. For more information
Top left: Unused paints and printing
chemicals collected for one-time disposal,
Warehouse Cherokee Agency. Top right:
Sediment discharge at Wapato Irriga-
tion Project. Bottom: Out of service trans-
former storage area, Wapato Mainte-
nence Complex.
regarding Cherokee, contact Anthony
Shelton at 404-562-9636; for information
on Wapato, contact Michele Wright at
206-553-1747.
[See related story on alleged UST vio-
lations at Wapato, on page 11.]
Printed on Recycled Paper
-------
GuestSpot
TXP3: The Texas Pollution Prevention Partnership
by Israel Anderson, Division Director, Small Business and Environmental Assistance Division, Texas Natural
Resource Conservation Commission (TNRCC)
The Texas Pollution Prevention Part-
I nership (TXP3) was bestowed with
Vice President Al Gore's "Hammer" Award
for its efforts to reduce pollution in Texas.
TXP3 is a collaborative initiative of the
Texas Natural Resource Conservation
Commission (TNRCC), the Department of
Defense (DoD), NASA-Johnson Space
Center, and the Texas Army National
Guard. Its mission is to promote pollution
prevention as the standard way of doing
business for federal facilities by develop-
ing and implementing model initiatives,
building trust, and producing measurable
results. TXP3 boasts numerous successes,
including reductions of nearly one million
pounds of hazardous waste and savings of
over $2.7 million at federal facilities in
Texas.
TXP3 began in 1995 as a result of joint
workshops, discussions, and projects and
was formally chartered in 1997 as the first
alliance of its type in the United States.
The Texas model is inspiring similar efforts
across the nation, including Ohio, Col-
orado, Illinois, New Mexico, Georgia,
South Carolina, New York, Arizona, and
EPA Region 7. The first and largest initia-
tive of its kind, TXP3 has 25 agency mem-
bers and has established itself as the pollu-
tion prevention partnership to be
emulated.
The success of TXP3 is due to broad-
based involvement and a collaborative
approach across many agencies, which has
established a culture of trust. Broad-based
involvement was established early in a
January 1996 workshop held in Austin
that included diverse representatives from
military installations across Texas. Agroup
of over 120 participants, including com-
manders, top and mid-level management,
and front-line environmental specialists,
were asked to develop ways for DoD and
the state to work together more effectively.
The group's primary recommendation was
to form a coordinating council, and thus
the Texas Pollution Prevention Partner-
ship was born. Other recommendations
included cross-training, technical assis-
tance, and holding an additional partner-
ing workshop. All of the group's recommen-
dations have been successfully
implemented and results have been made
available for use by the public, other part-
nerships, industry, and government
agencies.
The challenge facing TXP3 has been to
achieve environmental excellence despite
diminishing resources and budgets. Typi-
cally, to improve environmental perfor-
mance, the military and the state look to
policies, regulations, and technologies
that are geared towards cleaning up pol-
lution after the fact. TXPS's goal is to
reduce waste at its source, and tackle this
through partnering, communication, and
leveraging resources. This approach has
resulted in significant pollution reduction
and cost savings.
Member agencies of TXP3 have lever-
aged numerous resources to reduce pollu-
tion. For example, the Air Force Center for
Environmental Excellence has shared its
pollution prevention information clearing-
house, PRO-ACT, with all members. This
has helped facilities in implementing pro-
jects, as they are armed with the best
information available.
Another example is leveraging of man-
power resources by the military and the
state. As a direct result of a TXP3 work-
shop, Army reservists partnered with the
TNRCC to assist a small community in
East Texas in completing a wastewater
sewer project under the Small Town Envi-
ronmental Program. The military also
provided funding for distribution of educa-
tional videos for elementary teachers in
Texas. In turn, the TNRCC has provided
significant manpower to help the military
reduce waste, by providing technical assis-
tance visits to over 15 installations across
Texas, hosting and organizing training
events, and transferring successes from
the private sector to federal facilities.
Many successful projects have been
implemented to reduce pollution and save
money at Texas federal facilities. On-site
technical assistance visits, conducted
jointly with DoD and state staff, have
been performed at 15 partner facilities
across the state, identifying over 500
opportunities for reducing pollution and
saving money. For example, as a result of
technical assistance and TXP3 discus-
sions, Dyess Air Force Base is saving $2
million annually by reducing waste and
emissions, and eliminating environmen-
tal permits. Through numerous projects,
Dyess eliminated 520,000 pounds of haz-
ardous waste and 1.1 million pounds of
non-hazardous waste annually.
Beneficiaries of TXP3 include federal
facilities, state government, industry, and
the public. The military benefits by
achieving both environmental and mis-
sion readiness goals cost effectively. Like-
wise, the state benefits by more effective-
ly fulfilling its mission of protecting the
environment. Industry also benefits indi-
rectly from TXP3. Many successful and
well-researched projects from the mili-
tary, such as innovative vehicle manage-
ment programs, are proving to be useful
to the private sector.
Most importantly, the public benefits
from TXP3. Reduction in hazardous
waste and air pollutants directly benefits
the public by improving environmental
quality. The public also benefits because
this approach saves taxpayers money.
For more information, visit TXP3 at
http://www.afcee.brooks.af.mil/txp3.
2 FEDFACS
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Two New Executive Orders Signed
President Clinton signed two new
Executive Orders in recent months
that reflect the Administration's emphasis
on energy conservation and bio-based
products. Executive Order (E.G.) 13123,
Greening the Government through Effi-
cient Energy Management, was signed on
June 3, 1999. E.G. 13134, Developing and
Promoting Biobased Products and Bioen-
ergy, was signed on August 12.
Efficient Energy Management
E.G. 13123 is the second "greening" exec-
utive order; E.G. 13101, Greening the Gov-
ernment through Waste Prevention, Recy-
cling, and Federal Acquisition, was signed
in September 1998. Executive Order
13123 also replaces a previous energy effi-
ciency order, E.G. 12902, signed in 1994.
The new order establishes a number of
goals for the federal community, includ-
• Reduction of greenhouse gas emissions
attributed to facility energy use by 30
percent by the 2010.
• Reduction of energy consumption at
non-industrial and non-laboratory
facilities by 30 percent by 2005 and 35
percent by 2010.
• Reduction of energy consumption at
industrial and laboratory facilities by
20 percent by 2005 and 25 percent by
2010.
• Expanded use of renewable energy,
including support for the Million Solar
Roofs initiative.
• Reduced use of petroleum product
energy sources at facilities.
• Reduced total energy use and associat-
ed greenhouse gas and other air emis-
sion as measured at the source.
• Reduced water consumption.
Each federal agency will be required to
designate a senior agency official respon-
sible for meeting the goals of the order and
to form energy teams to support technical,
legal, procurement, and management
aspects of the order. The Department of
Energy and the Office of Management
and Budget (OMB) are required by the
order to provide a variety of assistance
documents and guidance to support
implementation of the order. Each
agency's progress in meeting the goals of
the order will be judged by agency energy
"scorecards."
At the field level, implementation of
E.O. 13123 will require facilities to sup-
port the goals of the order through actions
such as conducting facility energy audits,
purchasing Energy Star® products, and
employing Energy-Savings Performance
Contracts. The goals of the order are fur-
ther enhanced by requirements for poli-
cies such as sustainable building design
as well as training, awards, and perfor-
mance evaluations. DOE has taken the
lead in establishing work groups to sup-
port and coordinate federal efforts to meet
the requirements of E.O. 13123. Copies of
the order and additional information
about implementation can be found at the
Federal Energy Management Program
website at http://www.eren.doe.gov/femp/.
Biobased Products
and Bioenergy
Executive Order 13134, Developing and
Promoting Biobased Products and Bioen-
ergy, focuses on development of a nation-
al strategy for making biobased products
and bioenergy competitive in national
and international markets. As defined in
the order, "biobased product" means a
commercial or industrial product (other
than food or feed) that utilizes biological
products or renewable domestic agricul-
tural (plant, animal, and marine) or
forestry materials. The term "bioenergy"
means biomass used in the production of
energy (electricity; liquid, solid, and
gaseous fuels; and heat).
E.O. 13134 establishes an Interagency
Council whose purpose is to prepare a
strategic plan outlining national goals for
development and use of, and research
into, biobased products and bioenergy.
The plans also will consider ways in
which federal programs can contribute to
the goals of the order. The Council will be
co-chaired by the Secretary of Agriculture
and the Secretary of Energy, and is made
up of the Secretaries of Agriculture, Com-
merce, Energy, and the Interior, the EPA
Administrator, the Director of OMB, the
Assistant to the President for Science and
Technology, the Director of the National
Science Foundation, and the Federal
Environmental Executive.
E.O. 13134 also establishes an appoint-
ed advisory committee of stakeholders,
such as agricultural and energy business-
es, environmental organizations, and the
university research community. The com-
mittee will provide the Interagency Coun-
cil with an assessment of the Council's
goals, research and development activi-
ties, effectiveness of various agency
programs, and the environmental and eco-
nomic consequences of biobased products
and bioenergy. The Departments of Agri-
culture and Energy are also required to
establish working groups and a joint
National Biobased Products and Bioener-
gy Coordination Office to support the
Interagency Council and overall imple-
mentation of the order and strategic plans
developed by the Council. The Executive
Order can be found in the Virtual Library
at the White House Internet website at
http://www.pub.whitehouse.gov/.
UPDATED YELLOW BOOK
NOW AVAILABLE
The recently-updated Yellow Book: Guide to
Environmental Enforcement and Compli-
ance at Federal Facilities is available
for downloading from EPA's Enviro$en$e
website at http://es.epa.gov/oeca/fedfac/
yellowbk/index.html. To purchase a copy
contact GPO, 710 North Capital St., NW.,
Washington, DC, 20401, Phone:202-512-1800
or Fax: 202-260-1800; Stock Number 055-000-
00624-5 or Publication No. EPA-315-B-98-
011. Cost: $29.00.
FEDFACS 3
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New Emphasis on Compliance with LIST Regs
EPA is placing renewed emphasis on
compliance with underground storage
tank regulations at federal facilities. Last
summer, EPA issued a strategy for enforc-
ing UST regulatory requirements (under
Subtitle I of RCRA) that came into effect
in December 1998. EPA's goal is full com-
pliance with the 1998 requirements as
quickly as possible. EPA's regulations do
not provide for a grace period in which vio-
lations can be corrected without a penalty.
UST owners/operators have had over ten
years to comply with federal require-
ments. During this period, EPA conducted
extensive outreach activities to inform the
regulated community of the 1998 techni-
cal requirements and provided compliance
assistance to owners and operators of UST
facilities. Given the threat that sub-stan-
dard tanks pose to human health and the
environment, EPA believes it is essential
to ensure that violations are promptly cor-
rected.
Under RCRA Subtitle I, EPA has the
authority to, and will, inspect UST facili-
ties in order to assess compliance with the
UST regulations. While EPA may take
enforcement actions in all states,* its
activities will be concentrated in states
that have less active UST enforcement
programs. EPA also will try to be respon-
sive to requests from any state for support
in dealing with federal agencies or other
UST owners and operators who resist
state compliance efforts.
EPA can enforce federal requirements in
states and territories that do not have EPA's
approval to run their own UST programs,
and in Indian country. In approved states
and territories, EPA can enforce state regula-
tions that were included in the State Pro-
gram Approval process, even if they are more
stringent than the corresponding federal reg-
ulations. The Agency does not enforce state
regulations that are broader in scope than
the federal regulations, e.g., those applicable
to UST systems not covered by the federal
regulations, such as heating oil tanks for
direct consumptive use.
UST Training for FFEO Staff
As part of FFEO's participation in the
UST enforcement drive, FFEO staff mem-
bers participated in July 1999 in UST
inspector training along with other EPA
personnel. The class was conducted by
Marcel Moreau, a nationally recognized
expert in the UST field who has trained
regulators at all levels. In addition to
classroom work, trainees visited two gaso-
line stations and a power plant at federal
facilities in the Washington, D.C. area.
The training served as an introduction
to both technical and legal aspects of the
UST regulations. The course opened with
overviews of the federal UST program,
the acceptable tank, piping, spill contain-
ment, and overfill prevention technologies
likely to be encountered during field
inspections, and then turned to tank lin-
ing and cathodic protection and associat-
ed record-keeping requirements.
Inventory Control: Doing the
Numbers
Participants were given a week's worth of
raw inventory data (stick readings, tank
chart and totalizer meter readings) and
asked to calculate the variance for that
week. After learning how to do the calcu-
lations, the class was given an introduc-
tion to the various leak detection options
available for USTs and learned the steps
involved in performing inventory recon-
ciliation. The participants then discussed
the theory behind statistical inventory
reconciliation (SIR) and some of the diffi-
culties presented by how SIR is practiced.
Tanks greater than 2,000 gallons in
capacity may not use the manual tank
gauging method of leak detection to meet
regulatory requirements, which may be
especially important at federal facilities,
where large-capacity tanks are common.
The difference between gravity-drop
LEAK DETECTION SYSTEMS
Inventory Control or
Manual Tank Gaugini
Tank Tightness Test
nventory Probe for
Automatic Tank Gauging
Secondary
Containment
with Interstitial
Monitor
4 FEDFACS
-------
Given the threat that
sub-standard tanks pose
to human health and
the environment, EPA
believes it is essential
to ensure that violations
are promptly corrected.
Inside the Pumps
deliveries and pressure deliveries was dis-
cussed to emphasize how important it is
for federal facilities in particular to know
whether their fill-pipes are pressure-rat-
ed. Most DoD fuel deliveries are pressur-
ized. The consequences of a pressurized
fuel delivery being made in a non-pres-
sure rated fill-pipe could be serious.
The class turned to a discussion of the
variables affecting tightness tests and
ways that different tightness test methods
compensate for these variables. Both volu-
metric and non-volumetric methods were
discussed. A discussion followed of leak
detection evaluations and automatic tank
gauging. Other topics included: technolo-
gies for creating and monitoring sec-
ondary containment for underground
tanks and piping, the distinction between
pressurized and suction pumping sys-
tems, the workings of mechanical and
electronic line leak detectors, and the
requirements for suction piping systems.
The course also covered inspection issues
such as "What is a serious violation?" and
"How can consistency among inspectors
be achieved?" The class reviewed records
from facilities to be visited in order to
evaluate compliance and to identify items
to look for during the visits.
The training accomplished a great deal
towards increasing the understanding of
both the legal requirements and technical
complexities associated with UST regula-
tion and inspection. Further work by
FFEO staff is contemplated in the field
and in support of the regions, in order to
put this training into practice.
FFEO Staff Looking Under the Lid
FEDFACS 5
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EMRs
Environmental Management
Reviews in Region 8
by Dianne Thiel, EPA Region 8 Federal
Facilities Coordinator
Region 8 recently completed three envi-
ronmental management system reviews
(EMRs) and is working on a fourth. The
first three EMRs involved evaluating
both a facility and at least one other man-
agement level above the facility. During
the course of conducting these EMRs,
we've seen many examples of good envi-
ronmental management practices which
we would like to share with you.
EPA Region 8 Laboratory
At our laboratory in EPA Region 8, we
reviewed systems at the Lab itself, in the
Regional Office, as well as support pro-
vided by the Safety, Health and Environ-
mental Management Division at EPA
Headquarters. The Environmental Com-
pliance Manager reports directly to the
Laboratory Director and has the authori-
ty to make decisions. Environmental
funding is provided for pollution preven-
tion equipment and software, in addition
to pollution control and waste disposal
costs. The Environmental Compliance
Manager provides orientation training for
new employees, contractors, and visitors,
in addition to annual employee refresher
training. The system for tracking train-
ing, called REGISTRAR, documents
training sponsored by the EPA Regional
Office and can be audited and accessed
easily by all employees. Required training
can be flagged and tracked for supervi-
sors and employees. The Safety, Health
and Environmental Management Divi-
sion at EPA Headquarters provides for-
mal training, policies, manuals, technical
assistance, and contractor support on a
project specific basis. This division hosts
regular conference calls with the regions
and at least one national meeting a year.
The division also conducts regular com-
pliance audits at the laboratory and mon-
itors audit findings until they are closed
out.
Western Area Power
Administration
For Western Area Power Administration,
we looked at the headquarters environ-
Can You Guess What It Is?
• It's collaborative and inexpensive
• It uses an outside party
• It can lead to long-term environmental compliance
• It provides feedback and identifies opportunities for improvement
• It can enhance a federal facility's environmental management
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mental program and one of the four
regional offices. Western has a Corporate
Environmental Office as well as an Envi-
ronmental Manager at each regional
office. Corporate provides planning, sup-
port and compliance assistance to the
regions. For example, the planning group
in the Corporate Environmental Office
developed systems for tracking accom-
plishments and reviewing milestones
related to environmental impact state-
ments, environmental assessments, and
categorical exclusions.
The Corporate Office developed a list
of standard environmental specifications
for construction projects now maintained
by environmental staff in the Rocky
Mountain Region. Environmental staff
in the regions evaluate each new con-
struction contract and recommend the
appropriate specifications for that site
from the comprehensive list. One of the
managers at the Corporate Office follows
regulatory developments and shares that
information expeditiously with the
regions. Top management at the Corpo-
rate Office reviews an annual environ-
mental report on program accomplish-
ments and initiatives prepared by the
Environmental Office. The Public Affairs
Office publishes a professional newslet-
ter called "Closed Circuit," that is dis-
tributed to all employees, retirees, and
customers, and regularly features arti-
cles on environmental topics.
At the Rocky Mountain Region (RMR)
of Western Area Power Administration,
joint environmental and safety inspec-
tions are conducted annually at staffed
facilities and every three years at
unmanned facilities. Exceptions found
during inspections are reported to line
and top managers who ensure that cor-
rections are made in a timely manner. A
centralized database is used for inspec-
tion results, and findings from inspec-
tions are used to improve and target envi-
ronmental training. Baseline audits have
been done at all RMR facilities and these
records are maintained and updated. A
6 FEDFACS
-------
required safety and environmental
awareness training session is held annu-
ally for all craftspeople. Some line man-
agers and field supervisors also partici-
pate. Attendance is required and tracked
by the Safety office. In 1998, the Rocky
Mountain Region began training con-
struction inspectors to do field checks of
mitigation measures during construction
projects. RMRis also including inspectors
in the environmental training given
annually for maintenance workers.
The Environmental Manager at RMR
reports directly to the Regional Manager,
attends and reports at all RMR senior
staff meetings, and has authority
to approve and implement most new
environmental procedures. His monthly
environmental activity reports are widely
distributed to managers throughout the
region and are sent to the Corporate envi-
ronmental office. The Environmental
Manager is included in management of
the business: he participates in quarterly
Maintenance Managers' meetings and is
a member of the Maintenance, Design
and Construction Council which meets
quarterly to discuss long range planning,
budget formulation, performance goals,
and benchmarking for the business.
The Environmental Managers at the
Corporate Office and in the regions meet
quarterly to improve communication and
information sharing, plan, review proce-
dures, and address common problems.
The location and responsibility for plan-
ning the meeting rotate among the par-
ticipants. Corporate and regional envi-
ronmental personnel share responsibility
for developing and revising environmen-
tal procedures. One office is generally
tasked to develop or revise a procedure,
which is then reviewed and approved by
the Environmental Managers' Team and
issued through the Corporate Office. In
1998, the Environmental Managers'
Team initiated a pilot self-assessment
program to review their environmental
management systems within specific pro-
grams, such as RCRA, pesticides, and
cultural resources.
U.S. Postal Service
At the U.S. Postal Service, we reviewed
management systems at a vehicle main-
tenance facility (VMF), a District Office,
and the Western Area Office. USPS has
many good examples of effective manage-
ment systems. For instance, personnel
with environmental responsibilities are in
leadership positions at each level of the
organization.
At the Area, District, and VMF levels,
the environmental manager reports
directly to the top manager and part of
the senior staff. Postal procedures and job
descriptions clearly spell out environmen-
tal responsibilities up the management
chain. The VMF Manager and Line
Supervisors are knowledgeable about
environmental issues and alert to poten-
tial environmental problems as well as
opportunities for pollution prevention.
Weekly standup talks for staff at the VMF
focus on environmental topics in addition
to safety.
The District Environmental Compli-
ance Coordinators for the Colorado/
Wyoming District have taken numerous
proactive measures to reduce regulatory
reporting requirements, anticipate new
requirements, and share successes across
facilities. At the Area and national levels,
Environmental Coordinators are actively
involved in multilevel, cross-functional
work groups to improve program imple-
mentation and link the environmental
program to postal systems and opera-
tions. Minutes of some work group meet-
ings are posted on their internal website
to facilitate broad information sharing.
One national work group is finalizing an
environmental management system tied
to the Postal Service's quality system,
called Customer Perfect!
Specific tools developed by the Area
Office include a macro experience matrix
— a table which shows the level of exper-
tise and experience in RCRA, NPDES,
and other programs of all the environ-
mental coordinators within the Western
Area. This table makes it easy for envi-
ronmental coordinators to quickly deter-
mine whom to call if they have a question
on a particular regulatory program. The
table also helps identify training needs.
Another table shows the environmental
training recommended for various job cat-
egories within the Postal Service.
EPA Region 8 encourages other Region
8 federal facilities to volunteer for an
EMR so we can continue to showcase suc-
cessful environmental practices. For more
information or to volunteer your facility,
contact Dianne Thiel at 303-312-6389 or
thiel.dianne@epa.gov.
EPA Conducts 3 EMRs at
DOE SPR Sites
DOE's Strategic Petroleum Reserve
(SPR) Program Management office in
New Orleans, LA agreed to have an EMR
conducted at two SPR storage sites
(Bryan Mound in Freeport, TX and Bayou
Chatow in Baton Rouge, LA) and at the
Program Management office during the
week of June 14, 1999. SPR's willingness
to participate in the EMR process was
evidence of upper management's interest
in the importance of environmental man-
agement systems (EMS) for achieving
environmental excellence.
The SPR offices are primarily govern-
ment-owned/contractor-operated (GOCO)
federal facilities. At a GOCO site, the gov-
ernment owns the facilities and a con-
tractor manages all regular activities.
The contractor for DOE at the SPR sites
is DynMcDermott (DM). At the sites
reviewed in this EMR, DM is essentially
in charge of the environmental program,
with direction from DOE personnel.
Hence, the EMR team assumes that DOE
and DM personnel will work together on
implementing any recommendations.
Recommendations made by the EMR
Team are specific to the SPR sites and
are intended as guidance to be used in
improving and formalizing DM's EMS.
SPR requested that EPA's review include
the organization's entire environmental
management system, that included the
following elements: 1) organizational
structure; 2) environmental commit-
ment; 3) formality of environmental pro-
grams; 4) internal and external commu-
nication; 5) staff, resources, training, and
development; 6) program evaluation,
reporting, and corrective action; and 7)
environmental planning and risk man-
agement.
For more information, contact Joyce
Stubblefield, EPA Region 6, at 214-665-
6430.
FEDFACS 7
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Regional News and Notes
Region 6 Multi-Media
Inspections
Region 6 inspection teams recently con-
ducted two Type D Multi-Media Inspec-
tions (MMI) at Air Force facilities.
• Holloman Air Force Base, New
Mexico, is currently the home of the
49th Fighter Wing of the United
States Air Force. The 49th Wing is
the umbrella for several fighter
groups; the F-117 Nighthawk is one of
its main weapon systems. It is also a
major training facility for pilots from
other countries such as Germany and
Taiwan. The purpose of the inspection
was to determine the facility's compli-
ance status with the applicable provi-
sions of the Clean Air Act, RCRA,
TSCA, EPCRA, and the Clean Water
Act.
• Lockheed/Martin, Air Force Plant
#4, Fort Worth, Texas, is currently in
production and testing of the F-16
Fighting Falcon and development of
the F-22 Raptor. The purpose of the
inspection was to verify compliance
with regulations under RCRA, Clean
Air Act, Clean Water Act, TSCA, and
EPCRA. The City of Fort Worth par-
ticipated in the MMI by assisting EPA
inspectors under the Air program.
Although not directly involved with
the inspections, the Texas Natural
Resources Conservation Commission
provided valuable information to par-
ticipating programs during the file
review stage.
Region 6: Restoration
Summit
On August 18-19, 1999, the Air Force
hosted a restoration summit in Dallas as
a follow-up to the Federal Facilities Envi-
ronmental Restoration Dialogue Com-
mittee report recommendation to contin-
ue building consensus and focus on
goal-setting and priorities for cleanup
activities, as well as innovative cleanup
technologies.
The meeting included representatives
from the Air Force, EPA, and Region 6
states. The Air Force, EPA, and states
Division Directors discussed issues relat-
ed to base closure for FY 2000 and
beyond, Superfund, risk management
strategies, the Government Performance
and Results Act, data quality/lab fraud,
consensus building in priority setting
and state perspectives. A summary
report with action items is forthcoming.
Some potential actions discussed were to:
• Work with Texas to identify bases that
have problems with report quality and
remedy.
• Develop AF/EPA/state team(s) to
work all action items.
• Coordinate a process for regulators to
be involved in the peer review of
restoration sites.
• EPA/AFCEE to review standardiza-
tion of documents and terminology.
• Establish four EPA/state/AF working
groups to facilitate and fast track
restoration efforts at ACC-Barksdale;
AFMC-Tinker; AETC-Laughlin;
AFBCA/AFCEE-Carswell/AFP4.
Contact: Joyce Stubblefield, EPA Region
6, 214-665-6430.
Region 7: Army Officer
Exchange Program
The Army's Training With Industries Pro-
gram aims to develop a group of officers
experienced in higher level managerial
techniques and who have an understand-
ing of the relationship of industry to spe-
cific functions of the Army. Once an officer
is integrated back into an Army organiza-
tion, he/she can use this information to
improve the Army's ability to interact and
conduct business with industry.
One participant in the program, Cap-
tain Cedrick Farrior, is assigned to EPA
Region 7 through August 2000, beginning
with a rotation in the federal facilities
program. Captain Farrior has been in the
Army for 12 years and has served in a
host of assignments both in the US and
abroad. Several of his assignments
include Texas, Alaska, Indiana, Georgia
as well as tours to Japan and Thailand.
He can be reached at farrior.cedrick®
epa.gov
Region 9: Compliance
Agreement for Wake Island
EPA Region 9 and the Department of the
Army, U.S. Army Space and Missile
Defense Command (USASMDC) recently
signed a Federal Facilities Compliance
Agreement (FFCA) that establishes com-
pliance schedules to resolve several exist-
ing areas of noncompiance on Wake
Island. This is the first FFCA for a U.S.
possession not affiliated with any state or
territory.
Wake Island is an atoll approximately
4.5 miles long and 2 miles wide, located
2,460 miles west of Hawaii and 1,500
miles east of Guam. It has no indigenous
population; however, over 100 Army con-
tractor personnel reside on Wake and
during launch operations (about four
times a year) the population doubles.
USASMDC uses Wake Island to support
launch operations for the Ballistic Missile
Defense Organization.
Under the FFCA, the USASMDC and
EPA are addressing noncompliance areas
including: unpermitted point source dis-
charges; discharge of untreated domestic
wastewater; inadequate secondary con-
tainment and spill prevention and coun-
termeasure plans for petroleum storage
facilities; and solid waste disposal prac-
tices. The FFCA does not cover ongoing
remedial activities that the Air Force is
taking to address past activities.
EPA Region 9 supports the initiative
of the USASMDC to resolve compliance
issues on this small and historic atoll.
8 FEDFACS
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ConferenceUpdate
Region 7's Annual Federal
Facilities Conference
Over 100 attendees participated in
Region 7's Annual Federal Facilities
Conference in Kansas City on August 24-
25, 1999. The theme was "Achieving
Excellence In The New Millennium." Top-
ics dealt with regulatory and information
issues that concern federal facilities, as
well as environmental justice, Title VI,
and Project XL. Attendees represented
the Departments of Defense, Energy,
Transportation, the IRS, GSA, Federal
Aviation Administration, Food and Drug
Administration, USDA, and the Postal
Service, as well as state agencies.
Feedback from both attendees and
speakers has been very positive. The
Enforcement Coordination Office is
grateful for the tremendous support
from the various Region 7 sections
whose contributions were critical to the
success of the conference. Planning will
begin shortly on the next conference,
tentatively scheduled for Summer 2000.
Suggestions are greatly appreciated.
Please forward suggestions or comments
to Diana Jackson (Jackson.diana®
epa.gov) or Cedrick Farrior (farrior.
cedrick@epa.gov).
Region 6 Hosts Source
Water Assessment Meeting
In November 1998, the Clean Water
Action Plan (CWAP) Federal Multi-
Agency Source Water Agreement was
signed by nine federal agencies. The doc-
ument is an agreement to develop part-
nerships that will support state and
tribal government efforts to complete
source water assessments nationwide
and support source water protection pro-
grams with the primary goal of protect-
ing the nation's sources of drinking
water.
As a first step in building those part-
nerships, the Water Quality Protection
Division of EPA Region 6 hosted a
regional Source Water Assessment Pro-
gram Federal/State Coordination meet-
ing on May 25-26, 1999, in Dallas,
Texas. Representatives of the nine fed-
eral agencies and the five states in
Region 6 attended the meeting. The
goals of the meeting were to:
• Define mechanisms to make federal
data, information, and technical
expertise available to states for use
in conducting source water assess-
ments.
• Determine how program authorities
under relevant state and federal laws
can be applied to drinking water
source areas needing protection.
• Forge partnerships at the regional,
state, and field office level to imple-
ment the source water assessment
and protection programs within a
watershed framework.
• Focus on coordination needs
between agencies at all levels for
transboundary watershed issues.
• Establish an ongoing planning/coordi-
nation function to continue the
momentum generated at the meeting.
Contact: Ken Williams, EPA Region 6,
214-665-7129.
CFAs Meet in the Pacific
Northwest
The Civilian Federal Agency (CFA) Task
Force, in coordination with FFEO and
SGS ICS National Education Center,
sponsored the second annual CFA Envi-
ronmental Symposium on May 17-20,
1999, in Seattle, Washington. 245 envi-
ronmental managers and staff from 35
agencies and numerous federal facilities
attended the symposium.
Speakers, including Steve Clark, Act
ing Regional Administrator of the
Bureau of Reclamation, Great Plains
Region, and William Stelle, Jr., Region-
al Administrator, National Marine Fish-
eries Service, Northwest Regional
Office, addressed current environmen-
tal issues in the Pacific Northwest and
set the tone for symposium participants
to share solutions to environmental
business management challenges.
In addition to 27 break-out sessions,
the National Education Center provided
training in Environmental Compliance
Auditing and Implementation of ISO
14000 Environmental Management
Systems. Other training workshops con-
ducted by staff from CFAs provided
hands-on skills in:
• Environmental Statute Review
• Re-refined Oil Programs
• Environmental Justice
• Compliance Assistance Centers
• Green Purchasing
• Plain Language Principles
• Property Transfer
• Enviro-Surfing.
Continued on page 10
is published by EPA's Federal Facilities
Enforcement Office.
Joyce Johnson, FFEO, Editor
Gilah Langner,
Stretton Associates, Inc., Writer
Robin Foster,
SciComm, Inc., 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
Read FedFacs on the Internet:
http j/www .epa.gov/oeca/fedfac/ann/index.html
FEDFACS 9
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CONFERENCE UPDATE
Continued from page 9
The CFATask Force is making plans for
its next symposium. The date and loca-
tion are yet undetermined. To contribute
planning ideas, contact your CFA Task
Force representative or consider becom-
ing a member of the Task Force for your
agency. For more information about the
CFA Task Force or for a list of members,
contact FFEO at 202-564-2510 or visit
the EPA Enviro$en$e website at
http://www.epa.gov/oeca/fedfac/fflex.html.
Transient Drinking Water
Training Offered
In the fall of 1998, Ken Morin, Manager
of the Bureau of Land Management's
compliance auditing program,
approached EPA Region 8 about con-
ducting a training class for BLM per-
sonnel. Ken had identified a number of
difficult issues common to small, remote
locations such as campgrounds, recre-
ation sites, historic areas, and fire sta-
tions, where BLM provides drinking
water to the public and/or its employ-
ees. Ken volunteered to work with EPA
to develop a class to address these
issues. EPA agreed to the project if the
class would be open to other land man-
agement agencies with similar con-
cerns.
With Ken's input, the Region 8
Drinking Water Program designed a
course to address the needs of mainte-
nance and field personnel and man-
agers responsible for operating the
transient, non-community drinking
water supplies. The class was held May
18-20, 1999, at the EPA Region 8 offices
in Denver, Colorado. Representatives of
nine federal agencies attended, along
with a few state and local agency staff.
Of the 48 participants, 27 were from
facilities located within Region 8.
The major focus of the course was on
microbiological contamination. EPA
Drinking Water Program staff gave pre-
sentations on the different types of
water borne pathogens and methods
Steve Tuber, EPA Region 8 Water Program Director, welcoming participants
to the class.
used to detect these microorganisms,
taking a coliform sample, writing a site
sampling plan, monitoring and record
keeping requirements for transient sys-
tems, fixing and preventing bacteriolog-
ical contamination problems, and deter-
mining if a ground water supply is
under the influence of surface water.
EPA speakers also covered hauled
water requirements and disinfection
procedures, point of entry/point of use
requirements, and bottled water. Ken
Bousfield of the Utah Drinking Water
Program discussed proper development
of wells and springs, because Utah has
many springs that are used as water
supplies. The problem of cross connec-
tions between drinking water plumbing
and fire sprinkler systems, lawn irriga-
tion systems, or hose bibs was
addressed. A case study on Alpine,
Wyoming was presented, as well as
numerous other real world examples.
Source water protection programs, sani-
tary surveys, and closing of Class V
Underground Injection Control wells
were offered as techniques for prevent-
ing contamination of drinking water
sources.
Selected chemical contaminants
were also discussed, including nitrate,
nitrite, radium, uranium, radon, iron,
manganese, sulfate, fluoride,and total
dissolved solids. Health effects associat-
ed with each were covered briefly. Rep-
resentatives of the Bureau of Reclama-
tion's Water Treatment Engineering
and Research Group presented a ses-
sion on treatment technologies for
chemical contaminants. Finally, an EPA
inspector discussed enforcement of
drinking water regulations.
The slide presentations from this
training course were shared with two
other EPA regions in the hopes that
they will offer similar training. The
course presentations will be available
on EPA's website (http://www.epa.
gov/safewater/dwa) so that others
knowledgeable about transient, non-
community systems can download them
and offer similar training. EPA Region 8
is interested in hearing from other fed-
eral agencies in the region about other
training topics that could be offered in
partnership in the future. Contact:
Dianne Thiel, EPA Region 8, 303-312-
6389 or thiel.dianne@epa.gov.
1O FEDFACS
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The Hammer
Region 3
Southeast Federal Center: On July
28, 1999, EPA Region 3 mailed to GSA
a signed RCRA 3013 Order requiring
investigation of, and some interim mea-
sures on the Southeast Federal Center
(SEFC). This is the first Section 3013
Order on Consent that EPA has entered
into with a federal agency. The SEFC
occupies 55.3 acres along the Anacostia
River. Several studies of the area
revealed the presence of contamination at
or near the facility. The contaminants
detected, including benzene and lead,
have detrimental effects on human
health and the environment. Contact:
Sally M. Dalzell, EPA FFEO, 202-564-
2583.
Bainbridge, MD: On July 23, 1999, EPA
Region 3 issued a Clean Air Act Compli-
ance Order to the U.S. Navy for asbestos
violations at Bainbridge in Maryland.
The Navy recently discovered the pres-
ence of friable asbestos-containing air cell
insulation at a 10-acre area of the site.
The order requires the Navy to sample for
friable asbestos material, remove it, and
then properly dispose it. Contact: Sally
M. Dalzell, EPA FFEO, 202-564-2583.
Region 6
Camp Stanley Storage Activity Facil-
ity: Region 6 issued an Administrative
Order on Consent to the Camp Stanley
Storage Activity (CSSA) facility in
Boerne, Texas. The CSSA has been oper-
ating as a hazardous waste management
facility since November 19, 1980. The
order concerned the identification, inves-
tigation, and prevention of further conta-
mination due to the release of hazardous
wastes to the environment.
There are 12 wells at the CSSA facility
that are used as potable drinking water
sources, monitoring wells, and agricultural
water supplies. During a routine pesticide
screening site visit on August 9, 1991, the
Texas Department of Health sampled
water supplies from well #16 and found
traces of several chemicals in the water
samples. The contaminants consisted of
127 micrograms/liter of 1, 2 dichloroethane
(DCE), 151 micrograms/liter of trichloeth-
ylene (TCE), and 137 micrograms/liter of
tetrachloroethylene (PCE). Further testing
on August 23, 1991 confirmed the earlier
results. The well in question was removed
and the other wells were put on notification
on a quarterly basis. On December 4,1991,
the Texas Natural Resource Conservation
Commission collected samples from well
#16 and two inactive wells and found that
well #16 was contaminated with TCE and
PCE, and the other two wells were conta-
minated with DCE.
The order requires CSSA to do the fol-
lowing:
• Perform interim stabilization mea-
sures to prevent or minimize the fur-
ther migration of contaminants due to
the release of hazardous constituents
to the environment.
• Mitigate current or potential threats
to human health and the environ-
ment.
• Perform corrective action studies to
identify and evaluate alternatives for
corrective actions to prevent or miti-
gate any migration of pollutants from
the facility.
Failure by CSSA to comply with the
terms of the order will result in penalties
ranging from $500 to $5000 per day,
depending on the extent of the non-com-
pliance period. Contact: Greg Lyssy EPA
Region 6, 214-665-8317.
Tinker Air Force Base: In January
1998, the first set of underground storage
tank (UST) cases against federal facilities
were filed, including an action against
Tinker Air Force Base. The parties
attempted negotiations in accordance
with Administrative Law Judge's (ALJ)
orders. However, the case could not be
settled and the Air Force moved for an
accelerated decision by the ALJ.
At issue is whether EPA has the
authority to assess fines where federal
facilities violate the UST provisions of
RCRA. EPA's position is that the UST pro-
visions of RCRA and the context of RCRA
as a whole give EPA the authority to
assess fines. However, parallel to EPA's
administrative action, in the Spring of
1999, DoD referred this issue to the Office
of Legal Counsel (OLC) of the Department
of Justice. An opinion from OLC will settle
this dispute between the agencies.
Upon receipt of this referral in April
1999, the ALJ prepared an accelerated
decision that EPA did not have the
authority to assess fines. EPA filed its
response to DoD on August 13, 1999. Two
separate actions were filed in this case. A
hearing date was set before the ALJ in
November 1999. EPA also awaits either
an OLC opinion or a reply brief from Tin-
ker Air Force Base. Contact: Amie
Richardson, EPA Region 6, 214-665-2713.
Region 10
Wapato Irrigation Project: On August
30, 1999, Region 10 issued a complaint to
the Bureau of Indian Affairs (BIA) for
UST violations at the Wapato Irrigation
Project in Wapato, Washington, located
on the Yakima Indian Reservation (see
related article on page 1). EPA has pro-
posed $19,875 in penalties against BIA
for violations of several UST regulations
which ensure that leak detection alarm
systems are working properly. These UST
regulations are in place to detect leaks,
and to minimize the risk that a release
would affect groundwater. The violations
were discovered during a March 1999
inspection. Similar violations were found
during a 1996 inspection. Contact:
Melanie Barger Garvey, EPA FFEO, 202-
564-2579.
FEDFACS 11
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UpcomingEvents
December 6-9,1999
Joint Service Pollution Prevention Conference and Exhibition
San Antonio, TX
Contact: Joyce Stubblefield, 214-665-6430.
December 10,1999
Texas Pollution Prevention Partnership Meeting
San Antonio, TX
Contact: Joyce Stubblefield, 214-665-6430.
February/March 2000
Region 6 Phase II Stormwater Conference
Dallas, TX
Contact: Monica Burrell, 214-665-7530
LIST OF ACRONYMS
BIA Bureau of Indian Affairs
CAA Clean Air Act
CERCLA Comprehensive Environmental
Response, Compensation, and
Liability Act
CFA Civilian Federal Agency
CWA Clean Water Act
DoD Department of Defense
DOE Department of Energy
DOI Department of the Interior
DOJ Department of Justice
EMR Environmental
Management Review
EPA Environmental Protection
Agency
EPCRA Emergency Planning and
Community RightTo-Know
Act of 1986
FFEO Federal Facilities Enforcement
Office (EPA)
GPO Government Printing Office
GSA General Services
Administration
OECA Office of Enforcement and
Compliance Assurance (EPA)
RCRA Resource Conservation and
Recovery Act
TNRCC Texas Natural Resources Con-
servation Commission
TSCA Toxic Substances Control Act
USDA Department of Agriculture
UST Underground Storage Tank
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