~~ ~ 

United States Ottice ot tnrorcement ana twmu-iu-Y9-uo I u 

Environmental Protection Compliance Assurance Fall 1995 

Agency

____~__ 

(2261) __ ~ 

~ 

An environmental bulletin for federal facilities 

AGENCIES PLEDGE TO POLLUTION 

PREVENTION, ENERGY EFFICIENCY 

GOALS AT WHITE HOUSE CEREMONY 

In a White House ceremony on September 12, top environmental and energy 

officials highlighted outstanding examples of individual leadership and accomplishments under the President’s 

executive orders to increase federal recycling,energy efficiency, and pollution prevention. Hosted by Council on 

Environmental Quality Chair Kathleen 

McCity, the event, called “Environmental Excellence in Government,” also featured Energy Secretary Hazel OLeruy, 

EPAAdministrator Carol Browner, OMB 

Office of Federal Procurement Policy 

Administrator Steven Kelman, Federal 

Environmental Executive Fran 

McPoland, and North Carolina Assistant 

Secretary for the Environment Linda 

Rimer. 

During the ceremony, fifteen federal 

agencies signed a forpal charter under 

Executive Order 12856, “Federal Compliance with Right-to-Knowand Pollution Prevention Requirements.” Signed by federal 

agenq-members of the Executive Order 

Interagency Pollution Prevention Task 

FOE, the Charter rem the federal 

commitment to demonstrate leadership in 

pollution prevention and community rightto-know and to achieve the goalsestablished 

in the Executive Order. 

The first annual White House “Closing 

the Circle” awards were given to 23 individuals and groups from federal communities across the nation who have 

demonstrated a commitment to environmental excellence in the areas of recycling, waste prevention, model 

demonstration projects, procurement, 

environmental innovation, and lifetime . 

achievement. Gee list on pnge 12.1 

At the awards mmrnony:EPA Administrator 

Cam1 Browner (lepJ with Sherri Gxdman.DOD 

Deputj Under Secrztaq far Emironmental 

Security, and Stcuen Herman, EPA Assistant 

Administrator for Enforeernent orid Compliance 

Asuurnnce. 

In addition, 22 federal agencies signed 

the “Energy Efficiency and Resource Conservation Challenge,” pledging to purchase “best practice” products which are 

practicable, cost-effective, and in the 

upper 25 percent of energy and water efficiency. 

.......... 

BARRY BREEN 

Dear Reader: 

Many readers of FedFacs work on federal facilities issues full time. Some of us 

are regulators at agencies such as EPA, 

and some are program managers and 

implementers at agencies that operate 

federal facilities. Virtually all of us feel a 

deep commitment to a common goal 

improving the federal facility environment. Why do we feel our work is so 

important? 

Ch,i~wcdon page 9 
FRAN McPOLAND 

Federal Environmental Executive 

ernment's role in promoting recycling and 

related activities during the past quarter 

century. 

Despite our su,ccess'in recycling, the 

policies of the last 25 years must be 

viewed against a backdrop of ... overarching .

government policies promoting .the 

extraction and use of virgin materials. As 

you may recall, within six months of the 

first Earth Day in 1970, some 3000 Community Recycling Centers had been 

established. But by.the time of the ecw 

nomic slowdo'6in the mid-l970s, most 

of these had failed. These programs failed 

for a number of reasons, not the least of 

which is the fact that both federal policy 

and human inclination has long favored 

"new and improved" over "recycled and 

old." We did very little to educate consumers about buying recycling products. 

We forgot basic economics. We created the 

'supply' of collected products-but there 

wasn't enough 'demand' to keep the programs working. 

In 1976Congress realized that it had a 

role to play and directed EPA.to develop 

guidelines on recycled content products 

that the Federal Government itself would 

purchase. However, as a result of budget 

cuts, various controversies, and the 

urgency of the hazardous waste and 

Superfund programs, very little was done 

by EPA to actually develop this guidance 

until the mid to late 1980s. 

By 1989, EPAhad finally issued guidelines for five items: retread tires: paper 

arid paper products: re-refined lubiicnting ~il:cement and concrete containing fly 

ash; and building insulation. As of June 

1989, all federal agencies (as well as state 

and local governments receiving federal 

funds) were obligated, if they purchased 

more than $10,000 of any of these items, 

to procure products which conformed LO 

the EPAGuideliney 

However, the law gave :he agencies an 

"out"-and they took it! The law allowed 

agencies to avoid purchasing these products if the products (1)were not cost competitive;.(Z)were not.readily available; or 

.'[3)did not meet their requirements. 

Thus,'for the'past six years we have qeen 

agencies keate lube oil specifications that 

effectively mandated use of virgin lube 

oil, and tire tread specifications that 

retread tires couldn't .meet. While complaining that recycled content producLs 

were too costly or unavailable,these same 

agencies were taking steps to'cut these 

recycled products off fmm being developed. Some agencies, such as GSA, had 

even written manuals prohibiting the use 

of n-refined oil and retread tires. And, 

since GSA manages most of the federal 

civilian fleet of vehicles, its guidelines are 

generally followed by other agencies. 

With bamem like these, it has been 

almost impossible for federal purchasers 

who wanted to do the right thing, to get 

their agencies to purchase those products. 

Let me tell you what the President has 

directed me to do and what our overall 

plan is to turn around the federal recycling record. On October 20, 1993, President Clinton signed Executive Order 

#12873 on Federal Acquisition, Recycling 

and Waste Prevention- a unique and 

historically significant commitment to 

dramatically increase federal action on 

source reduction. pollution prevention, 

recycling, and procurement of recycled 

and energy efficient materials.As the first 

Federal Environmental Executive. I have 

r:<,,,t;,,twcl011 page If 

chemicali"and 'lack bf.. ,ihentification&; .

wastes: I.' " 

PAGE 2 f2%T%3 
.BRAC CLEANUP TEAM. .. 

SETTING A PRECEDENT AT 

NAVAL BASE CHARLESTON 

by WT1 Linda L Helmig 

Editor, The Bow Hook 

They came together with one common 

goal: to quickly and safely manage the 

environmental cleanup of Naval Base 

Charleston. They are the BRAC Cleanup 

Team (BCT) and they are comprised of 

representatives fmm the Department of 

Defense, U.S.Environmental Protection 

Agency, and South Carolina’s environmental agency. But what they do is far 

from routine. 

Together, the environmental agencies 

are breaking new ground’by creating a 

partnership with the U.S. Navy to solve 

environmental problems at the Naval 

Base. “I think that we have gotten more 

actual environmental work done here in 

the last two years than in the ten years 

before the BRAC Cleanup Team was 

established,” stated Doyle Brittain, 

Senior Remedial Project Manager for 

EPA. 

What is taking place is unprecedented 

and a sharp departure from business as 

usual. Teamwork among the BCT members is the key to this process that began 

over two years ago. Since its establishment in 1993,the BCT has identified all 

potential hazardous waste sites at Naval 

Base Charleston and developeda five-volume master work plan to investigate 

those sites. Because Naval Base 

Charleston is large and spread out over 

several square miles, the BCT divided the 

base property into 12 zones, to allow for 

the environmental investigation of the 

base in an efficient and timely manner. 

At this point, investigation of one full 

zone has been completed and two other 

zones are in the final stage of investigation. 

Once each zone investigation is completed and reviewed, a Corrective Measures Study will be performed to 

determine the most efficient method of 

cleanup. Public hearings will be held to 

give ciimmunity members the oppurtunity to be part of the 

decision-making 

process. 

Another issue 

being dealt with by 

the BCT is how 

future reuse of the 

base would affect 

the environment. 

The NZvy, through 

the ,BCT, has 

drawn up an Environmental Impact 

Statement which 

considers the clusure of the Naval 

Base and implementation of the 

community’s 

Reuse Plan. The , Aerial vkiu ofNaual Base Charleston 

Reuse Plan outlines the community’s concept of how the property at the 

base would be reused. 

While the base property cannot be 

turned over to the area’s Redevelopment 

Authority (RDA)until full environmental 

remediation has been accomplished, 

property can be temporarily turned over 

to the RDA for leasing to other groups. 

The BCT conducts smaller investigations 

to ensure the property is suitable for leasing. 

The good news is that most ofthe prop 

erty at the Naval Base can be leased 

today without significant environmental 

concerns. lho pieces of property that 

have already been leased to the community are the marina complex and the new 

building by McMillan Gate. There is no 

part of the base that presents an imniediate health hazard and there are no sites 

so contaminated that they cannot eventually be reused. 

The roots of the BCT come from President Clinton’sFive Part Program for revitalizing communities affected by the Base 

Realibmnlellt 3rd Closure Acts 

One (if those parts involved Vast ’linck 

Cleanup to speed the reuse of environmentally contaminated sites. From that 

has come the BRAC Cleanup Team and a 

proactive, cooperative approach to managing cleanup efforts. 

~,t~~im~~,,~~,~rni ;,zoost;brotor.scoiiect soil .snmp/cs 

/i,r lob o,lni.vsis. 

PAGE 3 EDJ!E$ 
FAVORABLE RULING 

FOR EPA ON MILITARY 

MUNITIONS AS 

HAZARDOUS WASTES 

A significant ruling was handed down 

earlier this year in a test case involving 

enforcement of the Federal Facility Compliance Act (FFCA). The FFCA ends the 

immunity to penalties that had been previously been available to federal facilities 

violating the provisions of RCRA. On 

May 12,1995,AdministrativeLaw Judge 

Spencer Nissen ruled on motions in the 

Lackland Training Annex case (Docket 

No. RCRA VI-311-H.) EPA Region 6 had 

initiated an administrative enforcement 

action against Lackland for unauthorized disposal of military ordnance by 

open burning and open detonation 

(OwOD).The RCRA violations were: (1) 

failure to obtain interim status for operating the Site 7 thermal treatment unit 

for OB/OD, and (2) operating a hazardous waste management unit without 

interim status or a permit. 

In his rulings on prehearing motions, 

Judge Nissen analyzed earlier decisions 

arid the law. He ruled that military ordnance is considered hazardous waste 

under RCRA. Furthermore, he ruled that 

EPA was not estopped from enforcing 

because Lackland had relied on a letter 

from the state regulator incorrectly 

advising the installation that it had 

interim status. Judge Nissen also ruled 

that even though Lackland had not disposed of additional hazardous waste at 

the Site 7 disposal facility after the effective date of FFCA, the failure to obtain a 

permit was a continuing violation. Site 7 

remained in active status and Lackland 

was liable for penalties for operation of 

the unpermitted unit until Lackland 

completed the RCRA hazardous waste 

unit closure pmcedure. EPA could assess 

a penalty for each day of violation after 

the enactment of the FFCA for failure to 

close an unauthorized hazardous waste 

inanagement unit. 

The case is expected to he appealed. 

For more information, contact Patrick 

Lnrkirr, Ofice of Regional Counsel, Dnllas, m,214-665-2156. 

USING EPA'S FEDERAL 

FACILITIESTRACKING 

SYSTEM 

The Federal Facilities Tracking System, or FFTS, is an EPA database maintaineh by FFEO that offers a 

multi-media view of compliance activities 

at over 15,000 federal facilities. EPA 

Headquarters and Regional Offices are 

currently using DOS version 2.01 of 

FFTS. The Wbdows.version ofFFTS is 

in the final stages of development and' 

should be in use in early fall. The Windows version, with new programming 

features, will allow for easier retrieval of 

data and provide more sophisticated 

graphics capabilities. 

FFTS data includes relevant federal 

facility information from seven existing 

EPA databases. They are: - NCDB, the National Compliance 

DataBase, run by the Office of Pollution Prevention and Toxic Substances 

PCS, the Permit Compliance System, 

run by the Office of Water Enforcement and Compliance 

RCRIS, the RCRA Information System, runby the Office of Solid Waste 

CERCLIS, the CERCLA Information 

System, run bythe Office of Emergency and Remedial Response 

FFIS, the Federal Facility Information System, runby the Officeof Federal Activities ' 

.. '. FIND.S, the Facility Index. System, 

ruii by^ the' Office of Information 

' . Resources Management. : 

FFTS links information for a single 

facility that is stored in various pmgram 

and media-specific offices. This infoimation includes: 

Continued on page 5 
. 

FEDERAL TRACKING SYSTEM 

Continued born page 4 

facility location 

points-of-contact 

status information 

permits 

cleanup activities 

inspections 

enforcement activities. 

Other facility linking and data 

cleanup activities are needed before 

FITS development is completed. Some 

civilian federal agencies will be asked to 

participate in facility identification exercises to assess the need for further data 

cleanup. When data linking and cleanup 

are concluded, FFTS reports for.federal 

agencies and federal facilities will be 

made available. Federal agency reports 

will be designed by EPA Headquarters 

and packaged for release to individual 

agencies' &ports for individual federal 

facilities will be prepared and distributed 

by Regional offices"'These reports

are expeded to be by mid-FY 

1996. -

NEW EXECUTIVE ORDER 

ISSUED ON POLLUTION 

DISCLOSURE 

On August 8, 1995, President Clinton 

issued Executive Order 12969, "Federal 

Acquisition and Community Kght-toKnow," which requires manufacturing 

facilities doing business with the federal 

government to comply with TRI reporting requirements, i.e., to disclose to the 

public information on their emissions of 

651 chemicals (including the 286 recently 

added to the TRI list). The Executive 

Order does not apply to contracts below 

$100,000 and uses the simplified right-toknow reporting requirements recently 

adopted for small businesses. 

Also announced at the same time was 

the President's directive to EPA to 

expand the right-to-know program to 

include information on chemical use, and 

to expand the number and types of facilities required to report. The President 

also took aim at Republican to 

severely limit EPKs ability to expand the 

TRI reporting requirements beyond 

those initially enacted; threatening to 

issue a second executive order that would 

secure the public's right-to-knowthrough 

executive action. 

APPLYING UR CYCLE 

AND TOTAL COST 

ASSESSMENT CONCEPTS 

In order to assist federal facilities in 

complying with Executive Order 12856, 

FFEO recently published Federal Facility Pollution Preuention Project Analysis: 

A Primer for Applying Life Cycle and 

Dial Cost Assessment Concepts. Section 

4-404of the Executive Order requires 

that federal agencies apply total cost 

accounting (TCA) and life cycle analysis 

(LCA),to the greatest extent practicable, 

when evaluating pollution prevention 

opportunities. 

The manual is written to help decision-makers and those who evaluate and 

recommend projects understand and 

implement life cycle and total cost assessment. In addition to explaining the primary concepts of LCA and TCA, the 

guide provides step-by-step worksheets 

for performing cost assessments and life 

cycle assessments. The guide also pm 

vides references for those needineI 

additional information. 

Contact: Risk Brenner: 202-260-6177. 

lb obtain a copy oftheguide, contact EPKs 

Pollution Preuention Information Clearinghouse at 202-260-1023.Electronic formats ofthe guide and worksheets are also 

available on EPKs Envide& bulletin 

board. 
A STRATEGY FOR IMPROVING CIVILIAN FEDERAL 

AGENCY ENVlRONMENTAL PERFORMANCE 

EPA has prepared a Strategy for 

Improving Enuironmental Management 

Programs at Civilian Federal Agencies 

(EPA 300-B-95-006) which is scheduled 

for release in September 1995. The strategy is a product of the Task Force of Civilian Federal Agencies (CFAs)convened by 

EPA in October 1992 to address the 

unique environmental compliancdmanagement problems of non-military agencies. (CFAs include all federal 

departments and offices other than the 

Departments of Defense and Energy.) 

The Task Force's goals were to identify 

deficiencies in CFA environmental management and compliance programs, 

determine their causes, and make recommendations for improvements. The,effort 

is directed at assisting CFA compliance 

and management programs in evolving to 

higher levels of performance by providing 

increased access to resources and a more 

active partnership with EPA. 

Civilian federal agencies often lack the 

infrastructure, budget, and technical 

expertise to effectively manage environmental problems. In a survey of 28 CFAs 

conducted in January 1993, for example, 

over 80%of the CFAs reported having no 

formal compliance training program at 

either the regional or installation level for 

employees charged with ensuring agency 

compliance. Only one agency reported 

having an agency-wide system or database to ensure that proper records are 

maintained and updated. 

SIX AREAS OF NEED .. . . .. .. '. .... 

The CFA Task Force 'identified six areas 

of need for CFA environmental manage­ . .. ment' . 

1. Inadequate or duplicative environmental management training. 

2. 

3. 

4. 

5. 

6. 

Difficulty in finding timely and reliable information on regulations, technologies, and management strategies. 

Absence of centralized data management systems to alert federal agencies 

to changes in facility compliance status. 

Need for EPA assistance on specific 

compliance issues and needs, such as 

environmental auditing. 

Insufficient staffing to provide adequate technical services and support. 

Poor communications among .EPA 

headquarters and regions, and 

between EPA and other federal agencies.: . . .... . .: 

+ommendations welp made in each area 

indicating where improvemenk can be 

accomplishedthrough technicalassistance 

Continued on page 7 
EPA-NEW ENGLAND "STEPS UP" 

ENFORCEMENT OF PUBLIC AGENCIES 

On July 5, EPA-New England unveiled 

its overhaul of the region's enforcement 

policy, bringing another round of enforcement actions against two federal facilities,. nine municipalities, two state 

facilities, and one municipal airport for 

violations of federal environmental laws, 

totaling $184,000 in penalties. The new 

enforcement policy, called STEP-UP, the 

Strong, Targeted Enforcement Program 

targets public agencies, the urban environment, sensitivecoastal resources, and 

high-risk sources of pollution. Up to 80 

percent of EPA-New England's enforcement resources are being dedicated to 

the target areas. Since the initiative 

began last fall, the region has brought 52 

cases against public agencies. 

ENVlRONMENTAL PEAFORMMICE 

Continued fmrnpage 6 

from EPA or other outside somes. The 

recommendations are a result of a collab 

orative effort of EPA and federal agencies 

to establish a greater sense of partnership 

and to Further the common goal of impmving environmental performance. 

FUTURE TASK FORCE 

ACTIVITIES 

The CFA Task Force is expected to 

become a permanent partnership group 

and serve as the primary conduit of communication between EPA and CFAs. 

Periodic informal meetings will be held 

to review the progress of CFAs and EPA 

in implementing the actions called for in 

the CFAStrategy document and to identify and resolve new issues as they arise. 

For more information, contact Rich 

Salterfield, 202-260-9759. For a copy of 

the strategy document. sce ordering in,'&­

ln~lt;ml011 p. 11. 

The two cases brought in July against 

federal facilities were as follows: 

* The Vermont Air National Guard. 

in South Burlington, VT faces a 

'. fine of $81,300 for numerous violations of federal waste management 

laws. The facility was cited for failing 

to properly mark, inspect, and store 

hazardous dastes, and failing to 

maintain adequate records of hazardous wastes generated at the site. 

The US.Army Natick Research,' 

Development and Engineering 

Center Facility in Natick, MA, 

which was recently listed on the 

National Priorities List, will pay a 

$49,700 penalty for violations of hazardous waste management laws. 

EPA inspectors found the Army had 

failed to properly identify hazardous 

wastes at its facility, failed to label 

and mark accumulated containers of 

wastes, failed to keep containers 

closed in storage, and failed to clearly 

mark hazardous waste storage areas 

In the next stage of STEP-UP, EPA-New 

England will target specific geographic 

areas for inspection, such as Narragansett Bay (R.1.) and Casco Bay 

(Maine). 

For more information, contact Alice 

Kaufman, 617-565-4592. 
GENERIC PROTOCOL AVAILABLE IN 

ELECTRONIC FORMAT FOR CUSTOMIZING 

A revised Generic Protocol for Conducting Environmental Audits of Federal 

Facilities (released in February 1995) is 

available for use by federal acencies. Prepared as a collaborative effort by the 

member agencies of the Federal Audit 

Protocol Workgroup for the Federal Community (EPA, DOE, DOD, USPS, NASA, 

DOI, USDA, and FAA), the protocol is 

meant to assist in the conduct of environmental audits and environmental management assessments. The protocol 

focuses on determining compliance with 

environmental requirements and adherence to good management practices. 

Because of its size -over 1,800pages - the protocol is being made available to 

federal agencies on computer diskette as 

well as online. 

The Generic Protocol contains three 

separate auditing sections or "phases" 

intended to provide both a micro and 

macro view of environmental manage 

ment and help identify root causes for 

problems found. 

Phase I provides for a review of facility conditions in regard to specific 

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

and hazardous waste) with a focus on 

compliance with Federal environmental requirements. Phase I may .be 

used as a starting point for agencies 

that have just begun new programs. 

. Phase II of the protocol examines 

cross-cutting issues, provides an 

assessment of pollution prevention 

initiatives for each environmental discipline, and evaluates seven management systems that are relevant to 

each environmental area. These are: 

organizational structure, environmental commitment; formality of 

environmental pr0gram.s;' internal 

and external communications; staff, 

resources, training, and development; 

program evaluation, reporting, and 

corrective action; and environmental 

planning and risk management. . .. . .

. Phase '111 examines the facility's 

'management of a11 environmental 

programs to help establish compliance as the starting point rather than 

the endpoint of environmental performance. 

A companion document to the protocol, 

Enuironmental Audit Program Design 

Guidelines for Federnl Agencies, is currently undergoing revision. The guidelines are tailored to federal agency 

organizational and budgetary contexts, 

and will help federal agencies design 

environmental audit programs for facilities that they own or operate. 

, ... . .. .

CUSTOMIZING THE PROTOCOL 

Federal agencies are 'encouraged'to customize the protocol to their own needs 

before issuing it to auditors. To facilitate 

that customizing,the protocol isavailable 

in a packet of seven diskettes (Diskettes 

1-5 cover Phase 1; Diskette 6 covers 

Phase 2; and Diskette 7covers Phase 111) 

in IBM compatible, Wordperfect format. 

CaU 202-260-9801to obtain a packet. 
MEET... EPA'S OFFICE OF 

FEDERAL ACTIVITIES 

EPA's Office of Federal Activities (OFA) is a "sister office" to 

the Federal Facilities Enforcement Office within OECA. OFA ' 

houses three major national programs: 

* Review of federal agencies' environmental impact statements (EISs) and other major action under the authority of 

the National Envimnmental Policy Act (NEPA)and Section 

309 of the Clean Air Ad, 

Review of EPA's own compliance with NEPA and related 

laws, directives, and Executive Orders concerning special 

environmental areas and cultural resources; and 

Coordination of OECA's international enforcement and compliance, and environmental impact assessment programs. 

OFA provides a central point of information for EPA, other 

government agencies, and the public on environmental impact 

assessment techniques and methodologies. OFA works with the 

Council on Environmental Quality on NEPA program administration, and administers the filing and information system for 

all federal EISs under agreement with CEQ. For the international community, OFA is EPNs focal point on the conduct of 

environmental enforcement and compliance assurance. 

OFA is organized into the NEPA Compliance Division and 

the International Enforcement and Compliance Division. 

NEPA Compliance Diuision. Last year, over 500 EISs were 

filed with OFAunder delegation from CEQ. EPAcommentedon 

about 200 draR EISs and 200 final EISs, and a number of pr> 

posed regulations, legislation, environmental assessments, and 

scoping notices. In addition to coordinating EIS reviews, this 

division is active in a number of areas ranging from DOD base 

closure tu endangered species management. The NEPA Compliance Division is currently working closely with EPNs regional offices and other agencies to implement Section2001 of Public 

Law 10419; this section, Emergency Salvage Timber Sales, was 

enacted on July 27,1995. On August 1,1995, the White House 

issued a letter implementing timber-related provisions of the 

law. A Memorandum ofAgreement was signed by EPA and the 

Departments ofAgriculture, Commerce, and Interior to coordinate the sale of 1.6 billion board feet of salvage timber. 

International Enforcement and Compliance Diuision. This 

division has ongoing coordination responsibilities with Mexico, 

Canada, Russia, the United Nations Conference on Environment and Development, and other international concerns. In 

Mexican relations, for example, OFA, in conjunction with EPA 

Regions 6 and 9, has begun efforts tu encourage US. parent 

companies totake leadership roles in promoting compliance and 

pollution prevention among their Mexican operations. Technical assistance in targeting enforcement efforts, and a training 

video have been made available to Mexico as well. 

DIRECTOR'S WORD ' 

Continued fmrnpge 1 

I can think of at least three reasons. 

First, federal facilities haue a dramatic, 

direct physical effect on the enuimnrnent. 

The federal judge handling the Army's 

Rocky Mountain Arsenal case called it 

"the worst hazardous and toxic waste site 

in America." The Energy Department 

observes that DOE "faces one of the 

largest environmental challenges in the 

world." The General Accounting Office 

concluded that "with close'to 730 million 

acres of land, federal civilian agencies' 

inventory of possible hazardous waste 

sites could be enormous." Both the 

breadth of the federal government's activities and the inherent danger in many of 

them lead to an enterpiise that requires 

direction to ensure its harmony with the 

environment. 

The second reason our lrnrlz i.7 so 

important isthat it sets an c.rarnplefor the 

rest of the nation. President Lyndon Johnson summarized it when he wmte "The 

Federal Government is rightly expected 

to provide an example to the nation in 

pollution control. We cannot make new 

demands on State and local governments 

or on private industry without putting 

the federal house in order." President 

Clinton carried forward this thought 

when he called on federal facilities to"set 

the example for the rest of the country 

and become the leader in applying pollution prevention." Federal facility compliance isn't a side event in environmental 

policy, it's a demonstration of federal commitment. 

The third reasnn we wn~kso hard on 

fidernl facilities enuirnnnieritnl issues is 

that they are a mattcr of trust between the 

American people arid the fillera1 gouerrrment. "Public officers arc servants and 

agents of the people," President Grover 

Cleveland said. As public servants, 

whether as regulators or federal facility 

personnel; we are trustees for this generation and America's future generations. 

Our part of the public trust is the federal 

environment, and when we manage it 

well we set the example not only for envimnmental policy, but for all of government. 

Our work is of the highest importance, 

and given the magnitude of it, we need 

help from all quarters. We look forward to 

working with you. 

I Bany Breen, Dircctnc FFEO 
16 FEDERAL AGENCIES COMMIT TO 

POLLUTION PREVENTION STRATEGIES 

Agencies submitting strategies 

include the Central In&gence Agency, 

the Departments of Agriculture, 

Defense, Energy, Health and Human 

Services, Interior, Justice, Transportation, Treasury, and Veterans Affairs, 

Environmental Protection Agency, General Services Administration, National 

Aeronautics and Space Administration, 

Smithsonian Institution, Tennessee Valley Authority, and U.S. Postal Service. 

(The Smithsonian, VA and Postal Service were not strictly required to submit 

strategies, but did so nonetheless.) 

POLLUTIONPREVENTION 

GOALS 

The Executive Order directs that each 

federal agency develop voluntary goals to 

reduce the agencfs total releases and 

transfers of toxic chemicals by 50 percent 

by the end of calendar year 1999. A 

majority of federal agencies explicitly 

committed in their pollution prevention 

strategies to the 50% reduction goal by 

the end of 1999. 

Some federal agencies went beyond 

the chemicals covered by EPCRA For 

example, USDA's strategy allows 'the 

various USDA services to set their 50 

percent reduction goal for toxic pollu 

'tants rather than toxic chemicals, thereby expanding the number of chemicals 

Sieen federal agencies have sub- that will be reported as well as identifymitted pollution prevention strategies to ing opportunities for source and release 

implement Executive Order 12856. The reductions at USDA facilities. 

16 strategies cover implementation The CIA'S pollution prevention strateactivities at over 2,500 covered federal gy includes a commitment expanding the 

facilities. Executive Order 12856 was 50 percent reduction goal to include 

signed by President Clinton in August releases of extremely hazardous sub1993, directing federal agencies to am- stances. 

ply with the Emergency Planning and 

Community Right-to-Know Act of 1986 ACQUISITION AND 

(EPCRA)and Pollution Prevention Act of PROCUREMENT 

1990. The Order sets a new standard for All of the federal agency pollution pre- federal environmental excellence by 

extending this compliance requirement vention strategies contain a commitment 

to many activities not currently moni- to pollution prevention in both facility 

tored in private industry. , . ' . .. .. management and .. 

acquisition. For example: . .. . .. . . . . .. 

.. 

. DODs strategy requires the integration of pollution prevention and other 

environmental concerns into the 

entire life-cycle of acquisition programs. 

The General Services Administration 

commits to reduce'or eliminate pmducts that contain haznrdous chemicals from the inventory of products 

purchased for the federal supply system. 

The pollution prevention strategy for 

the Department of Health and 

Human Services commits to revisions 

of standard internal administrative 

and policy manuals to ensure those 

documents embrace pollution prevention and reflect the Executive Order. 

The Tennessee Valley Authority strategy calls for a review of agency standardized documents to identify 

opportunities to eliminate or reduce 

use 'of extremely hazardous substances or toxic chemicals and ultimate revision of those documents to 

reflect goals of the Executive Order. 

FACILITY SPECIFIC PLANS 

The Executive Order directs that the 

head of each agency will ensure that its 

covered facilities develop a written pllution plan that sets forth the facility's contribution toward *e agency 50 percent 

reduction goal. Nearly all of the federal 

agency pollutjon prevention strategies 

include an agency commitment td ensure 

development of facility specific.pollution 

prevention plans for covered -facilities. 

Most of the strategies direct facilities to 

conduct formal facility pollution prevention opportunity'assessmentsto enhance 

the effectiveness of the plan. ' Each of the federal agency strategies 

also' includes a specific commitment to 

pollution prevention as the primary 

means of achieving and maintaining 

compliance with environmental requirements. Over half of the federal pollution 

prevention strategies contain specific 

commitments endorsing the development, testing and support of innovative 

pollution prevention technologies and 

programs. 

EPA's Federal Facilities Enforcement 

Office has prepared a document outlining 

the collective federal commitment to pollution prevention and community rightto-know, with summalies and full text of 

each federal agency strategy. For a copy 

of fhcdncrrrncnl. "iWeefingthe Cliallerrge", 

see ordwienrrg inforriinfiorr nn p. 11. 
.I To Receive FedFacs in the Mail or to Order Documents 

I Mentioned inthe Newsletter: 

I 0 Please include me on the FedFacs mailing list (no charge). 

I 

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I 0 Please send one copy of the followingdocuments (no charge): 

I . 0 Strategy for Improving Environmental Management Programs 

I at Civilian Federal Agencies (EPA300-B-95-006,September 1995). 

I 

I 0 Meeting the Challenge: A Summary ofFederalAgency Pollution

I 

I Prevention Strategies (EPA300-R-95-014,September, 1995). 

I 

I 0 Federal Facility Pollution Prevention Project Analysis: AF’rimer 

I forApplying Life Cycle and Total Cost Assessment Concepts 

I

I (EPA300-B-95-008,July 1995). 

I 

I 

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I 

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Organization 

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I Address 

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i Mailto: FedFacs (for newsletter) 

I Federal Facilities Enforcement Office (for documents) I 

I US.EPA(2261). 401 M Street, SW, Washington, DC 20460 

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I 

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I 

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I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

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I or Fax thiipageto: 202-260-3437 

I 

GUESTSPOT 

Continued fmm page 2 

been tasked by the President to come up 

with ways to make that.happen-quickly. 

Each Department has named an 

Agency Environmental Executive to work 

with both me and their own Departments 

to assure complete and rapid implementation. Over the past year, we have made 

important strides. 

One of the first things we did was to 

look at barriers in the federal government 

that limit demand for, or prevent procurement of, recycled items. For example, 

we have worked to convince GSA to allow 

the use of re-refined oil in government 

vehicles. We have also worked with EPA 

to identify 19 more items subject to a&­

mative procurement by federal agencies 

and governments receiving federal-funding. The leadership challenge we face will 

be to purchase and track nn expanded 

number of items better than we did for 

the first five. My office has brought 

together memhers from several large 

agencies to look at new ways of compiling 

purchase information using the upmming electronic commerce system that will 

significantly ease the burden of tracking 

and reporting by the agencies. 

There is more positive change on the 

horizon. Arecent law (PL 103-329)allows 

the proceeds from recycling effortsto go to 

federal agencies, rather than the US. 

‘heasm, to offsetat least some operating 

costs of recycling and pollution prevention programs. 

EPXs Officeof Pollution Prevention has 

been developing guidance for envimnmentally preferable pmducts which will begin 

to move the Federal Government towards 

purchases of less environmentallyharmful 

and more environmentally friendly products, through a series of pilot projects in 

various sectors of the govei-nment. The 

first pilot project is already underway: an 

EPNGSACleaners Project. 

In closing, I want tri assure you that 

the President and Vice President are as 

committed to the success of the goveniment’s recycling challenge as I am. But 

while the Agency Environmental Executives and I help to establish the overall 

battle plan, it is the front line troops in 

acquisitions offices, the people using 

those materials, and the people charged 

with final disposition who, by thinking 

“outside the box” of narrow responsibility, 

will make this process a success. We 

know what happens when facility managers and stafftake on this responsibility 

wholeheartedly-we saw the outstanding 

record of results compiled by the recent 

winners of the “Closing the Circle” 

awards for federal facilities. It is their 

effort-and yours-that will make the 

Federal Government a leader, not a follower, in the recycling arena. 
CALENDAR 

October 30-November 3,1995 

GOVERNMENTINSllTUTES.ME DEFENSE ENVIRONMENTAL 

MANAGEMENTINSTITUTE 

Alexandria,VA 

Five days of intensive compliance training sessions for DOD 

environmental professionals. A team of experts from the armed 

services and the civilian community conduct lectures and workshops on special issues of concern to DOD environmental personnel, including NEPA, BRAC, and other laws and regulations. 

$1,899, 40 credits, Level 1. Contact: Chernment Institutes, 

Inc., Suite 200,4 Research Place, Rockville, MD 20850, Tel:301-

921-2345, Fax: 301-921-0373. 

December 6-8 

NATIONAL POLLUTION PREVENnON ROUNDTABLE 

Miami Beach, FL 

Topics for federal facilities hclude painting,, depainting, cleaning, and degreasing; and voluntary and innovative.initiatives. 

..,. ,,.. .... ...... ... . .... . ...... ~... .. 

Co-sponsored x4th the Florida DEP and Dade County Pollution 

Prevention Program. Contact NPPR at 202-466P2P2. 

Januaty 16-18.1996 

1996 HAZARDOUSMATERIALS AND WASTE MANAGEMENT 

CONFERENCE &EXHIBITION 

Alexandria, VA 

Sponsored by the Defense Logistics Agency and the Military 

Services, the theme of this year’s conference is “Resource Conservation and Recovery into the 21st Century.” Contact: Ameiican Defen3e Preparedness Assn. at 703-247-2557. 

March 18-21,1!3!36 

22No ENVIRONMENTALSYMPOSIUM & EXHIBITION 

Orlando, FL 

Sponsored by the American Defense Preparedness Association, 

this year’s event is titled: “Investing in Our Future: Reinventing 

Environmental Protection for.1mpmved.Readiness.”For more 

information, fax ADPA at 703-522-1885. 

.............. .... .... . ............, 

CONGRATULATIONS TO MIS YEARS CLOSING ME CIRCLE AWARD WINNERS! 

Life’lime Achievement John 

Stanberry, GSA 

Affirmative Procurement Beth 

Law, National Naval Medical 

Center. Bethesda, MD. Paula

Ure, GSAand Paul Ruesch, 

EPA, Region V. U.S. Postal 

Service Headquarters,

Washington, D.C. 

Model 

US Coast Guard Support 

FedUnited States Environmental 

Protection Agency (2261) 

Washington, DC 20460 

Official Business 

Penalty for ~li~ateuw smo 

Center, Governors’Island. NY. 

U.S. Postal Service Hartford 

Vehicle Maintenance Facility, Ha,tford, cT. 

” 

mi,,^: sc6itJ. b,,ioR

Whiteman Air Force Base, MO. 

Brent Giezentanner, Aransas 

National Wildlife Refuge. TX 

Chip Britting, Blue River 

Ranger Station, Willamette 

National Forest. OR. Fort Sill, 

OK M&~~ corps hrsh.

tion, Cherry Point, NC. Department ofHousing and Urban 

Development Headquartem ‘Building,Washin.@on, D.C. 

Lake City Army Ammunition 

Plant, Independence,MO. 

waste u.~. Postal 

Service,Vehicle Maintenance 

Facilities in N~~ orleans, LA, 

Edison. NJ;Anchorage, AK,

Houston, TXand other sites in 

CT, RI, Nu,MA, ME, NH. 

Kennedy Space Center, FL. 

Y-12Site Management 

Services, Oak Ridge, TN. .. Envimnrnental Innovation: 

Captain Gordon Matthews,. 

Washingtonby National 

Guald, Tamma, WA.hY 

National Guard,Arlington, VA 

Savannah River Site, Aiken. 

SC. 

I E PA PERMlTN0.G-35 I 

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