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SP.TE OF W.1,SHINGTON

DEPARTMENT OF ECOLOGY

December 4, 1989

TO: Tom Eaton

FROM: Cindy Gilder ,

Hugh O'Neill ~~i:" C .

1

SUBJECT: HSWA Strategy

This memo is our analysis from the HSWA questionnaire. Overall, the

response rate was successful; 13 out of 20 (65%) organizations questioned

responded. Twelve of the 13 respondents said they had experience implementing the HSWA program. Although not all of the respondents gave uniform

answers, enough trends existed to use the information for making decisions.

We have separated our analysis into three general categories: Resources,

Organizational Structure, and Implementation. A recommendation follows

each synopsis. One overall follow-up action would be to conduct further

information gathering with NJ and MN. Their response indicates that their

programs are significantly developed. It might be useful to question their

management as to the feasibility of our approach.

RESOURCES

Three questions were asked: What are the big costs? How much does it

cost? What skill mix is needed?

Costs

The FTE analysis varied significantly (see Attachment A). Several factors

may have influenced the variation. EPA's FTE distribution is strongly

influenced by the number of treatment/storage/disposal facilities. Hence,

their FTE/universe ratio is more uniform. Conversely, the state grant .

formula incorporates other variables into' the distribution process. In

addition, the grant dollars are augmented by state funding. The result is

significant variation in an FTE/universe ratio.

The cost/activity ratio appears to be more uniform. Several EPA Regions

use EPA HQ model to estimate cost s, Attachment B is a partial summary of

the high cost activities for initial corrective action activities. Additional follow-up is being conducted with GA, MN, and NJ to gain a better

understanding of their response. A cursory evaluation shows if WA wished

to implement the corrective action process at all entities, 13 FTEs would
Tom Eaton

December 4, 1989

Page 2

be needed to conduct RFAs, 46 FTEs would be needed to impose RFIs, and 69

FTEs would be needed to oversee the RFIs. We expect funding 69 FTEs is not

realistic and believe further evaluation and policy direction is needed.

Once this is discussed (and the additional data is obtained), we propose to

build-up a resource need model.

The final analysis must incorporate contractor funding. EPA receives a

substantial amount of contractor funding (1-3.3 million dollars/region/

year); the dollars augment regional capacity primarily in the corrective

action area. Hence, the impact of this funding must be considered.

The level of funding (a significant amount over minimum match) did not

correlate with the state's view of their job of taking on HSWA. GA and TX

felt that they did an excellent job taking on HSWA (Implementation Question

4). The majority of their funding (75%) is provided by EPA. GA's program

is not broader than EPA's; TIC noted some broader ·authorities for release.

(We might guess this has limited resource implications.) The conclusion

from this data is that additional funding may not be the only key to

success.

A comparison of where an organization placed its resources against what it

viewed as its priorities showed inconsistencies. This was especially true

in analyzing EPA responses. The inconsistency provides another reason for

not utilizing the FTE/universe comparison. In addition, the priority

question (General Question 4) may not have been worded correctly.

Skill ~ix o

The skill mix required appeared to be more uniform. In general, the

staffing plan outlined below represents the range of responses.

Staffing Plan

Function % Total

~anagement

Administrative/Planners

Engineers

Hydrogeologists

Scientists

5-15

10-30

20-50

5-30

20-50

Attorney and laboratory support is also needed; an estimate cannot be

provided as many of the respondents indicated this support was provided

outside their organizational unit. .In general. the staffing plan is

consistent with our initial expectations; the majority of individuals

should have degrees in science or engineering with support from hydrogeo1ogists. Planners and management would provide overall program direction and

supervision. It is important to note that turnover was indicated. as a

o -------------- - - _._--- -~ ---..- ------

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Tom Eaton

December 4, 1989

Page 3

problem the majority of the time; the states indicate the promotion opportunities (or lack thereof) are the primary turnover reason. In order to

mirtimize this eventuality, junior level employees should be recruited. A

career ladder should be established to allow for uncontested promotion.

Management should be made aware that the first six months of employment are

often the most critical (in terms of how an employee feels about an organization). "Nurturing" combined with the opportunity for some promotion, may

reduce the turnover rate. Some senior level employees will be needed; one

state suggested using a team approach toward site management. We support

this concept as it would serve several functions: it would transfer

technical and programmatic knowledge from senior to junior employees and

inc~ease the promotion potential of the senior level employees (they would

gain experience in management functions).

ORGANIZATIONAL STRUCTURE

The majority of the respondents (70%) favored a technical centralized

section. This structure was favored even by organizations that have

decentralized' structures. Given this information, implementing a centralized structure to the maximum extent possible is desired. Given the ___

political realities of the existing state organizational philosophy, HSWA --

responsibilities will need to be split into both centralized and decentralized units. . Although problems may exist which might not have otherwise, the benefits should outweigh the costs. Implementation activities

which relate closely to the existing program (Le. , land ban inspections,

evaluating of new waste streams) could be conducted totally by the regional

offices. Corrective action activities could be split dependent on the type

of activity to be performed; the assessment (RFA) could be conducted by the

regional offices. A statewide ranking system would need to be developed to

prioritize which sites had RFI's imposed. (This is currently being done by

the Northwest Corrective Action Workgroup.) This uniform ranking system

would then allow management to allocate resources where there is the

greatest environmental need. Imposition of the RFI would be done either by

the regional office (when enforcement was the chosen vehicle - if this or a

comparable authority can be "delegated") or by the Permits Section. Once

the RFI was imposed, the site could move to a centralized section fOL_oversight and remedy selection (possibly, the Clean-Up Program). Attachment C

illustrates the initial corrective action process showing the proposed

responsibility unit.

The proposed structure should satisfy most of the organizational needs --

having the regional offices involved with the process and utilizing clean-up

expertise. Difficulties in managing entities may arise. Unfortunately,.

sites rarely flow through the corrective action process precisely as the

process is designed. Specific contaminated areas (Swlrus) within the

facilities boundary may be further along the corrective action process than

others. This could cause a facility to "bounce" back an forth between

offices. One solution could be to turn the responsibility to the centralized section for both information gathering and oversight activities.
Tom Eaton

December 4, 1989

Page 4

IMPLEMENTATION

A phased approach to accepting HSWA respon~ibility was clearly the chosen

method (five out of six respondents) .. Although CA did indicate that they

took on responsibilities all at once and this approach was excellent, we

would be cautious in adopting CAls philosophy. EPA generally implemented

the HSWA all at once. We believe no other options existed for EPA. In.

general, their assessment was this worked fairly well.

EPA was seen by the states has having HSWA expertise. Formal training was

mentioned several times as the mechanism for transferring expertise.

Overlap from Superfund was rated either non/little (46%) or moderate (54%).

This would indicate that there should not be an expectation that Superfund

site managers will want to become RCRA site managers.

CC:HO:ss

Attachments

cc: Rick Renaud

o

c

o
•

ATTACHMENT A

Resource Analvsis ,

R1 R2 R4 RS R7 R8 R10

Total FTE/Universe .21 .08 • 17 .18 .16 .50 .25

HSWA FTE/Universe .07 .06 .10 .05 .20 .08-.13

HSWA FTE/Total Staff .33 .75 .58 NR .30 .40 .33-.50

Total FTE/Working TSDF .21 .40 NR .28 .20 .50 .80

HSWA FTE/Working TSDF .07 .30 NR NR .06 .20 .26-.40

GA ID MN NJ PA TX WA

e Total FTE/Universe .48 1.64 1.28 .43 .14 .01 .72

HSWA FTE/Universe NR NR .32 .11 NR NR

HSWA FTE/Total Staff NR NR .25. .25 NR NR

Total FTE/Working TSDF .48 .61 1.28 .43 ~R

HSWA FTE/Working TSDF NR NR .32 .11 NR NR

NR • No response.
ATTACHMENT B

Activity Cost

G

R1/R4 R2 R5 R7 EPA/Hq Average

RFA •1 •1 .08 .27 •1 .14

Consent Actions .36 .3 .6 - 1.14 .68 ".36 .49 - .62

Unilateral Actions .4 .2 N/A .91 •?? .5

RFI .73 .6 .57 1.09 .73 .75

Permit Modification

RCRA .14

HSWA .55 .5

0

Interim measures?

Values in FTE/Year/Site

o - - ---------------------------------
Responsibility Unit

Regional Office

Regional Office/

Management Team

Regional/Permits

Office

ATTACHMENT C

Corrective Action Process

Activitv,

Identify TSD Facilities

Gather Preliminary

Information

Initially Screen and Rank

FaciH ties

Complete RFA

Release?

Decision to Determine

Type and Priority of

Action Per NW Corrective

Action Strategy

Issue Permit or Order

Public Participation

(Permit Only)

Centralized Unit Submits RFI Proposal

Implements RFI

Submits RFI Proposal

Submits RFI Proposal

Review and Approve

Oversees

Review and Approve

Review and Approve

Sets MPS