Environmental Protection

Agency

Compliance Assurance

(2261A)

Winter 1998

DOJ Ruling Gives EPA CAA Penalty Authority 

Against Federal Agencies

an environmental bulletin for federal facilities

ISSUE #5

T

he Department of Justice has

resolved a dispute between EPA a n d

the Defense Department by giving

E PA the authority to require federal

agencies to pay penalties for violations of

the Clean Air Act. The decision came on

July 16, 1997, from DOJ’s Office of Legal

Counsel (OLC), in accordance with Executive Order No. 12146. The dispute

between EPA and DoD originated from

the two agencies’ differing interpretations

of whether federal agencies are subject to

field citations under Section 113(d) of the

Clean Air Act. 

OLC decided that EPA has penalty

authority not only under section 11 3 ( d ) ,

but also under sections 205(c) and

2 11(d)(1), against federal agencies for violations of the CAA using the clear express

statement standard. OLC affir m a t i v e l y

ruled that EPA has penalty authority for

stationary source and mobile source

2 Guest Spot: Charles Bravo

3 Historic First for Project XL

and ENVVEST

4 In the News

5 America Recycles Day

6 P2 Assessment at Training 

Center Cape May

7 EMRs 

8 The Hammer

1 0 Online with Enviro$en$e 

and Envirofacts

11 Conference Update

1 2 Upcoming Events

requirements, not merely field citation authorit y. FFEO has included

new language in the

FY98-99 Memoranda of

Agreement between

E PA Headquarters and

the Regional Offic e s

emphasizing the importance of including federal facilities in upcoming

regional CAA i n s p e c t i o n

and enforcement efforts. In addition,

FFEO will be issuing guidance this

spring implementing this new authority.

The decision is also significant because

DOJ determined that EPA has penalty

authority against federal agencies under

any law provided that the statute clearly

provides the authority, regardless of

whether the waiver of sovereign immunity would be considered broad enough to

subject the federal agencies to penalties

assessed by those outside the federal government. EPA now has administrative

order and penalty authority against federal facilities under several other environmental laws including the Safe Drinking

Water Act, RCRA (underground storage

tanks and hazardous waste), and the lead

requirements added by Congress to TSCA

in 1992. 

I ns i d e

Fe dFa c s

E PA Cites U.S. Mint for Clean Air Act Vi o l a t i o n s

E

PA announced on January 26, 1998 that it has cited the U.S. Tre a s u ry for Clean Air Act (CAA)

violations at the United States Mint in Philadelphia. This is EPA’s first CAA penalty order against

a federal facility using its newly clarified authorities (see article above).

In the administrative complaint issued January 23, 1998, EPA charges that the Mint violated

regulations governing the emission of chromium compounds and chloro flu o rocarbons (CFCs). EPA

seeks a $129,400 penalty for these violations.

An EPA inspection revealed that the Mint failed to comply with regulations which reduce pollution from chromium compounds. EPA alleged that the coin-making site violated testing, monitoring, and operation and maintenance re q u i rements for chromium electroplating since January

1997. Chromium compounds are regulated as hazardous air pollutants under the Clean Air Act.

Hexavalent chromium, one such chromium compound, is a known carcinogen causing lung cancer and other non-carcinogenic, toxic eff e c t s .

The October 23 inspection also uncovered violations of Clean Air Act regulations on the re p a i r

and servicing of equipment containing CFC-based refrigerants. 
M

oving A m e r ic a ’s mail is big

business. It takes a

lot of energy,

resources, and people to handle more

than half a billion

pieces of mail each

and every day. It

also takes a whole lot of cars, trucks,

planes, fuel, buildings, and pieces of

paper, which has the potential for a lot

of pollution and waste. In an organization of the size, scope, and influence of

the Postal Service, which touches nearly

every American every day, it is important to develop policies that protect our

air and water quality, prevent pollution,

save energy, control waste, and develop

environmental technologies that will

lead us into the future. 

Environmental issues affect our core

business. To address environmental

issues in an integrated way, the Postal

Service has developed an Environmental

Strategic Plan, which is built on a twopronged strategy of leadership and compliance. A “Greening of the Mail” Ta s k

Force, which includes representatives

from the U.S. Conference of Mayors,

ADVO, Direct Marketing Association, and

E PA, was created in 1996 to identify new

business opportunities, increase recycling, and help make the mail more environmentally friendly. 

The Postal Service’s commitment to

the environment includes many innovative products and projects. For example,

we operate one of the largest and most

successful recycling programs in the

nation. Last year we recycled more than

one million tons of waste paper and other

materials, generating $8 million, and we

purchased more than $160 million worth

of products containing recycled materials.

In addition, all of our Priority and

Express Mail envelopes and packages

contain recycled materials. We also are

one of the nation’s largest user of recycled

motor oil and retreaded tires.

We have the largest fleet of alternative-fuel delivery vehicles in the nation —

nearly 7,300 of our vehicles have been

converted to compressed natural gas. We

have reduced our use of targeted hazardous chemicals by 50 percent and our

use of underground storage tanks by

about 25 percent.

In a pilot test in North Carolina, we

are replacing our gasoline-powered lawn

mowers with quiet, cordless, battery-powered mowers. According to EPA, these

battery-powered lawn mowers result in a

99 percent reduction in pollutants such as

carbon monoxide, hydrocarbons, and

methane. They are also cheap, costing

less than $4 a year for electricity.

Some of our most creative environmental products have come from recycling

undeliverable mail, which not only

reduces waste and pollution, but also

saves landfill fees and hauling costs. We

have turned such mail into such innovative products as rich soil compost and pencils. The soil is now growing vegetables at

Texas A & M University, and the pencils

are being tested by our employees and

school children in A l a b a m a .

We also have replaced 25,000 Exitlights in facilities nationwide with lowe n e r g y, longer-burning lights, saving

$500,000 in energy costs and six million

pounds of greenhouse gases; and we have

replaced four million pallets with long-life

plastic types.

That all sounds pretty impressive, and

it is. But the Postal Service is not resting

on its environmental laurels. Most of our

environmental efforts in the past have

been based on preventing pollution, and

that is a sound practice, both from a business perspective, and as a means of

achieving environmental compliance. But

the Postal Service wants to do more than

just comply. We want to lead the environmental fight. To protect the future of our

employees and customers and their families, we are committed to sustainable

development. We are moving beyond

efforts that save the environment to

efforts that r e n e w the environment. 

For example, we recently broken

ground on a “green” showcase facility in

the Dallas area that will be built out of

materials with recycled content, will have

natural and energy-efficient lighting, and

will use natural landscaping and water

conservation. Natural landscaping, which

means using plants that are well-suited to

the climate and water conditions of the

area, minimizes the use of pesticides and

saves water.

The main mail processing plant in

Santa Barbara just received a Federal

Energy and Water Management Award in

recognition of its “demonstration garden,”

which incorporates drought-tolerant vegetation, use of reclaimed water, and integration of existing wetlands into its

design. The reclaimed water is used for

irrigation and is plumbed into the building to flush toilets.

F o r t u n a t e l y, all that we are doing that

is good for the environment is also good

for the bottom line. Recycling and conserving energy save the Postal Service

m o n e y, which means we can deliver

A m e r i c a ’s mail at a lower cost. For example, the money the Postal Service made

from recycling increased by 60 percent

last year, and that doesn’t include the

money saved from fewer trash pickups

and landfill fees.

The Postal Service is meeting the environmental challenges of the future with

enthusiasm and creativity. Our environmental team is working hard to improve

the quality of life and sustain and renew

the environment for our customers, our

employees, and for all Americans. We are

committed to being a good environmental

neighbor in every community we serve

and leaving the environment better than

we found it.

Charles Bravo

M a n a g e r, Environmental Management Policy, U.S. Postal Service

G u e s tS p o t
A

landmark agreement w a s

signed on November 3, 1997 which

allows the Air Force to reduce environmental program costs and apply savings

directly to clean-up programs on Va n d e nberg Air Force Base, CA. 

The final project agreement was a collaborative effort on the part of many

stakeholders and agencies over the course

of a year and a half. The agreement

d e fines milestones which are part of President Clinton’s “reinventing government”

initiatives to promote regulatory fle x i b i l it y. This is the first EPA Project XL ( e X c e llence & Leadership) taking place at a federal agency and the first Department of

Defense ENVVEST (Environmental Investment) Air Quality

I n i t i a t i v e .

Vandenberg is expected to

serve as a model for cleaner air

programs at other bases

throughout DoD. At the signing

c e r e m o n y, Tad McCall Deputy

Assistant Secretary of the A i r

Force for Environment, Safety

and Occupational Health, called

the FPA a “prototype for

progress without pollution!”

For more information, contact John

Walser at 415-744-1257 or Sara Segal at

415- 744-1569.

Historic First for Project XL/ENVVEST in Region 9

N

ationwide, 27 multi-media i n s p e ctions were performed at federal facilities during FY97 in a coordinated effort

by EPA and state inspectors. Each

inspection covered a minimum of two

environmental statutes (one of which

was either RCRA, CWA or CAA) at each

f a c i l i t y. Overall, inspections covered

RCRA, CAA, CWA, TSCA, EPCRA,

FIFRA, and SDWA program requirements. 

The multi-media inspections took place

at 20 DoD facilities, three DOE facilities,

and four civilian federal agency facilities.

Regions 1, 4, and 8 had the largest share

of the inspections (16 out of 27). Regions 2,

3, 6, 9 and 10 performed the remaining

eleven inspections (see box).

Multi-media inspections are part of

F F E O ’s Federal Facilities Multi-Media

Enforcement/ Compliance Program initiated in FY93. In FY95, multi-media

inspections were incorporated into

Regional base inspection programs. Over

the five-year period FY93-FY97, EPA

Regions have conducted a total of 169

multi-media inspections. 

Region 1

US Postal Service, Boston, MA

DOJ Federal Correctional Institution, 

D a n b e rry, CT

RI Army National Guard, Quonset Pt., RI

RI Air National Guard, Quonset Pt., RI

Region 2

DOE Brookhaven National Laboratory, 

Upton, NY

US Arm y, Ft. Drum, NY

Region 3

Quantico Marine Corp Base, VA

Oceana Naval Air Station, VA

Region 4

Naval Submarine Base, Kingsbay, GA

US Army Redstone Arsenal, Huntsville, AL

DOE, Oak Ridge, TN

Naval Station Mayport, FL

US Air Force Plant #6, Marietta, GA

Region 6

USAir Forc e - Tinker MTC, Midwest, OK

US Navy, Corpus Christi, TX

US Army Ammo Depot, TX

Region 8

M a rty Indian School (BIA), Yankton Sioux, SD

FE Wa rren Air Force Base, WY

VA Fitzsimons Army Hospital, CO 

US Arm y, Ft. Carson, CO

DOE, Naval Petroleum Reserve No. 3, 

C a s p e r, WY

US Army Dugway Proving Ground, UT

DOD Rocky Mountain Arsenal, CO

Region 9

Pearl Harbor Naval Complex, Pearl Harbor, HI

(included three facilities: Naval Interm e d i a t e

Maintenance Facility; Naval Station Pearl

Harbor and Fleet and Industrial Supply Center)

Luke Air Force Base, AZ

Fallon Naval Air Station, NV

Region 10

US Army Ft. Wainwright, Fairbanks, AK 

Multi-Media Inspections at Federal Facilities

At the signing are Tad McCall, Air Force; John

Wise, Deputy Regional Administrator, EPA

Region 9; Doug Allard, Santa Barbara County

Air Pollution Control District; staff of Va n d e nberg AFB.

FY97 Multi-Media Inspections at Federal Facilities
duplication.” The policy clarifies roles and

minimizes overlapping federal and state

regulatory oversight of cleanups on the

National Priorities List (NPL), and is

intended to lead to more efficient use of

federal and state oversight resources. The

policy furthers the RCRA/CERCLA c o o rdination concepts presented in the September 24, 1996 EPA guidance, “Coordination Between RCRA Corrective A c t i o n

and Closure and CERCLA Site A c t i v i t i e s , ”

and focuses on the unique coordination

issues associated with federal facilities on

the NPL. An appendix to the policy

includes examples of lead regulator

approaches that have been used by states,

E PA, and other federal agencies to

address federal facility cleanup. The policy was developed by a workgroup with

state, federal, and EPA headquarters and

regional office representation. C o n t a c t s :

Helena King, 202-260-5033 (main EPA

contact); Melanie Barger Garvey, 202-564-

2579 (OECA contact). 

E PA Region 6 Aw a rds 

E n v i ronmental Justice 

Grant to Residents Near 

Kelly Air Force Base

E

PA Region 6 awarded a grant in the

amount of $19,914 to the Foundation

for a Compassionate Society to work with

North Kelly Gardens residents who live

near Kelly Air Force Base in San A n t o n i o ,

Texas. The objectives of the one-year project include supplementing the North Kelly Gardens Health Study with medical

p r o files, toxic inventories and risk maps;

making presentations to target audiences,

including DoD, the Greater Kelly Development Corporation, Kelly AFB, local

school boards, etc.; and training local people in identifying environmental contamination and its causes in working toward

pollution prevention and health hazards

prevention. Project Contact: Genevieve

Vaughn, 512-262-2300.

F o rt Pickett U.S. Army 

R e s e rvation Agre e m e n t

S i g n e d

T

he Virginia Department of Environmental Quality (DEQ) and Togo We s t ,

Secretary of the A r m y, signed a “Use

Agreement” on September 30, 1997, for

the Fort Pickett site in Blackstone, Vi rginia. Fort Pickett was placed on the base

closure list in 1995. The agreement provides for Vi r g i n i a ’s continued use of 40,

000 acres of the site for a State A r m y

National Guard training facility. The other 5,000 acres of the site will be transferred to the local reuse committee for privatization. The agreement details DoD’s

i n d e m n i fication of the Commonwealth of

Virginia from any past environmental contamination at the 40,000 acres. EPA is not

a party to this agreement. Currently, EPA

Region 3 is overseeing a preliminary

assessment and site analysis (PA/SI) of

the 5,000 acres which will be privatized.

As requested, EPA provided advice and

assistance to DEQ on the agreement

before it was signed. Virginia included

provisions in the agreement implementing several EPA-suggested pollution prevention initiatives at the Ft. Pickett site.

“Lead Regulator” Superf u n d

Policy Signed for Federal

Facilities 

O

n November 6, 1997, Steve Herman,

Assistant Administrator for OECA,

signed a joint OSWER/OECA p o l i c y, also

signed by Tim Fields, Acting A s s i s t a n t

Administrator for OSWER. The policy was

developed in response to one of A d m i n i strator Browner’s 1995 Superfund A d m i nistrative Reforms to “establish a lead regulator at each site undergoing cleanup

activities under competing federal and

state authorities to eliminate overlap and

The Environmental Justice Small

Grants Program is administered by the

10 EPA Regional Offices. Each year,

approximately $2.5 million is awarded in

a competitive process nationwide. Grants

provide funding primarily to grassroots,

community-based organizations to

address environmental justice concerns. 

For more information, contact Shirley

Augurson, Region 6 Environmental Justice

C o o r d i n a t o r, 214-665-7401 or the toll-free

EJ Hotline, 1-800-962-6215. A summary of

all EJ Small Grant awards for FY97 can

be viewed on the Internet at www. e p a . g o v /

e n v i r o s e n s e / o e c a / o e j . h t m l / .

CAMU Approved at Sandia

National Laboratories 

O

n September 25th, 1997, EPA R e g i o n

6 approved Sandia’s Class III permit

m o d i fication for construction of a Corrective Action Management Unit (CAMU).

Sandia is located in Albuquerque, New

Mexico within the boundaries of Kirtland

Air Force Base. Once constructed, the

CAMU will provide on-site staging, treatment, and containment capabilities for

S a n d i a ’s remediation wastes.

The CAMU application was received

by EPA in July 1996. In a spirit of cooperation and communication among regulators, Sandia, and the public, the CAMU

m o d i fication was approved in 13 months

and EPA received no adverse comments

on the CAMU modification during the

public comment period.

This is the first permitted CAMU for a

DOE facility, the first CAMU in New Mexico, and the first permitted federal facility

CAMU approved by EPA Region 6. Besides

the staging and treatment areas, the

approved CAMU includes a containment

cell with liners and a leachate detection

system. The containment cell is designed

to accommodate 1 million cubic feet of

waste. Only treated remediation waste

will be placed in the containment cell. 

In t he N e w s
Depending on the volume of hazardous

waste accepted at the CAMU, the Environmental Restoration Project at Sandia

will experience a savings of $4-15 million,

primarily due to lower transportation and

disposal costs. The CAMU is a critical

component in Sandia’s efforts to expedite

cleanup, as provided for in “Focus 2006”

(formerly called the Ten Year Plan). The

approval of the CAMU is a significant step

toward achieving DOE’s goal of having all

remediation actions in place at Sandia by

2002. 

For more information, contact Richard

M a y e r, EPA Region 6, 214-665-7442, or

m a y e r. r i c h a r d @ e p a m a i l . e p a . g o v / .

RCRA 7003 Guidance Issued

E

PA issued a RCRA Section 7003

enforcement guidance applicable to

both federal and private parties. Section

7003 orders may be issued to address a

situation when any solid or hazardous

waste may present an imminent and substantial endangerment to human health

or the environment. The guidance

addresses the opportunity to confer with

the Administrator prior to an order

becoming final, as provided in 42 U.S.C.

Section 6961(b)(1). EPA expects that such

an opportunity will not be necessary for

those cases which settle. Specific a l l y, the

guidance lays out the steps to be taken for

a conference, including who should

request the conference, how it should be

requested, and how the results of the conference will be communicated.

N

ovember 13, 1997 marked the fir s t

“America Recycles Day.” Special events

were organized around the country to educate Americans about the environmental

and economic benefits of recycling. Many

organizations helped make the day a success. National sponsors included:

Premier Founding Sponsors:

Steel Recycling Institute

U.S. EPA

Environmental Champions:

Union Camp Corporation

U.S. Postal Service

Recycling A d v o c a t e s :

B F I

The Home Depot

S a f e t y - K l e e n

In Washington, DC, federal workers celebrated America Recycles Day by sponsoring a rally on Freedom Plaza, where federal agencies and other recycling

advocates displayed recycled products

used by their organizations. 

Festivities were enhanced with performances of the EPA M e n ’s Chorus, the

E PA DixielandBand, and the GSA B a n d .

The Department of Commerce’s Day Care

Center children sang for the audience.

And the National Forest Service’s Wo o d s y

Owl and EPA’s Garbage Gremlin made

special appearances. Speeches were given by Fred Hansen, EPA Deputy A d m i nistrator; David Clark, Postmaster of

Washington, DC; and Will Ferretti, Executive Director for the National Recycling

C o a l i t i o n .

For more information on how to “K e e p

Recycling Working: Buy Recycled,”

visit the website at www. s s a . g o v / r e c y c l e .

htm or www. a m e r i c a r e c y c l e s d a y. o r g .

Federal Agencies Celebrate “America

Recycles Day” with D.C. Rally

Co-Chairs of the Federal Steering Committee: George Mohr (Social Security Administration) and Jim Edward (EPA) with National Forest Service’s Woodsy Owl and EPA’s

Garbage Gremlin

E PA Deputy Administrator Fred Hansen

Fe dFa c s

is published by EPA’s Federal Facilities

Enforcement Office. 

Joyce Johnson, E d i t o r

Gilah Langner, Wr i t e r

Robin Foster, L a y o u t

To receive FedFacs in the mail, contact:

Federal Facilities Enforcement Offic e

U. S. EPA (2261), 401 M Street SW, 

Washington, DC 20460

or Fax : 2 0 2 - 5 0 1 - 0 0 6 9

Or Intern e t :

h t t p : / / w w w. e p a . g o v / o e c a / f e d f a c / a n n / i n d e x . h t m l
OECA/FFEO updated the following

environmental auditing guidance documents in FY97:

Generic Protocol for Conducting

Environmental Audits of Federal

Facilities ( E PA 300-B-96- 012A&B,

December 1996). This is the latest revision of the Generic Protocol prepared in

1989 by EPA’s Office of Federal A c t i v ities, and later revised in 1995 by FFEO.

The 1996 version discusses EPA’s 1995

audit policy and reorganizes the protocol

into a two volume set. Both volumes contain the instructions for use of all three

auditing sections or “Phases.” Volume I

includes Phase 1 of the protocol which

focuses on compliance with federal environmental requirements in 16 media and

statutory areas (e.g., air, water, solid and

hazardous waste). Volume II contains

Phases 2 and 3 of the protocol which

detail procedures for conducting environmental management system audits of

T

raining Center Cape M a y, which

trains approximately 4,000 military

recruits per year and houses over 400

full-time Coast Guard personnel, participated in a pollution prevention (P2)

assessment in August 1997.

The Training Center houses a number

of tenant activities that impact the environment. These include aircraft, vessels,

a firing range, maintenance shops, housing, medical services, dining facilities,

and athletic facilities. The Training Center covers approximately 300 acres, about

150 of which are wetlands. Several

endangered species are found on-site,

including species of piping plovers and

least terns, not to mention a lone harbor

seal spotted during the visit.

Coordinating with the Training Cent e r’s Environmental Protection and Safety

Section Chief, Chris Hajduk, and Facilities Engineer CDR Stan Douglas, the P2

assessment focused on the following areas:

hazardous and non- hazardous solid waste

generation and storage; energy conservation; water conservation; TRI releases;

alternatively fueled vehicles; pesticide

usage; ozone-depleting chemicals; EPA’s

list of 17 industrial toxics included in the

33/50 Program; affirmative procurement;

and recycling. 

The assessment recognized the numerous pollution prevention activities already

initiated at the Training Center, which have

helped the installation reduce its purchase

of toxic chemicals, reduce hazardous and

solid waste generation, and reduce energy

consumption. Their accomplishments provide a foundation for further reductions in

waste generation and materials consumpboth facility-specific programs and overall programs managed at an agency’s

headquarters. The Generic Protocol i s

designed to help auditors focus on specific technical issues to determine compliance with environmental requirements

and adherence to good environmental

management practices.

Environmental Audit Program

Design Guidelines for Federal

Agencies ( E PA 3 0 0 - B - 9 6 - 0 11, Spring

1997). This document highlights some

unique issues and considerations related

to conducting environmental audits at

both domestic and overseas federal facilities. The Design Guidelines discuss in

detail: the design and administration of

effective environmental auditing programs, specific steps involved in conducting an environmental audit, the

components of a thorough environmental

management program, and the kinds of

issues that arise and require addressing

in environmental audits. The D e s i g n

G u i d e l i n e s identify the elements of a

sound environmental auditing program,

including management elements and

resources (both human and capital) that

are typically required in establishing an

auditing system. The document does not,

h o w e v e r, provide detailed descriptions of

how to actually conduct an audit, nor of

how to create an environmental management program. The Design Guidelines

should be used in conjunction with the

Generic Protocol in order to create and

undertake an environmental auditing

p r o g r a m .

For more information on environmental auditing at federal facilities, contact

Andrew Cherry, FFEO, 202-564-5011 .

Copies of the Generic Protocol and the

Design Guidelines can be obtained by faxing your request to Priscilla Harrington,

FFEO, 202-501-0069, or electronically at

w w w. e p a . g o v / e n v i r o s e n s e / c e c a / f e d f a c / f f

l e x . h t m l / .

tion. It is critical that the Training Center

apply adequate resources to incorporate pollution prevention concepts and approaches,

implement acquisition and procurement

policies, and to the greatest extent possible,

prevent pollution at its source.

The pollution prevention plan that

resulted from this assessment is based on

current Coast Guard and DOT guidance

and will allow Training Center Cape May

to comply with environmental laws and

requirements. Several P2 projects and

management practices were identifie d

during the review for the Center to consider in carrying out its P2 plan. The Center will also disseminate a pollution prevention policy statement to all affected

individuals in the installation.

For more information, contact: Susan

We i n e r, 202-564-2471.

Environmental Auditing Publications

EPA Hosts P2 Assessment at Coast Guard Training Center
A

n Environmental Management

Review (EMR) is an evaluation of an

individual federal facility’s program and

management systems to determine how

well the facility has developed and implemented specific environmental protection

programs to ensure compliance. EMRs

are consultative technical assistance visits intended to identify root causes of

environmental performance problems.

EMRs are voluntary and are usually initiated by the recipient agency or facility.

They generally focus on one or two of the

following seven components of a fully

developed Environmental Management

System (EMS): organizational structure;

environmental commitment; formality of

environmental programs; internal and

external communication; staff, resources,

training, and development; program

evaluation, reporting, and corrective

action; environmental planning and risk

management. 

In FY97, ten EMRs were conducted by

the EPA Regional Offices at the following

f a c i l i t i e s :

• Region 1: Army Corps of Engineers

dams in Oxford, MA, and South Royalston, MA; Coast Guard Support

C e n t e r, Boston; Coast Guard Buoy

Depot, South Weymouth, MA;

National Park Service’s A r c a d i a

National Park, Bar Harbor, ME;

Army National Guard’s facility in

Camp Johnson, VT. 

• Region 6: Postal Service facility in

Houston; Federal Aviation A d m i n i stration facility, Oklahoma City, OK. 

• Region 8: EPA L a b o r a t o r y, Denver.

• Region 10: Fairchild Air Force Base,

Spokane, WA .

These EMRs were conducted as part

of a pilot program based on EPA’s I n t e r i m

Final Policy and Guidance on EMRs at

Federal Facilities issued in May 1996.

The pilot program will carry over into

FY98 when a number of additional EMRs

are being planned. After the pilot has

been completed, EPA will develop a summary report evaluating the EMRs, and

revise and finalize the Interim Policy as

a p p r o p r i a t e .

Positive Feedback

Results from the EMRs conducted by Region

6 determined that the overall environmental

management systems at the FA Aand USPS

facilities have the elements needed to keep

the facilities in compliance with environmental regulations. However, in order for the

facilities to achieve and maintain the level of

environmental excellence desired, these

management systems must make continuous improvements. 

In Region 1, EMRs conducted at 17

facilities since 1994 have led to a number

of changes at the facilities, including

increases in environmental staff and budgets, and development of cross-media

environmental training for staff/managers. Comments from Federal Facility

Environmental Managers in EPA R e g i o n

1 where EMRs have been conducted

include the following:

“ Very positive experience. The EMR

helped tremendously. It was a great

learning experience. EPA i d e n t i fied the

positives and the areas needing improvement. The EMR energized our Environmental Program.”

“The EMR was very helpful. I like it

when we get suggestions. It is better than

a ticket!”

“I truly applaud the initiative. We

appreciate the cooperative, positive

approach. The EMR also showed my boss

that the EPA is out there and is concerned

enough about our issues to be at our

d o o r s t e p . ”

For more information on EMRs or to

sign up for one, contact your EPA R e g i o n a l

Federal Facility Coordinator (see list on

page 9).

The EPA Region 2 Federal Facilities Pro g r a m

and the US Postal Service (USPS) New Yo r k

M e t ro Area Office will be participating in a

pilot Environmental Management Review

(EMR) project that will focus on policy implementation. Since policy implementation overlaps with a number of EMR focus areas, a special protocol will be developed for this EMR

The project will also have a broader scope

than most EMRs, focusing not only at the facility level, but at the district and area levels as

well. 

The USPS Metro Area consists of :

• Seven Districts: New York City; Tr i b o ro ;

Long Island; Westchester; Central NJ; Nort he rn NJ; and the Caribbean

• 1700 facilities

• 18 vehicle maintenance facilities

• 30 plants (distribution operations)

• 14,000 vehicles

• 85,000 employees.

The long term goals of the project are for

the area EMR to serve as the prototype EMR

model to be implemented at other USPS are a s ;

for both EPA and the USPS to learn about

management system review perf o rm a n c e

m e a s u res; and for the USPS to partner with

other federal agencies in developing EMRs.

For more information, contact Jeanette

Dadusc, Assistant Federal Facilities Coord i n at o r, EPA Region 2, 212-637-3492.

EMR AT US POSTAL SERVICE IN 

NEW YORK METRO AREA

Environmental Management Reviews 

at Federal Facilities
REGION 1

N

aval Undersea Warfare Center,

C o n n e c t i c u t : The Naval Undersea

Warfare Center (NUWC) of the Department of the Navy agreed on September

18, 1996, to pay an $80,625 penalty to settle an EPA complaint alleging violations

of federal and state hazardous waste

management laws at three of its Connecticut locations — two in New London

and one in East Lyme. NUWC researches

and develops acoustic sensing devices for

the Navy. EPA Region 1 and the Connecticut Department of Environmental

Protection jointly inspected the three

NUWC facilities and discovered RCRA

violations. NUWC failed to have a complete contingency plan for responding to

an accidental hazardous waste spill,

failed to properly train personnel, failed

to determine if wastes were hazardous

and therefore subject to federal management and handling laws, and failed to

properly label hazardous waste containers at the facility. Region 1 prenegotiated

a settlement for these violations. A c o mplaint was filed simultaneously with the

consent agreement and order. 

REGION 2

W

atervliet Arsenal, New Yo r k : E PA

Region 2 issued an Air Compliance

Order to U.S. Army Watervliet A r s e n a l

addressing Watervliet A r s e n a l ’s failure to

meet the chromium emission standards

required for chromium electroplating

facilities, as specified in 40 C.F.R. Part 63,

Subpart N. These regulations require

Watervliet Arsenal to operate control

devices that limit emissions of chromium

to the atmosphere. Watervliet A r s e n a l

n o t i fied EPA that it had tested its control

devices (scrubbers) in August 1996, and

found that the devices were not capable of

meeting the regulatory limits (which

became effective on January 25, 1997).

On February 26, 1997, the facility notifie d

E PA that replacement of its scrubbers

would be required in order to comply

with the chromium emissions limits and

that this project would be completed by

no later than December 1, 1997. In compliance with the order, Watervliet A r s enal completed installation of equipment

to control chromium emissions and was

to complete stack testing of this equipment by the end of 1997. 

REGION 4

R

edstone Arsenal, Alabama: In June

1997, EPA Region 4 issued a unilateral compliance order against the U.S.

Army Missile Command, Redstone A r s enal Water System located near

Huntsville, Alabama, for violations of the

Safe Drinking Water Act (SDWA) and its

implementing regulations. Redstone provides water to 22,000 individuals. The

violations included exceeding the MCL

for total coliform bacteria and failing to

meet the total coliform monitoring/

reporting requirements during all the

months from January 1996 to April 1997.

In addition, the system failed to provide

n o t i fication to the public of the violations,

as required. This is the first unilateral

compliance order issued against a federal

facility under authorities contained in

the August 1996 revision to the SDWA. 

In December 1997, EPA’s Region 4

n o t i fied Redstone Arsenal that Redstone

would be assessed a penalty for violations of the Safe Drinking Water Act and

its implementing regulations. This will

be the first penalty assessed since the

S D WA was amended. Settlement discussions are ongoing. To date, Redstone

Arsenal is in compliance with the order.

Fort Campbell (Kentucky/Te n n e s s e e

b o r d e r ) : E PA Region 4 settled a RCRA

case, assessing a $36,000 penalty against

the Fort Campbell Army base located on

the Kentucky/Tennessee border. Fort

C a m p b e l l ’s violations included: failure to

make hazardous waste determination,

failure to correctly label containers, failure to remove hazardous waste from

satellite accumulation areas in a timely

m a n n e r, and failure to maintain emergency equipment. The base is now in

compliance with the order. The original

penalty proposed in the September 1996

complaint was $48,700. 

Memphis Depot, Te n n e s s e e : E PA

Region 4 filed a final order settling a

R C R A case against the DoD’s Defense

Logistics Agency (DLA) military supply

depot located in Memphis, Tennessee. The

order called for a penalty payment of

$12,000. This action settled a September

1996 administrative complaint the Region

filed under RCRA §3008(a) against DLA

(Defense Depot) Memphis, TN which

alleged that the facility stored containers

of incompatible hazardous wastes next to

one another without properly separating

them in accordance with RCRA. The complaint assessed a penalty of $20,000, and

ordered the facility to submit a plan within thirty days ensuring that incompatible

wastes were no longer stored together. The

facility submitted the required plan and

provided the Region with new information

concerning the its storage practices. Based

on this new information, the penalty was

reduced to $12,000.

REGION 5

E

PAAssesses Penalties at Fernald: I n

July 1997, EPA Region 5 resolved a dispute with the Department of Energy over

D O E ’s Fernald facility. In September 1996,

DOE requested an extension to complete

the design of a waste treatment facility,

raising questions about future treatment of

radioactive silo materials. EPA denied the

extension request and DOE invoked dispute resolution procedures as provided in

the Fernald Consent Agreement. The

resulting dispute resolution agreement

addresses schedule revisions, submittal of a

“lessons learned” document from DOE,

implementation of five environmental proT h e H a m m e r
jects that will benefit the Fernald site, and a

cash penalty of $100,000 to be paid by DOE.

Overall DOE will pay approximately

$1,100,000 to resolve the issues with this

dispute through implementing the projects

and the monetary penalty. 

REGION 7 & 10

E

PA Negotiates Two Interagency

Agreements: E PA has completed

negotiations on two interagency agreements (IAGs) under CERCLA Section 120

which call for cleanups by the Army Corps

of Engineers. The cleanups will cost

approximately $34 million. EPA has experienced great success with using IAGs to

coordinate cleanups in that they provide

enforceable schedules, help avoid disputes, and provide the framework for

achieving an expeditious cleanup. One of

the IAGs negotiated with the Corps

addresses contamination at the Formal

Naval Ammunition Depot in Nebraska

(Region 7); the other addresses the Old

Navy Dump Manchester Lab Annex in

Washington (Region 10). Cleanup at the

Old Navy Dump is estimated to cost

approximately $5.4 million, while cleanup

of Hastings should cost about $30 million.

REGION 8

U

.S. Department of the Interior,

Bureau of Indian Affairs, North

Dakota and South Dakota: On December 12, 1997, EPA announced a proposed

agreement with the Bureau of Indian

Affairs under which BIA’s Aberdeen A r e a

O f fice must correct problems with 52

underground storage tanks on nine Indian

reservations in North and South Dakota.

The agreement contains a proposed

penalty of nearly $938,000. BIA may offset

a portion of that cash payment with a SEP

focusing on environmental issues in the

Aberdeen area. Funds for compliance must

come from BIA itself and must not impact

the budget of any tribe or tribal program. 

B I A’s Billings Area Office is included in

the proposed agreement for work it must

do at the Crow Agency in Montana where

fuel had leaked from tanks removed in

1994. EPA has not proposed a penalty in

that case because the cleanup is underway but a “compliance schedule” has been

set to ensure that work is done.

Warren Air Force Base, Wyoming: P u rsuant to the CERCLA Federal Facility

Agreement (FFA) for F.E. Warren A i r

Force Base, EPA Region 8 issued a stop

work order requesting that work being

done at Operable Unit 3, Landfill 6 be

immediately stopped. The stop work

order may be the first issued to a federal

facility pursuant to a FFA. The order was

issued because F.E. Warren proceeded

with construction of the compacted layer

of the evapotranspiration (ET) cover prior

to finalization of the amendment to the

Record of Decision changing the remedy

from a RCRA Subtitle C cap to an ET cove r. Although work on the ET cover has

stopped, EPA and the State of Wy o m i n g

are now evaluating how to control erosion

of Landfill 6’s surface during the winter

season, and how winterization activities

can be accomplished in the context of the

stop work order and the FFA .

REGION 9

U

.S. Department of the Interior,

Bureau of Indian Affairs, Fort

D e fiance, Arizona: On September 30,

1997, EPA filed a compliance agreement/consent order for the Bureau of

Indian Affairs (BIA), Fort Defiance Road

Maintenance Facility, RCRA e n f o r c e m e n t

case. The BIA settlement calls for $48,423

in penalties and undertaking three supplemental environmental projects (SEPs)

costing a total of $585,000. The cash

penalty amounts to 18% of the assessed

p e n a l t y. Under the SEPs, the BIA w i l l

conduct environmental audits at 100

Navajo Nation facilities (primarily

schools); develop hazardous waste management standard operating procedures

for Navajo Nation facilities; and provide

hazardous waste training for tribal and

B I A employees. 

U.S. Department of the Interior,

Bureau of Reclamation, Yuma, A r iz o n a : On September 30, 1997, EPA filed a

compliance agreement/consent order for a

R C R A enforcement case against the

Bureau of Reclamation (BOR), Yu m a

Desalting Plant. This settlement calls for

the payment of $36,769 in penalties and

three SEPs costing $768,712. Under the

SEPs, BOR will conduct compliance

audits and follow-up compliance work at

six BOR facilities and establish enhanced

spill response capabilities, including creating a spill response team, along the Colorado River. 

U.S. Department of Interior, National

Park Service, Hawaii Vo l c a n o e s

National Park, Hawaii: On September

30, 1997, EPA filed a compliance agreement/consent order for the Hawaii

National Park RCRA enforcement case.

The NPS settlement calls for a cash

penalty of $41,100 and one SEP c o s t i n g

$234,875. Under the SEP, NPS will develop hazardous waste management plans

for six national parks and, following

lessons learned from those six, will establish a model hazardous waste management plan to be instituted at all NPL

f a c i l i t i e s .

U.S. Department of the Interior,

Bureau of Indian Affairs, Hoopa Campus, California: In September 1997, EPA

filed an administrative complaint against

the U.S. Department of Interior, BIA,

Hoopa Campus, CA, alleging RCRA h a zardous waste violations and assessing

$260,650 in penalties. The complaint

alleges that at a now-vacated campus facility the BIA stored hazardous waste without

a permit and failed to have an EPAg e n e r ator identification number. All waste has

now been properly disposed of.
E

PA’s Envirofacts database is a

repository for EPA data systems. The

Envirofacts database has been released

to internal EPA users and is available to

the public as an Internet resource. 

Envirofacts is a relational database

implemented in the Oracle Relational

Database Management System

(RDBMS) and is available through the

Envirofacts Warehouse. It contains data

from the following EPA d a t a b a s e s :

• Comprehensive Environmental

Response, Compensation, and Liability Information System 

( C E R C L I S )

• Permit Compliance System (PCS)

• Resource Conservation and Recovery Information System (RCRIS)

• Toxics Release Inventory System

( T R I S )

Tables (LRT), which contain latitude and

longitude information. Future EPA p r ogram systems to be included in Envirofacts are: the Emergency Response Notification System (ERNS), the Biennial

Reporting System (BRS), and CERCLIS3.

The Envirofacts database website provides documentation on the structure and

content of the database and access to

“metadata.” The website also explains

how to connect Oracle access tools to Envirofacts to query and view data directly

from the database via the Internet. 

For more information, contact:

Shashank Kalra, 202-260-3105, or Pat

G a r v e y, 202-260-3103.

The Enviro$en$e electronic network has also moved from its INEL server in Idaho to a new Eart h 2

s e rver at RT P. Enviro$en$e can be reached at w w w. e p a . g o v / e n v i rosense/. F F E O ’s home page

F F L E X has a new address, too: w w w. e p a . g o v / e n v i rosense/oeca/fedfac/ fflex.html/. 

For more information contact: Isabelle Lacayo 202-564-2578, lacayo.isabelle@epamail.

e p a . g o v / .

O nL i n e

E n v i ro$en$e Update

w w w. e p a . g o v / e n v i ro s e n s e

In FY97, E PA initiated 14 enforcement

actions at federal facilities under RCRA.

Nine were informal actions (e.g., notices of

violations), one was a RCRA Section 7003

order at the Washington Navy Yard in the

District of Columbia, and four were RCRA

Section 3008(a) orders. Total penalties

assessed amounted to $442,825 in penalties against federal agencies, including the

Veterans Administration, the Bureau of

Indian Affairs, and the Navy. In addition,

E PA settled 13 penalty cases in FY97, collecting $1,011,524 in penalties and requiring $2,824,639 to be spent on SupplemenP E N A LTIES ASSESSED

FOR FEDERAL UST 

V I O L AT I O N S

In February 1997, FFEO and

E PA’s Office of Underground Storage

Tanks sent a memorandum to the

E PA Regions encouraging them to

conduct inspections and issue fie l d

citations to federal facilities, where

appropriate. Approximately 40

inspections have been conducted

nationwide in this area, resulting in

18 field citations assessing over

$6,650 in penalties. Seven agencies

have paid the fines, including the

Department of Justice, the A r m y, the

N a v y, FAA, and the Veterans A d m i nistration. 

E n v i rofacts on the We b :

w w w. e p a . g o v / e n v i ro

• Aerometric Information Retrieval

System/AIRS Facility Subsystem

( A I R S / A F S )

• Grants Information and Control System (GICS)

• Safe Drinking Water Information

System (SDWIS)

In addition, the Envirofacts database

supplies information from the Facility

Index System (FINDS), which cross-links

facilities in multiple databases; the Envirofacts Master Chemical Integrator

(EMCI), which provides chemical crosslink information for PCS, RCRIS, and

TRIS; and the Locational Reference

tal Environmental Projects. Finally, EPA

settled a RCRA Section 3008(h) order

requiring cleanup at Altus Air Force Base.

Passage of the Federal Facility Compliance Act (FFCA) has enhanced EPA’s

enforcement authority, enabling EPA t o

pursue federal agencies in the same manner that it pursues private parties. Several of these penalty cases were settled with

civilian federal agencies (including the

Park Service, the Bureau of Indian A f f a i r s ,

and the Bureau of Reclamation) which

have not traditionally been inspected to

the same degree as DoD installations. 

EPA Assesses Over $400,000 in 

Penalties Against Federal Agencies
FFEO Attends Meeting 

of National Congress of

American Indians

E

PA’s federal facility e n f o r c e m e n t

program was invited to give a presentation in November 1997 to the Natural

Resources Committee of the National

Congress of American Indians (NCAI),

meeting in Santa Fe, NM. FFEO outlined

E PA’s federal facilities priorities for FY98

and explained how EPA uses a mix of

enforcement and compliance assistance

tools to ensure that federal facilities and

g o v e r n m e n t - o w n e d - c o n t r a c t o r- o p e r a t e d

(GOCO) facilities comply with all applicable environmental regulations. 

FFEO stressed its commitment to

work in partnership with tribes on a government-to-government basis to ensure

the protection of tribal human health,

natural resources and environments.

FFEO also emphasized its commitment to

seek tribal input early in any federal facility enforcement matters that may affect

tribes to ensure that full consideration is

given to the policies, priorities and concerns of the affected tribe and, where

appropriate, to affected tribal members. 

FFEO staff also attended a meeting of

the NCAI Nuclear Waste Policy Committee. Since 1983, the NCAI has had a cooperative agreement with DOE’s Office of

Civilian Radioactive Waste to provide

timely information to, and gaining feedback from, tribal governments. NCAI,

which was founded in 1944 and is the oldest and largest national Indian organization, represents many tribes on potential

transportation routes and emphasizes

safe transportation of spent nuclear fuel.

For more information, contact Wi l l i a m

Frank, FFEO, 202-564-2584.

E n f o rcement Roundtable

Held in Durham, North 

C a ro l i n a

by Darlene Boerlage

E

PA held the second in a series of

Environmental Justice Enforcement

Roundtables in Durham, NC on December 11-13, 1997. The event was hosted by

the National Environmental Justice A d v isory Council and EPA Region 4. The

Roundtable is a forum for federal agencies

to discuss enforcement issues with communities and hear their recommendations on enhancing citizen participation.

A Public Awareness Forum was held on

the first day of the Roundtable, followed

on the second day, by a series of 10 breakout sessions. The Federal Facility

Enforcement breakout session yielded a

number of interesting points and recommendations, summarized here: 

• Community representatives should

be a major player in selecting advisory board members (e.g., RABs).

• Agencies need to implement the Federal Facilities Environmental

Restoration Dialogue Committee

(FFERDC Report) recommendations.

• Reuse of closing bases is not beneficial to communities when “dirty facilities” are transferred prior to appropriate cleanup.

• DOE should decode and redistribute

its report on “external regulations.”

• DOE and DOD should conduct an

internal audit of their Environmental Justice programs, and other EPA

and state government offices should

be trained in environmental justice

issues, including Title VI of the Civil

Rights Act of 1964. 

For more information, contact Darlene at

2 0 2 - 5 6 4 - 2 5 9 3 .

Region 5’s Federal 

Facilities Confere n c e

S

ome 150 environmental m a n a g e r s

from around the country visited Chicago for Region 5’s 1997 Federal Facilities

Multimedia Compliance/Pollution Prevention Conference last July. Included among

the 36 speakers were: Gary D. Vest, Principal Assistant Deputy Under Secretary of

Defense (Environmental Security); the

U.S. Postal Service’s Charles Bravo, Mana g e r, Environmental Management Policy;

the U.S. Air Force’s Colonel Patrick T.

Fink, Director, Pollution Prevention Directorate, and James Edward, A s s o c i a t e

Director of EPA’s FFEO.

The 1997 conference featured two additions to the already-packed roster of speakers, and exhibits: computer workshop

training opportunities in Enviro$en$e, and

tours of the Region 5 laboratory. C i v i l i a n

federal agencies made up about three

quarters of the participants. 

If you have never attended a Region 5

Federal Facilities Conference and would

like to place your name on the mailing list,

contact Rafael Agustin, tel: 312-886-0394,

fax: 312-353-5374. 

C o n f e re n c eU p d a t e

LIST OF ACRONYMS 

C A A Clean Air Act

C E R C L A C o m p rehensive Environmental Response,

Compensation, and Liability Act

C WA Clean Water Act

D o D D e p a rtment of Defense

D O E D e p a rtment of Energ y

D O I D e p a rtment of the Interior

E M R E n v i ronmental Management Review

E PA E n v i ronmental Protection Agency

E P C R A E m e rgency Planning and Community

R i g h t - To-Know Act of 1986 

F I F R A Federal Insecticide, Fungicide, and

Rodenticide Act

F F E O Federal Facilities Enforcement Offic e

( E PA )

N P L National Priorities List

R C R A R e s o u rce Conservation and Recovery

A c t

S D WA Safe Drinking Water Act

S E P Supplemental Environmental Pro j e c t
MARCH 10-12, 1998

First Annual Nationwide Civilian

Federal Agency Enviro n m e n t a l

S y m p o s i u m

D e n v e r, CO

S p o n s o red by the Civilian Federal Agency Enviro nmental Task Force, the audience will be CFA enviro nmental managers and facility level personnel with

e n v i ronmental compliance responsibilities. To p i c s

include: criminal liability, status and trends in media

regulations, lab management practices, enviro n m e ntal auditing, etc. Contact: Will Garv e y, 202-564-2458.

APRIL 28-29, 1998

R e s o u rce Efficient Federal 

Buildings Symposium

Colorado Springs, CO

Contact: Dianne Thiel, EPA Region 8, 303-312-6389 or

t h i e l . d i a n n e @ e p a m a i l . e p a . g o v / .

J U LY 1-2, 1998

Federal Facility 

E n v i ronmental Seminars

Dallas, TX

Topics: July 1: Indoor environment (indoor air, radon,

asbestos, lead, green buildings, energy conserv a t i o n ) .

July 2: Clean Air Act. Registration deadline: May 15,

1998. Contact: Evelyn Daniels, 214-665-7453 (indoor

e n v i ronment) or Te rry Thomas, 214-665-7160 (Clean

Air Act).

AUG. 25-28, 1998

T h i rd Annual Joint Service 

Pollution Prevention 

C o n f e rence and Exhibition

San Antonio, TX

Open forum for exchanging ideas, success stories,

case histories, and technologies related to pollution

p revention. Hosted by the Headquarters Air Forc e

Center for Environmental Excellence. Supported by

the National Defense Industrial Association. Contact:

Christy Kline or Christin Berry, tel: 703-522-1820, fax:

703-522-1885, ckline@ndia.org / .

S E P T. 9-11, 1998

E PA Post-Emergency Response

Issues Confere n c e

Washington, DC

F ree conference focuses on issues of concern to

e m e rgency respondents following a significant radiological release. Contact: Sarah Wallis, 301-652-1900

or www. e p a c o n f e re n c e @ s c i c o m m . c o m / .

Computer Course 

E n v i ronmental Statute Review

C o m p u t e r-Based Training Course

O v e rview of seven major environmental statutes

using a mix of text, narration, graphics, video, and

interactive exercises, aimed at state and re g i o n a l

e n v i o rnmental enforcement personnel. Developed by

the National Enforcement Training Institute. Ord e r

t h rough http://earth2.epa.gov/neti or contact Ellen

Epstein, 202-564-6067.

United States Environmental 

Protection Agency (2261)

Washington, DC 20460

O f ficial Business

Penalty for Private Use $300

Forwarding & Return Postage Guaranteed

Address Correction Requested

FIRST CLASS

POSTAGE & FEES PAID

EPA

PERMIT NO. G-35

U p c o m i n gE v e n t s

REGIONAL FEDERAL FACILITIES COORDINATORS 

Region 1 (CT, ME, MA, NH, RI, VT): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Anne Fenn, 617-565-3927

Region 2 (NJ, NY, PR, VI): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Jeanette Dadusc, 212-637-3492

Region 3 (DE, DC, MD, PA, VA, WV): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . William Arguto, 215-566-3367

Region 4 (AL, FL, GA, KY, MS, NC, SC, TN): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Dave Holroyd, 404-562-9625

Region 5 (IL, IN, MI, MN, OH, WI): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Lee Regner, 312-353-6478

Region 6 (AK, LA, NM, OK, TX): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Joyce Stubblefield, 214-665-6430

Region 7 (IA, KS, MO, NE): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Jamie Bern a rd - D r a k e y, 913-551-7400

Region 8 (CO, MT, ND, SD, UT, WY): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Dianne Thiel, 303-312-6389

Region 9 (AZ, CA, HA, NV, Amer. Samoa, Guam, TT): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Sara Segal, 415-744-1569

Region 10 (AL, ID, OR, WA): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Michele Wright, 206-553-1747

Fe dFa c s