Summer 2003

Federal Agencies Making Progress 

Implementing E.O. 13148 

Printed on Recycled Paper

an environmental bulletin for federal facilities

ISSUE #15

F

ederal agencies are making considerable progress in implementing Executive Order 13148 Greening the Government Through Leadership in

Environmental Management, and its

broad goals of integrating environmental considerations into day-to-day planning and decision making. This progress

is evident from agency annual reports

and “scorecards”, a new tool used by the

federal government to measure and

evaluate implementation milestones. 

Section 307 of E.O. 13148 requires

federal agencies to report on their implementation progress annually to the EPA.

EPA and the Office of the Federal Environmental Executive (OFEE) will collaborate closely with the President’s Council on Environmental Quality and the

Office of Management and Budget to

review the annual reports and develop a

“scorecard” on environmental management system (EMS) implementation by

federal agencies. 

Guidance on writing this year’s

report was also developed by the InteraInside

FedFacs

3 Fort Meade ISO 14001 Certification

4 DOE E.O. 13148 Implementation

5,6,7 EMS Implementation and Training

8 EPA, VHA Cooperative EMR Initiative

9 EMRs at NASA Michoud and Army Fort

Polk

10 Enforcement News: Ft. Wainwright;

UST Cases

11 Federal Environmental Spotlight and

Awards

12 EPA Regional CWA/SPCC Initiative

13 In Brief: Regulatory Updates and 

Program News

14 Federal Facilities Compliance Center

15 Upcoming Events Calendar

ABOUT THIS ISSUE...

Executive Order 13148 Greening the Government Through Leadership in Environmental 

Management, (April 21, 2000) requires federal agencies and facilities to integrate environmental considerations into day-to-day planning. In this issue, you will read about some of the 13148

implementation activities taking place . 

Successful implementation of E.O.13148 requires the combined and collaborative efforts of

federal agencies, states and others. Many of these efforts will be spotlighted in this issue, as

well as the contributions of a few individuals at the facility level. Environmental management

systems (EMSs) are a key requirement of the Order, and there is considerable focus on EMS

activities at the national and local facility level. 

Federal agencies and facilities are doing a good job of implementing E.O. 13148 – but there

is still challenging work ahead. The EPA, Office of the Federal Environmental Executive, and

other leaders in the federal community are there to guide these efforts and help the federal

government be a role model for cutting-edge environmental stewardship and management,

making a cleaner and healthier work place and environment for generations to come. 

WORKING FOR 

ENVIRONMENTAL 

EXCELLENCE

By John Howard, Federal Environmental Executive

Federal agencies have

worked hard for years

to improve their environmental compliance

and performance.

This effort has seen

several approaches,

including internal compliance assessment, pollution prevention planning,

regulatory compliance assistance, and

environmental management system

(EMS) implementation. Each approach

has had some basis in law, rule, policy,

or Administration priority.

The Office of the Federal Environmental Executive works to promote sustainable environmental stewardship

throughout the federal government,

using these and other approaches. EMS

offers an opportunity Continued on page 4

Environmental

Spotlight

gency Environmental Leadership Workgroup. Guidance focuses on both the

required sections and relevant topics, in

particular agency EMSs and compliance

program implementation. These metrics

recognized the EMS process is evolving

within the federal community and

focused on program development rather

than implementation. 

For calendar year 2002, in addition

to reporting on reduction goals for Toxic

Release Inventory chemicals, Section

503 priority chemical and reductions

and ozone depleting substances, agencies were asked to report on the following areas: 1) EMS policy, including top

management commitment; 2) Determination of “appropriate” facility for purposes of the Order; 3) Identification of

resources necessary for EMS implementation; 4) Guidance for implementing

EMS at agency facilities; 5) EMS training for senior-level managers; 6) Programs to support facility environmental

compliance audits. 

Not all reporting Continued on page 2
2 FEDFACS

FedFacs

is published by EPA’s Federal

Facilities Enforcement Office. 

EPA #300-N-03-006

Marie Muller, FFEO, Editor

Robin Foster, 

Legin Group, Layout

To receive FedFacs

in the mail, contact:

Federal Facilities Enforcement Office

U.S. EPA (2261A)

1200 Pennsylvania Ave, NW

Washington, DC 20460

Phone: 202-564-2510

Fax : 202-501-0069

Internet: www.epa.gov/compliance/

resources/newsletters/civil/fedfac/

index.html

federal agencies have responded, but a

preliminary review of the available

information is summarized below. A

more in depth report on that review will

be completed this summer and provided

to each Agency Environmental Executive and the President’s Council on

Environmental Quality. 

1. EMS Implementation Policies.

Approximately half of federal agencies responding have prepared,

signed and distributed agency policies for implementing EMSs at

agency facilities. Policies range from

brief directives endorsing EMS

FEDERAL AGENCIES MAKING PROGRESS 

IN E.O. 13148 IMPLEMENTATION

Continued from page 1

implementation to extensive delineations of agency EMS goals and

expectations and facility responsibilities to meet those goals. 

2. Determining “appropriate”

facilities under E.O. 13148. Agencies are using the Order’s criteria of

“size, complexity and environmental

aspects, ” and regulatory status of

the facility for determining whether

their facilities must develop and

implement an EMS. In several

instances, agencies included consideration of outside parties’ perspective in identifying appropriate facilities. Several agencies developed an

organizational EMS that will be

implemented across all facilities

with that organization. 

3. Resource allocation. Some agencies implemented a process to identify and quantify supplemental

resources, funds and personnel necessary to develop and implement

EMSs at the facility or organizational

level. These efforts include a review

of private sector organizations’ implementation costs and review of pilot

efforts at agency facilities. Other

reporting agencies concluded that

development and implementation

resources should be supplied from

normal facility operating funds.

4. Agency EMS guidance. Some

agencies developed specific EMS

development and implementation

guidance for their facilities with

milestones and other measurement

criteria that allow consistent review

of agency progress towards EMS

implementation. Other agencies will

promote and use existing EMS guidance and implementation tools

allowing facilities to select and

implement EMS independently.

5. EMS awareness tools for senior

managers. Some agencies developed awareness tools ranging from

background briefings and audiovisual presentations to video tape

training describing the EMS process

and role of senior managers in supporting EMS implementation. Other

agencies expressed a commitment to

senior manager training subsequent

to full development of agency EMS

implementation, and also an interest

in sharing training developed by

other agencies.

6. Agency audit programs. Many

agencies have mature environmental

compliance programs while others

with less developed programs, were

actively reviewing and updating

audit programs. Most mature programs include both internal and

agency oversight audits, and are

pursuing protocols for identifying

and addressing findings revealed by

compliance audits.

FEDFACS ON THE WEB

This and past issues of FedFacs can be

found on EPA’s website at: http://www.epa.

gov/compliance/resources/newsletters/

civil/fedfac/index.html

THE E.O. 13148 INTERAGENCY ENVIRONMENTAL 

LEADERSHIP WORKGROUP

Executive Order 13148 calls for the establishment of an Interagency Environmental Leadership

Workgroup to “develop policies and guidance” required by the Order. While the Workgroup is

chaired by EPA, 18 federal agencies have formal representatives to the Workgroup and responsibilities are shared. Several particular Workgroup efforts such as environmental management system implementation, budget issues review, priority chemical selection, and an analysis of general

training needs, were led by member agencies including the Departments of Defense and Energy,

and NASA. The Workgroup also develops guidance for each year’s annual report on progress

towards the goals of the Executive Order including metrics to prepare the federal agency EMS

implementation “scorecard” issued by the Office of the Federal Environmental Executive. The

Workgroup has developed documents used across the federal government including an EMS

background primer and a budget document explaining how the goals of the Order should be

included in the budget process.

For more information about Workgroup activities, please contact Workgroup Chair Will Garvey

at garvey.will@epa.gov
FEDFACS 3

The U.S. EPA - Fort Meade Environmental Science Center (ESC) is the

first non-industrial “civilian” federal facility to be registered under ISO 14001 for

its environmental management system

(EMS). With its innovative approach to

environmental sustainability and pollution prevention, ESC is protecting the

environment, saving money, and is considered a model for other federal facilities

required to implement an EMS under

Executive Order 13148. 

Located on 25 acres in Fort Meade,

Md., ESC is an analytical chemistry laboratory occupied by EPA’s Region 3

(Philadelphia) and Office of Prevention,

Pesticides, and Toxic Substances (OPPTS)

program laboratories. The Center, which

was commissioned in February 1999, is a

state-of-the-art facility housing 65 scientists and support staff. It has 145,000

grass square feet with 89,000 finished

square feet including over 70 lab rooms.

ESC began designing its EMS in

August 2000, and chose ISO 14001, one of

the primary international standards for

EMSs. EPA Region 3 and OPPTS decided

to invest in the EMS – even prior to the

requirement to do so under E.O. 13148 –

because of a desire to be a good neighbor

in the Fort Meade community and realize

operational benefits like cost savings and

lower risk profile. Now, almost three

years later, a self-directed team of volunteers has led the facility through implementation and ISO recognition.

The Center is reaching the point

where it can measure and point to direct

results and benefits of the EMS. Benefits

of EMS implementation to date include:

1) better cross-facility cooperation; 2)

greater awareness of environmental

impacts and linkage of environmental

aspects; 3) complete documentation of

environmental management programs;

and 4) greater awareness and integration

of Executive Orders. Staff believe

improvements to environmental performance are virtually guaranteed.

As new EMS target initiatives are

launched the Center expects to see more

return on its investment with more pollution prevention, cost savings, and implementation of creative environmental

management practices. The overall goal

is to establish a culture that institutionalizes the consideration of environmental

impacts into everyday management decisions at the ESC.

Designing and implementing the EMS

required about 1.2 EPA full time

employee equivalent (FTE) per year and

included costs of approximately $80,000

for consulting support and $12,000 for

ISO 14001 registration. To maintain the

system, contract dollars will drop significantly and FTE needs will reduce somewhat, perhaps 10-20 percent.

ESC Viewed as a Leader in the

Federal Community

The EPA/Fort Meade Science Center has

received many accolades for its EMS and

related implementation activities. It is

highlighted at ISO

EPA/Fort Meade Environmental Science Center 

Receives ISO 14001 Certification

PERFORMANCE TRACK

EPA’s National Environmental Performance Track program is designed to recognize and encourage top environmental

performers — those who go beyond compliance with regulatory requirements to

attain levels of environmental performance and management that benefit people, communities, and the environment.

Currently, the program has over 300

members. As part of their membership in

Performance Track, program participants

receive a range of incentives to motivate

further improvements. The Performance

Track web site contains extensive information about the program and how to

become a member. It can be visited at:

http://www.epa.gov/performancetrack/

EXECUTIVE ORDER 13148 

“GREENING THE GOVERNMENT THROUGH 

LEADERSHIP IN ENVIRONMENTAL MANAGEMENT”

(Apr. 21, 2000)

Executive Order 13148 is the most recent of a series of “Greening the Government” Executive

Orders and requires the federal government to integrate a broad array of environmental considerations into day-to-day management, decision-making, and long-term planning across agency missions, activities, and functions. 

The Order establishes seven primary goals for federal agencies and facilities. They are: 1)

developing and implementing environmental management systems; 2) ensuring compliance with

environmental statutes and regulations; 3) fully implementing Community Right-to-Know Act

(EPCRA), emergency planning, and pollution prevention programs; 4) reducing releases of toxic

chemicals; 5) reducing use of toxic and hazardous substances where there are known cost- effective substitutes; 6) reducing the use of ozone depleting substances; and 7) instituting environmentally sound landscaping practices. 

E.O. 13148 also established an interagency workgroup chaired by the U.S. EPA’s Federal Facilities Enforcement Office (FFEO) to assist federal agencies in its implementation. (See related box on

page 2).

For more information on E.O. 13148, please contact Will Garvey at EPA’s Office of Federal Facility Enforcement (garvey.will@epa.gov) or Ed Pinero at the Office of the Federal Environmental Executive (OFEE) (edwin_pinero@ceq.eop.gov). The Order itself can be found on OFEE’s website at:

http://www.ofee.gov/eo/eo.htm

Continued on page 14
4 FEDFACS

people coming from throughout a facility or agency to work together on a

shared vision of improved environmental stewardship. An EMS can bring people together – and then who knows what

good they’ll achieve once they’re encouraged to work for the betterment of the

facility and the agency. 

As part of Executive Order 13148’s

broad goal of seeking integration of

environmental considerations into dayto-day management and long-term

planning across missions, activities, and

functions, federal agencies must

develop and implement EMSs by

December 31, 2005. Thanks to some

visionary (and hard-working) folks,

nearly 30 facilities are implementing

EMSs already, more than 170 federal

facilities are actively developing their

EMSs, and hundreds more are getting

educated about EMSs. Congratulations!

Some of these early successes are highlighted in this edition.

We’ve made some great progress, but

we still have challenges ahead. We need

training for facility level implementation as well as for senior manager

awareness. We need to better integrate

EMS with other issues, such as affirmative procurement and sustainable buildings. So, through our office, EPA’s EMS

team, and the interagency EMS workgroup, we’re working to provide assistance – training, materials, mentoring,

workshops, best management practices,

modules, and more.

We’ve also been working closely with

the President’s

to systematically manage not just compliance and performance in the environmental arena, but also for health and

safety, energy, transportation, housing,

and more. Because an EMS is to be tailored to reflect each organization’s

unique situation, each facility can

determine what particular priorities it

wishes to stress. And because it’s not

static, it makes you keep pushing to

continually find even more improvements. In sum, it can help you and others address environmental, safety,

health and other issues as efficiently as

possible so that everyone can focus on

achieving your agency’s core mission.

To me, the most important benefit of

an EMS, though, is not compliance, or

cost reduction, or risk avoidance, or efficiency. Those are important. Instead,

the most important benefit of EMS is

the unforeseeable and positive dynamic

synergy that will flow from a team of

ENVIRONMENTAL SPOTLIGHT

Continued from page 1

The Office of the Federal Environmental

Executive (OFEE) promotes sustainable environmental stewardship throughout the federal

government by identifying, advocating and disseminating sustainability practices across

agencies. OFEE trains agency personnel, and

measures and reports on agencies’ progress.

Visit OFEE website at: www.ofee.gov for more

information on how to prevent pollution at your

facility and incorporate sustainable practices

into its operation.

Continued on page 6

tants into the environment.”

DOE has incorporated the goals and

requirements of the executive order into

its existing environmental directives

and policies. In February 2001, Secretary Abraham signed a Notice assigning

responsibilities for implementing E.O.

13148. In January of 2003, this was

replaced by a DOE-wide Order laying

out requirements and responsibilities

for DOE’s Environmental Protection

Program. The Department is actively

developing guidance to support implementation of these requirements.

For more information about DOE’s

implementation of E.O. 13148, contact

Larry Stirling on EMSs, at 202-586-

2417 or larry.stirling@eh.doe.gov, or

Jane Powers on pollution prevention

issues at 202-586-7301 or jane.

powers@eh.doe.gov, both in DOE’s 

Office of Environmental Policy and

Guidance.

The Department of

Energy (DOE) strives

to be a leader in implementing E.O. 13148. For

Earth Day 2003, Secretary Spencer Abraham

issued a Departmentwide message highlighting DOE’s progress and

challenges in implementing environmental management systems

(EMSs) and meeting its

Pollution Prevention

Leadership Goals.

Seven DOE sites have

been registered to the ISO

14001 EMS standard. Three of these sites,

and two others, are charter members of

EPA’s National Environmental Performance Track Program. All sites have management systems under DOE’s Integrated

Safety Management System (ISMS) policy

and requirements. The goal is

to have EMSs in

place at all these

sites within the

existing ISMS

framework by

2005.

DOE has made

great progress

toward meeting

its Pollution Prevention Leadership goals for

2005, which were

established in

1999. Most of the

goals, however, have not yet been met.

The Secretary charged DOE programs “to

use their ingenuity to reinvigorate their

efforts towards meeting DOE’s 2005 pollution prevention goals for reducing the

generation of waste and release of polluDepartment of Energy Implements E.O. 13148

Raymond Orbach, Director of DOE’s

Office of Science, and Beverly Cook,

DOE Assistant Secretary for Environment, Safety and Health, discuss

the progress and challenge of Greening DOE, at the Department’s Earth

Day display.
FEDFACS 5

FEDS RECEIVE AWARDS FOR E.O. 13148 EFFORTS

Executive Order 13148 states that federal employees who demonstrate outstanding leadership in

implementing the Order may be considered for recognition under the White House Closing the

Circle Awards program. For 2002, five awards were issued in the Education and Outreach and

Environmental Management Systems (EMS) categories recognizing those efforts.

Under the Education and Outreach category, awards were given to the Federal Network for

Sustainability (FNS), and the U.S. Army Forces Command Installation Sustainability Program

(FORSCOM-ISP). The FNS accomplished a number of outreach activities including those

designed to support implementation of EMSs. The FORSCOM effort included a range of activities

to share lessons learned regarding EMS implementation and compliance with E.O. 13148. 

Under the Environmental Management Systems category, award winners included Dyess Air

Force Base, Texas, for their efforts using an EMS to significantly improve facility operations; the

U.S. Coast Guard Yard in Baltimore, Md., for ensuring the effectiveness of their EMS for tenant

commands and their commitment to continually improve environmental performance; and Greg

Allen, the EMS Team Lead at the U.S. EPA, Fort Meade, Md., Environmental Science Center for

his efforts to implement EMS at other federal facilities. More information on the Closing the Circle winners can be found on the OFEE website at www.ofee.gov.

One way EPA is helping federal agencies comply with Executive Order

13148’s requirement to implement environmental management systems (EMS)

is by providing EMS training and networking opportunities to federal facility

staff and management. EPA will next

deliver EMS training in San Diego on

July 16-17, and in Kansas City on August

5-7, 2003. 

The training is taught by a team of

EMS experts from EPA, other federal

government agencies, and selected EMS

consultants. It was first presented in

June 2002 at the U.S. Naval Support Station, Newport, R.I. and has been presented to both civilian and military staff

and management in other regions of the

country, including Washington D.C., New

Orleans, San Francisco, Seattle and

Phoenix, often in conjunction with other

meetings or agency conferences. 

The training covers the essential components of EMS development and implementation, as well as the benefits of

EMSs to facility operations, management

and strategic planning. The course uses

ISO 14001 as a standard, and emphasizes

the “nuts and bolts” of EMS planning.

Course sessions focus on the basic elements of an EMS, gap analyses, structure, facility “fence line” determinations,

team and policy development, management commitment, training, communication and proper integration into agency or

facility missions. Emergency preparedness and response, and other corrective

actions are also covered. The course also

emphasizes the importance of identifying

impacts and objectives, setting targets for

successful implementation, and using

administrative tools to ensure internal

accountability. 

EPA has also delivered training in conjunction with federal agency national conferences or meetings, most notably with

the Department of Defense and Department of the Interior. In other situations,

EPA has partnered and combined collective resources and expertise with other

federal agencies to deliver training

designed specifically for facilities in different regions of the country. For instance,

EPA collaborated with the Department of

Energy’s (DOE) Strategic Petroleum

Reserve (SPR), and the Federal Network

for Sustainability (FNS), a voluntary, collaborative network of

ENVIRONMENTAL 

MANAGEMENT 

SYSTEMS

Under Executive Order 13148 all federal

agencies were required to conduct agencylevel environmental management systems

(EMS) self-assessments by October 2001

and implement EMS pilot projects at

selected facilities by April 2002. Federal

agencies are required to implement EMSs

at all appropriate agency facilities by

December 2005. Currently, over 200 federal

facilities are implementing EMSs.

Environmental management systems

are relatively recent but accepted management tools developed to ensure that consideration of an organizations environmental

priorities and interests are institutionalized

into operations and planning processes.

Numerous private sector organizations

require that their facilities and facilities of

those supplying services and parts be formally certified as complying with accepted

EMS standards (usually ISO 14001). Under

Executive Order 12856, EPA, in coordination

with other federal agencies, developed the

Code of Environmental Management Principles (CEMP) which formed the basis for initial federal efforts in implementing EMSs;

standards under ISO 14001 are also recognized EMS standards. 

Since July 2001, an interagency work

group has met to discuss and address the

concerns of federal agencies developing

and implementing EMSs. EPA’s Federal

Facilities Enforcement Office (FFEO) coordinates the group. In conjunction with other

agencies, FFEO and its regional Federal

Facility Program Managers have delivered

EMS training to hundreds of federal environmental managers across the country.

EPA will continue providing technical

assistance and training for agencies

designing and implementing new EMSs, or

those wishing to improve existing ones. In

this newsletter we’ve reported on some

recent EPA-sponsored EMS training and

technical assistance, as well as some innovative EMS activities at federal facilities.

Please consult the calendar at the end of

this newsletter for upcoming EMS training

opportunities. 

Continued on page 6

EPA Sponsored Environmental 

Management System Workshops
6 FEDFACS

Council on Environmental Quality and

the Office of Management and Budget

to promote the use of EMSs. Using metrics developed in coordination with the

interagency EMS workgroup, the

annual 13148 report for 2002 will form

the basis of a scorecard to be released

shortly. The scorecard will raise the

level of awareness about EMS and

13148 requirements, and it complements recent discussions of the President’s Management Council about

improving environmental compliance

and performance. The Secretaries of the

ENVIRONMENTAL SPOTLIGHT

Continued from page 4

federal agencies in the western states

which promotes sustainable environmental stewardship. (See related article in

this issue).

In some instances, EPA used this

training platform as a forum for civilian

and military agencies to exchange information and experiences on EMS design

and implementation. Some trainings

included interactive panels of federal

facilities with “real world” EMS experience. Panelists discussed the steps taken

to develop and implement their EMSs,

unique challenges they faced to integrate

them into their facility’s mission, and the

benefits they’ve received as a result of

using an EMS. 

Through collaboration with EPA in

course development and training, federal

agencies have also maximized the benefits of this EMS training for their organizations. For instance, in addition to tailoring training to regional concerns or

problems, federal agencies have also used

this course as an opportunity to train

staff who can later train other facility personnel in EMS principles. 

In the future, EMS training may need

further refinement or restructuring as

agencies continue to implement EMSs at

their facilities. EPA welcomes input from

federal agencies on possible refinements

in order to tailor training to fit agency

and facility needs. Feedback forms are

TEXAS WORKING WITH

FEDERAL FACILITIES ON

EMS IMPLEMENTATION

Through training and partnerships, the

Texas Commission of Environmental Quality

(TCEQ) is helping federal facilities in their

state implement environmental management systems (EMS) designed to yield environmental benefits and cost savings.

This past April, TCEQ, with co-sponsor

Texas Environmental Partnership, conducted EMS training in Austin, Texas. Representatives of EPA’s Federal Facility Partnership Corrective Action and RCRA

programs attended the training along with

Department of Defense Texas installation

officers and staff, and others from federal

and state government. Because of the

effectiveness of this training, it will be given

at two other Texas military installations in

the future.

The training identified how EMSs can be

used to generated management commitment and organizational change and common EMS traps and how to avoid them. The

training also detailed TCEQ’s EMS program,

the history and future of EMSs at Texas federal facilities, and TCEQ’s EMS program as a

template for states throughout the country. 

The Texas EMS program is performance

based and emphasizes systems which yield

real environmental results and cost savings.

For those Texas federal facilities which

have performance based EMSs that meet

Texas requirements, real incentives will be

available, from regulatory incentives to

recognition and assistance.

For further information on the Texas

EMS program, including details on how

sites will be audited and types of incentives,

visit: www.abouttexasems.org. James Harris, EPA Region 6 RCRA Facility Manager

can be contacted at harris.jamesa@

epa.gov. 

EPA SPONSORED EMS WORKSHOPS

Continued from page 5

generally provided at the end of each

training. Agencies may also contact EPA

Headquarters staff and regional Federal

Facility Program Managers directly with

their input. [See Contact information in

this issue]. 

EPA will next deliver EMS training in

San Diego on July 16-17, and in Kansas

City on August 5-7, 2003. Please see

related articles and the calendar at the

end of this newsletter for further details.

Announcements for EMS and other training will also be made in EPA’s federal

facility electronic newsletter FedEnviroNews. To subscribe to FedEnviroNews,

please visit: http://www.epa.gov/

compliance/resources/listserv.html 

Departments of Energy and Commerce

recently issued clear policy directives to

their agency senior management directing EMS implementation. And we’re

working with the Environmental Council of the States and the Multi-State

Working Group to review opportunities

for state and local governments to

engage federal facilities on EMSs.

A lot of great things are going on, and

we’ll continue to strongly support these

efforts. I encourage each of you to learn

more about how EMSs can assist your

efforts to lead by example, be a good

neighbor, and be a good environmental

steward. 

For more information about 

Environmental Management

Systems visit: 

www.epa.gov/ems or

www.ofee.gov/ems/ems.htm

JOIN FedEnviroNews!

FedEnviroNews is EPA’s electronic newsletter which delivers environmental news and

information of interest to federal facilities.

This newsletter is free and is part of EPA’s

continuing efforts to improve awareness of

and provide access to environmental information. Subscribers may cancel their subscription at any time, and new subscribers

are welcome.

To subscribe (or unsubscribe) to 

FedEnviroNews, please visit: 

http://www.epa.gov/compliance/resources/

listserv.html 

Check “federal facilities” and provide

requested information.
FEDFACS 7

Are you an EMS team member or

manager creating an EMS for your

federal facility? Are you working on

EMS development but don’t understand

the hoops you need to jump through?

Are you a senior manager responsible

for doing a top management review of

the EMS at your facility but aren’t sure

what questions to ask? If you answered

yes to any of those questions, there are

free training opportunities available. 

Under the auspices of the Federal

Network for Sustainability (FNS), EPA

Regions 8, 9 and 10 are offering environmental management system training for

federal agencies in the West. Larry

Woods of EPA Region 9 (San Francisco)

will present a two-day EMS Development Workshop on July 16-17, 2003 at

the Ridgehaven Auditorium in San

Diego, Calif. This workshop will focus on

early steps in EMS development. It will

include exercises on policy development,

identification of aspects and impacts and

setting objectives and targets. The training will be the same as a well-received

workshop sponsored by Michele Wright

of EPA Region 10 (Seattle) on May 28-29,

2003. For more information on the San

Diego workshop, go to http://www.

epa.gov/region09/cross_pr/fedfac/03

agenda.html.

If your facility is located in Colorado,

Utah, Wyoming, Montana, North or

South Dakota, and your top management would be interested in a module on

EMS Leadership Opportunities for

Senior Managers, contact Dianne Thiel

at (303) 312-6389 or thiel.dianne@

epa.gov. Dianne or her contractor may be

able to travel to your facility or to a centrally located management meeting. If

FNS Sponsors EMS Training for Facilities and 

Senior Managers

your office is willing to help the trainers

customize the materials in advance, the

module could be specific to your agency.

Options for length of the session vary

from 1-2 hours. The goal of this session

is to help senior managers understand

their roles and responsibilities within an

EMS.

The Federal Network for Sustainability is a voluntary, collaborative network of federal agencies in the western

United States who strive to promote

sustainable environmental stewardship

and implement the President’s Greening the Government Executive Orders.

Through the FNS EMS initiative, a

series of training sessions is being

developed and presented for government agencies. For more information on

FNS, go to www.federalsustainability.

org.

EPA Regions 4 (Atlanta) and 6 (Dallas),

in partnership with the Department of

Energy, Strategic Petroleum Reserve

(SPR) sponsored a successful environmental management system (EMS)

implementation training course the week

of February 24, 2003 in New Orleans, La.

The course included a half-day executive

meeting followed by a two-and-a-half-day

workshop. Over 100 federal employees

from 25 different departments, agencies

and bureaus attended. In course evaluations, attendees gave the class a 4.4 on a

5-point scale.

The executive meeting informed

senior federal leaders about successful

EMS approaches in federal agencies.

Warren Behlau, from the Tennessee Valley Authority (TVA), presented a summary of the TVA’s EMS efforts. Since

implementing their EMS in 1996, TVA

saved over $7 million a year through

improvements in environmental training and hazardous materials management, and has a better compliance

record and fewer reportable environmental events. William Gibson of the

DOE/SPR summarized SPR’s ISO

14001 registered EMS and explained

how SPR saved over $350,000 in four

years and improved its operational efficiencies due to their EMS.

Workshop content was similar

to that given in other EPA trainings, and is detailed in related articles in this issue. Additionally,

attendees also heard from a panel of

officials who have implemented

EMS at federal facilities: Panel

members included: Marcia Stewart,

a support contractor from NASA

Stennis Space Center; Bill Bozzo,

DOE/SPR; Greg Allen, EPA Region 3

Environmental Science Center; Randall

Louvier, U.S. Coast Guard Integrated

Support Center, New Orleans. 

Each panelist discussed steps they

took to implement an EMS and

described the benefits and challenges

faced during implementation. Workshop

participants had an opportunity for

questions following the panelists’ presentations. Materials for the New

Orleans course are at: www.dynseg.

dyncorp.com/epa/ems/emsworkshop.nsf

Panel participants at the joint

EPA/DOE (SPR) environmental management systems training in New

Orleans, La.

EPA Partners with DOE to Deliver EMS Training
8 FEDFACS

The U.S. EPA and the Department of

Veterans Affairs (VA) Veterans Health

Administration (VHA) have embarked on

a cooperative partnership in which EPA

will conduct environmental management

reviews (EMRs) at 17 VA medical centers

across the nation. This will be the largest

number of reviews conducted by EPA at

any one federal agency, and is one illustration of EPA’s goal to offer assistance to

federal facilities interested in improving

their compliance records, as well as meeting the requirements of Executive Order

13148.

These EMRs are part of a larger partnership initiated in the summer of 2002

where VHA and EPA agreed to work

together on several initiatives to enhance

VHA’s environmental compliance programs and address concerns of a similar

nature found during inspections at a number of VA medical centers over the last few

years. They are intended to help individual facilities improve operations and minimize impacts on the environment, and

assist VHA in designing and implementsize, location and operation, and represent the diverse universe of VA facilities.

This group ranges from large, multicampus facilities with primary, tertiary

and nursing home

care and research

operations with a

thousand or more

beds, to small facilities with under one

hundred beds and

limited medical services. Facilities are

located in all areas of

the country. 

The VA conducted

a VA-only kick-off

teleconference with

over 50 representatives from selected

facilities in each of the VA Regional

offices. This “kickoff” was modeled after

the initiative that the VA had with OSHA.

They found it made for smoother operations to speak with all of the selected

facilities at once to explain the concept,

goals, timeframe, etc. of the initiative.

Following this VA-only call, joint VA-EPA

meetings were held to further explain the

process and respond to questions. The VA

response has been favorable. 

Some reviews have already begun,

including EPA’s Region 4 office (Atlanta)

EMR at the VA Medical Center in Birmingham, Ala. in March 2003. Prior to this

review, Region 4 and the VA southeastern

region representatives met to discuss VA

compliance issues and chose the Birmingham facility for an EMR. The Birmingham facility is a 313-bed, tertiary care,

university-affiliated facility, with no

incinerators, or boilers. EPA is currently

preparing a report of this review which

will be given to the facility in the next few

months. Further reviews are scheduled

for the rest of this year, with other

reviews to be done in 2004. 

For further information, visit

http://www.epa.gov/compliance/assistance/sectors/federal/epavha.html

ing changes nationally to address common

environmental issues found nationwide at

the VA medical centers.

Reviews will be conducted by a team of

EPA and VHA experts who will interview

VA medical center

staff and managers

about facility operations and how these

impact the environment. Following each

review, EPA will provide VA medical centers a written report

with specific recommendations for

improvements. In

turn, VA medical centers will provide EPA a written plan laying out how they intend to make operational changes to improve environmental

programs. Reviews will also help the VHA

design environmental management systems required by Executive Order 13148.

The 17 medical facilities at which

EPA will conduct the reviews vary in

EPA and VHA Launch Cooperative Environmental 

Management Review Initiative

EPA EVALUATES FACILITY ENVIRONMENTAL 

PROGRAMS AND MANAGEMENT SYSTEMS

Executive Order 13148 directs EPA to provide technical assistance in meeting the requirements of

the Order by conducting environmental management reviews (EMRs) at federal facilities. An EMR

is a collaborative effort between EPA and a federal facility to evaluate the facility’s environmental

program and management systems. An EMR is conducted to determine how well the facility has

developed and implemented specific environmental management systems to ensure good environmental performance. EMRs are voluntary and are initiated by an agency or facility. They are not

compliance-driven assessments, audits or inspections. 

An EMR is generally coordinated out of one of EPA’s ten regional offices, and may be conducted

at any type of federal facility. Federal facilities which request EMRs determine the scope of the

review. There are several areas of inquiry for an EMR, including:

1. Organizational Structure 

2. Environmental Commitment 

3. Staff resources, training, and development and internal and external communications 

4. Program evaluation, reporting and corrective action 

5. Environmental planning and risk management formality of environmental programs

To learn more about EMRs, and how your facility may schedule one, please contact EPA’s Federal

Facility Program Manager in your region (listed next page).

It is EPA’s goal to offer

assistance to federal 

facilities interested in

improving their 

compliance records, 

as well as meeting the

requirements of 

Executive Order 13148.
FEDFACS 9

U.S. EPA Region 6 (Dallas) conducted

environmental management reviews

(EMRs) at two major federal facilities; the

NASA Michoud Assembly Plant in New

Orleans, La. and the U.S. Army Joint

Reserve Training Center (JRTC) at Fort

Polk, La. The EMRs included a review of

each facility’s environmental program

and management system to determine

the extent protection programs and plans

have been developed and implemented. 

Prior to each EMR and on-site visit,

EPA regional staff worked with each facility and designed the parameters and

scope of the review. Both Michoud and

Fort Polk reviews included an in-brief by

the EPA team, a tour, interviews with

appropriate staff from top management to

staff level, and an out-brief. NASA has

received EPA’s report of its Michoud facility review, which took place in November

of 2002, and has been very open to implementing several EMR recommendations

into its existing EMS. 

Fort Polk is leading the way to transforming Army operations to meet emerging security challenges and established

its installation-wide EMS in January

2003. EPA conducted its EMR in April

2003. The Installation Environmental

Quality Control Committee serves in the

top management role at the facility. Fort

Polk provided a briefing to EPA and the

Forest Service on the Army’s transformation and Fort Polk’s NEPA Analysis. 

A draft report of the recently conducted Fort Polk EMR is pending, but

already Fort Polk has indicated the

review was especially helpful with suggested implementation measures such as

stronger internal inspection programs

and sponsorship of a special children’s

emphasis program. EPA also met with

Fort Polk’s Geographic Information System (GIS) staff and discussed the EPA

GIS Screening Tool and its possible use

for Fort Polk. 

EPA Region 6 will also be conducting

EMRs this year at the Bureau of Prisons,

Fort Worth Medical Center, Texas; the

Veterans Administration, Dallas/Temple,

Texas; and is working with the U.S. Army

Depot, Corpus Christi, Texas, and the

Department of Energy Southwestern

Power Administration, Okla./Ark. on possible future EMRs.

Environmental management review at

the U.S. Army Joint Reserve Training

Center, Fort Polk, La.

EPA Conducts Environmental Reviews at NASA 

Michoud Assembly Plant and Fort Polk

HEADQUARTERS

Greg Snyder, Director

Planning, Prevention, & 

Compliance Staff

US EPA

Federal Facilities Enforcement Office 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

snyder.greg@epa.gov

Phone: 202-564-4271

Fax: 202-501-0069

REGION 1 

Anne Fenn

CT, ME, MA, NH, RI, VT

US EPA Region 1

Office of Environmental Stewardship

1 Congress Street

Suite 1100, Mail: SPP

Boston, MA 02114-2023

fenn.anne@epa.gov

Phone: 617-918-1805

Fax: 617-918-1810

REGION 2 

Kathleen Malone

NJ, NY, PR, VI

US EPA Region 2

Compliance Assistance Section

290 Broadway, 21st Fl.

New York, NY 10007-1866 

malone.kathleen

@epa.gov

Phone:

Phone: 212-637-4083

Fax: 212-637-4086

REGION 3

Bill Arguto 

Denise Rigney

DE, DC, MD, PA, VA, WV

US EPA Region 3

Office of Environmental Programs 

1650 Arch Street

Philadelphia, PA 19103-2029 

arguto.william@epa.gov

rigney.denise@epa.gov

Phone: 215-814-3367 (BA)

Phone: 215-814-2726 (DR)

Fax: 215-814-2783

REGION 4

Mark Robertson

AL, FL, GA, KY, MS, NC, SC, TN

US EPA Region 4

Environmental Accountability 

Division, Federal Facilities

61 Forsyth St., SW

Atlanta, GA 30303-8960

robertson.mark@epa.gov

Phone: 404-562-9639

Fax: 404-562-9598

REGION 5

Lee J. Regner

IL, IN, MI, MN, OH, WI

US EPA Region 5

Office of Enforcement & Compliance 

Assurance

77 West Jackson Blvd

Chicago, IL 60604-3507

regner.lee@epa.gov

Phone: 312-353-6478

Fax: 312-353-5374

REGION 6

Gabe Gruta

Joyce F. Stubblefield

AR, LA, NM, OK, TX

US EPA Region 6 

Compliance Assurance & 

Enforcement 

Division

1445 Ross Avenue

Dallas, TX 75202

gruta.gabriel@epa.gov

stubblefield.joyce@epa.gov

Phone: 214-665-2174 (GG)

Phone: 214-665-6430 (JS)

Fax: 214-665-7446

REGION 7

Diana Jackson

IA, KS, MO, NE

US EPA Region 7

Enforcement Coordination Office

901 North 5th Street

Kansas City, KS 66101

jackson.diana@epa.gov

Phone: 913-551-7744

Fax: 913-551-9744

REGION 8

Dianne Thiel

CO, MT, ND, SD, UT, WY

US EPA Region 8

999 18th Street

Denver, CO 80202-2466

thiel.dianne@epa.gov;

Phone: 303-312-6389 

Fax: 303-312-6044

REGION 9 

Larry Woods

Tom Kelly

AZ, CA, HI, NV, Pacific Islands

US EPA Region 9

Cross-Media Division 

75 Hawthorne St, CMD-2

San Francisco, CA 94105

woods.larry@epa.gov;

kelly.thomasp@epa.gov

Phone: 415-972-3857 (LW)

Phone: 415-972-3856 (TK)

Fax: 415-972-3562

REGION 10

Michele Wright

AK, ID, OR, WA

US EPA Region 10

Office of Enforcement & Compliance

(OEC-164)

1200 6th Avenue

Seattle, WA 98101

wright.michele @epa.gov

Phone: 206-553-1747

Fax: 206-553-7176

FEDERAL FACILITIES PROGRAM MANAGERS ENVIRONMENTAL PROTECTION AGENCY
10 FEDFACS

“Economic Benefit” and “Size of

Business” Issues Decided in Fort

Wainwright Case

On June 5, the EPA Environmental Appeals Board (EAB)

upheld the Administrative Law Judge (ALJ) decision in the

Fort Wainwright case and decided that, as a matter of law, the

“economic benefit of noncompliance” and “size of business”

penalty factors of the Clean Air Act (CAA) are appropriate to

consider in an enforcement action against a federal facility.

The EAB remanded the matter to the ALJ for a penalty-phase

evidentiary hearing. 

The issue stems out of EPA Region 10’s (Seattle) case

against the U.S. Army Alaska Garrison - Fort Wainwright

Alaska, in which EPA is seeking a substantial penalty for

alleged CAA violations. The penalty total is based on over 10

years of almost continuous noncompliance at the facility. The

Chief ALJ issued her opinion on the issue in April 2002 and

held that CAA Section 113(e) penalty assessment criteria of

“economic benefit of noncompliance” and “size of business”

applied to the Army and may be taken into account in determining the penalty for the Army’s violations. In June 2002, the

Army sought and was granted interlocutory review of the

Chief ALJ’s decision to EAB. Oral argument before the EAB

took place in November 2002.

A copy of the current decision can be found at: http://www.

epa.gov/eab/new.htm 

EPA Fines U.S. Postal Service for UST 

Violations

The EPA, working jointly with Hawaii Department of Health

staff, fined the U.S. Postal Service in Hawaii $1,500 for violating federal underground storage tank (UST) regulations.

The Waikiki and the Honolulu Main Post Office were cited for

failing to monitor their tanks at least every 30 days for petroleum releases and for neglecting the required annual maintenance on their leak detection systems.

The EPA also cited two other facilities in Hawaii for less significant violations of the federal UST regulations as part of a

larger effort to protect groundwater sources and local habitat

in the state.

“The federal field citation program helps bring underground

storage tanks into compliance as quickly as possible without

putting the gasoline stations out of business,” said Norwood

Scott, an underground storage tank inspector for the EPA

Region 9 (San Francisco). “Leak prevention is critical for

underground fuel storage tanks because a pin-sized hole can

release 400 gallons of fuel in a year’s time, enough to foul millions of gallons of fresh water. Plus, given the reliance on

groundwater in Hawaii, it is vital to protect underground

water resources.” 

The EPA frequently conducts unannounced tank inspections. Owners and operators who receive a citation are

required to correct the violations, submit requested documentation, and pay the settlement amount within 30 days. If they

do not pay the settlement amount and comply within this time,

they are subject to formal enforcement action that carries

penalties of up to $11,000 per violation per tank per day in

addition to the added cleanup costs for leaking tanks.

More information on EPA’s underground storage tank program can be obtained at: www.epa.gov/OUST/

EPA Region 8 Files Complaint Against BIA

Alleging Violations of UST Requirements

On April 1, 2003, EPA Region 8 (Denver) filed an Administrative Complaint against the Bureau of Indian Affairs

(BIA) – Standing Rock Agency, Fort Yates Law Enforcement

facility, Fort Yates, North Dakota. The BIA’s Fort Yates Law

Enforcement facility is within the exterior boundaries of the

Standing Rock Sioux Indian Reservation. The Complaint

alleges violations of the RCRA Subtitle I - Underground Storage Tank (UST) requirements, and proposes a civil penalty of

$33,371. The alleged violations include failure to maintain

leak detection monitoring records, failure to operate leak

detection equipment in accordance with manufacturer’s

instructions, failure to report a suspected release of regulated

product (gasoline), and failure to investigate a suspected

release of regulated product (gasoline).

Leaking USTs pose a serious threat to human health and

the environment, including groundwater contamination. Once

gasoline or chemicals get into groundwater, it is extremely

expensive, sometimes impossible, to clean up the contamination. It makes more sense to keep contamination out of the

water supplies in the first place, and that begins with leak

detection.

Accordingly, it is extremely important that the UST regulations be followed and when they are not, that enforcement be

initiated to compel compliance and ensure adequate health

and environmental protections. Amy Swanson - EPA Region 8

(303) 312-6906, Andrew Cherry - FFEO (202) 564-2589.

Enforcement News
FEDFACS 11

In the Spotlight

Department of the Interior 

Environmental Management

Awards

The Department of Interior (DOI) recognized four of its employees for outstanding achievements made in environment

management in 2002. The employees

came from several DOI offices and

employed a variety of innovative

approaches for environmental management and sustainability.

Kent Bullard, of Channel Islands

National Park, was recognized for his

commitment to learning and sharing

knowledge of sustainable practices. Projects he has championed have included

conversion of fleet vehicles to natural gas

and biolubricants, introduction of

biodiesel to the boat fleet operation, and

development of highly efficient waste

management practices required for an

island park setting. Mr. Bullard has also

provided vital web development service

for the NPS Environmental Leadership

and Green Energy Programs, by creating

and maintaining the Renew website

(www.nps.gov/renew) where NPS and

other facility managers can learn about

the efforts of others who are working

toward these same goals.

Don Durbin, of Dinosaur National

Park took the lead in recycling activities,

hazardous waste reduction, “green procurement,” and in promoting environmental awareness within the park, local

community, and the Intermountain

Region. Mr. Durbin developed and showcased alternative energy sources to staff

and visitors by installing a solar-powered

system and interpretative display, converting numerous park facilities from

propane and AC power over to 12V solar

systems, and using solar lighting, refrigeration, and swamp coolers at several

locations. 

Gary Melvin of the Alaska Peninsula/Bercharof National Wildlife Refuge

was recognized for helping establish a

community-recycling program for the

remote area of King Salmon, Alaska by

arranging for these materials to be transported off the Refuge at no cost by outfitters on return trips. Solar panels now

power electronic and radio equipment at

remote field camps. Melvin was also

responsible for replacing gravity-feed

diesel drip heaters with propane systems,

and using environmentally-preferable

deicer on roads. At Melvin’s suggestion,

the environmental management system

at the Refuge now includes procedures for

grey water management, fuel efficient

operations of vehicles in a cold climate,

hot-draining oil cans to ensure clean disposal, and other environmental performance objectives. 

Jim Behrmann, of DOI Region 6

Health and Aviation Division of the U.S.

Fish and Wildlife Service (FWS), demonstrated innovative leadership in promoting environmental stewardship in DOI

Region 6 Refuges and Fish Hatcheries.

Mr. Behrmann emphasized the relationship between sustainable practices and

FWS mission and objectives by encouraging the use of recycled products such as

re-refined lubricating oil,environmentally

preferable copy paper. 

EPA Region 9 Recognizes DOE

Stanford Linear Accelerator

Center For Reducing Solvent

Emissions 

EPA Region 9 (San Francisco) recognized the Department of Energy’s Stanford Linear Accelerator Center (SLAC)

in Menlo Park, California as a “Champion of Green Government” for efforts to

reduce their use of ozone depleting solvents and prevent thousands of pounds

of emissions. 

Replacing the ozone depleting solvents was a complex task for scientists

and staff at SLAC because when parts

and equipment being cleaned must be

returned to a particle accelerator, contamination can interfere with subatomic

particle experiments. The Alternative

Solvents Team (Ali Farvid, Balbir Gosal,

Robert Kirby Harold Morales, Mary

Regan, Michael Hug, Butch Byers, and

Richard Cellamare) began by using xray photoelectron spectroscopy to compare the cleaning performance of existing and new cleaning methods. Once

this method was in place to determine

how “clean is clean”, the team proceeded

to: (1) replace two vapor degreasers with

a low- water aqueous cleaning system;

(2) implement alternative organic-based

solvent in the cleaning of vacuum equipment; and (3) purchase and install a

near zero emission vapor degreaser. 

The result is a dramatic reduction in

solvent emissions from the facility’s Plating Shop. From 1988 to 1998 average solvent emissions for the Plating Shop averaged 5,400 pounds per year. In 2001

solvent emissions were less than one

pound. Last year EPA Region 9 recognized the Alternative Solvents Team as

Champions of Green Government for

their efforts, and

FEDERAL EMPLOYEES

HONORED FOR 

ENVIRONMENTAL

STEWARDSHIP

On June 10, 2003, federal employees from

across the United States gathered in Washington, D.C., to accept White House "Closing

the Circle" Awards for their outstanding

environmental stewardship work. Twentysix teams from 15 states and the District of

Columbia were honored for outstanding military and civilian facility efforts in such categories as environmental management systems, education and outreach, purchase of

environmentally preferable and biobased

products, sustainable design for buildings,

waste and pollution prevention, and recycling. For more information on the awards,

please visit: http://www.ofee.gov/whats/

Federal_Employees_Honored.html

Continued on page 14
12 FEDFACS

In the News

EPA Regional CWA/SPCC

Compliance Assurance 

Initiative for Federal Facilities 

The recent extension of compliance deadlines for Clean Water Act (CWA) Spill

Prevention, Control, and Countermeasure (SPCC) regulations enable EPA

Region 4 (Atlanta) to conduct a novel two

year comprehensive compliance assurance initiative for federal facilities. The

initiative will use an integrated strategy

consisting of compliance assistance followed by inspections and enforcement to

ensure federal facility compliance with

these regulations. 

The initiative will begin by identifying

a pool of federal facilities believed to be at

risk for noncompliance. Region 4 will

then implement this initiative in three

phases:

1) Provide compliance assistance

through educational outreach to

selected federal facilities on common

compliance issues;

2) Encourage selected federal facilities to

use EPA’s Audit Policy to self-disclose

violations; and 

3) Conduct cluster compliance evaluation

inspections at selected federal facilities.

In 1974, EPA established this rule

under authority of the CWA to ensure

regulated facilities prevented discharge

of oil into or upon navigable waters of the

United States or adjoining shorelines.

Following the 1989 Exxon Valdez spill,

Congress passed the Oil Pollution Act

(OPA) of 1990 that set additional requirements, including preparation of a Facility

Response Plan (FRP), for certain facilities

storing large quantities of oil. 

On July 17, 2002 (167 Fed.Reg.

47,042; codified at 40 C.F.R, §112), EPA

published final amendments to the SPCC

rule pursuant to Section 311(j) of the

CWA. The rule was effective August 16,

2002. In this rule, EPA granted regulated

facilities six months to amend their SPCC

plans, and 12 months to implement them.

In response to facility requests for more

time to update or prepare plans in accordance with the amendments, EPA

extended the compliance deadline to 18

months. Among the reasons for this

extension was a shortage of professional

engineers to certify that plans meet

requirements, and EPA’s desire to collectively address individual facility compliance deadline extension requests. EPA

recently issued another and final rule on

April 17, 2003 that extended the compliance deadlines to August 17, 2004 for

revised plans and February 18, 2005 for

implementation of the revised plans. 

Even though there have been laws and

regulations since the 1970s ensuring prevention of oil pollution, the regulated federal facility community compliance rate

is of concern. In 1995, EPA conducted a

survey of more than 2,600 oil storage

facilities in 23 different industries to analyze the effectiveness of EPA’s SPCC program. Specifically, this study investigated

whether a facility’s overall compliance

with the SPCC program, as well as specific individual regulatory provisions,

impacted certain measures of oil spill

risk. 

The analysis indicated that a large

proportion of facilities which met the

SPCC capacity threshold applicability

requirements may not actually be in full

compliance with SPCC regulatory

requirements. In addition, for several

years Region 4 has delivered outreach

assistance and conducted multi-media

compliance evaluation inspections at federal facilities and discovered many were

in noncompliance. Other regional studies

support this analysis and indicate 90 percent of the 1200 federal facilities in the

region are likely out of compliance.

Region 4 is addressing this problem by

implementing a three-phase comprehensive compliance assurance initiative on

federal facilities. Before the actual initiative begins, Region 4 will identify a pool

of federal facilities believed to be at risk

for noncompliance. Region 4 will likely

select this pool from federal facilities with

deficient FRPs and SPCC plans, those

which reported oil spills, or have compliance problems in other programs such as

CWA, National Pollutant Discharge

Elimination System (NPDES), and

Resource Conservation and Recovery Act

(RCRA) subtitles I and J. Region 4 will

then compare its data with non-EPA data

bases and further identify federal facilities which may be required to have

OPA/SPCC plans.

The first phase of the initiative will

occur during the amendment and implementation period of the OPA/SPCC regulations. Region 4 will prepare and distribute to selected federal facilities materials

describing SPCC and OPA laws and regulations, instruct federal facilities on how

to comply and where to get further assistance. Region 4 will then conduct compliance assistance visits at selected federal

facilities to evaluate SPCC Plans and

FRPs. If deficiencies are found, EPA will

make recommendations to facility management on how best to modify and

implement plans. In the latter part of the

first phase, Region 4 will organize a

SPCC and OPA compliance assistance

seminar for the selected federal facilities.

In the second phase, Region 4 will

send out letters to the selected federal

facilities encouraging them to use the

EPAAudit Policy to disclose facility violations, especially those violations related

to SPCC/OPA requirements. After

approximately six months of encouraging

the use of the EPA Audit Policy, EPA will

begin the third phase by targeting compliance evaluation inspections at those

selected federal facilities that have not

disclosed violations under the EPA Audit

Policy and appear to be at the highest

risk for noncompliance. 

Region 4 believes this initiative will

improve OPA/SPCC federal facility compliance rates in its region, and possibly

serve as a national Continued on page 13
FEDFACS 13

Regulatory Notes: 

Executive Order 13212, Actions to Expedite

Energy-Related Projects, has been amended

and reissued as Executive Order 13302. The

amended Order was published in the Federal Register on May 15, 2003. (68 Fed.

Reg.27429). You may also view the amended

Order at: http://www.ofee.gov/eo/13302.pdf 

Executive Order 12580, Superfund Implementation, was amended June 20,2003. The

amendments address Brownfields and can

be found at: http://www.whitehouse.gov/

news/releases/2003/06/20030620.html

OFEE Announces Federal Electronics Challenge – The Office of the Federal Environmental Executive has announced the Federal

Electronics Challenge, a new initiative

designed to help the federal government

continue to improve the environmental stewardship of its electronic assets. For more

information, please visit: http://www. federalelectronicschallenge.net/

Around the Country

U.S. EPA Region 6 Compliance Assistance

Activities (Federal Facility Program Manager:

Joyce Stubblefield 214-665-6430)

EPA Region 6 (Dallas) was invited to participate at the U.S. Postal Service Southwest

Area Environmental Compliance staff meeting held in November 2002. Several environmental topics were covered by EPA Staff,

Kara McCoy-Belle (EMRs), Brent Larson

(“No Exposure,” Storm Water), John

Cernero (On-site fueling and UST), and Gabe

Gruta (RCRA 6002 Inspections). 

EPA invited to U.S. Department of Justice

Bureau of Prisons (BOP) South Central

Regional Office to discuss water related

issues and Environmental Management

Reviews. In addition, EPA has had the opportunity to hold conference calls and discussions with several BOP sites throughout

Texas, Louisiana and Oklahoma.

EPA developed an environmental management review fact sheet for the Federal Executive Board to use at their meetings about environmental management system workshops.

The executive meeting was held in New

Orleans, Louisiana, in February 2003. EPA (Kara

McCoy-Belle) consulted with the Dallas FEB

office on the fact sheet. Ms. Marvel Robertson

from the New Orleans Federal Executive

Board opened the executive meeting. 

EPA Regions 4 and 6 Federal Facilities Programs and the Region 6 Pollution Prevention

(P2) Roundtable collaborated on its annual

meeting in New Orleans, LA on February 25-

28, 2003. Region and state P2 program activities and strategies were discussed, including

opportunities for further collaboration. A

highlight of the meeting was a presentation

from representatives of the Department of

Energy Strategic Petroleum Reserve, who

described the pollution reductions achieved

with their P2 based EMS. This collaborative

opportunity provided excellent new insights,

perspectives, contacts and new partnerships

for the Pollution Prevention Roundtable,

states and federal facilities. Region 6: Joy

Campbell, P2; Gabriel Gruta, FF; Region 4:

Tony Shelton, FF.

In Brief

model for other cooperative efforts to

improve federal facility compliance. EPA

anticipates that the initiative will bolster

the collaborative relationship between

the federal facility community and EPA,

thus improving their compliance rates for

other environmental statutory requirements. 

EPA Region 4 Reorganizing

Program with Help of States

and Federal Facilities

The Federal Facilities Branch (FFB) of

the Waste Management Division, EPA

Region 4 (Atlanta) is reorganizing and

refocusing its program through a unique

effort which includes internal and external surveys with staff, states and other

federal agencies. The effort is intended to

fully analyze and understand program

needs, while allowing staff and clients a

role in designing a program which meets

those goals.

The FFB oversees cleanup of federal

facilities in its eight states. In the mid1990s, FFB began to partner with both

states and federal agencies to clean up

federal facilities in its region. Partnering

teams share technical and procedural

information and decisions, and train participants in group dynamics and interpersonal and intra-organizational tier communication. Because of these partnering

efforts, cleanup operations have become

more efficient and require fewer staff.

In response to a recent internal reorganization and decreased Superfund

resources, FFB management decided a

revitalization would be useful. With the

help of a consultant, surveys were conducted on an internet interface in order to

ensure confidentiality. In addition to EPA,

federal agencies and states were also

invited to participate. External response

to the survey was 66 percent, and

included all regional states, all Department of Defense services, and the Department of Energy. After survey results were

compiled and analyzed, facilitated meetings with FFB management and staff

were held to discuss and evaluate information, and to develop an action plan for

prioritization of changes and implementation. 

The reorganization effort is ongoing.

Implementation teams have instituted

short-term solutions for some issues, and

are conducting additional analysis for

others. The FFB management is optimistic this effort will lead to many positive changes, with happier and more productive Branch employees and more satisfied external customers. This effort will

continue as initial issues are resolved and

survey results point to further improvements. For further information on this

effort, please contact Annie Godfrey at:

godfrey.annie@epa.gov.

IN THE NEWS/CWA/SPCC

Continued from page 12
14 FEDFACS

further the goals of Executive Order

13148 to eliminate ozone-depleting substances.

NASA Using Landfill Gas For

Energy

EPA recognized the National Aeronautics

and Space Administration (NASA) as the

first federal agency to directly use landfill

gas to produce energy at one of its facilities, the Goddard Space Flight Center in

Greenbelt, Md. NASA’s decision to use

landfill gas, a renewable energy source,

will save taxpayers millions of dollars over

the next 10 years, and also prevent as

much pollution annually as planting

47,000 acres of trees, or removing 35,000

cars from Maryland’s roads. EPA’s Landfill

Methane Outreach Program is a voluntary

assistance and partnership program that

promotes the use of landfill gas as a renewable energy source. For more information

on EPA’s Landfill Methane Outreach Program, visit: http://www. epa.gov/lmop

IN THE SPOTLIGHT/SLAC

Continued from page 11

14000 technical and environmental conferences, and is considered by many to

be a model for federal EMS efforts. 

In particular, ESC has been recognized by the federal community for its

robust documentation of EMS elements

such as the activities and impacts register and environmental management program form. These documents have been

used as exhibits in EMS training to provide examples of how the EMS elements

are addressed during implementation

and the outcome of initial EMS efforts

under “real world” circumstances.

The Ft. Meade Science Center experience is particularly important due to the

facility’s status as a small (165 people),

civilian facility. This type of facility represents a significant portion of the federal community affected by the E.O.

13148 requirement to implement an

EMS. The Center has provided presentations during training exercises for broad

federal audiences and has partnered

with EPA’s Office of Acquisition and

Resource Management to produce a

series of multi-media training modules

that lead organizations through the

implementation process. 

Greg Allen, of EPA Region 3, also

received a White House Closing the Circle award for the associated EMS training modules. The training modules are

rich with examples, templates, and

detailed information from the Center

and are helping the 37 EPA facilities and

several other federal agencies currently

implementing EMSs. Several other federal agencies have expressed interest in

using the training modules as part their

implementation strategy. Agencies interested in learning more about the Center’s EMS, or obtaining training modules

may contact Greg Allen at

allen.greg@epa.gov or Jerry Oakley at

oakley.jerry@epa.gov. 

EPA/FORT MEADE ENVIRONMENTAL SCIENCE

CENTER RECEIVES ISO 14001 CERTIFICATION

Continued from page 3

FEDERAL AGENCY 

HAZARDOUS WASTE 

COMPLIANCE DOCKET

UPDATE

The seventeenth update to the Federal

Agency Hazardous Waste Compliance

Docket will be published in July 2003. The

Docket identifies federal facilities which

have hazardous waste or have the potential

to release hazardous waste into the environment.

Section 120(c) of the Comprehensive

Environmental Response, Compensation,

and Liability Act of 1980 (CERCLA), as

amended by the Superfund Amendments

and Reauthorization Act of 1986 (SARA),

requires EPA to establish the Docket. It was

first published February 12, 1988, and is

updated periodically. The Docket can be

viewed at: www.epa.gov/compliance/

cleanup/federal/index.html Additional information can be obtained from Augusta Wills:

wills.augusta@epa.gov

EPA’s Federal Facilities Enforcement

Office (FFEO) has launched an initiative to create a new and enhanced stewardship and compliance assistance center

for federal facilities. With this initiative,

FFEO intends to enhance and supplement the existing virtual compliance

assistance center for federal facilities,

FedSite (www.epa.gov/fedsite). The new

web-based Center will be independent,

supported and directed by federal agencies, and will integrate both good practices and compliance assistance resources

of the federal government in one site.

Among the services likely to be offered

federal facilities by the new Center will be

compliance assistance tools, pollution prevention information, environmental management system information, as well as

interactive training and certification

opportunities. In addition, the Center will

provide the latest regulatory/executive

order information, green product/vendor

information and listserver subscription

services. The new Center is envisioned as

an essential tool in assisting federal agencies timely meet the EMS requirements of

Executive Order 13148. 

FFEO staff have begun meeting with

agencies to discuss plans for the new Center. FFEO is soliciting suggestions concerning Center governance, structure and

services agencies identify as necessary to

further environmental stewardship and

compliance. FFEO will soon publish a

request for initial proposals (RFIP) in the

Federal Register requesting suggestions

about the Center. The new Federal Facilities Stewardship and Compliance Center

is expected to be operational by April next

year. For more information or to offer

comments or suggestions about the new

Center, please contact Mike Shields at

202-564-9035 or shields.mike@epa.gov.

New Federal Facilities Stewardship

& Compliance Center
FEDFACS 15

UpcomingEvents

FNS Sponsors EMS Training for 

Facilities and Senior Managers 

July 16-17, 2003, San Diego

Under the auspices of the Federal Network for Sustainability (FNS), EPA Regions 8 (Denver), 9 (San Francisco)

and 10 (Seattle) are offering environmental management system training for federal agencies in the western states, July 16-17, 2003 in San Diego, CA. This

workshop will focus on early steps in EMS development, and include exercises on policy development,

identification of aspects and impacts and setting objectives and targets. For more information on the San

Diego workshop, please visit: http://www.epa.

gov/region09/cross_pr/fedfac/03agenda.html

Super Energy Savings Performance

Contracting Workshop 

July 22–23, Washington, D.C. 

The U.S. Department of Energy’s Federal Energy Management Program is presenting a free workshop for

federal employees involved in energy management,

engineering, and procurement. Attendees will learn

how to lower capital costs while reducing long-term

energy and water bills. For further information or to

register, call (703) 243-8343.

Federal Facility Workshop on EMS 

August 5-7, 2003, Kansas City, Kansas.

U.S. EPA Regions 5 (Chicago) and 7 (Kansas City) will

host a free EMS training, “Designing Your EMS: A Federal Facilities Workshop” on August 5-7, 2003, in

Kansas City, Kansas. This workshop is designed for federal facility EMS coordinators and team members, and

others at federal facilities who control operational

activities and/or report on their facility’s environmental

performance. The training will cover what an EMS is,

EMS requirements under Executive Order 13148, and

designing and implementing an EMS for facility operations. For more information or to register, please visit:

www.epa.gov/region7/ EMS_WORKSHOP

2003 RCRA National Meeting 

August 12 - 15, Washington, DC.

“RCRA: Putting Resource Conservation into RCRA.’’

This year along with EPA, the meeting is being

cosponsored by the Air & Waste Management

Association (A&WMA), Solid Waste Association of

North America (SWANA), International City/County

Management Association (ICMA), and Association

of State and Territorial Solid Waste Management

Officials (ASTSWMO). This year’s meeting focuses

on the Resource Conservation Challenge, which is a

major national effort to find ways to conserve natural resources through waste reduction and energy

recovery programs. For more information please

visit: www.epa.gov/ osw/meeting

NDIA 8th Annual Joint Services 

Pollution Prevention & Hazardous

Waste Management Conference 

and Expo 

San Antonio, TX, August 11-14. 

The Conference theme is “Sustaining Readiness

Through Environmental Stewardship”. This conference brings together professionals from military

services, industry, academia, and local, state and

federal agencies to share ideas and success stories

relating to pollution prevention and hazardous

waste management. Visit the conference website

at: www.p2-hwmconference.com 

Federal Facilities Manager’s 

Symposium 

August 20 - 22, 2003, Portland, Oregon.

The Federal Facilities Manager’s Symposium, entitled “Learning from the Past, Building for the

Future,” is designed to promote better understanding and foster better communication on critical federal facilties issues that are important to the states.

The Symposium is sponsored by ASTSWMO and is

being organized by the ASTSWMO Federal Facilities Training and Technology Transfer (T3) Focus

Group. For more information please contact Dania

Rodriguez at ASTSWMO daniar@sso.org, 202-624-

5973.

EPA /State /DoD Region 3 Federal

Facilities Conference

Sept. 9 - 11, 2003, Williamsburg, VA

EPA Region 3 (Philadelphia) will host its annual colloquium in Williamsburg, VA on Sept. 9 - 11, 2003.

This colloquium, themed “Interdisciplinary Environmental Management – Integrating Resources for

Environmental Excellence” is co-hosted with Region

3 states, Department of Defense and the General

Services Administration. Session and training topics

include EMSs, Chesapeake Bay & Natural Resources,

remediation, pollution prevention and innovation,

range management and encroachment, hazardous

waste management, NEPA and coastal zone management, and more. Registration and other preliminary information can be found at: http://www.

epa.gov/reg3esd1/fedfac/index.html or by contacting

Bill Arguto at arguto.william@epa.gov or Denise

Rigney at rigney.denise@epa.gov

“Partners to Promote Stewardship”

U.S. EPA Region 8 (Denver), the

National Park Service - Inter-mountain

Region, Peaks to Prairies 

Sept. 29 - Oct. 2, 2003, Grand Teton National

Park, Wyoming

The Pollution Prevention Information Center and

regional states are sponsoring “Sharing Common

Ground: Partners to Promote Stewardship” Sept. 29 -

Oct. 2, 2003 in Grand Teton National Park, Wyoming.

This conference is for federal, state and local land

managers, regulatory agencies, and non-profit and

private sector organizations involved in public land

use, which are looking for ways to work cooperatively

to sustain the wealth of environmental resources on

public lands and the surrounding communities. For

more information please visit: http://www.mesllc.

net/conference

2003 International U.S. Green Building

Conference and Expo, USACE Various

Environmental Training 

November 12-14, 2003, Pittsburgh, PA

The U.S. Army Corps of Engineers (USACE) Professional Development Support Center has released the

fiscal year 2003 course schedule, at http://pdsc.

usace.army.mil/courseschedule.asp. Information on

various environmental courses may be found on the

site either by searching with a keyword or by using

the course number (CN). Environmental courses

include Clean Air Act Workshop (CN 443),

CERCLA/RCRA Remediation Processes, (CN 356)

Environmental Regulatory Practical Application (CN

398), and many others.
United States Environmental 

Protection Agency (2261)

Washington, DC 20460

Official Business

Penalty for Private Use $300

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Address Correction Requested

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FedFacs

ALJ Administrative Law Judge

BIA Bureau of Indian Affairs

BOP Bureau of Prisons

CAA Clean Air Act

CEMP Code of Environmental 

Management Principles

CERCLA Comprehensive 

Environmental Response,

Compensation and 

Liability Act

CWA Clean Water Act

DoD Department of Defense

DOE Department of Energy

DOI Department of the Interior

EAB Environmental Appeals

Board

EMR Environmental Management

Review

EMS Environmental Management

System

EO Executive Order

EPA Environmental Protection

Agency

ESC Fort Meade Environmental 

Science Center

ESE Environmental Service 

Center

FFB Federal Facilities Branch

FFEO Federal Facilities 

Enforcement Office

FNS Federal Network for 

Sustainability

FRP Facility Response Plan

FWS Fish and Wildlife Service

GIS Geographic Information 

System

ISMS Integrated Safety 

Management System

ISO International Organization

for Standardization

NASA National Aeronautics and

Space Administration

NEPA National Environmental 

Policy Act

NPDES National Pollutant Discharge 

Elimination System

NPS National Park Service

OFEE Office of the Federal 

Environmental Executive

OPA Oil Pollution Act

OPPTS Office of Prevention, 

Pesticides, and Toxic 

Substances 

OSHA Occupational Safety and

Health Act

P2 Pollution Prevention

RCRA Resource Conservation and 

Recovery Act

SARA Superfund Amendments and 

Reauthorization Act

SLAC Stanford Linear Accelerator 

Center

SPCC Spill Prevention Control and 

Countermeasure

SPR Strategic Petroleum Reserve

TCEQ Texas Commission on 

Environmental Quality

TVA Tennessee Valley Authority

USACE U.S. Army Corps of 

Engineers

UST Underground Storage Tank

VHA Veterans Health 

Administration

VISN Veterans Integrated Service 

Network

LIST OF ACRONYMS