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LHRISTINE Q CilECOIl\E Dtrl'(lQ( SP.TEOFW.1,SHINGTON 

### DEPARTMENTOF ECOLOGY

December 4, 1989

TO: TomEaton 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 HSWAprogram. Althoughnot all ofthe 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 gatheringwith NJ and MN. Their response indicates that their programs are significantly developed. Itmightbe useful to question their management as to the feasibility ofour 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/universeratio. The cost/activity ratio appears to be more uniform. Several EPA Regions use EPA HQ model to estimate costs, Attachment Bis a partial summary of the high cost activities for initial corrective action activities. Additional follow-up is being conductedwith GA, MN, and NJto gain a better understanding of their response. Acursory evaluation shows ifWA wished to implement the corrective action process at all entities, 13 FTEswouldTom Eaton December 4, 1989 Page 2
be needed to conduct RFAs, 46 FTEs would be needed to impose RFIs, and 69 FTEswouldbe needed to oversee the RFIs. We expect funding 69 FTEsis not realistic and believe further evaluation and policy direction is needed. Once this is discussed (and the additional data is obtained), wepropose 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 theirjob of taking on HSWA. GAand TX felt that they did an excellentjob taking onHSWA (ImplementationQuestion 4). The majority of their funding 

### (75%) is provided by EPA. GA's program is not broader than EPA's; TIC noted somebroader ·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. Acomparison ofwhere an organization placed its resources againstwhat 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 nothavebeenworded correctly. Skill**~ix** 

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The skill mix required appeared to be more uniform. In general, the staffing plan outlinedbelow represents the range ofresponses. 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 shouldhave degrees in science or engineeringwith support fromhydrogeo1ogists. Planners and managementwould provideoverallprogramdirection and supervision. It is important to note that turnover was indicated.as a 

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------------- -- - _._---**-~** --- ..- ------ \**~------------_._--------**TomEaton 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 shouldbe made aware that the first sixmonths of employment are often the most critical (in terms ofhowan employee feels about an organization). "Nurturing" combinedwith 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 inmanagement 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 ofnewwaste streams) couldbe conducted totally by the regional offices. Corrective action activities couldbe split dependent on the type of activity tobe performed; the assessment (RFA) could be conductedby the regional offices. Astatewide ranking systemwould need to be developed to prioritizewhich sites had RFI's imposed. (This is currently being doneby 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 wouldbe done eitherby the regional office (when enforcementwas the chosenvehicle

- if this or a comparable authority can be "delegated") or by the Permits Section. Once the RFIwas imposed, the site couldmove 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. Theproposed structure should satisfy most of the organizational needs

-- having the regional offices involvedwith 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 boundarymaybe further along the corrective actionprocess 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.

### TomEaton December 4, 1989 Page 4
IMPLEMENTATION Aphased 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. EPAwas seenby the states has having HSWA expertise. Formal trainingwas mentioned several times as the mechanism for transferring expertise. Overlap from Superfundwas rated eithernon/little (46%) ormoderate (54%). This would indicate that there should notbe an expectation that Superfund sitemanagers willwant tobecome RCRA sitemanagers. CC:HO:ss Attachments
cc: RickRenaud 

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c

o

# • ATTACHMENTA

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/WorkingTSDF .21 .40 NR .28 .20 

### .50 .80 HSWAFTE/WorkingTSDF .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 HSWAFTE/Universe NR NR .32 .11 NR NR HSWAFTE/Total Staff NR NR .25. .25 NR NR Total FTE/WorkingTSDF .48 .61 1.28 .43**~R** 

### HSWAFTE/WorkingTSDF NR NR .32 .11 NR NR

NR• No response.

### ATTACHMENTB
Activity Cost 

# G

R1/R4 R2 R5 R7 EPA/Hq Average RFA •1 •1 .08 

### .27 •1 .14 ConsentActions .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 PermitModification RCRA .14 HSWA .55 

### .5 

# 0

Interimmeasures?

Values inFTE/Year/Site



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- - ---------------------------------

### 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 FaciHties Complete RFA
Release?
Decision toDetermine Type and Priority of Action PerNW Corrective Action Strategy
Issue Permit orOrder
Public Participation (Permit Only)

Centralized Unit Submits RFIProposal Implements RFI
Submits RFIProposal
Submits RFIProposal Review and Approve
Oversees
Review and Approve
Review and Approve
SetsMPS