Publication Number 540s20001
Summary of Early Engagement with our Partners for the
FY 2022-2023 OLEM National Program Guidance
November 13, 2020
Process for Soliciting Early Input
In August 2020, OLEM's Assistant Administrator initiated early engagement with our partners by
notifying state, tribal and local government partners of OLEM's approach to discussing priorities for FY
2022-2023. Within these email communications, OLEM briefly described the process by which it would
seek input from its partners and included a list of meetings when priorities would be discussed. The
communication also included a link to OLEM's FY 2020-2021 National Program Guidance (NPG) as the
basis for our thinking as we consider priorities for FY 2022 and beyond.
During the early engagement period, OLEM program offices held conference calls and web-based
meetings with state, tribal and local partners to discuss priorities and other important issues. Written
comments also were received. The results of OLEM's early engagement process are summarized below.
Date(s)
Venue
Priorities/ Issues Raised by State, Tribal or Local
Partner
6/4/20
7/23/20
8/19/20
Virtual Corrective
Action Stakeholder
Outreach Meetings
and Roundtables
with ASTSWMO
and States
Discussed stakeholder input to development of RCRA Corrective
Action 2030 Vision/Mission/ Goals. Priorities included:
Adjusting universe of facilities in the cleanup pipeline
Long term stewardship for cleanups
Effective and efficient cleanup, including addressing emerging
science issues, off-site receptors, and operating facilities
Measures, commitments, and priorities
7/29/20
8/19/20
Virtual Corrective
Action Tribal
Partner Outreach
Meetings and
Roundtables
Discussed tribal input to development of RCRA Corrective Action
2030 Vision/Mission/Goals. Priorities included:
Involve tribes early and throughout the cleanup process, including
remedy selection
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Focus on human health and the environment
Utilize tribal members for cultural resource monitoring
8/4/20
Monthly
ASTSWMO Tanks
Subcommittee
Conference Call
Emerging fuels
Investing in new UST infrastructure helps identify past problems
and prepare systems for new fuels
COVID related budget impacts will be significant; federal funding
essential
8/12/20
8/19/20
Virtual Corrective
Action Stakeholder
Outreach Meetings
and Roundtables
with the Local
Government
Advisory
Committee
Revitalizing
Communities
Workgroup
Discussed stakeholder input to development of RCRA Corrective
Action 2030 Vision/Mission/Goals. Priorities included:
Focus on human health and the environment
Addressing off-site contamination
Effective engagement and involvement
August
17-20,
2020
Tribal Lands and
Environmental
Forum Virtual
Gathering
Identify all tribes that have an OLEM-recognized emergency
response program and create a contact list so tribes can
communicate with each other
Prioritize prevention of releases by increasing the number of AST
inspections, either by EPA or federally credentialed tribal
inspectors
EPA personnel should participate in regional FEMA exercises, and
work with tribal colleagues to foster cross-agency cooperation and
communication
Facilitate tribal use of National Response Center communications
and outreach tools at national and local levels
8/25/20
Monthly Regional
UST Program
Manager Call
Priorities included getting our records digital, updating databases,
increasing compliance rates in Indian country, finalizing state
regulations, SPA, severe weather impacts/resiliency, alternative
fuels, high non-compliance at marinas, recruitment/retention of
UST personnel, and using brownfields and other sources to assist
with cleanup
9/2/2020
ASTSWMO Federal
Facilities
Monitor long-term remedies and ensure they remain protective
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Subcommittee
Conference Call
Ensure ARARs are identified and implemented
Work collaboratively with state and federal agencies to address
contaminants of emerging concern, including perchlorate, PFAS,
and 1,4-dioxane
Participate in the implementation of the Military Munitions
Response Program (MMRP)
9/16/20
Tribal and EPA UST
Contacts Call
None
9/10/20
Tribal Waste and
Response Steering
Committee Bi-
monthly Call
EPA should acknowledge the enormous stressors (economic,
resource, emotional, etc.) that tribes are experiencing as a result
of COVID19. These stressors may have repercussions in tribal
environmental programs for several years and EPA should ensure
the NPG provides flexibilities that consider and reflect this reality
Cost matches can be difficult for tribes to implement, especially
during COVID19 (and may continue for years)
Expand opportunities for brownfields work in Indian country
EPA Region 7 engagement with tribes on USTs (monthly calls to
discuss compliance) could be a model for other regions working to
improve Indian country compliance with tank regulations
Ensure tribes are included and tribal issues/experiences
considered in the National Recycling Framework
Tribes will have high interest in the stated work of the new Office
of Mountains, Deserts and Plains; EPA should ensure tribes are
included in any new sections for that office
Continue to build capacity for tribes to take on assessment and
cleanup work at Superfund sites
Ensure tribes are considered in the permitting process at specific
sites of interest (for example, permitting to reopen Stibnite Mine)
10/8/2020
OLEM/ECOS Early
Engagement Call
Importance of continued adequate and flexible federal funding
Member state hired Environmental Justice (EJ) coordinator to
integrate EJ throughout their programs and asked how to further
these efforts with federal partners under limited budgets
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Anticipate additional brownfields due to increased bankruptcies
related to the coronavirus pandemic; state resources also may be
constrained due to increased focus on PFAS
Microplastics in water has its origin as a waste issue. Recycling is a
priority - becoming more pressing, as time goes on
10/20/20
ASTSWMO
Remedial Action
Focus Group
[Summary of written comments upon reviewing the FY 2020-2021
OLEM NPG]
Current document states that 255 additional Superfund sites RAU
site-wide, additional information could be provided on how that
long-term goal or specific number was obtained
Consider role of EPA Environmental Justice program in supporting
communities or providing information and resources on site clean-
up
Leverage and integrate new technology: incorporating information
on the TRIAD approach
Agree that top priorities are protecting human health and the
environment and cleaning up sites
Consider including states in identifying work-sharing opportunities
along with EPA HQ and regions
Under the Strengthen Partnerships and Community Engagement
heading, suggest adding an objective to review the 2019 memo
regarding EPA and State Cooperative Efforts at Superfund Sites and
then further develop new strategies to strengthen partnerships
with states
In reference to the direction under the States and Tribes marker,
"Collaborate and coordinate with OLEM on program
implementation plans or activities to achieve environmental goals,
as appropriate," there are more aspects of state involvement that
should be strengthened. This is a statement on what is asked of
the states and tribes regarding participation, but in turn the
National Program Guidance should showcase the partnership and
role the state have under CERCLA and how EPA will help foster
that
10/20/20
ASTSWMO
Investigation and
Remedy Selection
Focus Group
[Summary of written comments upon reviewing the FY 2020-2021
OLEM NPG]
Page 7 bullet currently states:
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Continue to foster strong partnerships with states, tribes, local
governments, and other federal agencies on site assessment, risk
assessment, remedial responses, community engagement and
revitalization
Proposed change:
Continue to foster strong partnerships with states, tribes, local
governments, and other federal agencies on site prioritization, site
assessment, risk assessment, remedial responses, regulatory
requirements, community engagement and revitalization.
10/20/20
ASTSWMO CERCLA
Post Construction
Focus Group
[Summary of written comments upon reviewing the FY 2020-2021
OLEM NPG]
Our state's Federal Project Unit periodically meets (at a minimum
annually) with the EPA Region to discuss all projects. This is a great
way to sort out any misunderstandings and to align on our
positions to move projects forward. Additionally, we hold regular
meetings with EPA and, as a result, are fully engaged on issues and
improvements
10/26/20
ASTSWMO Annual
Meeting
None
Next Steps
OLEM and the EPA regional offices will consider the early input received from state, tribal and local
partners in developing the FY 2022-2023 National Program Guidance.
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