United Stales Environmental Protection Agency EPA 300-K-96-001 Revised Spring 1996 Office of liii for cement anil (2261 A) Compliance Assurance ¦® FPA Federal Facilities ^ Enforcement Office ------- "While our enforcement efforts provide a strong incentive for maintaining high levels of compliance at Federal facilities, this is not the only set of responses being used by EPA to achieve this goal. By providing compliance assistance tools to promote pollution prevention, FFEO is helping to build the capacity of Federal facilities to move toward cleaner, cheaper, and smarter methods of environmental management." Steven A. Herman Assistant A dministrator for Enforcement and Compliance Assurance ------- Organizational Structure of the Federal Facilities Enforcement Office Federal Facilities Enforcement Office Phone: (202) 564-2466 Director: Barry Breen Associate Director: Craig Hooks Senior Counsel: Joyce 01 in Planning, Prevention and Compliance Staff Director: James Edward (202) 564-2461 Kelly Conrad Susan Donald Don Franklin Will Garvey Priscilla Harrington Joyce Johnson Isabelle Lacayo Diane Lyrihe Rich Satterfield Sarah Walsh Susan Weiner Augusta Wills (202) 564-2459 (202) 564-2473 (202) 564-2463 (202) 564-2458 (202) 564-2461 (202) 564-2592 (202) 564-2578 (202) 564-2587 (202) 564-2456 (202) 564-2457 (202) 564-2471 (202) 564-2468 Site Remediation and Enforcement Staff Director: Sally Dalzell (202) 564-2583 Darlene Boerlagc Lance Elson Bill Frank Melanie Barger Garvey Dave Levenstein David O'Very Otis Pratt Jean Rice Kathy Seddon (202) 564-2593 (202) 564-2577 (202) 564-2584 (202) 564-2579 (202) 564-2591 (202) 564-2588 (202) 564-2581 (202) 564-2589 (202) 564-2573 J. Regional Federal Facility Coordinators Page I ------- Federal Facilities Enforcement Office (FFEO) As part of EPA' s Office of Enforcement and Compliance Assurance {OECA), FFEO is responsible for ensuring that Federal facilities take all necessary actions to prevent, control and abate environmental pollution. Major FFEO functions include: ~ Policy and guidance development, ~ Regional program support, ~ Interagency agreement (IAG) negotiation support, ~ Enforcement support, ~ Program and information support, and ~ Technical assistance and capacity building. FFEO is divided into two groups: the Site Remediation and Enforcement Staff and the Planning, Prevention and Compliance Staff. Together, these groups provide for the effective development of national policy and guidance to address the broad range of enforcement and compliance issues confronting Federal facilities. Site Remediation and Enforcement Staff (SRES) SRES efforts primarily involve working with Federal agencies and OECA to streamline enforcement and cleanup at Federal facilities. For cleanup issues, SRES works closely with the OSWER Federal Facilities Restoration and Reuse Office (FFRRO) on many of these issues. Page 2 ------- Specific SRES responsibilities affect every aspect of Federal facility enforcement, from planning to implementation. For example, SRES reviews proposed Federal legislation and develops EPA positions on appropriate Federal responsibilities under such legislation. SRES also is involved in developing Federal facility enforcement strategies and in preparing guidance to assist Regions in their implementation. Finally, SRES is directly involved in enforcement negotiations, including Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA) IAGs and Memoranda of Understanding (MOUs), and in litigation and enforcement oversight at Federal facilities. A summary of SRES activities is presented below. Enforcement Policy and Regulatory Development Federal Facility Policy Group Reconciliation Workgroup National Mining Framework • Mixed Ownership Task Force Federal Facilities Leadership Council Compliance and Enforcement Implementation FFCA implementation Supplemental enforcement projects guidance » Civilian Federal Agency enforcement DOE and DoD issues Mixed waste/radioactive waste Regional Coordination » Administrative Order/FFCA oversight • IAG oversight • Accelerated cleanup • Formerly utilized defense sites Page 3 ------- Community Relations Environmental justice Community involvement Ecosystem protection Through careful planning and application of enforcement tools, SRES helps ensure compliance and expedite cleanup of Federal facilities posing the greatest risk to human health and the environment. Planning, Prevention, and Compliance Staff (PPCS) PPCS is responsible for initiatives to prevent noncompliance at Federal facilities and overseeing compliance and enforcement activities. On a strategic planning level, PPCS works with OECA on enforcement and inspection targeting at Federal facilities, oversees the Federal agency environmental management planning program (i.e., FEDPLAN), and coordinates FFEO's involvement in interagency pollution prevention and compliance assistance task forces and working groups. On an implementation level, PPCS tracks compliance at Federal facilities; promotes pollution pre-vention, multi-media enforcement/compliance, and environmental justice at Federal facilities; and encourages the use of innovative technologies to attain pollution prevention, compliance, and cleanup goals. A summary of PPCS activities is presented below. Program Management • Strategic planning and development Program Management and administration Budget formulation and execution Contract Management Policy Formulation and Guidance * Annual operating guidance Page 4 ------- Regional MOA guidance FEDPLAN guidance FOTW guidance Multi-Media Program « Multi-Media Enforcement/Compliance Program • " FFCA oversight Environmental auditing/management Code of Environmental Management Principle Pollution Prevention (P2) • E.O. 12856 implementation guidance P2 Facility Planning Guide Interagency P2 Task Force P2 opportunity profiles and assessment Information Management Federal Facilities Tracking System (FFTS) Envirosense/FFLEX bulletin boards • Hazardous Waste Compliance Docket FEDPLAN-PC STARS and CERCLIS Interagency Communications/Outreach "Fed Facs" bulletin • Civilian Federal Agency Task Force Federal Agency Environmental Roundtable Military exchange program • Environmental justice profiles Federal agency training Innovative technology • Technology transfer DOIT Committee • SERDP and NTI programs Page 5 ------- By tracking and evaluating compliance at Federal facilities, PPCS helps identify high priority compliance issues and develop proactive multi-media measures to prevent pollution and reduce future noncompliance at Federal facilities. FFEO Program Highlights and Initiatives FFEO administers numerous programs to facilitate the cleanup of and foster improved environmental compliance at Federal facilities. These range from direct involvement in enforcement negotiations to technical assistance and training, Recent examples of FFEO's efforts include the following: ~ Enforcement Actions and Negotiations « FFEO participates in enforcement negotiations, oversees enforcement activities undertaken by the Regions, and is responsible for resolving enforcement disputes between EPA and other agencies. On nationally significant cases, FFEO coordinates with the Regions on issuing compliance orders and agreements. Actions against Federal agencies include notices of violation, I AGs, Orders, and agreements under all relevant environmental statutes. In appropriate cases, enforcement actions may involve monetary penalties. ~ Planning of Cleanup Activities -- FFEO supports the implementation of the Superfund program at Federal facilities by helping to establish specific cleanup goals and objectives, identifying appropriate funding levels, and assessing progress in meeting goals and objectives using the Superfund Comprehensive Accomplishments Plan (SCAP) and Strategic Targeted Activities for Results System (STARS). ~ Federal Facilities Multi-Media Enforcement/ Compliance Initiative (FMEC1) — The FMECI uses Page 6 ------- EPA and state multi-media inspections and enforcement actions to improve Federal facility compliance, reduce environmental risks, increase enforcement efficiency, and encourage pollution prevention. ~ Federal Agency Environmental Management Program Planning — To provide technical assistance in environmental planning and operations to Federal facilities, FFEO reviews annual FEDPLAN submissions from all Federal agencies and forwards the results to OMB. FFEO also provides guidance to assist EPA Regional staff and Federal agency personnel on the FEDPLAN-PC system. ~ Federal Agency Environmental Roundtable - FFEO has established a monthly interagency roundtable to provide an exchange of information and ideas on environmental compliance topics between EPA and other Federal agencies. 4 Federal Facilities Leadership Council — FFEO coord- inates monthly conference calls and quarterly meetings of senior EPA Regional and Headquarters personnel to address issues relating to remediation and enforcement at Federal facilities, including closing military bases. ~ Civilian Federal Agencies Task Force — FFEO created this task force to provide targeted compliance assistance to Civilian Federal Agencies (CPAs) on improving their environmental management programs. ~ Federal Facilities Environmental Justice — FFEO coordinates environmental justice initiatives at Headquarters and works closely with the Regions on these issues. FFEO supports the Regional enforcement actions at Federal facilities when environmental justice concerns exist. Page 7 ------- ~ Federal Facilities Environmental Restoration Dialogue Committee (FFERDC) -- FFEO participates in the FFERDC, which recommends improvements to Federal facilities environmental restoration, decision-making, and priority-setting processes. ~ Federal Facilities Tracking System (FFTS) - FFEO maintains FFTS, a PC-Based system that, provides a multi-media view of Federal facilities compliance for EPA Regions and Headquarters. Regional Federal Facility Coordinators (FFCs) FFCs, in conjunction with program office staff, are responsible for coordinating the implementation of FFEO policies and programs at the Regional level. FFCs serve as the primary Regional point of contact for facility environmental managers and as a link between EPA and the Federal facilities. Specific FFC responsibilities include: ~ Coordinating with Regional media program staff to implement Federal facilities enforcement programs. FFCs provide clarification on Federal facilities policies and guidance and assist in multi-media inspections and compliance activities at Federal facilities. ~ Managing tracking, oversight, and compliance planning activities. These activities include updating 'the FFTS and STARS databases, maintaining records on Federal facilities enforcement actions, and preparing routine briefings for the Regional Administrator and Deputy Regional Administrator on Federal facilities issues. FFCs also ensure that Federal facilities issues are addressed in EPA/State Enforcement Agreements. Page 8 ------- ~ Managing Federal facilities environmental management program plans. FFCs coordinate and provide training for the review of these plans. FFCs also communicate information about the planning process to both the Regional office and the Federal facilities. ~ Providing program assistance, training, and outreach for Federal facilities. FFCs conduct Federal facility program review visits and help coordinate training opportunities available to Federal agencies. In addition, FFCs establish interagency forums such as annual Regional Multi-Media Federal Facilities Conferences and quarterly roundtable meetings used to disseminate information and discuss critical issues. 4 Encouraging P2 at Federal facilities. FFCs conduct Pollution Prevention Opportunity Assessments, in cooperation with the Regional P2 coordinator; evaluate P2 projects reported through the Federal agency environmental management project planning process and help Federal facilities develop P2 programs by providing information, identifying opportunities, and fostering technology sharing among Federal facilities. By providing a contact for enforcement, compliance, and outreach activities, FFCs streamline the Federal facility compliance and enforcement process for both Federal facilities and Regional and Headquarters personnel. A list of Federal Facilities Coordinators appears at the end of this brochure. Page 9 ------- Questions and Assistance Federal Facilities Enforcement Office Barry Breen, Director . . (202) 564-25)0 Craig Hooks, Assoc. Director ........ (202) 564-2510 Joyce Olin. Sr. Counsel (202) 564-2582 Site Remediation and Enforcement Staff Sally Dalzell, Director (202) 564-25S3 Planning, Prevention, and Compliance Staff James Edward, Director (202) 564-2461 EPA Regional Federal Facility Coordinators i Anne Fenn (61?) 565-3927 II Bill Lawler (212)637-3491 in Eric Ashton (215) 597-9857 IV Dave Holroyd (404)347-3776 V Lee Regner (312)353-6478 VI Joyce StubbleHcId (214)665-6430 VII Jamie Drakev (913)551-7400 Vlfl Dianne Thiel <303)312-6559 IX Sara Segal (415)744-1575 X David Telia (206)553-1327 Written inquiries can he addressed to: Federal Facilities F.nforccment Office U.S. Environmental Protection Agency 401 M Street S.W. (2261 A) Washington, DC 20460 FAX: (202) 501-0069 ------- |